Department of Final Environmental Forest Service

Pacific Northwest Impact Statement Region

Deschutes National Forest APPENDIX J Response to Public Comment

Land and Resource Management Plan

Deschutes National Forest Appendix J Appendix J Public Participation in Forest Plan Development

Public Participation Philosophy communication effort. Issues have occurred at least twice a year Since inception It is intended The Deschutes National Forest was one of a handful that once the Plan is finished a new communtcation of National Forests selected as lead Forests after vehicle will be put in place similar to the Report passage of the National Forest Management Act (NFMA) The Forest was just completing a Land When the Forest conducted major public review Use Plan (Plan) underthe old unit planning concept efforts for 1982-1983 and 1986 Draft Environmental Considerable public involvement work had already Impact Statements (DEIS), they planned for longer occurred. than minimum review periods. This was done because of public interest, document and issues With the lead Forest designation efforts geared complexity, season of the year and concern for up to meet the intent of NFMA regarding public adequate review participation, Forest leaders recognized it was important to keep the public informed and solicit Throughout the over 10 year process Forest public input. The Forest worked to culture an personnel met informally with individuals and atmosphere of open, candid, and continuous organizations. People have been invitedto continue communication The Forest kicked off the NFMA dialogue even though there were not any participa- effort with a newsletter entitled 'Forest Plan Report " tion activities planned. That newsletter has been a key part of the

Appendix J - 1 Appendix J Public Participation in Forest Plan Development

Public Participation Activities (from concern The new issue statement was, "Should start of planning through DEIS) the Forest continue to use land for recreation residences (summer homes)?' The questions under Looking at the lssue were similarly revised. Issue Identification (November 1978) The issue of summer home residences in general will be discussed later in this report Activities Several comments reflected a need to insure that In November, 1978, the Forest mailed a list of 28 highly productive commercial timber land is issues/concerns prepared by the Forest Interdisci- seriously considered for uses other than timber plinary Team (ID Team) to approximately 850 production. In issue seven, the question is now organizations and individuals. Copies were also asked, 'Should all highly productive commercial provided to state and federal agencies as well as timber land be allocated to timber production?n other Forest Service offices. A request for written response to these issues resulted in the return of Concern was also expressed that the needs of 59 response forms and letters. special interest recreational groups (is , horse groups, off road vehicle (ORV) clubs, snowmobile Additionally, workshops were held in seven groups) would be adequately addressed in the locations (La Pine, Crescent, Bend, Sisters, Plan In response, the question 'Is there a need Eugene, Portland, and Redmond) to determine to provide facilities for Forest recreation groups, the concerns and issues most important to the I e., horse groups, backpackers, trailers, ORV, attendees. One hundred and nine persons attend- etc.9. was added to issue number 9 Similar ed these workshops A summary of the public questions were added to issue numbers 14 and involvement is included with this report. 18.

During January and Februaly of 1979, the public Issue number 23 concerning fire management input was analyzed and used by the ID Team to was reworded from simply asking the question, evaluate and revise the original list of 28 issues. 'How acceptable is the role of fire in management of the Forest?' to a much more specific statement Public comment concerning the initial list of issues asking how to integrate the role of fire management prepared by the Forest resulted in changes to 11 into the Forest Plan. The new statement reads, of the 28 issues A large percentage of the written "What are the fire management goals that are responses confirmed the importance of each of responsive to and supportive of the expected the issues considered, so none were deleted outcomes from land and resource management?' Although several changes were made in consider- Comments from the Pacific Northwest Regional ing different aspects of the listed issues, public Office of the Forest Service prompted this change comments did not seem to require any addltional issue statements. From 1979 until release of the first DEIS in 1982 numerous issues of 'Forest Plan Report" were Some of the major changes in the issues were as produced. These provided people with updated follows information on the planning process

Issue 12, 'How long should the Forest continue to Publlc Involvement Summary (January 1979) allocate land for recreation residence (summer home) use?' drew perhaps the strongest criticism There were 7 public workshops held, with a total Public comments indicated the wording of the attendance (excluding Forest Service personnel) statement tended to preludice the consideration of 109 At these workshops, 17 issues llsts weie of the issue. The issue as written seemed to say produced by workshop groups, and 84 issue the Forest will eventually foreclose all recreational cards were collected from individual attendees residence use, the question being only when. The The 'Forest Plan Report' announcing the work- issue statement was reworded to reflect that shops, and requesting input on the issues, was

Appendix J - 2 Appendix J Public Participation in Forest Plan Development

mailed to approximately 850 individuals and From this input, a total of 560 individual comments organizations on the Forest mailing lists. The were identified and coded for analysis and Forest received 46 returned response forms, 8 evaluation. personal letters, and 5 letters from government agencies. The following charts show the geographical, and interest spread of the workshop attendees, and responses.

Public Workshop Attendance

Interest Category*

I Location I Date 1 Gov. 1 Ind. 1 Rec. I Env. I Private I News I Total

Crescent 1 211 2/78 1 5 6

Sisters 12/13/78 1 3 19 23

Bend 12/14/78 2 1 6 10 1 20

Eugene 12/18/78 1 I 8 0 16 I 35

I Redmond I12/20/78 I I I I I Totals 2 6 15 15 66 3 109

*Abbreviations Key: Gov. = Government representative ind. = Industry representative Rec. = Recreationist group representative Env. = Environmentalist group (other than USFS) Private = Private individual News = Press and broadcast media representatives

In the public comment analysis, approximately Some examples of these approaches are as follows 560 separate comments were isolated pertinent to identification of issues and concerns. Approxi- "Investment in timber should be at better growing sites.' mately 120 of the 560 comments could be considered approaches (they seemed to express "Don't experiment with Mt Hemlock clearcuts " an opinion of how the Forest or resource should be managed rather than simply posing a question 'More developed recreational facilities should or concern). be developed.'

Appendix J - 3 Appendix J Public Participation in Forest Plan Development

'Allocate new areas for all year recreation.' The meeting schedule was.

'Maintain summer home leases at reasonable January 5 Sisters lease charges.' January 6 Redmond January 10 LaPine 'Roadless areas should be preserved for January 12 Eugene wilderness values.' January 13 Bend January 18 Portland DElS Release (December 1982) January 24 Crescent January 27 Madras Actlvltles About 350 people attended Attendance varied The first DElS was released in late December considerably between communities, with Portland 1982. Information meetings were held during (Western Forestry Center) having the least, while January, 1983, on the DElS and Draft Forest Plan Bend had the most (over 70) People were pleased for the Deschutes National Forest. They were scheduled in Bend, Crescent, Eugene, LaPine, that we made the effort to come and provide Portland, Madras, Redmond and Sisters. Although them information no formal presentations were made, Forest Specialists were available to answer questions. In The comment period closed February 15, 1983 addition, displays described the Alternatives and Forest Supervisor Dave Mohla encouraged people the differences between them as well as the to provide written comments along with supporting planning process. No oral testimony was taken at reasons. The combination of the two could help the meetings. in understanding the public's point of view and concerns In the development of the Plan and DES, Forest personnel wanted public participation. Because Public Involvement Summary - DElS (1982/1983) the Forest had recently completed a Forest Plan (three and one-half years prior), we were very Comment Analysis Process and Results concerned that interested people might be burned out with planning and public participation We Once a comment was received a systematic also did not want debates between people. process was used in the analysis of responses received on the various issues, alternatives, Therefore, the public participation and review planning process, the Forest Plan, and DElS meetings for the Draft Forest Plan and DElS were documents The process included portions of two designed to. systems--aContentSummary Analysis" and "Code- involve.' The former captures a comment and its 1 Minimize confrontation between Forest Service supporting reasons and then summarizes areas personnel and the public, and between any of agreement or disagreement within categories participants: by issues, alternatives, or demographic areas 2. Disseminate information about the proposed The Code-involve technique allows for categoriza- Plan, the DEIS, and the process; tion of comments or responses, especially for demographic information. 3 Be informal, thus encouraging people to have one-on-one exchanges with Forest staff and Above all, the system was designed to planners, and 1 Be visible and traceable, 4. Encourage comment on the DEIS, and specifical- ly the proposed Plan, along with an individual's 2. Remain objective as long as possible in the supporting reasons, analysis process:

Appendix J - 4 Appendix J Public Participation in Forest Plan Development

3. Evaluate the meaning of the comment as it tables show where the respondents lived, who relates to Forest planning and Forest management, they represented, and how they responded. and

4. De-emphasize numbers or vote-counting, while Orlgln of Responses Number emphasizing areas of agreement or disagreement among issues or respondent categories. Central Oregon 127 Rest of Oregon 195 A response from an individual or organization was Washington 14 first logged in, assigned a file number, and then California 7 read. Then initial analysis identified the issues or Other States or Countries 8 alternatives that were being commented on. This data was entered into a Data Based Management TOTAL 35’ System available on the Prime 550 computer I I used on the Deschutes National Forest The specialized instructions for data entry, updating, and report writing are included by reference as appendix material. A complete copy is filed at the Interest Represented Number Deschutes National Forest Supervisor’s Office in Bend Self: Black Butte Ranch Homeowners The Forest Plan public comments analysis system 1 295 I identifies each comment by the area it came from, Groups: who responded, response form type (letter, Amenity (Conservation) response form, etc.), the alternative being ad- Commodity (timber industry, dressed, and the alternative(s) preferred (if any). etc.) Each set of comments on a particular issue or alternative combination can be written into a Government: separate data record for the purpose of sorting Federal these comments. Retrieval can be done by issues, State alternatives, areas, documents, etc. Local

Comments were extracted from responses relatively intact and in the respondent’s own words and phrases. They were then filed with similar com- ments. Once reports were retrieved by similar Response Format Number

comment, the summation and eventual evaluation __~~ was done. The Forest Service response was based Letters 264 on similar comments. Response Forms 66 Meetings 4 Overall, people were generally supportive of the Other 7 Preferred Alternative (Proposed Plan). Most of the Petition 1 comments were about wildlife, the planning process itself, timber, recreation, and adjacent landowners. Many of the comments were very specific. During the analysis process, it became apparent that similar environmental factors or resource A total of 351 written responses provided more concerns could be grouped for summary purposes than 1,400 comments. One petition with 300 This does not mean that an individual issue would signatures concerning the firewood program was be lost. Listed below are the Summations of the received from Madras area residents. The following comments by major resource area and in order of

Appendix J - 5 Appendix J Public Participation in Forest Plan Development

most comments received down to those receiving Flora and Fauna the fewest comments. The number in parentheses This was broken down into three areas: threatened indicates comments' F'gures in the "umber' and endangered species, plant and animal diversity column will not always totalthe number In parenthe- (old growth), and wildlife population levels A total ses. of 235 comments were received

Area of Concern Number

Bald eagle areas okay 30 Osprey areas okay 6 More owl areas 6 Too much bald eagle habitat I

Plant and Animal Diversity

(54 Comments)

~~ ~

Area of Concern Number ~ ~ ~~ ~ ~ I I Increase old growth 28 Proposed plan 5 percent old growth okay 15 Need more information 11

Appendix J - 6 Appendix J Public Participation in Forest Plan Development

Wildlife Population Levels and Habitat

(1 38 Comments)

Area of Concern Number

Deer or big game habitat should be maintained or increased Concerned about wildlife habitat in a general sense, but especially distribution Liked alternatives G and H best because they provided for more wildlife Proposed plan okay Wanted more wildlife information Concerned about management indicator species Concerned about snags Concerned about hunting Opposed to clearcutting Wanted less deer

Timber Management

This section includes chemical use, firewood, mountain pine beetle, fire management, timber harvest and clearcutting.

Collectively, 516 comments (Madras petition included) were received

Tlmber Harvest, Levels, and Schedules

(76 Comments)

I Area of Concern I Number I Concerned or opposed to the harvest levels proposed. Of that 27, 12 concerns stemmed from wildlife and old-growth issues, and 12 from visual quality and recreation issues 27 Thought Alternative F okay 21 Concerned about clearcutting 8

Appendix J - 7 Appendix J Public Participation in Forest Plan Development

Area of Concern Number

Concerned about future supplies (Madras Petition) 307 Program conceptually okay but we need to manage it better 24 Use more slash and waste less 19 Want lower fees 5 Save more snags 3

Mountain Pine Beetle Epldemlc Management

(46 Comments)

Area of Concern I Number Proposed Plan okay 32 Additional treatments need to be discussed 6 Conversion should occur a lot sooner than 30 years 6 Concerned about clearcutting 2 Concerned about chemical use 2 Felt It was done only to hold up the ponderosa pine harvest level 2

Clearcuttlng

(15 Comments)

Area of Concern I Number I Too damaging to wildlife populations and impacts recreation, wildlife, visuals, and water quality. 14 Do not restrict size of clearcuts 1

Appendix J - 8 Appendix J Public Participation in Forest Plan Development

Area of Concern Number

Concerned about smoke 5 A progressive Fire Management Plan okay 3

Chemicals

(7 Comments)

I Area of Concern I Number I Discuss impacts more 3 Okay to spray 2 Wrong to spray, specifically in the watershed 3

Recreation

Aspects of recreation gathered 190 responses.

Developed Recreation

(42 Comments)

I Area of Concern I Number I Emphasis an intensive recreation good, and an increase okay 24 Too much emphasis on It already 14 More areas should be set aside for cross-countty skiing 2 More snowmobiling 1 No more snowmobilinn 1

Appendix J - 9 Appendix J Public Participation in Forest Plan Development

Dispersed Recreation

(20 Comments)

Area of Concern I Number I More dispersed recreation Less motorized dispersed recreation More cross-countly skiing Close Swampy Lakes to snowmobiling

Area of Concern Number

No more snowmobiling, with 21 of the 31 wanting Swampy Lakes only for cross-country skiing More consideration of snowmobiles with 12 of those saying keep Tam McArthur Rim open

Cross-Country Skiing

(30 Comments)

I Area of Concern I Number I More skiing 27 Close Swampy Lakes to ORVs 25

Area of Concern I Number I ~~ ~~ Protection is important 20 Too much emphasis on scenics 2

Appendix J - 10 Appendix J Public Participation in Forest Plan Development

Area of Concern Number

Proposed Alternative F okay Concerned about the specific management actions proposed in the Plan Concerned about roads and trails Close 1534 to protect wilderness Put roads closer to lakes so they can be seen better

Planning Process

One hundred sixty-nine comments were received of the decision in the Draft Environmental Impact on the Forest Planning process and documentation Statement

Monltorlng

(36 Comments)

I Area of Concern I Number I Concerned about monitoring of the economic effects 13 Concerned about wildlife population monitoring 15 Concerned about harvest schedules monitoring 5 Concerned about water quality monitoring 3

Other Concerns

(44 Comments)

Area of Concern I Number Recreation okay or should be increased 14 Beef up the economic analysis 9 Alternative range was poor and not broad enough 9 Increase coordination in public participation 6 More soil information 4 Increase research natural areas over the proposal 3 Concern about cultural resources 3 Inadequate coordination with adlacent landowners 3 Inadequate coordination with State Department of Forestly 1

Appendix J - 11 Appendix J Public Participation in Forest Plan Development

Area of Concern Number

No exchanges around Black Butte Ranch, principally because it has traditionally been 149 public land and it is best to stay in public land. An exchange would change the character of the development

Recreation Residences

(72 Comments)

I Area of Concern I Number I Leave the summer homes program as is, with no terminations 32 Phase them out now or in the future for higher and better public use (if needed) 24 Analysis inconsistent and decision process was weak 15

Soil and Water

(61 Comments)

~~

Area of Concern Number

~~ ____ Concerned about the Bend Watershed. Twenty-seven of those said the Proposed Plan was okay with limitations on such things as logging and road access 38 Miscellaneous comments concerning river protection and hydroelectric development 11 Concerned about water quality and its importance 19 Wanted additional information on soils 4

Appenduc J - 12 Appendix J Public Participation in Forest Plan Development

Area of Concern Number

Concerned about the protection of the area for recreation and visuals Alternative F (the Proposed Plan) okay New leasing should be confined to Zone 3 Zone 1 should be eliminated More information needed about the resource before decisions can be made

Area of Concern Number

Ought to protect and increase roadless and wilderness, with 6 concerned about wildlrfe and general protection 30 Too much wilderness 13 It is unavailable to the majority 5 Only cross-country skiers could go into these area 5

Area of Concern Number

~ ~____ ~~ ~ ~~ Rafting okay, and 9 of the 26 felt that it should be limited or restricted No; 9 of those were concerned with the commercial aspect Concerned about coordination with Warm Springs

Appendix J - 13 Appendix J Public Participation in Forest Plan Development

Local and Regional Economies and Lifestyles

(35 Comments)

I Area of Concern 1 Number I Proposed Plan okay Recreation and tourism important Jobs and employment are the general concerns that ought to be considered Minorities would not be impacted Alternatives G and H are better

Area of Concern Number

~ ______~ ___ ~ ~~ Metolius ought to be designated; 3 said no 25 Said yes to the Little Deschutes, and 4 no 11 Said yes on the Deschutes, while 4 said no 25 Said yes for Big Marsh and Crescent Creek, and 3 said no 7 Said yes to hydroelectric and water development projects on these streams, while 5 said no 2

Resource Planning Act Targets

(23 Comments)

Area of Concern I Number I Too much timber emphasis Need more explanation of the targets and rationale More wildlife habitat Too much recreation Too much wildlife

Appendix J - 14 Appendix J Public Participation in Forest Plan Development

Roadless Area Public Comment (1983)

Activities Comments Number During 1983 the Forest was directed by the Chief (along with other Forests) to fulther analyze public No comments opinion regarding roadless areas. The Forest Protect developed a packet which was sent to all people Part Wilderness on the Forest Plan mailing list. Of the respondents Wilderness Nonwilderness 36 were individuals, 8 were from special interest groups, and 3 were sent anonymously. Special interest groups included Western Speleological Special Concerns Society, Waldo Country Study Area, Washington Native Plant Society, Obsidians, Occidental Wildlife habitat, botanical species, recreation, Geothermal, Inc., Mazamas, Oregon Hunters’ geology. Association, and Lane County Audubon Society. Recommendation Summary Retain in Undeveloped Recreation.

Of the respondents, 3 were from Portland, 22 Mt. Jefferson Roadless Area from the Willamette Valley, 11 from Central Oregon, 5 from Washington, 4 from other States and 2 were of unknown origin. I Comments 1 Number 1 The following summary will discuss, by roadless No comments area, the category of comments, a brief summary Protect of those reasons, and our recommendation to the Part wilderness line members Wilderness Nonwilderness Oregon Wilderness Act Speclal Concerns After the roadless area involvement effort in 1983, the United States Congress enacted the Oregon Most requests for wilderness had more to do with Wilderness Act of 1984 This added 59,265 acres Mt Hood/Willamette NF parts of the existing to wildernesses on the Forest. Additionally, the wilderness Congress created the Oregon Cascade Recreation Area from 37,891 acres of roadless land and 4,765 Recommendation additional acres. The remaining 145,142 acres of roadless area land were allocated to various No special classification; the small, isolated fingers multiple use activities in the Forest Plan. would complicate the boundary

Appendix J - 15 Appendix J Public Participation in Forest Pian Development

Mt. Washington Roadless Area WesVSouth Bachelor Roadless Area

~

Comments 1 Number 1 I Comments I Number 1 No comments No comments 15 Protect Protect 4 Wilderness Part wilderness 0 Nonwilderness Wilderness 9 Nonwilderness 12 I I Speclal Concerns Speclal Concerns Concerned about protecting existing wilderness. Intensive Recreation: Mt. Bachelor, Inc. would be Has high scenic value. best use. Improve cross country ski trails.

Recommendation Recommendation

Wilderness. Continue to emphasize Intensive Recreation and Scenic Values No wilderness classification Three Sisters Roadless Area Bearwallows Roadless Area

I Comments 1 Number 1 I Comments 1 Number I No comments Protect No comments Part wilderness Protect Wilderness Part wilderness Nonwilderness Wilderness Nonwilderness

Speclal Concerns Speclal Concerns Boundary locations. Mostly indifference.

Recommendation Recommendation

Wilderness, use logical boundaries. No wilderness

Appendix J - 16 Appendix J Public Participation in Forest Plan Development

Comments Number Comments Number _____ No comments 17 No comments 19 Protect 9 Protect 4 Part wilderness 0 Part wilderness 0 Wilderness 9 Wilderness 7 Nonwilderness 9 Nonwilderness 9

Special Concerns Special Concerns No strong statement about wilderness More roads Water quality and wildlife. Manage dispersed recreation

Recommendations Recommendation Put most in General Forest, consider West 1/3 for Undeveloped Recreation.

Maiden Peak Roadless Area

Comments I Number I No comments 15 No comments 13 Protect 4 Protect 4 Part wilderness 2 Part Wilderness 0 Wilderness 10 Wilderness 17 Nonwilderness 8 Nonwilderness 7

Special Concerns Special Concerns Manage for recreation values (PC Trail, Gold Lake, Rosary Lakes) and cross country skiing People Nonwilderness proponents want it left as it is felt strongly about portions and want dispersed Significant number for wilderness mentioned recreation protecting the Many Lakes area. Recommendation Recommendation Undeveloped Recreation from Twins north along township line along Waldo Road -- Maiden Peak Consider for wilderness, as we have it now (West south will be Undeveloped Recreation -- rest to Many Lakes area). the south should be General Forest

Appendix J - 17 Appendix J Public Participation in Forest Plan Development

Windigo/Thielsen Roadless Area

Comments Number Comments Number

No comments No comments Protect Protect Part wilderness Part wilderness Wilderness Wilderness Nonwilderness Nonwilderness

Comments Number

Comments Number No comments Protect No comments Part wilderness Protect Wilderness Part wilderness Nonwilderness Wilderness Nonwilderness Special Concerns

Special Concerns Unique biologically and geologically Mountain Trails, high lakes, wildlife, exclude Summit Lake pine beetle epidemic Road from wilderness. Recommendatlon Recommendation

Wilderness or Undeveloped Recreation allocations. Stay with present recommendation (Preferred Need to discuss Alternative)

Appendix J - 18 Appendix J Public Participation in Forest Plan Development

Comments Number Comments Number

No comments 14 No comments 6 Protect 4 Protect 0 Part wilderness I Part wilderness 3 Wilderness 9 Wilderness 4 Nonwilderness 9 Nonwilderness 11

Recommendatlon Special Concerns I Leave as It is. Dispersed recreation

Appendix J - 19 Appendix J Public Participation in Forest Plan Development

Nature of Respondents

Nature of Respondents I Federal and State Agencies 14 Timber lndustly 49 Associations 15 Motorized Recreation Interests 4 Riding and Hiking Interests 7 Individuals 1353 Academia 3 Professional Societies 4 Conservation Groups 42 CMC Groups 6 Business Groups 101 Other 37 Total 1623

Elected officials who provided written comment included State Representatives Tom Throop and Peg Jolin. Throop basically supported the Preferred Alternative with some exceptions. He requested the Wild and Scenic River recommendations be expanded to include the upper Deschutes and lower Metolius. He also requested that the denial area for geothermal leasing in the Newberry Crater more closely correspond with State and County recommendations. He also requested more attention be given to fisheries on the Deschutes River. Peg Jolin requested that the Waldo Lake road be paved

Other elected officials included the Deschutes and Klamath County Commissioners. The thrust Origin of Responses Number of their comments were to maintain or increase revenues to the Counties Outside of Oregon 127 Western Oregon 41 2 Following IS a relative comparison on the number Eastern Oregon 1084 of comments received regarding various issues Total 1623 and subjects This can be used as a barometer for the intensity surrounding various issues

f Appendix J - 20 Appendix J Public Participation in Forest Plan Development

~ Area of Concern Number Comments on many other subjects such as RPA, - range, soils, Wilderness use, fire, etc ,were usually less than fifty. All comments were used in the Roadless areas 51 0 analysis regardless of numbers. Fi r e w oo d 190 Geothermal 370 Roads 70 Recreation 650 Summary of Comments by Resource/ ORV Use 100 Issue Area Wild and Scenic Rivers 350 Cross Countrj Skiing 270 Tlmber Trails 160 Sustained Yield 170 Lodgepole Pine Salvage Old Growth 170 Visual Resources 190 Very little support for accelerating on a 15-year Water 90 basis for the following reasons: Wildlife 430 Fish 60 Established industries do not need or TE Species 50 particularly want a lot of lodgepole JobsIlncomelEconomics 250 Employment 350 There is no certainty that new industries Departure 80 will emerge to utilize the material, and if Below Cost Sales 100 they did, what would be the long-term Timber Harvest Levels 580 implications Lodgepole Pine/Epidemic 130 Clearcutting 21 0 Do not like the large clearcuts associated with the lodgepole pine harvesting

Do not like the effects on mule deer habitat Alternative Number since cover is reduced, more roads are constructed, and the forage gains are only Alternative A 200 short term. A more desirable condition Alternative B 80 would be small areas treated through time to create a mosaic. Alternative C 180 Alternative D 100 Alternative E (Preferred Alternative) 590 Not economically sound because the Alternative F 110 material is going for minimum bid, the Forest Alternative G 170 Service and counties are not gaining any Alternative H 100 revenues, and it suppresses the amount of Central Oregon Alternative 960 ponderosa pine that could be harvested, which is the more valuable species

The Central Oregon Alternative was one developed People do not like the departure timber schedule associated with accelerated by timber industry during the public comment lodgepole program period. Its basic thrust was to increase the amount of ponderosa pine offered each year. Many of the People would like to see the wood used for people who commented were concerned about firewood rather than commercial products. lobs and employment and were basically opposed to locking up land at the expense of timber Seem to think It is okay to treat stands not harvesting already infested through forms of thinning.

Appenduc J - 21 Appendix J Public Participation in Forest Plan Development

Ponderosa Pine Harvest Levels Below Cost Sales

Many people asked for a constant, dependable Strong objections to below cost sales from flow of ponderosa pine sales at or above historic environmental community. Most of these people levels. Some people recommended a harvest requested that a map of these sales as well as unsuitable lands be included in the Final Plan level of 140 MM board feet, which was proposed Many people relate below cost sales to unsuited by the timber industry. Some of these same people lands. Also, although not always stated, many of said, 'sell what grows' and do not impact other these comments are aimed at not entering resources such as wildlife and recreation. Two Roadless Areas. significant misconceptions exist in the minds of many respondents: Wildlife

That the Forest is proposing to sell signifi- A great deal of concern was expressed cantly less ponderosa pine volume than in that the great grey owl was not considered the past. in the plan and that the Standards and Guidelines for goshawks were inadequate That the Forest can produce 140 MM board Some concern that no provisions were feet of ponderosa pine with little or no impact made for osprey outside of the Crane Prairie on other resources. area.

The impact on jobs and the local economy were Much concern expressed about snags in the key reasons behind support for this issue. ponderosa and request that all snags be left in ponderosa pine. Some expressions Clearcutting that the 60% level was too low and we Should go to 80-100% There is strong objection to clearcutting, even from industry. Few, if any, comments were received There was concern about the impact of in support of clearcutting Many people recommend roads and ORVs on wildlife There was concern that no specific road management selective harvest as an alternative. Maintaining direction was included in the Plan biological diversity was the most common justifica- tion Some people claim our clearcutting policies It was pointed out that the Townsend's violate NFMA bigeared bat was not included in our Management Indicator Species list It is Sustained Yield/Even Flow Versus Departures now classified as a Sensitive Species and should be included, and direction developed There is strong support for sustained yield/even and incorporated in the Plan. flow. There is almost no suppoFt for departures, even in lodgepole There was a high level of concern about the accelerated harvest of lodgepole pine and the impacts that would have on hiding Firewood cover for mule deer A slower conversion rate was recommended, with small cutting There IS strong support for the firewood program units to develop a more diversified Forest from nearly everyone, including the timber industry. condition Many people want firewood separated from ASQ calculations, and some industry representatives Considerable comment about old-growth claim this violates NFMA regulations (preliminary and its value. Topics included wildlife, research indicates they may be correct). riparian areas and visual management as

Appendix J - 22 Appendix J Public Participation in Forest Plan Development

well as real estate and a supply of material Trails for the large ponderosa pine mills. Viewed collectively, trails (hiker, horse, mountain Fish bike, Nordic, motorized, and canoe) received just slightly fewer but more varied and individualistic Though not large in numbers, there was intense comments than roadless areas or Wild and Scenic criticism that the Plan was grossly inadequate in Rivers. Many letters stated interest in loop trails at addressing fish and fish habitat. Most of this all campgrounds, development of trails to scenic centered on the Deschutes River and the larger locations, and separation of motorized use from lakes and resewoirs. trails used by hikers. Close in trails also received favorable attention. Recreation Most commentors remarked on the need to Roadless Areas separate types of users to optimize the quality of the recreation experience Separation of Nordic Of the recreation related topics, the greatest ski and snowmobile trails, hiking and ORV trails, number of comments received advocated mainte- and mountain bikes from heavily used hiking trails nance of existing Roadless Areas in their current was advocated. condition with no motorized use, geothermal development or logging. Maintenance of the Protection of the scenic values of trail corridors roadless condltion was strongly supported for from timber harvest (clearcutting) especially for several individual areas: Maiden Peak, the Bend the horse users of the Windigo-Metolius trail and Watershed, the Metolius Breaks, South and West the Newberry Crater area was very important. Bachelor, and North and South Paulina. Many comments focused on developing these areas for Mountain bikes received mixed reviews Most hiking and Nordic skiing away from motorized commentors simply said "avoid conflicts with vehicles Support was expressed for additional hikers,' but a few requested bikes be prohibited. snowmobile trails in the Paulina area. Nordic Skiing and Snowmobile Use A large number of people were concerned about further wilderness allocations and their fear about A great deal of interest was shown for increasing locking land up. There obviously is a perception Nordic skiing opportunities, particularly in areas that what is going on in land management planning readily accessible to population centers Many involves such activities. comments favored separating Nordic skiing and motorized use. Areas most often suggested for Wild and Scenic Rivers expansion of Nordic ski trails were the Bend Watershed, south and west of Mt. Bachelor, Strong interest has been expressed in adding Swampy Lakesflodd Lakes, and Maiden Peak- both the entire upper Deschutes River and the Willamette Pass area entire Metolius River in the Wild and Scenic River System. A number of individuals and groups also Some interest was also expressed in expanding expressed interest in Fall, Spring, and Little opportunities for snowmobiling in the Newberry Deschutes Rivers, as well as Crescent, Squaw Crater and into remote areas generally inaccessible and Big Marsh Creeks. Although protectionfrom to skiers. hydroelectric and commercial development were major concerns, protection and enhancement of Comments were also received expressing a need fish and wildlife habitat, scenic values, and to extend snowplowing so wilderness would be compatible recreation were advocated more accessible for day use skiing

Appendix J - 23 Appendix J Public Participation in Forest Plan Development

Off-Road Vehicles Several letters expressed a preference for maintain- ing a scenic corridor along Squaw Creek, Pole Comments on ORVs showed up in many areas. Creek, and the Three Creek Lakes road. Suggestions were to keep them out of sight and sound from Roadless Areas, wilderness. scenic Overall tone was that visual resources were areas, sensitive habitat areas, Research Natural important to the lifestyles and recreation experience Areas, and summer and winter trails, campgrounds, on the Forest as well as affecting the monetary Nordic ski areas, etc. value of real estate.

A few comments recognized that ORVs should be Energy and Mlnerals given some opportunities. Geothermal Snowmobiles received the greatest support.

Metollus River Corridor There is considerable and varied input to the geothermal resource. The key points are: Comments were sprinkled throughout the recre- ation related input that specifically focused on the A concern that geothermal leasing should Metolius Strong support was stated for Wild and not occur in Roadless Areas. Scenic River classification for the Metolius from its source to Bridge 99 (scenic) and from Bridge 99 Request a map showing the current leasing to Lake Billy Chinook (wild). The Warm Springs Tribes are adamantly opposed to classification of A concern that leasing and development the latter segment. should not be allowed to conflict with any other resources. There was strong support expressed for maintain- ing the roadless character for the Metolius Breaks. A concern that there be no leasing in visual, critical wildlife habitat, and other ecologically Interest was also strong for maintaining or enhanc- sensitive areas. ing the existing visual character of the corridor and restricting or limiting timber harvest and any That the winter recreationlgeothermal additional commercial or recreation development. management area be treated as separate designations since winter recreation is not Visuals compatible with geothermal. Primaly interest came in comments expressing That the Bend Watershed, Research Natural the need to protect scenic values along rivers Areas, and Experimental Forest be leased and highways. It was suggested that ORVs and geothermal not be permitted in visually sensitive with no surface occupancy restrictions as areas. Also, many comments favored utilizing opposed to being denied. landscape management techniques more widely, especially for timber harvest and in rehabilitating That there be a better analysis of the older cutting units. resource and economic outputs in an area before leasing is denied out of hand. A number of comments focused on the Sisters area in addition to the Metolius corridor. Several Hydropower comments suggested more sensitive treatment (less cutting) around Black Butte. These were Hydropower development has been of considera- countered by comments advocating no special ble interest in the Central Oregon area for the last treatment be given to lands adjacent to exclusive three years as a result of numerous applications homesites. to establish low-head hydropower facilities.

Appendix J - 24 Appendix J Public Participation in Forest Plan Development

Numerous respondents were concerned about quality. They would like the National Forest hydropower developments along portions of the to make sources of this material available Deschutes and to a lesser degree the Metolius to the public. River. The vast majority were opposed to such developments. Areas of Agreement

Speclal Uses The public as a whole agrees that the Deschutes National Forest should be managed so that large Most of the comments were about the standards/ ponderosa pine trees are always here and not guidelines for Special Use Permits. Comments just in special areas such as roadside zones or focused on Recreation type permits and particularly scattered old growth stands Reasons are they outfitter and guide permits since the Plan proposed like the looks of large yellow bellied trees in the rather restrictive policies with the greatest limltation Forest environment and from a timber standpoint, in wlderness they are the most valuable tree. Key concerns: There is a general consensus that clearcutting in ponderosa pine is inappropriate For the most Equitable treatment of all publics in applying part they do not like the looks of clearcuts, timber wilderness capacities. industry does not like to have to cut and haul small trees, and people perceive it to be bad for Limits on party size should include only people and not livestock. wildlife

Limitations should recognize business need There IS general consensus that accelerating the to grow to an economical size harvest of lodgepole pine on a 15 year basis is inappropriate. There were some comments that requested the continuation of the recreation residence There is agreement that we should not be entering program and one which suggested it be the Roadless Areas in the first decade for purposes terminated; also that the Plan relate to any of harvesting timber or salvaging dying or dead future use determination. lodgepole pine.

Land Adjustments There is sweeping support for including the Deschutes and Metolius Rivers in the Wild and There were relatively few comments which tended Scenic River System (One noticeable exception to be concerned about land adjustments adjacent is the Confederated Tribes of the Warm Springs to subdivisions or destination resorts. Reservation on the Metolius.)

Common Mlneral Materials There appears to be agreement that the amount of personal use firewood which we proposed to Not all material sources on the Ft. Rock make available on an annual basis is acceptable District are shown that will be needed in the next 10 years. There is agreement that the Forest plays a vital role in the economic health of Central Oregon Deschutes County comprehensive plan is being revised to deal with common material There was strong support not to allow geothermal needs and their potential conflict with other leasing in the interior of the Newberry Crater uses. Their present plan recognizes a There is some discussion on just where the line shortage of gravel and stone of building between leasing and denial should be placed.

Appendix J - 25 Appendix J Public Participation in Forest Plan Development

Areas of Disagreement Continue on as presented in the DElS

There is no agreement on how much ponderosa Ponderosa Pine Harvest Levels pine should be harvested. Increase the flow of ponderosa pine harvest by ignoring the impact of lodgepole pine salvage Even though there is agreement about timber program. harvesting in the Roadless Areas in the first decade, there is not agreement as to whether those areas Since the flow of large ponderosa is lumpy in the should be removed from the base when calculating first three decades due to the accelerated harvest- the ASQ ing of lodgepole, use a schedule that smooths off the first three decades of ponderosa harvest levels There is no agreement on what the long term Use a departure timber schedule to achieve higher direction for Roadless Areas should be. first decade timber harvest levels of ponderosa pine. There is no agreement on what the role of the Forest should be in providing for economic Continue on as presented in the DEIS stabilization or growth in our local economy. Many feel we should focus on timber and commodity Clearcutting resources while others feel strongly we should focus on our recreation resources. Evaluate multrgaged management techniques through the 'Prognosis Model.' Determine where these techniques are appropriate Include appropri- There is sharp disagreement on whether additional ate direction in standards/guidelines. Change cross country ski areas should be established yield tables where snowmobiles are excluded. Continue on as presented in the DEE There is no agreement that cross country skiing and geothermal leasing are compatible or that Wild and Scenic Rivers leasing should occur at all. Stay with our proposed classification is one choice Courses Action to Conslder of Another is to recommend the entire Deschutes, and the Metolius only down to Jefferson Creek. The first five subjects listed below were the focus of planning revisions between DEE and Final EIS. A third choice is to recommend certain segments The remainder of the subjects were dealt with by of the Deschutes above Spring River, primarily the Forest. excluding the private lands, in addition to what we have already recommended Lodgepole Pine A fourth choice is to work with the state and include the Deschutes in the Scenic Waterway program Extend the conversion period from 15 years to and include the Metolius down to Jefferson Creek 30-40 years in the federal program

Take the dead lodgepole out of the calculation of For the lower Metolius it appears we need to work the ASQ and work with it strictly as a salvage out a cooperative approach with the Confederated program with no specific conversion period. Tribes but not recommend it for classification.

Appendix J - 26 Appendix J Public Participation in Forest Plan Development

Some combination of the above alternatives is Wlldllfe also feasible. Develop some addltional Standards and Guidelines Roadless Areas that address great grey owls, osprey outside of the Crane Prairie area, and re-do the standards/ For the most part the areas that people expressed guidelines for goshawk if necessary the most concern about are not proposed for a lot of development The exception, in the long Stay with 60% population level in snags, and term, would be Charlton and Maiden Peak Roadless better explain what is going on with snags in Areas. Re-evaluate whether to retain these two in ponderosa pine stands. an undeveloped condition. Review the ORV Plan to assure it provides for Sustained Yield/Even Flow Versus Departure wildlife needs and incorporate more specific road management objectives developed as a result of Eliminate the departure in lodgepole. coordination with the Winema- and Fremont Do not propose departure in ponderosa pine Develop direction to address the Townsend's bigeared bat. Treat dead lodgepole as a salvage operation Explore different conversion periods for lodgepole Flrewood pine.

Maintain the provision for 60,000 cords of firewood. Fish

Develop standards/guidelines that will tell where Develop and include more specific information on and how the firewood program will be managed fish habitat, with a focus on the Deschutes River

Keep firewood out of ASQ calculations (do not Trails really know how to resene it and keep it out of the ASQ, however). Establish direction in the Plan that sets the frameworks for developing a more site specific Get Regional Office opinion of legality of having trail plan as a part of implementing the Plan firewood part of ASQ (possible NFMA violation). Nordlc Skiing and Snowmobile Use Below Cost Sales lncorporate an expansion of trails for winter use Include explanation of the below cost/deficit sales in with an overall trail plan issue in our response to the public comments. Set aside new areas for cross country skiing and Include direction in standard/guidelines on how exclude snowmobiles the Forest should manage low value or below cost sales. Congress is going to force us to do Maintain status quo with regards to cross country this anyway. skiing and snowmobiles.

Include a map of unsuited lands in the final plan. Off Road Vehicles

Do not attempt to make a map of below cost Review the ORV plan to determine if sensitive sales, but we need a good justification on why we areas have been covered and where appropriate, did not. conflicts minimized.

Appendix J - 27 Appendix J Public Participation in Forest Plan Development

Visual with denial than with a no surface occupancy stipulation Re-evaluate scenic views emphasis on the Sisters District, the higher flanks of the Cascades, and We need to strengthen the display of outputs and the slopes of the Newberry Crater. economics for the geothermal resource This can be done by creating an assumption that there will Geothermal be a modest size pilot plant developed during the Plan period (which is feasible f a resource is Will need to discuss the effect of existing leasing found). It is much more difficult to compare potential on Roadless Areas. Show the amount of Roadless outputs of the geothermal resource on a broad Area within the management areas with high area basis with other resources (although this is geothermal potential and explain whether geother- probably what we have been doing on a subjective mal leasing is compatible with the objectives of basis in making decisions up to this point). the management area. Explain that the Plan is not making a decision to lease nor to determine the Speclal Uses conditions of leasing. Better explanation of the objectives of wilderness We can include a map showing the status of management and reasons for favoring individual current leasing use over commercial use.

Point out that one of the goals of the Plan is to Some possible easing of the restriction on growth provide for geothermal resource development of existing permit capacities including allowing which is compatible with other resources. The more growth outside wilderness areas Plan is making some decisions about leasing in the form of denial of leasing for some management Identify the future use determination study as a areas. The Plan also indicates the general level of post LMP activity and indicate when it will be compatibility and amount of restrictiveness which scheduled. might be applied to other management areas subject to a post Plan analysis which will make Land Adjustment the decision about leasing and the conditions under which leasing will be permitted. Review the plan for logic and consistent treatment in these areas Explain that the land adjustment We should give further consideration to the plan does not make the ultimate decision about relationship of the winter recreationlgeothermal an exchange proposal and that the environmental management area. There are several alternatives process provides for public input and a decision including renaming the area, strengthening the on a specific exchange proposal standards/guidelines to explain the relationship, or creating separate management areas which Common Mineral Materials separate the perception of conflict. The intent of the Plan was to designate the sources We could consider removing from denial the to be used during the Plan period, however, there Research Natural Areas and the Experimental was an attempt to eliminate and consolidate sites Forest These areas could be adequately protected to lessen the impact on the Forest recognizing by a no surface occupancy type of stipulation that the economics of haul might necessitate which could be determined in the post Plan some changes with time assessment. The procedure would in effect defer the decision on how to handle these two areas to Sources not designated in the Plan would have to the post Plan assessment We suggest not doing be allocated through a NEPA process We should the same thing with the Bend Watershed because review this map to make sure all the sites are there is a stronger public perception of protection located to the best of our ability

Appendix J - 28 Appendix J Public Participation in Forest Plan Development

We should coordinate with Deschutes County to type of material without competing with the private see if the data they are now collecting still indicates sector, then we could amend the Plan to do some a shortage of aggregate. If the shortage has of this. reached the stage where we can dispose of this

Appendix J - 29 Appendix J Public Participation in Forest Plan Development

Summary of Responses to Supplement, Draft Environmental Groups Forest Plan and DElS Virtually no response. The Washington Native Industry Plant Society asked us to weed out the "No Change" Alternative but MRs are to its liking It said SOHAs There were three industry responses The most have to be dedicated (not managed) because we extensive was from the Northwest Forest Resource can't create old growth "Some of the finest Council. it was apparently sent, in virtually identical examples of old growth Ponderosa Pine in the form, to all Supplement Forests. The RO planning world exist on the DNF, and we believe that the shop, in the person of Tim Tolle, has prepared a DNF must demonstrate that an adequate and response, which is included in the comment/ well-distributed representation of such habitats response section of this Appendix. It can be are preserved across the Forest.... adopted to the Deschutes NF situation Mazamas A description of the remainder of the response follows. 'First, we consider the "No ChangenAlternative an exercise in futility " Northwest Forestry Association The remainder of the response was an amendment --The 'No Changen Alternative's timber output to comment the Mazamas submitted to the DElS level should have been described in terms of its (kosher?) The letter goes on at length about old programmed harvest level, not potential yield. growth and roadless areas and endorses Alterna- tive G --The range of scientific opinion wasn't acknowl- edged Individuals

--Other ways of meeting the MRs weren't analyzed. As expected, a number of people seized the opportunity to hold forth on a variety of matters --The final Forest Plan must provide for the area's There were SIX in ail existing resource-based industries One respondent wants the MRs to address bugs. Douglas Timber Operators, Inc ("Insects provide the bulk of the diet for many game birds and song birds. ") He thinks we need They agreed with NFRC. to count our bugs

Agencies Several people opposed cutting on Black Butte Four voiced concerns about old growth A person The Department of Interior wrote to say it had from Minneapolis proposed no action in spades, nothing to say, as did the Department of Health & a dedicated National Natural Preserve One Human Services. The Environmental Protection declared. "I don't give a hoot about the Spotted Agency said implementation of the 'No Change' Owl' but also said "scenery is the foundation of a Alternative would be a bad idea. It took the tourism economy" opportunity to remind us of its lack of enthusiasm for the DElS Cenvironmental concerns - insufficient Responses to these submissions will be pub- information") The Boneville Power Administration llshed In a separate portion of Appendix J, wanted to talk about utility corridors, which has Response to Public Comment. nothing to do with the Supplement.

Appendix J - 30 Appendix J Public Participation in Forest Plan' Development

List of Respondents

Elected Officials, Federal and State Agencies, and Trlbal Government Responses

FEDERAL AGENCIES

OEPTOF ENERGY DEPTOFTRPlNSWRTATION COT USCG (2) ENMRONMENTAL PROTECTION AGENCY FED AVATlON AOMlNlSTRATlON FED HIGHWAY AOMINISTFRTlON FED ENERGY REGULATORY COMM GENERAL SERVICES ADMINIATPATION TENNESSEEVALLW AUTHORlIY US OEPTOF INTERIOR US DEPT OF LABOR US OEPTOF DEFENSE HOUSING URBAN OMLOPMENT US DEPTOFAGRICULNE usw. NR. OCEANIC~ATN AOM US01 ENVIRONMENTAL PROJECT REVIEW STATE AGENCIES AND ELECTED OFFICIALS

STATE REPRESENTATNEJOUN HONOWBLE ROBEFKPICKARD HONORAQLE ROBERT SMiTH HONORABLE RON WEN OREGON DEPT OF ENERGY OREGON OEPT OF FISH AND WLDUFE OREGON DEPT OF FORESTRY OREGON OEPT OF ECONOMIC OEV OREGON DEPTOF AGRICULTURE OREGON DEPTOF LAND OREGON STATE LANDS STATE OF OREGON OEPTGEO 8 MIN STATE OF OREGON INTERGOYT DEPT OF TRANSWRTATlON OEPT ENVlRONMENTAL QUW INTERSTATE COMMERCE COMMISSION RELATlONS COUNNAGENCIES

MSCHlslEs Mum FUNNING OESCHlslEs COUNTY COMMISSIONERS KLAMATH COUW PUBUC WORKS CIN/MUNICIPAL GOVERNMENTS

CITY OF SISTERS PUBLIC EDUCATIONAL INSTITUTIONS

BENDWINE SCHOOLS JOHNSON STATE WUEGE KLAMATH COUNTY SCHOOL DlST OREGON STATE UNlVEPSlTY

Appendix J - 31 Appendix J Public Participation in Forest Plan Development

BUSINESS AND INDUSTRY REPRESENTATIVES

0ACHELOR RE4LlY' BEND AGGREGATE EIACK COMPANY WISE CASCADE

0RoADVlEw LUMBER ~ ~ . ~~ ~~ CASCIIOE~~ TMYE. ~ CHAMPION MElAL M CHASE FITZPATRICK W HODDER LUMBERM CLEAR PINE MOULDING COLUUOA hEUCOF'TER MLUMElAPLWWD CONTACT LLMOER M CONTlhENTA.RCQD C 0 WED hG SLPPLY 0 STAKE MILL D UE WJBPriOTO DAnGREI\'S. hC DAW FOREST PRODUCTS DlNECORBm FAhlLY COOSO& LUMBER E.USOh COMPANI ENOUROAW\B!ANS EWALODGE FlUilF EDUED CUI( C FARWEST CHEMICAL FOREST PROD SALES CO FORnFlOER CORP FMDRJEGG COMPANY FREMONT SAWMILL

FULLMER~~ LUMBER CDMPANV GEO OPERATOR COW GEORGA-PACF C CCRP GlLCHRlST LUMBER M GlLCHRISTTlMBER CO GWOWlN BROTHERS. IN0 HAPPY JACK SKIADV HARDMAN LLUMBER COMPANY MWATER LCGG NG HELENA LUMOER h Gn CASCADE PACA IOZAL WYPAhY. IhC NDAAA FOREST PROD INAND AOUA-TECH hN OF ThE 7vI MM 1,SERSTATE .UMBER COMPAhY

.MSUOUCH MOTORS. INC JOE~~~~~ WAIEEL~~~.~~~ LffiGIKG~ KR.EGEROROUGr4TON LLMBER M KWSlFMR4DO u\KNIEW LUMBER PRODUCTS LUMBERMEN'S INSURANCE McPHlWFSMGF CO MEOFORO MRWPAnON METOLUS mm.OOGES METROWUTAN LUMOER MILL SUPPLY CORP MR KRUSHAM Ml BAChELOR P NE SALES lKC hlT BACnE-OR IhC MYRMO a SONS N W ALPINE AOV NEE-Y SCrV)-BJN 8 W NORDIC WEST NORTH IDAHO WWD NUGGEI NNVSPAPER OREGON INDUSTRWSUPPLY OUECORADV PLJS OXBOW GEOTHERUA. PACIFICGASTFANS CO PAPE' BROThEFS. hC PINE PRODJCTS COUP

R as LEASING co RAHOWEUM~~ REED momw RWLN ROBBERSONFORD RUSSELL INDUST, INC SISTERS VETRINARY CLINIC SNOW MOUNTAIN PINEM THUNDER OlRD MOULDING TIMBER 8 WWD PROOlCTS UNIVESAL LUMBER COMPANY VALE LANCE PA010 SEMCE WEYERHAEUSER COMPANY WlNG INOUSTRIES WWD PRODUCTS CREDIT UNION

Appendix J - 32 Appendix J Public Participation in Forest Plan Development

LIST OF RESPONDENTS

ORGANIZATIONS

ACHP AUOuToooRS, INC AMERICAN RNERS. INC Assoc OF OREGON LCGGEPS BEND BADMINTON CLUB BEND CHAMBER CRIBBAGE WNG BEhO CWBER OF WMMEffiE BLACK BkEhOMEOWERS BLUE MT PROT ALLIANCE CWFORhA EhERGY COMPANY W\SW\DIA WUDUFE hSmE CENTRAL OREGOh AUD-BON 8OC.W CENTR4L OR RUNNING CLUB DELAWARE RNER BAS NS MMM 0ESCnUTESGEO.OGVCL.B ES FR ENDS OF WhITEWATER hdS SPECIAL PROORAM CCY)RO HIGH DESERTMUSEUM IZAAK WALTON LEAGUEOREGONDlVlBlON I(ELIR EhVlWNMEMAL ASSOC KIWWIS CLUB OF SISTERS KLAMI\M COUNlY CHPMMBER OF WMMERCE L B.C< WhSEhSUS~. U)M MMAh4AS MIDOREGON IAEQRCOM MISSOURI RIVER @ASIN WMM MWNWUWFXSNOWMOBILERS NATIONAL RESOURCE MNSRV UnVEPu\M 8oc m NdNRE WNSERVWCV NORTHWEST FOREmY ASSOCIATION NOFThWEST RESOJRCES NW PINEASSOCI/\TION OBSIDIANS, INC ODE1 LAKE SUMMER HOME Ass OHIO RNER BASIN ORGUIDESSBPACKERS OREGON HUMERSASSOCIATION OREGON hEVMBER OREGON NATURAL RESOURCES OREGOh STAlE SNOWMOBILE WTARY CLUB SISTERS FOREST PIAN WMM soc m OF AMER CAN FORESTERS SOUWERN OREGON TIMBER IN0 SUNREROWERS SLRUdA. CENTER THUNDERBIRD MO#,,I "ING TROUTUNUMKEO WALDO W LOWNESS CO-NCL WASH NATIVE PLANl SOcIElY WILDERNESSSOCI~

Appendix J - 33 Appendix J Public Participation in Forest Plan Development

INDIVIDUALS

ABEWN. BRUCE ABNEY. RACHEL C B ADAIR. RICHARD ADAMS, ROD AGEG, CHUCK ALLEN, CLARENCE ANOERES. H F & PAT ANDERSON, WUG

ANDERSON. STANLEY H ANDERSON TERRY ANDEMN.~~ ROBERT L. SR ANGLE, JERRY ANGTEN. ROB ARW. TOM ARMSTRONG. BOB 8 NANCY ATKINSON, RAYMOND G AUGUSTSON. BONNIE AUSTIN, ALEX J AWES. OALE BABMCU CWG EACH, MIKE EAER, WILLIAM J BAER, JR, WILLIAM J BAILLIE. GORWN C BAIN. JUDY 8 RANDY EAKER EARL L BAKER. G EAKER VALERIE A EALSIGER SANDY BARBER. WILLIAM BARR4 JOHNW snr",USA K EAUSINSLEY, J BUIROSLW, COLLEEN EEASLEY. LYLE D

BE" JOSE L ~~ BENSON, NEIL 8 DIANE BERRY, WNU BERRY. ROBERT W BERTW\M. JEFF SESSEY. ROY E BETESWORTH. R SN BIELEFELDT, TALBOT BILLINGS. GARY SSn3? GOIABJffirlJA BISHOP. JAMES M &ALICE BISSET, DAN BLACKER, WNALD R SLACSLEE. CHARLES A BLWMOUIS. GlLBERT&ELAlNE BOND, WRY ELLW BORGHIRST ROBERT 60SIR MA-MU! BOURKE. WRGINW EOWERLY. GEPAW J BOYD. CAROL ERANWN.JUNE BW.J CALYIN BRPSSARD. LYNN BREWER. EO0 BAITION. JOANNE ERONSON. ROEERT P BROWN. WNAW E EROWN. LYNN M BRUCE, CHARLES ERUSSEAU. CUFFORD BUEU MR ~MRSo A EULKLEY, WNAW R BURGER. R D &WANDA L EURKHOWER. KENNEM A BURR, LAWRENCE

BUSH, ALY M CABLE~ THOMAS CAWWEU OUFFY M CAMERON, STNEN 0 WLMEL WWTREL GARY CARLSEN, LESUE A CARLSON. P L CARLSON, PEE CARMICKLE ME CARP, TERESA CARPENTER, RONALD E CARPENTER. WILLIAM &SYLVIA CARPER, BRIAN 8 CHARLOTE CEE. HAROW D CASTELL UUESIL CASTER. W R CATHERS. JOHN & JENNESSE CHAMBERUUN. CHARLES CHANCE, TERRY A CHASE. PHIL 8 JO CHASM, MR RICHARD M CHEN, TSE FANG S CHESS FRANKA CHEWNING. CUNTON C CHRISTENSEN, NT CHRISTENSEN, STURN w CHURCHILL AS 8 YICTORIA CLARK. BERT CLARK, DAYID WADE CLANGARTH CLARK. WRCHELLE L CMK, RK CLARK, ROY CUNE, EDWARDS COATES. ALAN 8 EDWIN COEN, VIRGINIA MIFF-, JOSEPH WGAN. JAMES H COLE. RONNIE R COLE so WUINS. DARREL L COLLINS, NANCY J W-PITIS. WIUAU S CONLEY. MAGGIE CONVERSE. PAUL MXIPES FAROW R WOPER, JACK COOPER MICHAEI CORWIN. RONALD L CQRJM~~ ALLEN WRUM JAMIUEUNE COVEY. UNDA L COX GRACE M COX. SUSAN E CRA0TREE. LEONARD CRATES. NANCY CREW, HENRY CRIDER. DAVID CRONEN. GARY CROW, JAMES P CROWDER, CUTON CROWSON. STEVE DANIEL EARRY L CYRUS, RAY ~ ~~ DAGGl3r. JACK D OALGUESH. KEN 8 wmy DANIEL FRANCIS & MY DANIEL MARK E DANIELS, KENNEW R DASCH, EUZABEM 8 FREDRICK DAVENPORT, ROY & JOYCE DAYIDSON, L G OAYIS. BERT E DAYIS. LARRY P OAYIS. PAUL 8 CRYSTALLE -"AWS . .. RODNEY._- DAYIS, WILLIAM E DAY, DIANA DAY, E J DE CARNE, TRISTAN & OEBRA DE GIOVANNI LOUIS V OE VOSS. VERA N DEGHUEE. JUDlE DEHUNGER. BARMRA DELLEN. L FAYE DESANTIS. NICHOLPS DESMOND. JACK om.LORN P WAN. WILLIAM WDSON. JAMES 6 DARLENE ~~ ~ ~. DRAKE, JERRY DUBOlS. CORNELIA K DUGAN. WILLIAM R BAUCE OUNN, K W OURAND. LUCIA OURR, ROLAND DYER & FAMILY, RAD EAMES. CkLESE,JR EASTER, KENNEM R EASTON, ART EBNER. JOHN EDGAR, MARION EOGINGTON. JESS EDICK. KEN EDWARDS. CATHERINE EIBERT. JOHN ELDRIOGE, RONAW K ELKUS. BEN ELLINGSON PETER EUINGSON. ROBERT ELLIS. JAMES 0 FLSHOFF. CAL & AUCE ENDICOT GWENDOLYN ENGUSH. JERRY ENGUSHIZ]).JERRY ERNST, MARY G

ERNST. WILL ERWIN. ALAN 8 MYRA .~~~ ~ EULER, H M EVANS, UOYD L MNGER. ROBERT FAIUNG WlLUAM L. JR FAMILY, FRENKEL FARLEY. WRY& JOAN FARRIOR. DANIEL & CATHERINE FAUMhER OilG - R FEWMAN. G & V FERGUSON, NA FlhhERAh STEVE & CAROLNE

FISHER, EO8 FISHER, JIM ~~ ~~ FLANAGAN. PA-LNE D FLURY. FLYNN. KURT FOLEY ROEERTH FLANARY. FRED 8 BEKY ~ .~ ~~ SUSAN FORD, CURnS FORD. LARRY 8 JAN FORD, TOM 0 FORRESTER. ROEERT FOSTER DAVID M FOSTER. ROBERT FOWLER JAhE FOWLES. GARY FOX. STEPHEN A FRANCIS C E FRANKEL RUSSEU FRAKLUN. GEORGE E FRANKUN, GREG FREESE. EUGENE & OORlS FRENCH ANOV FRIESEN LARRY FRENZEN. PEER FRERES.~~ ROBERT. ~~~ . JR FRESHWATERS, SCOT C FROST, ART FUCHS. DENNIS 8 NORMA FULLBRIGHI, VIRGIL GAFFNEY BILL GALKA ROGER GALlAGHER,MR BMRS UNCE GALldGHER, YINCENT M GANONG. FRANK F GARNER, JOHN C, JR GARRElT, ROGER C GARRl3r. TERRY GI\RTEN, ROY 8 MARGARm GAUTIEFVBAKER, ClAYlON 8 GEISINGER. JIM GELINER, THOMAS L GENnS WALT GERKE, FRED GAIL GERL EO8 GERL GARY GEYER, JOHN GILBERT CAROL GILSERT, WILLIAM GILCHRIST, BEN GILLAM, JAMES H GIOT, DENNIS W GLADDEN. JEAN GIASOW. MARLENE GLOVER, JAMES GOLDAMMER. JAY GOLTZ, DANIEL E GONZALES. FRANC1 GWOW~N,JAYNE GWOWIN, WTHY GOTCHY MIKE GOUGH. DAW0 W GPACE. WNL GRAHAM, ED GRAHANE PAUL J GREEN, DAVE GREENE, SARW E GREEVE. RODNEY GREGG. SElN C GREGSON. TOMS GRIFFRH. MARW GRIFFIMS. SYDNEY GRIMSLEY. BILL GRINOSTAFF. DAYID C GROOM. J AND V GRUBER, GERAW HACKHT, TERRY

Appendix J - 34 Appendix J Public Participation in Forest Plan Development

HAWERNICK... US, M D P C HAE, CHARLES W HAU BOB HALL DAFWL J HAUJOHN HAUOWAY. JIM WERN. CHARLES HAMMACK. JONAS HAMMACK. MELVIN L HAMMER, JOHN W HAM". WRY HANKS. J WAYNE HANNAM. JEFFRY nl\hSE.MAN J€Ah HANSON. MEX dANSON. OAV 0 R W.JERRY HRRBISON, JOHN F HARDlh CATHBY R.Sn MGAS, KEN" A MRPER TIM W HARR. PETER HARRIS. ALOHA HARSdFsED MICdAE. WHMAN, WILLIAM HIWTFORO. ROY H HARWEU DWANE HATCHER, Y HAFIELD, ELAINA M HATTERMAN RAhWWH D HAWN. RICHARD L HAXBY. MIKE HAYDEN. MARY K HAYWARD OEhhS HEDIN, JOHN HELMS, OANIEL J HENDERSON, MUMN HERBERT, LYNN HESSEL MIKE HICKS, MICHAELS HIGGINS. CAROLYN HIU SANORA HIWKE, MARK HILTY, RPI E HINZPETER. NORBERT 8 SUSAN HOCKEIT. BERT L HOERNING. DAVE HOFF AND FAMILY TED A HOFFMAN, KMN L HOFFMAN. LYNN HOLMMB. DIANA DEE HOLLAND. OAVIO A HDLMAN, HANK& PATIN HOLMAN. KERRY hWESNlThLR W HOWN. ED HOPE, JOHN J hORXBR. RCHARD L HoRTMAN, PHIUP w HORVATH. CAROL HOSINER, WNALO M hOLGHIO. ROBERT L HUGHES, MARY 8 ROBERT HUNT. BOB G HUMSINGER-MICHEL, ALYCE HURTLEY, DAVE a JUDY HUSTON. WLLY INGHAM. ANN IWCK, JACK M ISAACS. TERRY ISMAN. HARVEY JAWS. BRENT8 PAlT JAWSS, FLOYD M JAWSSEN. CHARLES 8 MARGE JAWBY, WNRAD L JENXlNS DEBERTR JENSW. GARY JENSEN, GREG JESSUN, R E JIANG. WNGFIE JMEANEZ WANOAM JOHNSEN. ROB JOHNSON, EUZABETI1 JOrihSOh GARY D JOHNSON. GAYLORD l"khSOh J&Cd.. JOHNSON, WALTER JOHNSON, WILLIAM T JOrlNSTO:, EUGENE R JOW, RUSS JONES. B M JONES. MIKEAL E .ORON\. U.WY a OAV D JOURNAGAN, JOYCE KARNES. ROBIN KEEP.-- . SWTR KEW,RICHARD E KELLY, OARREL KELLY. RAYMOND L KEMP, JON KENNEDY, ROY M KERR, GERAW KILMEk, BILL KIWATRICK, KWlN S KIMBAU ED KINCAID. NWA L KINNAMAN, ANN KIRBY, KIM KlTCHER. BILL KNOKE. DALE KONING. MARINUS W . M 0 KONO ROBERT H KOSER. KEN KWCIk M/\x WIEGAR. DAMD M KREWSON. GREG KUNZ ALCO J LA WUR. MARSHALL LANGWN. LARRY IANGDON, LARRY LAUNG. TRpiCY L IAWRENCE. C M LEACH, CHARLES M a JEAN LENT, GARY A LEF'PER. JACK LEWIS, KRISTEN LEWIS. MARY L LEWIS, VlRGlL D LOCKYEAR. MAX L LOHNER, FREO a LORRAINE s LWPER, DUANE LORANCE. ESTHER LOUGH. WARRW LOVELAND; PATRICIA LUDWIG. EO WHMAN. DALE LUSK LUCILLE A LYNCH, LARRY MACY. WNL MADWX. ROBERT W MADSEN. STNE 8 UNDA MAHARY. JANET WOR, DAVlD L MALTBIE; RB MANGUM. HAW MA". JAMES R MANEFIELD GARY N MIWCW, EMRET MARCUS, MARILYN MARGUERTTE WMlNlMlE wmn, WLOUEE MARSH, FRANCIS MARSHALL DENNIS G MARTIN, CUMON MARTIN. WESLEY MARVIN, MARLA MATHEWS. LEO R MATHISEN. LEN MAUDLIN. OlCK MAXWEU MARYlN L MAYFIELO, R D MAFIELO. STEVE MAYNARD, OAN E, JR MAYO, JAMES D MC CAUUM, ALBERT A MC ELFRESH. ADRIAN M MCCLAIN, BERT MCCIAIN. MEL a REGINIA MCCOIN, LYNN 8 SHEM

MCGIAU. ELMER E MCGILVRAY. BONITA MCGREGOR.~ CHARLES W MW.hXlN. ROGER MCiNLEY, RUSSELL J MCLAUGHUN. GRACE MCNAMARA,' WESLEY R ANN MCSVIAIN. M CdELLE MEGOWAN, PATRICK S MELER VlCTORA MESSINGER, R C Mg%LF, ERNEST MICKEL GARY MILANO. GARY MILLAR, hFWC MILLAR. WN~ANCEI MIWR.MRS TERESA c MILLER, BRUCE H MILLER, CAL MILLER. CLARK J MILLER. D B MILLER, JAMES R MILLER, JERRY MILLER. JUDY MILLER. ROBERT8ALERA MILLER. SHIRLEY MILLER, STERLING MILLER, JOHN JR MILLER, JOHN F , JR MILLS, KAREN MINNIEAR. LARRYR MITCHELL JAMES R MITZEL VERNON MOLLMAN, DAVE MONFORE, JOHN MOODY, P L MWRE. EARL L MOORE, JACKSON a THELMA MOORE, PATRICU MOREHEAD, PAUL MOREHOUSE, MARION R MORGAN, PEGGY a JOHN MORSEUO. GERALD MOSAR. MERLE A MOSAR, MERLE A MOSS. RICHARD L MOUSER, JERRY M MUELLER. MIDGE 8 RICHARO MUWKIN. GORWN MYRON, JIM NANCE, PHIUP NEE, JAN NEIL FAMILY NELSON. DAVlD NELSON, DAM0 R NELSON, ERIC NELSON, HNlRY T NELSON, JAKE J NELSON, LONA M NEW MUSM NEWMAN, JOHN G NEWPORT, CARL A NICHAMOFF. PAUL NICHOLSON, DOUGLAS NICKISON. TEO NIELSEN. LAWRENCE NORMAN. JUUE NORMAN. REGINA R NORRIS, JOHNNIE C NYSTROM. Bb8W8ROBEFh OBRIEN, PATRICK J OWNNEUJIM o HARA &RR, SHARON OREILLY. BRIAN OBERWRFER, RICHARD ORR. MR 8 MRS PAUL ORR. WAYNE E OVERCRSH. DUWE OVERTON, JAMES OWEN, GENE L OWEN, JACK OWEN, M~NNE OWENS, DONNA OWENS, M H PAGE, CATHLEEN L PAGE, &AN PALMER, KINGWN. JR PANGAUO. CUFF PANKEY. GARY 8 HAYSEL PARKER, WALTER PARKS, WNAW PARTIN, TOM PATRICK. DWAYNE PAlTY, LAURA PAUT, WARREN H PAYNE, FLOYD 8 WNIFRED PEARCE. HAROW L PEARSON. FRANK PENTEWST. WlS PEPIN, SUZANNE PEPINCOST. SUZANNE PERKINS, J MARK PEERSEN. JAMES D PEERSEN. JAN PETERSON. CLYDE PETRIE, GORDON PEllY. DEAN PHILLIPS, JEAN PIERCE. GENE PIERCE, LINDSAY C PlsaN, LOUIS PLAT, PHILUP E PLA? F R a LOREVA POINDMTER. STRATTON POLING. JUDY WNClL ERNESE KKATHRYN PWR; JANE mwE, RM E PORCH, DELORES F POTTER. WNAD L POTlER. JOHN POT@, JEANNE POTWIN. STEVE POURNELLE, DON L

Appendix J - 35 Appendix J Public Participation in Forest Plan Development

mwa BE~IY WWEUJAMESH 8W PRINCE SUSAN PRINCE. WIWAM S PRINOLE. R 8 J PROSSER, MIKE PUMON, AMANDA QUEST. PETER C PAGON. ROSERT MER.STEVE 0 PAMOSS. TOM WP. CARL J WMUSSEN, OALE R PAWLS. JEAN READ, JOHN RECTOR, CAROL 8 JAMES REED, JOHN REED. STARR W REES. HELEN RMR. PAUL REYNOLDS, JUUE ANN MOA& LEE A RIAL OANIEL RICE JEFFERY L RICH, F BRENT RICHARDS, STEVEN C RITCHM, MARTIN ROBERTS, AGNES 8 IVAN ROBERTS. RAY E ROBINSON. CHERI L ROBINSON. EDWINA ROWERS. WANDA ROGERS. SCQTl A ROGERSON. MRS LOUIS RWPER WN ROSE. DAVID P ROSENBAUM. LA RUDDEU REBECCA S RUSH, AUCE RUSSO. WN SANDER. TERENCE SAN& LAUPA LEE SAPERSTRN. RALPH SARRETT,~JACK A SAUNOERS. JOHN C SCHAnr. PHIL SCHMIDT, KURT SCHMrrKE, OAhlEL C SCHNEIOERMAN. SHARON SCHWR MIDRED 8 LENORE SCHOTT. .OSEPn C SCHREIBER LAURA SCHULZE. PAUL SCHU&. WN SCOFIELD.km SCOTT, RONALC SCOTT. SARA A SCQlT, VERNON R SEAWARD. WARREh SWY, AM8RIA J SEIBERT. NORMA L SEID. VICKY SEIDEL KAREN M SENFF. WNE SEXTON, RICHARD W SHARKEY, JA SHAW, JESSE G SHAW. THELMA SHEARER. PiTER W SHELWN. STEM SHELTON. ROY V SHEPARO CLAY C SHEPARDSON. STAN SHER DAN. OENN S SHERMAN', JEFFREY G SHERRELLAUDRMR SHILLING, GARY SHINN. JOHN SHCCKEY. GARY SHCCW, KEN D SHORES, LYNN SHRUM. KENNETH 8 PATRICIA SHULTS. UNDA A SIKES. TOMMY SILVER, HOWARD SIMONS. ERNEST J 111 SIMONSON CARROLL R SIMS, LONNA SITZUAN, JERRY ALAh SKOW DANIEL M , SR SLEGEL LOUIS SLEGIK. MARK SMAUEY. SANDRA K DYM SMALLWWO. BARBAM 8 SMITH, WNNA SMITH, WNE SMIM. ETHEL I STEVE SMITH, J 8 R SMITH .uDITY 0 SMml, KELLY SMITH KELLY SMITH. LAURIE SMITH, uom A SMIM. MYB SMml. PAUL SMITH. ROGER 0 SMOLANO PAUL SNW.0, SARWA SOOERBERG. ROBERT W SONFIELD. AL SORWEIDE. ROBERT 8 WANDA SOUTHWARO C V SPANSEL RICKA SPEAWAN JAMES SPENCER, MARY KATE SWNGSERG. PAY 8 JOAN SPRING, RICHARD U STANDISH. CHRISTIAN G SlAhFORO. ma0 C M D P C STABR. MRE CLAM STEELE. WRlS STEINLEY GERl STENNETT. OALE STEPHENSON, GEORGE STEPHENSON, GEORGE STEVENS BRUCE STEWART.GEORGE A STICKEN, PAUL E sn& J.UM E 8 GLOR'A STILLNER GARRY STOCKER. DENh S R STORM. DUANE L STRJCCCnRSTOPnER J SULLIVAN, MICHAEL 0 SUM.ALFH:LD SUWERLAND. EDWIN A SWbhsOII WR4 SWANSON JOHN R TABER. R J IAhEY WJ 8 E. TAYLOR. GARY TAYLOR. LYNN TERREU CMRE0

~ , MIESSIN. ALBERTA E mows. M L THOW. MARY LO.. THORNTON. OAVIO P TICHENOR. STEVEN TIMMENS. JOY TrrlLE. AVERY GARY TOFTOAHL.DWIGM E TOMUNSON. NORA TWLE. KEN 8 GRACE TORKELSON. C S TORRES, DAW0 Tom. WA TPdCH. ALAN 0 TRACY, NANCYLOU 8SEPHEN TMNOSEN. MRS taw

TRIPP. WAYNE TRUMBUU MRY8LEE TSCHERSICH.~~~ HANS U M 0 NCKERER, TOM 0 NMIOhJ. LES TURNER. MERLE 8 MARJORIE UERUNGS JAMES UHRIMAN, CYNTHR UUU. RICHARD VMGEN, OAUD I VAL BARW VAN CISE. 0 J VAN DATTA CHAPITO JOAN

VAN DE WALKER. HUGH M VAN HISE, FAYE 8 WAUCE VAN MATRE. DENNIS E VAN ORSOW. EUGENE VAN PATEN~~ KENDRA VANUERT. GARY VI\RCOE.~. R VARLEY. T VERRET, JOSEPH U VICE. WILLIAM A VINCENT, OAYID YmER, JOE VrmE. MICHAELS VWS, STNE VROUAN. GEW.0 P WAOASKY, DANIEL J WADOEU NORM WALKER. BErIY WALKER, MERYUN A. WALSn ThOMffi E

WARD. ELDEN C WARD. JOHNS WARNEN. RICH WARREN. LARRY YIATERS~ .oafiE ~ n WATKINS. TOO WATSON. ROBERT P WEAVER, LANCE WEAVER. MIKE WESSTER DAVID L WEIONER. NAOMl WEIL MARY 8 DAVE WEINSERGER ROBERTG WEISLER. MELANIE WELCH, JOHN T WELKER. DAVE

WEST. CHAR WESTFAU PAMELA S ~~~~ WHEELER WOLGEOFFREY WICKER. KERRY A WICKERSHAM. RON WENKE. KEN WIGGINS. JANE WILBER. BRIAN WILBER, DALE R. JR W nEA! CHERY. WIWAMS. ALAN WILSON, EDWARD E WILSON. HARRY E WILSON, JAMES 0 W 90N. WALACE E

WINGER. MARK H WINTER. WALTER C WBECK STEVW W WISEMAN. NAYDA W mE~~ DOhA.0 G WITIRUP. RICH WOLFE. WALT WOLBMN. MAFEARETA WWD. CHARLES R WWO GORDON WOXEU TOM WPAYIJUDITH SPARKS. JUUS WRIGHT, CUFFORO M WRIGHT GARY WRIGHT, JEFF L WRIGHT, KENNEM A WRIGHT, SHERM WYAT WILUAM WYKES. R THOMAS YAGEh JAMES E YOUNG, WILE ZAPPELU FRED ZEHNER. JIMMY L ZIGELHOFER. ART ZOO< SHIRLEY

Appendix J - 36 Appendix J Public Participation in Forest Plan Development

Public Involvement Between the Draft Envlron- the public comment period, making themselves mental Impact Statement and the Final Envlron- available on the telephone and for meetings in mental Impact Statement the Forest Supervisor's Office.

The Proposed Deschutes National Forest Land The results of this concentrated effort to involve and Resource Management Plan, and the Draft the public in the planning process were impressive Environmental Impact Statement for the Proposed The Deschutes National Forest received over Plan, showing the Preferred Alternative, were 1600 written comments to the Proposed Plan and published and released for public review and Draft Environmental Impact Statement. The com- comment on January 10,1986. The public comment ments were carefully analyzed by planning person- period closed May 9, 1986. nel and entered into a special computer program according to the resource issue addressed. The purpose of the public comment period was Comments and questions received showed that to gather all the public concerns for resource the public was well-informed concerning the management issues contained in the Proposed planning process in general and the elements of Plan and DEIS. To be certain that as wide an the Proposed Plan and DEIS in particular. audience as possible was exposed to the Proposed Plan and DEB, Deschutes National Forest person- Three alternatives included in the Draft EIS, nel held press conferences, issued news releases Alternatives D, F and H, gained essentially no and mailed information to concerned groups and public support during the public comment period individuals As a result, they were dropped from detailed analysis in the Final EIS They will be discussed The Forest planning staff put together a presenta- as alternatives which were considered, but not tion which explained the major resource issues in displayed in detail in the Final EIS the Proposed Plan, and outlined how each resource was to be managed under the Preferred Alternative. There were also several changes in the Preferred Forest Service personnel then traveled throughout Alternative between the Draft EIS and the Final Oregon to present the program to groups ranging EIS which can be attributed to the high level of from local church groups to Congressional delega- public involvement during the public comment tions, and from timber industry groups to environ- period. The proposed departure schedule for mental organizations. Presentations were made to timber harvest was dropped due to an overwhelm- County Commissioners and Chambers of Com- ing rejection of the schedule by the public, including merce throughout Central Oregon regarding the timber industry and environmental groups, potential economic effects of the Proposed Plan. based on the written responses received Opposi- tion to clearcutting was expressed by approximately A 30-minute program was taped by the Oregon 60% of the written comments, and was expressed Public Broadcasting System which covered all the verbally by concerned private citizens, environmen- material in the Forest Service presentation. Forest tal groups and the timber industry at the numerous Supervisor Dave Mohla and Forest Planning Staff presentations and open houses held to outline Officer Larry Mullen were interviewed for the the Proposed Plan. As a result, Forest Service program The program was broadcast by PBS silviculturalists developed an uneven-aged man- three times during the public comment period. A agement system for Ponderosa pine stands similar 30-minute program was taped and aired by a Portland- based television station. Other key issues which arose during the public comment period, and resulted in revisions to Each of the presentations, news releases, letters, standards/guidelines for the Final Land and newspaper articles and programs encouraged the Resource Management Plan, or changes in public to address their written concerns for Management Area Allocations, included. visual particular resource issues to the Forest Service resource management (particularly for the area by May 9,1986. Forest Service planning personnel on and around Black Butte and in the Metolius also practiced an 'open door policy throughout River Basin area), fisheries management, manage-

Appendix J - 37 Appendix J Public Participation in Forest Plan Development

ment of riparian areas, water quallty in the 1986 Deschutes River, roadless area management, Wild and Scenic River designations, old growth 1/8/86: Press conference in Portland, timber management and 'big trees., snag levels, Oregon through Regional Office elk habitat management, mule deer habltat to announce up-coming release of management, management for other wildlife the Draft Environmental Impact species such as Thompson's big-earred bat, the Statement for the Deschutes National Forest Land Management great grey owl, and spotted owl, and a comparison Plan. Stated that there would be a of economic effects of management for timber public comment period for the versus management for other resources (wildlife, Proposed Plan and DEIS. ending recreation, etc.). on May 9, 1986 Press conference attended by media and representa- Changes in the Management Area Allocations tives of Northwest Pine Association also occurred as a result of the Omnibus Oregon Wild and Scenic Rivers Act of 1988 and the Final i ii oia6: Draft Environmental impact Supplement for the Spotted Owl Management Statement for the Deschutes Environmental Impact Statement in 1988 National Forest Land Manage- ment Plan published. The four year-plus period between the Draft and Final Plan has permitted extensive discussion to .I Forest Plan Report. Announced continue with our publics over the main issues that the Draft EIS and Plan was ready for public review, and which arose during the public comment period. explained the 70-page Reviewers Some issues have been refined to such a degree Guide. The Preferred Alternative by public comment and input that they should was briefly outlined and the public present little further concern after the release of comment period dates were the Final Environmental Impact Statement and included Also included were Final Land and Resource Management Plan. We phone numbers for the Forest have had considerable time to educate the public Planner and Public Affairs Officer and to modify our position in the draft. In addition, to contact for more information, or we have kept the public and the Oregon delegation to schedule a meeting informed through periodic newsletters (Forest Plan Reports), press releases and articles in the .. Forest Service News Release newspaper 'Proposed Deschutes Forest Plan Available for Comment" An- Public involvement has been a key part of the nounced that the Proposed Man- planning process since it began in 1978, and has agement Plan and Draft Environ- mental Impact Statement (DEIS) continued through to the upcoming release of the were available for public reivew Final EIS The result of this public committment to and comment. Summarized some the Deschutes Land and Resource Management of the major issues for the Manage- Plan has been a combined Forest Service/public ment Plan and stated where effort in the determination of major issues for the information and copies of the Proposed Plan, the development of the Alternatives, Plan, DEIS and Reviewer's Guide and the refinement of standardslguidelines in the could be obtained Public com- Final Plan and of the Preferred Alternative present- ments must be received by May ed in the Final EIS. 9, 1986. Public Input Chronology for the Proposed Forest .. Forest Service News Release Plan and DEIS 'Firewood - How Much For How

Appendix J - 38 Appendix J Public Participation in Forest Plan Development

Long?' Outlined concerns for a of Sierra Club; conducted by Bill continuing supply of firewood Arthur, Sierra Club's associate rep which will be addressed through for the Northwest. Held at De- the Land Management Plan for schutes Room l at COCC from 9 the Deschutes National Forest. am to 4 pm. Forest Service Article encouraged people to read attended workshop to provide and comment on the proposed overview of the Plan and informa- Plan and DElS using the Reviewers tion Key issue raised at the Guide. workshop was lack of attention given in the proposed Forest Plan I /I2/86 Article in Bend Bulletin 'Forest to water quality in the Deschutes Plan Unveiled' Described Plan River and to fisheries. Was first and DEE with 8 alternatives, also time the issue had been raised; highlights of the Plan for timber, resulted in specific Standards and recreation, geothermal, and Wild Guidelines being developed for and Scenic River possibilities. fisheries and water quality Copies of DElS available for public review: meetings to be held in 111 9/86. Article in Bend Bulletin "Club Gives Central Oregon and Willamette Hints for Plan Critiquesa Outlined Valley in March and April Public what occurred at Sierra Club comment period ends May 9, Workshop. Stated where copies 1986. Sierra Club sponsoring of Plan and DElS could be re- workshop on January 18 on how viewed, and gave examples of to read and respond to the Plan how to respond to a particular and DEIS. alternative Quoted Bill Arthur saying that preferred alternative is 1/16/86: Forest Service personnel attended most likely the one that the Forest meeting of Society of American Service would adopt. He advised Foresters to present an overview people to write the Forest Service of the proposed Forest Plan and if they objected to plans for a the major issues of the Plan. particular area of the Forest For Meeting was also attended by help, contact the Forest Service, local tele- vision station: inter- or group who will be closely viewed loggers who had recently reviewing Plan and DElS such as been laid off to determine their Sierra Club. reactions Forest Service clarified that the proposed Plan was in 1/28/86 Article in Bend Bulletin "Plan draft form and was not responsible Addresses Deschutes Uses". for current slow-down in local Outlined some of the key points in timber industry. First time question the Plan regarding timber, recre- was raised of effect of timber ation, game management, fire- industry-generated dollars vs wood, geothermal, and Wild and dollars generated by service Scenic Rivers Copies of Plan industries, such as tourism and were available for review approx recreation. Became an on-going 10 days later than originally discussion with many groups planned due to delay in mailing concerned with local economy. from printer in Salt Lake City, UT Stated that public hearings on 1/18/86: Public workshop on how to read Plan would be held beginning and respond to Forest Plan and with March 12 meeting in Red- DEIS. Sponsored by Juniper Group mond.

Appendix J - 39 Appendix J Public Participation in Forest Plan Development

.I Article in Bend Bulletin 'Reviews Economic Development Depan- Set in February'. Coalition of local ment. Agencies generally accepted conservation groups (Deschutes the components of the proposed Forest Planning Citizens Group) Forest Plan, DEIS and preferred to hold a series of meetings to alternative. discuss Plan and DEE Group composed of Oregon Natural January: Meeting with Environmental Protec- Resource Council. Juniper Group tion Agency representatives from of Sierra Club, Oregon Hunters the Seattle Office regarding Stand- Association, Central Oregon ards and Guidelines for water Audubon Society, and local Nordic quality and riparian environment. Ski Clubs. Stated that meetings Discussed their concerns, resulted were to be held each Tuesday in changes and revision to Stand- and Thursday night, beginning on ards and Guidelines to be included February 4, and would cover a in Forest Plan to correct or mitigate diferent aspect of the Plan and their concerns. DEE each meeting. January: Half-day meeting between Forest 1/29/86 Letter mailed to permittees, appli- Service Planning personnel and cants and others interested in the the editorial staff for the Oregonian management direction being newspaper. Presentation and proposed for Outfitter/Guide and over- view of the proposed Forest Recreation Event Special-Use Plan, the Draft Environmental Permits in the Draft Land and Impact Statement and preferred Resource Management Plan and alternative Discussed all major DEIS. Letter mailed to advise them resource issues and how they are of the release of the Plan and addressed in the preferred alterna- DEIS and of the public comment tive. Also outlined the public period set for the next few months comment period and the Review- Explained that to be included in er's Guide for the DEIS. public comment period were a series of public meetings which January Monthly meeting between Forest were designed to encourage Sewice Planning personnel and written comments. Comments Bend Chamber of Commerce received would then be analyzed regarding proposed Forest Plan and included in the Final Plan. and DEIS, and the effect on the local area Opened an on-going January. Deschutes NF Planning personnel dialogue regarding the effect of met in Corvallis, Oregon with key the timber industry-related dollars State Agencies to present an vs. the effect of service industry- overview of the proposed Forest related dollars (from tourism, Plan, Draft Environmental Impact recreation, real estate develop- Statement and preferred alterna- ment, etc) on the local economy, tive. State Agencies represented: and the importance of each Oregon Department of Fish and industry. Wildlife, Parks and Recreation, Water Resources, State Lands, 2/4/86. Deschutes Forest Planning Citi- Department of Energy, Department zens Group public meeting Dis- of Geology & Minerals, State cussed Plan's effect on recreation Forestry Department, Department First of series of meetings of Environmental Quality and the organized by Juniper Group of

Appendb J - 40 Appendix J Public Participation in Forest Plan Development

Sierra Club. Meetings scheduled .. Forest Plan Report. Announced every Tuesday and Thursday that the Draft Environmental Impact night for approximately three Statement was delayed in mailing weeks: different section of the from the printer in Salt Lake City, Forest Plan and DElS was covered Utah, but now should be received at each meeting. by the public for review. Also announced meeting dates and 2/6/86: Deschutes Forest Planning Citi- locations for the open houses to zens Group public meeting. Dis- present. cussed wildlife issues as a result of the proposed Plan. Key issues 211 3/86: The Forest Plan and DEIS Report raised involved more information explained some of the terminology used in the Forest Plan and DEB, the Thompson's bigearred bat on and corrected some errors in the and the great grey owl. Resulted Reviewer's Guide, Response Form, in development of Standards and DEE and Forest Plan. Guidelines for the bat and great grey owl which were included in 2/14/86. Article in Bend Bulletin "DAW to the revised Plan Give Views" Announced that DAW would present its views on Forest 2/9/86: Article in Bend Bulletin 'Future Plan on February 21 at I1am. Forest Will Look Younger. Local, state and national politicians were invited. Focus on annual "I Article in Bend Bulletin 'Public harvest levels if Plan is adopted; Invited to Review Plan'. Reminded concern is that the levels are too public that Plan was available for low. Have been encouraging DAW review. For further information, workers to write congressman call Greg McClarren. Also an- about proposed Plan. nounced meeting of Deschutes Forest Planning Citizens Group "U Article in Bend Bulletin "Forest every Tuesday and Thursday Plan Meetings Set" Announced night. schedule of public open houses for the Plan. 2/11/86: Deschutes Forest Planning Citi- zens Group public meeting. Timber 2/18/86: Deschutes Forest Planning Citi- issues were discussed; representa- zens Group public meeting. Last of the series of scheduled meet- tives of environmental groups and ings Discussed geothermal issues the timber industry were present. for the Deschutes National Forest Key issues raised included the management of roadless areas, Feb Forest Service analysts created a and the effects on the local presentation for the Supervisor's economy of the timber industry vs Advisory Group that analyzed the the service (recreationltourism) relation between economics tied industry to timber vs. economics tied to service-related issues such as 2/13/86: Deschutes Forest Planning Citi- tourism and recreation Analysis zens Group public meeting. Forest showed that money generated Service not represented at this through timber tended to be very meeting. Discussed water issues cyclic, and also tended to leave affected by the Forest Plan the local area, while money gener-

Appendix J - 41 Appendix J Public Participation in Forest Plan Development

ated through service areas tended manage the resource for multiple to be more steady and to stay in use the local area Conclusion is that there is no need to choose between 3/13/86 Forest Service Open House meet- timber and recreation Best option ing for proposed Forest Plan and for the local economy is to diversify DEB-Redmond Fire Hall, Red- and include both. mond, Oregon

Forest Service Planning personnel 311 9/86. Forest Service Open House meet- made presentation to Oregon ing for proposed Forest Plan and Association of County Commis- DEB--Sisters Fire Hall, Sisters. sioners Group composed of Oregon. county commissioners from throughout the state. Presented 3/20/86: Article in Bend Bulletin ‘Informed overview of the proposed Forest Residents Discuss Forest Plan” Plan, the DElS and preferred Follow-up article to Sisters Open alternative. Outlined major re- House for proposed Plan. Approx source issues and how they were 25 people attended Sisters Open addressed. House Public seemed to be well- informed about Plan and DElS Dave Mohla, Forest Supervisor Public comment period ends May and Larry Mullen, Planning Staff 9. Also announced next meeting Officer taped a 30-minute program to be March 27 at Camp Sherman for the Oregon Public Broadcasting System. The program consisted 3/27/86 Forest Service Open House meet- of the complete presentation and ing for proposed Forest Plan and overview of the proposed Forest DEB-Camp Sherman Community Plan, the Draft Environmental Hall, Camp Sherman, Oregon Impact Statement and the pre- ferred alternative. The overview 3/31186: Forest Service Open House meet- covered all the major resource ing for proposed Forest Plan and issues of the Plan, descriptions of DEB-La Pine Junior High School Management Areas, and maps cafeteria, La Pine, Oregon. and charts outlining various as- pects of the proposed Forest March Planning Staff met with Forest Plan. Service personnel on each District, the Redmond Air Center, and Monthly meeting between Forest Bend Pine Nursery to present an Service Planning personnel and overview of the proposed Forest Bend Chamber of Commerce Plan, Draft Environmental Impact regarding proposed Forest Plan Statement and preferred alterna- and DEIS, and the potential effects tive. on the local area. Presented analysis comparing timber- March Presentation and overview of generated dollars vs service Forest Plan, taped earlier for area-generated dollars and the Oregon Public Broadcasting conclusion that there is no need System by Forest Supervisor Dave to choose between timber and Mohla and Planning Staff Officer other resources on the Forest. Larry Mullen, aired again on local The best option for the local PBS station. Also included informa- economy is to diversify and tion regarding public comment

Appendix J - 42 Appendix J Public Participation in Forest Plan Development

period, and where to get more roadless areas on the Deschutes information and copies of the Charlton and Maiden Peak road- Reviewer's Guide for the DEIS less areas Showed on a map that and proposed Forest Plan. the protection of those two areas would complete astring of undevel- March: Monthly meeting between Forest oped areas along the Cascade Service Planning personnel and Crest stretching from Canada to Bend Chamber of Commerce Northern California. Decision was regarding proposed Forest Plan made to include those two roadless and DEIS, and the potential effects areas in the Undeveloped Recre- on the local area ation Management Area

March: Meeting between Forest Service 4/3/86: Congressman Bob Smith (Ore- Planning personnel and Madras gon's 2nd District) and Congress- Chamber of Commerce regarding man Sid Morrison (Washington's proposed Forest Plan and DEE, 4th District) hosted a public and potential effects on the local information meeting at the Central area. Presented overview of Plan Oregon Community College in and issues. Bend that was attended by over 75 people At the session, presen- 4/1/86 Article in Bend Bulletin 'Plan tations were made by conservation- Alternative Backed--Industry Offers ists, woodproduct manufacturers, Its Choice'. Described Central economic development interests, Oregon Alternative, alternative tourism and recreation proposed by timber industry to representatives, logging and labor ensure that timber harvest levels people, and the Forest Service. are high enough to sustain local Bend television station Channel timber industry and jobs. Alterna- 21 was also present The transcript tive proposed to increase Pon- of the session will be given to the derosa harvest levels by 40 MMBF Forest Service for consideration over Forest Service proposal in as input to the Forest Plan and order to continue to supply mills. Draft Environmental Impact State- Alternative was presented on ment behalf of Citizens for Responsible Forest Management, a group 4/8/86 Forest Service Open House meet- representing three timber industry ing for proposed Forest Plan and associations and several indepen- DEE--Gilchrist Restaurant and dent operations in Midstate. Stated Lounge, Gilchrist, Oregon. that copies of pamphlet describing alternative were available through 411 0186 Forest Service Open House meet- DAW ing for proposed Forest Plan and DEIS-Deschutes Room, River- 4/2/86 Forest Service Open House meet- house Motor Inn, Bend, Oregon ing for proposed Forest Plan and DEB--Hilton Hotel Convention Y" Forest Plan Report. Highlighted Center, Eugene, Oregon. Key specific issues as well as areas of issue raised involved management the forest that people have been of roadless areas. Individual concerned about: Big Marsh and attending meeting offered explana- the Oregon Cascade Recreation tion of importance of maintaining Area, the Metolius River Corridor, undeveloped condition in two and the question of how much

Appendix J - 43 Appendix J Public Participation in Forest Plan Development

Ponderosa Pine is enough. Dis- management for inclusion in the cussed the meetings held to this revisions to the Forest Plan point, and the release of the Forest Plan mailing list to outside organi- April: Field trip on Sisters District to zations and individuals. Also examine timber harvest methods included a reminder of the closure Jim McClain, representing timber date forthe public comment period interests; Paul Dewey, Sisters May 9,1986. Forest Planning Committee, and Dr Stu Garrett, representing other 4/13/86 Article in Bend Bulletin 'Open environmental interests. Don House on Deschutes Land Plan Pederson, Timber Staff Officer Draws Questions from Curious and Larry Mullen, Planning Staff Crowd'. Recap of Open House on Officer for Deschutes National 4/10 at Riverhouse; approx. 60 Forest. people attended. Issues raised at meeting ranged from geothermal Purpose of trip was to define what to timber harvest levels. Article was 'acceptable" in appearance stated that the proposed Plan has by comparison with an actual site, been presented to 55 organizations rather than vague description around the State by Forest Service Was the key to defining the officials, in addition to the seven uneven-aged management pro- Open Houses held in Central gram as preferred alternative to Oregon and the Willamette Valley. clearcutting Based on this meet- ing, silviculturists were able to 411 5/86: Forest Service Open House meet- start working on uneven-aged ing for proposed Forest Plan and management yield tables for DEIS-Winema Hotel, Ballroom, revisions to the Forest Plan Klamath Falls, Oregon. April: Forest Service planning personnel 411 6/86: Article in Bend Bulletin 'Extensions met with Jim Noteboom, attorney Asked on Forest Plan' Stated that representing the Confederated there have been requests made Tribes of Warm Springs and the to Regional Forester to extend Tribal Council Purpose of meeting public comment period due to was to define Tribes position delay in receiving Plan from printer. regarding Wild and Scenic River Also not able to reach certain recommendations for the Metolius areas of Forest to view effects on River, particularly the lower Metoii- ground due to snow. us Tribe prefers no recommenda- tion for the lower Metolius to be April. Trout Unlimited and Central Ore- included in the National System gon Flyfishers came in to De- Discussion begun for agreement schutes National Forest Supervi- to be signed by the Department sor's Office to bring in written of Agriculture and Department of comments and discuss weakness- Interior (Bureau of Indian Affairs) es in proposed Forest Plan and with the Confederated Tribes to DElS regarding water quality, manage the lower Metolius and particularly for the Deschutes area around the Horn of the River, and fisheries management. Metolius to provide a Primitive Resulted in specific Standards Recreation Experience as defined and Guidelines being written for by the Recreation Opportunity water quality and fisheries habitat Spectrum.

Appendix J - 44 Appendix J Public Participation in Forest Plan Development

April: Forest Service planning personnel PBS station. Also included informa- met with Congressman De Fazio's tion regarding public comment staff in Eugene regarding status period, and where to get more of Roadless Areas, particularly the information and copies of the Charlton and Maiden Peak Road- Reviewer's Guide for the DEE less Areas. Informed him of deci- and proposed Forest Plan. sion to change the allocation for those two Roadless Areas to April: Thirty-minute presentation and Undeveloped Recreation. This overview of Forest Plan taped for change in allocation would com- a Portland television station. Similar plete the string of undeveloped to presentation taped for PBS areas along the Cascade Crest stretchingfrom Canadato Northern April: Deschutes NF Planning personnel California. held series of meetings in Prineville with the Ochoco National Forest April: Presentations to County Commis- and Prineville District of Bureau of sioners for Klamath County in Land Management. Presented Klamath Falls and to County propsed Forest Plan and DEE Commissioners for Lake County in with preferred alternative Lakeview. Overview of proposed Forest Plan, DElS and preferred April: Monthly meeting between Forest alternative. Outlined major re- Service Planning personnel and source issues and how they are Bend Chamber of Commerce addressed in each document. regarding proposed Forest Plan and DEIS, and the potential effects April Presentation to Deschutes County on the local area Planning Commission in Bend. Overview of proposed Forest Plan, April Presentations to two separate DElS and preferred alternative. local women's organizations Outlined major resource issues associated with churches. and how they are addressed in Overview of proposed Forest Plan each document and DElS and preferred alternative. Outlined major resource issues April: Forest Service Planning personnel and how they are addressed in met in La Pine with key community each document. Also discussed leaders and local businessmen. the Reviewers Guide and encour- Meeting was set up by Kiwanas. aged public comment through Presented overview of proposed May 9, 1986. Some concern was Plan, DElS and proposed alterna- expressed by group to have their tive, including major issues and written comment in by the deadline how they were addressed. Held question and answer session after 5/4/86: Article in Bend Bulletin Comment the presentation. Considerable Period Over USFS Plan Ends interest in the Plan expressed. Friday' Profiled some of the principle reviewers and their views April Presentation and overview of of the Plan and concerns for Forest Plan, taped earlier for clearcutting, harvest levels, scenic Oregon Public Broadcasting areas and geothermal activity. System by Forest Supervisor Dave Confirmed that the public comment Mohla and Planning Staff Officer period ends May 9, and that Larry Mullen, aired again on local comments would be analyzed for

Appendix J - 45 Appendix J Public Participation in Forest Plan Development

the final document. Stated that tion of the current harvest levels there would most likely be compro- in the Timber Plan. mises made before the final Plan is approved May: Field Review with Endangered Species Branch of US Fish and Sidebar article in Bend Bulletin Wildlife Service and Bob Anthony, 'Senior Forest Planner Answers Cooperative Wildlife Research Common Queries'. Outlined some Unit, Oregon State University, for of the more common concerns management within Bald Eagle and misconceptions about the Management Areas on the Forest. plan and answered them. Stated Purpose was to re-affirm that that there would be clearcuts and management was still satisfactory even-aged management under for eagles. Official review for bald the Plan, with about 109 MMBF of eagles and peregrine falcons timber offered on average per occurred April 7, 1982 prior to year. Explained that timber offered release of Forest. for sale must not exceed the amount that can be grown back Plan, letter is included in the annually. proposed Plan. Consultation under Section 7 of Endangered Species Act of 1973 5/9/86: Public comment period on DElS ends May. Monthly meeting between Forest Service Planning personnel and 5f 15/66: Article in Bend Bulletin 'Comment Bend Chamber of Commerce on Plan Pours In'. Described high regarding proposed Forest Plan number of wrMen responses being and DEIS, and the potential effects received by the Forest Service on the local area regarding the proposed Forest Plan Stated that comments were 6/1/86: Article in Bend Bulletin "Forest being categorized according to Service Workers Sifting Through the area of concern Predicted Piles of Plan Comments". Stated that Forest Service would most approximately 1400 written com- likely take second look at clearcut- ments were received and were ting, as well as proposed wild and being categorized and entered scenic river designations, fisheries into a computer program according habitat on the Deschutes, pon- to the concern expressed. Ex- derosa pine harvest level and plained that comments would be proposed accelerated harvest of used by those writing the Final lodgepole pine. Plan, and that comments had already caused the Forest Service 511 9/86: Appeal filed by Northwest Forest to look at certain issues, such as Resource Council to request true alternatives to clearcutting and No Action Alternative. No Action wild and scenic river designations. (Current Direction) Alternative in DElS actually incorporated some 6/20/86 Forest Plan Report. Discussed mandatory changes to the original the procedure being used to Timber Plan that affected current analyze the public comments harvest levels. Northwest Forest received on the Plan and DElS Resource Council wanted an Also contained an explanation of Alternative that showed a continua- the Spotted Owl Supplement

Appendix J - 46 Appendix J Public Participation in Forest Plan Development

currently being done by the Forest the effects of Management Re- Service in Oregon and Washington quirements for wildlife, etc, on as a Regional Guide. Stated that timber harvest levels. the Supplement would provide direction on the management of 11/4/86 Meeting between Deschutes habitat for the spotted owl, not National Forest Planning personnel the management of old-growth and Region 6 Regional Forester timber. The Report also outlined to discuss progress of planning the timeline for the planning process since release of Draft process for the Deschutes, and Environmental Impact Statement. promised to continue to keep the Discussed public comments and public informed throughout the concerns expressed during public process. Some topics commented comment period Regional Forester on to date include Roadless Areas, gave go-ahead to re-evaluate Winter Recreation, Jobs and issues involving ponderosa pine Healthy Economy, Visual Quality, and lodgepine pine harvest, Clearcutting and Fisheries alternatives to clear- cutting, May/ uneven-aged management, fish- June Summary of all public comments eries habit management, Wild and received during the public com- Scenic River designations and ment period, along with responses, roadless areas. was posted in the front lobby of the Deschutes National Forest 11/14/86' Forest Service News Release Supervisor's Office. Representa- "Forest Plan Public Input Results". tives of the timber industry came Summarized the number of public in to read comments from environ- comments received, and outlined mental agencies and vice versa. areas of agreement and disagree- Public came in to view the respons- ment regarding the proposed es, as well as Forest Sewice Forest Plan based on the public personnel. comments.

July. "Interim Definitions for Old-Growth 11/19/86. Management Information Bulletin. Douglas-Fir and Mrxed-Conifer Categorized the comments re- Forests in the Pacific Northwest ceived according to the various and California' published. De- issues, and listed the number of signed to guide efforts in land- comments by Alternative; also management planning until more summarized areas of agreement comprehensive definitions based and disagreement on on-going research can be made. 11/25/86 Article in Bend Bulletin 'Timber Harvest Levels Questioned- De- July' Forest Sewice Planning personnel schutes National Forest Plan Elicits met again with Environmental 1,611 Letters" Summarized the Protection Agency representatives comments and concerns ex- from the Seattle Office to review pressed in the written responses changes to Standards and Guide- that were received during the lines for water quality issues and comment period for the proposed riparian environment. Forest Plan. Timber harvest levels, roadless areas and recreation- 911 8/86: Another appeal filed by Northwest related topics received the most Forest Resource Council regarding comments; clearcutting, employ-

Appendix J - 47 Appendix J Public Participation in Forest Plan Development

ment and Wild and Scenic River tion' Outlined new proposal for designations also received com- uneven-aged management as an ment Also contained chart show- alternative to clearcutting that had ing breakdown of comments by been proposed in the Deschutes category National Forest Land Management Plan Approximately 60% of public 12/1/86 Forest Plan Report. Outlined the comments received for the pro- status of forest planning, and a posed plan were opposed to summaly of the public responses clearcutting timber Based on that received, broken down by area of public input, Forest silvicultural origin, respondant (agency, associ- personnel designed an uneven- ation, individual, etc), and number aged management plan for timber of comments by resource/issue. harvest which has been presented There was also a summary of to the Chief of the Forest Service comments by resourcelissue area, in Washington, DC including concerns for timber, fish and wildlife, recreation (including 1/27/87. Meeting between Deschutes roadless areas, wild and scenic National Forest Planning personnel rivers and the Metolius River and Regional Forester to check Corridor), visuals, special uses, progress of revisions to proposed and energy and minerals (including Forest Plan common mineral materials). The Report also displayed the areas of L1" Article in Bend Bulletin "Forest agreement and disagreement Plans May Change'. Discussed concerning the issues in the appeals filed by the Northwest proposed Forest Plan. Forest Resources Council stating the proposed Forest Plans re- 12/12/86' Article in Bend Bulletin 'Survey leased by Region 6 National Shows Ponderosa Loss'. Outlined Forests do not show a true "No the results of the recently complet- Action' alternative that reflects ed timber inventory for Deschutes current harvest levels. Forests National Forest. Inventory showed may need to release a supplement there was approximately 39% less to proposed plans, which will then ponderosa pine on the Forest be subject to another 90-day than originally thought. Decrease public comment period Deschutes shown across the Forest rather NF has requested to be exempted than in one particular. Forest from preparing supplement based Planner Larry Mullen stated that it on the fact that proposed Forest would take at least three years to Plan and DElS released early last completely analyze the new data, year already contained similar therefore, the Forest Plan would information to that requested by not utilize the new data. Stated the NFRC that the Forest Plan would be updated at a later date if necessary 411 7/87: Forest Plan Report. Announced based on the analysis of the the preparation of the Supplement inventory. to the Draft Environmental Impact Statement as a result of the appeals 1987 filed by the Northwest Forest Resources Council, there will be a 1/22/87' Article in Bend Bulletin 'Clearcut- 90- day public review period when ting Option Gains National Atten- the supplement is released. Report

Appendix J - 48 Appendix J Public Participation in Forest Plan Development

then outlined the five major issues Statement in response to the that surfaced during the public appeals filed by the Northwest comment period: alternatives to Forest Resources Council, a timber clearcutting, ponderosa pine industry organization harvest levels, management of lodgepole pine and the mountain 6/1/87: Meeting between Deschutes NF pine beetle, inclusion of the Planning personnel and Regional Deschutes and Metolius Rivers in Forester to check progress of the National Wild and Scenic revisions to proposed Forest Plan. River System, and future manage- ment of the remaining roadless 711 71w Briefing paper concerning Uneven- areas on the Forest. Report stated aged Management prepared by these issues were discussed with Forest Silviculturist Mike Znerold the Regional Forester, and the in response to large number of Forest is going ahead with analysis public comments received during of the input and possible re- the public comment period for the evaluation and response in those DElS Comments were largely five areas The results of the current opposed to clearcutting as a timber Forest Vegetative Inventory were harvest method, and in favor of also included (volume of Pon- an uneven-aged management derosa Pine is less than original plan. Paper also included draft for data for the Forest Plan indicated, Standards and Guidelines for and volume of firs, hemlock and Timber Management in the Forest lodgepole pine is greater) Stated Pian, following an uneven-aged that current information would be management silvicultural system the basis for the Final Forest Plan as the preferred timber manage- ment system rather than the original data used for the draft Forest Plan 7/29/87. Forest Service Personnel met with Norm Johnson, Governor's Forest 4/29/87. Article in Bend Bulletin 'Plans Planning Team, and other State Pose No Threat, New USFS Chief representatives to discuss De- Says". New USFS Chief Dale schutes National Forest's work on Robertson addressed timber unevenaged management Find- industry concerns that the timber ings to date were discussed relative harvest level would be drastically to development of an unevenaged reduced by the implementation of management prescription for new Forest Plans. Stated that ponderosa pine (silvicultural plans would be implemented over regime) and the estimated effects a period of time, and that mills of implementing this regime on should not expect any significant harvest levels reduction in the availability of timber. ai1~87: Article in Bend Bulletin "Old Growth - USFS Officials Oversee Fate of 511 8/87: Article in Bend Bulletin 'Deschutes Majestic Stands". Discussed the Plan Enters Final Stage". Quoted issue which has been growing, Forest Planner Larry Mullen that and which was reflected in much Forest got the 'go-ahead" to begin of the public input received for preparation of Supplements to the the proposed Forest Plan, of Draft Environmental Impact "preserving old growth for old

Appendlx J - 49 Appendix J Public Participation in Forest Plan Development

growth’s sake’ rather than tieing It tested on selected timber sales to wildlife or other issues. Development of uneven-aged management guidelines was done 811 7/87: Article in Bend Bulletin Two in response to public comments Appeals May Force Delays in recerved during the forest planning Forest Land Planning Process’. process. Report also included an Discussed the effect of the two analysis of the geothermal re- appeals filed by the Northwest source on the Deschutes NF Forest Resources Council, and the release of a policy statement 12/17/87 & Meeting and field trip with Norm by the Deputy Assistant Secretary Johnson and others from the of Agriculture regarding prepara- State. tion of Supplements to proposed Forest Plans. 12/18/87 More discussion of State’s alterna- tive, unevenaged management for 811 9/87: Article in Bend Bulletin ‘Logging Ponderosa pine, lodgepole pine Option Gains Attention’ Described management, and status of the the uneven-aged management Plan. program for timber harvest that has been utilized by Gilchrist Timber Co for manyyears. Gilchrist 1988 Woods Superintendent Bill Steers led reporters on a tour of portions 1988-1 989: Forest Supervisor Norm Arseneault of Gilchrist lands to give them an met several times with the Sisters on-the-ground look at the results Forest Planning Committee to of uneven-aged management. continue discussions of manage- Mike Znerold, Deschutes National ment for the Squaw Creek area Forest Silviculturist, worked out a and visuals in the Metolius Basin plan for uneven-aged management area for the Deschutes similar to that used by Gilchrist. Article stated 111 0188. ‘Greenbook” published for limited that the plan had been presented review. Was the first draft of a to the Chief of the Forest Sewice revised Forest Plan containing in Washington, DC, and was revisions to Standards and Guide- waiting approval from the Regional lines resulting from public input Forester. received during the comment period Also contained revisions 11/20/87 Forest Planners met again with to original proposed Management Norm Johnson Informal informa- Areas tion exchange on Deschutes National Forest planning process 1/22/88. Larry Mullen, Forest Planner, Norm status Also discussed preliminary Arseneault, Forest Supervisor, ideas concerning what the State and Kendrick Greer, LMP Analyst, might propose as the Governor‘s met with Norm Johnson and Reis alternative for the proposed Plan. Hoyt in Eugene. Talked more about the Plan and the State’s 1 1/25/87’ Forest Plan Report. Initial develop- proposal Also discussed what ment of guidelines for uneven- tradeoff analysis the State needed aged management in ponderosa the Deschutes personnel to do pine and mixed conifer stands before they could fully develop has been completed, and will be their proposal or analyze the Plan.

Appendix J - 50 Appendix J Public Participation in Forest Plan Development

2/5/88: Article in Bend Bulletin 'Groups At discuss revisions to the Standards Loggerheads Over Deschutes and Guidelines and get input. Plan - Environmentalists, Industry Feud Over Loss of Trees, Jobs'. 3/1/88. Bob Rainville and Kendrick Greer Recap of disagreement between met with Oregon Department of environmentalists and timber Fish & Wildlife to discuss proposed industry for timber harvest levels. Standards and Guidelines revi- Predicted that ponderosa halvest sions. levels in the final Forest Plan would be higher than environmentalists 3/5/88: Norm Arseneault, Forest Supervi- would like, and lower than timber sor, conducted workshop on industry wants. Stated there would Greenbook for Advisory Group be no departure schedule for composed of members of the timber harvest, instead would timber industry, local business manage for a 'sustained yield'. owners, environmental groups Decision to manage for sustained and concerned citizens. Purpose yield was based on public com- was to review the Standards and ment received after DEIS released Guidelines and receive input from which overwhelmingly rejected the the Advisory Group. departure halvest schedule includ- ed in the DEIS. Also, uneven-aged 3/7/88 Received comments on first draft management would replace of revised Forest Plan (Greenbook) clearcutting as the preferred from Advisory Group, Oregon silvicultural prescription based on Department of Fish and public comments received through 3/8/88 Wildlife, and Forest Staff Officers the public comment period which Comments concerned Standards ended May 9, 1986. and Guidelines.

211 7/88: Article in Sisters Nugget 'Forest 3/18/88: Meeting with Norm Johnson, Forest Plans Unfold'. Regional Forester Management Team members and Jim Torrence announced that Forest Supervisor. Governor's proposed land and resource Forest Planning Team emphasized management plans have been the need to use the new timber released for all 19 National Forests inventory in the Final Plan. in Oregon and Washington. Stated that draft plans released are only 3/27/88 Article in Bend Bulletin "National part of the picture, and that the Forests Likely to See Clearcutting's draft plans will be refined through End'. Recap of public comment public comment and further analy- regarding clearcutting and expla- sis on a Regional basis. nation of uneven-aged manage- ment harvest techniques which 2/18/88 Meeting with Don Tryon, local would replace clearcutting as representative for the Oregon preferred management technique Natural Resource Council to for ponderosa pine. Article also discuss plan status and preliminary touched on mountain pine beetle findings from the latest timber salvage situation for lodgepole inventory. pine and second-growth pon- derosa pine Geothermal energy 2/23/86 Several members of the Forest also continues to be a resource Management Team met with Forest issue, especially in Newberry Supervisor's Advisory Group to Crater area.

Appendix J - 51 Appendix J Public Participation in Forest Plan Development

3130188: Article in Sisters Nugget Senators progress of revisions to proposed Sponsor River Protection Bill'. Forest Plan Decision made to Announced Senators Packwood incorporate the new vegetative and Hatfield to sponsor Omnibus inventory into the preparation of Oregon Wild and Scenic Rivers the Final Environmental Impact Act of 1988 to designate sections Statement and Forest Plan of Oregon rivers for Wild and Scenic classhation. Senators 7/15/88: Article in Bend Bulletin "Deschutes seeking public input on proposed Forest to Use Current Timber Act Inventorya Announced that the Deschutes would use the results 4/12/88: Additional meeting between plan- of the most recent timber inventory ning personnel and Norm Johnson, in preparing the final Forest Plan Governor's Forest Planning Team, Inventory showed a 39% decrease to discuss status of Forest Plan in the volume of ponderosa pine and response from State. on the Forest, and a 2.6% decrease in total volume for all species 4/26/88 Article in The Oregonian 'Can Both Old-Growth Trees, Timber 7/18/88 - Forest Service personnel from the Industry Be Saved', written by Deschutes, Winema and Fremont Harry Lonsdale, Bend Research, Inc. Analysis of the old-growth vs 7/20/88 National Forests met with represen- timber situation and personal tatives of the timber industry, recommendations for a compro- Oregon Department of Fish and mise Wildlife, and members of the Klamath Tribes to discuss Stand- May: Forest Supervisor Norm Arseneault ards and Guidelines in the Forest met with Deschutes County Com- Plan for management of mule missioners to discuss issues deer habitat Included field trip to regarding uneven-aged manage- examine existing condition of ment and timber harvest. mule deer habitat on the Forests

5/14/88 Meeting at Bend Research, Inc 8/3/88' Article in Bend Bulletin "Owl Plan between Forest Service personnel Would Cut Timber Harvest" Dealt and representatives from timber with the effect on timber harvest industry, environmental groups, for the Deschutes National Forest and state and local government. if USFS Chief Dale Robertson Purpose of meeting was to discuss were to accept the final supplement old- growth issues and projections to owl management guidelines for the Deschutes National Forest issued this week Would reduce the ASQ by approximately 6 9 6/13/88: Additional meeting between plan- MMBF or 3 5% from that proposed ning personnel and Norm Johnson, in the current draft management Governor's Forest Planning Team, plan Currently set aside 1000 to discuss status of Forest Plan acres per nesting pair of owls, and response from State. final supplement to owl manage- ment guidelines would require 711 2/88: Meeting between Deschutes 1500 acres set aside for each National Forest Planning personnel nesting pair Chief expected to and Regional Forester to check issue decision later in Fall

Appendix J - 52 Appendix J Public Participation in Forest Plan Development

8/5/88: Forest Supervisor Norm Arseneault 911 3/88' Article in Bend Bulletin 'USFS met with Hance Haney, member Violations Alleged - Lawyer Paul of Senator Packwood's Staff, to Dewey Claims the US. Forest discuss concerns for management Service Violated Its Own Plans". of the Metolius Basin area. Outlined concerns of the Sisters Forest Planning Committee for 8/9/88 Forest Service personnel met with timber harvest methods used in Oregon Department of Fish and scenic areas, particularly the area Wildlife to discuss Standards and around and on Black Butte and in Guidelines in the Forest Plan for the Metolius Basin. Methods for management of mule deer habitat. harvesting timber in scenic or visual areas have been a continu- 811 0188 Article in Sisters Nugget 'Owl ing concern of the Committee Habitat Plan'. Announced upcom- throughout forest planning, and ing release of FElS for Spotted have been the topic of numerous Owl Habitat Management in Ore- meetings with forest planning gon and Washington Stated that personnel alternative selected would be incorporated into Forest Plans for 9/14/88 Forest Service personnel met all Forests in PNW Region with again with Maya Schempff to spotted owls. Public comment present additional inventory data. period begins August 12 and ends thirty days later. Article 911 9/88: Supplement to DEE published included address for public com- containing No Change Alterna- ments. tive. In response to appeals filed by Northwest Forest Resource Council in "I4 Final Supplement to the Spotted 1986. Owl Management Final Environ- 9/26/88 Forest Plan Report. Contained mental Impact Statement released. status report on Forest Plan and recently released supplement to 8/15/88 & Coordination meeting with Winema DEIS. Encouraged public comment and Fremont National Forests that to the Supplement; public com- border the Deschutes National ment period ends 1/6/89 Also Forest For best management contained information on the new 811 6/88 of the contiguous timber stands forest inventory which was being needed to coordinate proposed incorporated into the Forest Plan, management plans. the Mountain Pine Beetle, and the Spotted Owl 8/23/88, Forest Service personnel met with Maya Schempff and Harry Lons- 9/29/88 Article in Bend Bulletin "Forest dale, Bend Research, Inc , to Data Available" Announced that discuss large-diameter trees. Harry supplements to the Draft Environ- was interested in the results of mental Impact Statement, detailing the new timber inventory that the effects on Forest resources of showed the number of large trees continuing with current forest by diameter present on the De- management plans, have been schutes Discussions were related released for public review. Stated to old growth issue, but Harry's that public comment on the real interest was in retaining large supplements would be taken until diameter trees on the Forest January 6, 1989 for the Deschutes

Appendix J - 53 Appendix J Public Participation in Forest Plan Development

National Forest Supplement to the idea of industry proposing an DEIS, and that public comment alternative for consideration in the would be incorporated in the final Final to counter the State's alterna- management plan. tive.

9/30/88: Forest Supervisor Norm Arseneault I2/9/86: Record of Decision released for spoke to Redmond Chamber of the Final Supplement for the Commerce regarding major issues Spotted Owl Management Final in the proposed Forest Plan. Environmental lmoact Statement for Oregon and Washington 1 0/10/88' Pacific Northwest Region, Old Recommendations for size of Growth Briefing Paper prepared Spotted Owl Habitat Areas were by Jeff Blackwood, Regional incorporated into the Forest Plan Planner. Summarized the 'old Deschutes National Forest to set growth' situation in Region 6. aside 1500 acres for each of 14 Contained definitions for old- nesting pairs of owls growth in Pacific North- west proposed by R6 Regional Guide, 12112/88' Article in Bend Bulletin "Final Owl Society of American Foresters, the Plan Cuts Timber Harvest'. Stated Interagency Old-growth Develop- that result of the decision for the ment Committee, and the Wilder- Spotted Owl FElS would be ness Society, with a comparison approximately 4% decrease in the table Also outlined Region 6 Allowable Sale Quantity for the Approach to managing Old Growth Deschutes National Forest. Adjust- through Forest Plans. ments were made to the Forest Plan to allow 1500 acres to be set 1 011 4/88: Forest Supervisor Norm Arseneault met with retirees to discuss Forest aside for each of 14 pairs of nesting Planning issues. owls on the Forest.

1 0/19/88' Omnlbus Oregon Wild and Scenlc 12/28/88' Article in Redmond Spokesman Rivers Act of 1988. Added several 'Governor Takes Note of Forest rivers and creeks on the Deschutes Lettersn Stated that letters received to the National Wild and Scenic by Governor Goldschmidt regard- Rivers System. segments of ing proposed management of Metolius, Deschutes and Little areas on the Deschutes National Deschutes Rivers, and Big Marsh, Forest were being reviewed by Crescent and Squaw Creeks. the Governor's Forest Planning Changed original Management Team. Norm Johnson, an Oregon Areas for Wild and Scenic River State University Forestry Professor; Areas to include all the rivers and Gail Achterman, the Governor's creeks designated by the Act. assistant for natural resources, Standards and guidelines for and Reis Hoyt, an environmental managing Wild and Scenic Rivers analyst The Planning Team is Areas were incorporated into the preparing an alternative for the Forest Plan Deschutes National Forest Land Management Plan Letters were in 11123188. Forest Service personnel met with response to flyers sent out by the Wayne Ludeman and other timber Sisters Forest Planning Committee industry representatives to discuss to local residents calling for new inventory, plan status, and protection of old growth trees and

Appendix J - 54 Appendix J Public Participation in Forest Plan Development

scenic areas such as Black Butte 3/26/89. Article in Bend Bulletin and the Metolius River. ”Cut-VS.-Save Debate Tugging at Forest PlansmContinuing dialogue 1989 between timber industry interests and environmentalists regarding January: Forest Supervisor Norm Arseneault appropriate amounts of timber met with Advisory Group to discuss offered for harvest. Forest Plans issues regarding Deschutes Na- for the Deschutes and Ochoco tional Forest position on old-growth have seen significant changes in and approach to management. proposed amount of allowable sale quantity (ASQ) since draft plans were released. Some 1/6/89: Public comment period ends for changes due to public comment Supplement to DEIS. received, Deschutes will be using results from new timber inventory 1 /26/89. Forest Service planning personnel into final plan Inventory showed a met again with Maya Schempff 39% drop in ponderosa pine concerning management and volume from previous inventory retention of large-diameter trees. Other resources that affect timber supplies include: wildlife, roadless 1/31/89: Kendrick Greer, LMP Analyst, met areas, and old growth with Paul Dewey to discuss doing an old growth inventory coopera- 4/28/89: Forest Supervisor Norm Arseneault tively. met with Bill Marlett, Ancient Forest Alliance and Paul Dewey, Sisters Forest Service personnel met with Forest Planning Committee to representatives of the timber discuss old-growth inventories on industry, Oregon Department of the forest. Fish and Wildlife and members of the Klamath Tribes to discuss 5/9/09: Overview meeting with the State Standards and Guidelines in the of Oregon regarding Deschutes Forest Plan for management of Forest Plan. Attendees: Norm mule deer habitat. Johnson, Governor’s Forest Plan- ning Team; Norm Arseneault, Deschutes NF Supervisor: Neil February. Forest Supervisor Norm Arseneault Hunsaker, Scott Beyer and met again with Advisory Group to Kendrick Greer, Deschutes NF discuss management of old-growth LMP staff, and Sarah Crim and and Standards and Guidelines. Dick Phillipsfrom the Forest Service Regional Office for Region 6. 211 7/89 Forest Service planning personnel Focused on intended changes to met with Norm Johnson, Gover- Forplan modeling and analysis for nor’s Forest Planning Team for the Plan; examined Forplan model status update on yield table work. itself in terms of land stratification, allocation and harvest scheduling 311 0189: Forest Service personnel met choices, and outputs represented again with Wayne Ludeman and Norm John talked about the State’s other representatives of the timber proposal for the Deschutes Nation- industry to update them on prog- al Forest based on earlier work by ress and results of new timber the Governor’s Forest Planning yield tables Team.

Appendix J - 55 Appendix J Public Participation in Forest Plan Development

511 1/89 Meeting with Oregon State Task Standards and Guidelines in the Force on National Forest Planning Forest Plan for management of to discuss Deschutes Plan State mule deer habitat Agency personnel Ken Johnson, State Public Affairs Officer; Jim 811 5/89 & Legislative Tour of the Metolius Mair and Bob Brown, State Depart- Basin Area conducted by Forest ment of Forestry, Ann Hanus, State Economist, Darryl Gowan, 811 6/89' Service personnel. Members of Staff Biologist and State Forest Congressman Bob Smiths and Planning Coordinator, and Don Senator Packwood's Staff attend- Elxenberger, Research Analyst, ed. Issues included Wild and State Park and Recreation. Forest Scenic River Areas, Scenic Views Service personnel: Norm Arse- and the Metolius Basin Area as neault, Forest Supervisor, Bob related to the Forest Plan and Rainville, Range, Wildlife and management Standards and Watershed Staff Officer, Bernie Guidelines Smith, Recreation Staff Officer; Don Pederson, Timber Staff Officer; 811 8/89 Forest Supewisor Norm Arseneault Steve Galliano, Landscape Archi- met with Norm Johnson from the tect, Ed Styskel, Wildlife Biologist; Governor's Planning Staff and Neil Hunsaker, Kendrick Greer, Paul Dewey to discuss major Scott Beyer, Kim Boddie, Jack issues of the Forest Plan and Berry, and Rich Thomas, from Standards and Guidelines Land Management Planning staff, Carolyn Wisdom, Environmental Coordinator, Andrea Carpenter, 8/22/89 Save the Metolius, local conserva- Planning Assistant, Sisters District; tion group, proposed establish- and Dave Craig, Planner, Region ment of a National Conservation 6 Regional Office Focused on the Area (NCA) in Metolius Basin resource issues and analysis Area Would include approximately process being addressed between 154,000 acres of the Sisters Ranger the Draft and Final Forest Plan District Proposed special timber harvest methods (Metolius-grade 511 5/89 Meeting between Forest Service lumber to be sold to Central planning personnel and Harry Oregon mills only), some restric- Lonsdale (Ancient Forest Alliance) tions on recreation development, to talk more about maintaining and improvements to visual and more large- diameter trees. wildlife management standards.

6/17/89: Forest Supervisor Norm Arseneault 8130189 Article in Bend Bulletin 'Group met with Associated Oregon Proposed Conservation Plan' Loggers. Discussed issues of the Described proposed Metolius Forest Plan relating to timber National Conservation Area out- harvest, Wild and Scenic Rivers lined by Save the Metolius Commit- and Northern Spotted Owl habitat. tee. Article included map of proposed NCA, as well as descrip- 6/23/89. Forest Service personnel met with tions of the three proposed "stew- representatives of the timber ardship zones' which would industty, Oregon Department of emphasize recreation, sustainable Fish and Wildlife, and members of timber harvesting and wildlife and the Klamath Tribes to discuss primitive recreation.

Appendix J - 56 Appendix J Public Participation in Forest Plan Development

9/5/89: Article in Bend Bulletin 'Industry Products, Ochoco Lumber and Wary of Metolius Proposal' Out- GilchristTimber). Discussed timber lined reaction of timber industry to industry's concept of their pro- proposed Metolius National Con- posed Central Oregon Alternative, servation Area. Concerned about designed to maintain current the further reduction to the ASQ timber harvest levels while looking for the Deschutes, and the inclu- at each management area and sion of one of the largest remaining providing for other resource stands of valuable old-growth activities Forest Service agreed to ponderosa pine in the region. provide group with chart compar- ing acres by Management Area 9/6/89. Article in Sisters Nugget describing between 1986 DElS and current proposed Metolius National Con- Areas proposed, and to keep servation Area outlined by Save them informed as to status of the the Metolius Committee proposed Metolius National Con- servation Area 9/14/89. Forest Strategy Group established to deal with Metolius National 10/19/89. Chief of Forest Service Dale Conservation Area proposal. Robertson announced policy on old- growth forests Policy recog- 911 5/09: Meeting between Forest Service nized significant values associated personnel and Save the Metolius with old-growth forests, and made Committee Purpose of meeting recommendations on managing was to discuss ways to incorporate old- growth forests, and for increas- Metolius Conservation Area pro- ing research efforts directed at posal into Deschutes Forest old- growth ecosystems. Forest Planning effort. Planning adjusted for less fragmen- 9/24/89. Norm Arseneault, Forest Supervi- tation of old-growth designated sor; Len Farr, Sisters District areas. Ranger, and Greg McClarren, Public Affairs Officer met with Toni i o/zz/ag Norm Arseneault, Forest Supervi- Foster, Byron Beach and Steve sor; Len Farr, Ststers District Prince from the Save the Metolius Ranger, Andrea Carpenter, Sisters Committee regarding proposed RD Planner: and Greg McClarren, Metolius NCA. Initial meeting was Public Affairs Officer met with Toni a 'get acquainted" meeting to Foster, Byron Beach and Steve open communications and under- Prince from the Save the Metolius standing. Forest Service agreed Committee regarding proposed to work with Committee to clarify Metolius NCA. Discussed Commit- concerns, to provide information tee's response to Forest Service regarding allocations, Standards questions regarding proposal and Guidelines for the Metolius Committee presented silvicultural Area, and to work towards some proposal that had been prepared sort of resolution. by Mark Wigg, Consulting Forester Cordial meeting, lots of discussion, 10/4/89. Meeting between Forest Service agreement to continue to work Timber and Planning personnel, together. Northwest Forestry Association and timber industry (DAW Forest 11/6/89. Regional Forester issued similar Products, Prineville Sawmill, Pine direction to that issued by Chief

Appendix J - 57 Appendix J Public Participation in Forest Plan Development

for old-growth management in Arseneault asked the Committee project activities. to include all interested parties in any future tours. 11/13/89 Telephone conversation between Scott Beyer, Deschutes NF LMP 11/21/89: Forest Service personnel met with Analyst and Mark Wigg, Consulting Bob Brown, State of Oregon and Forester for Save the Metolius Mark Wigg, Consulting Forester Committee to clarify specific items for Save the Metolius Committee needed to model alternative cutting Discussed Wigg’s recommenda- proposals described by Commit- tions for alternative cutting propos- tee. Agreed that proposals would als for stands commonly found in be modeled using the Stand the Metolius Basin. lncluded old- Prognosis Model and reviewed growth Ponderosa pine stands, with Bob Brown, State of Oregon, old-growth mixed conifer stands, and Mark Wigg at November 21, two- storied stands, and pine or 1989 meeting mixed conifer thickets

Forest Service News Release 1211 6/89’ Norm Arseneault, Forest Supervi- outlined a five point policy for the sor; Len Farr, Sisters District Metolius River Area. Addressed Ranger, and Greg McClarren, recreation development along the Public Affairs Officer met with river area, Wild and Scenic River Save the Metolius Committee planning, and the proposed regarding proposed Metolius NCA Metolius National Conservation Presented data regarding acres Area. Stated detailed consideration and timber types within the pro- of the Metolius NCA proposal posed boundary for NCA Also would occur as part of the soon- showed an overlay of proposed to-be completed Forest Plan, Management Areas in the Forest using state-of-the-art computer Pian included in the proposed modeling techniques and the Metolius NCA Agreed to look at latest timber inventory information specific Standards and Guidelines for all zones at next meeting 11/19/89: Letter mailed to Mark Wigg contain- ing information requested earlier 1990 regarding Acreage by Stand Type and Volume Estimates for Metolius 1/29/90’ Andrea Carpenter, Sisters RD Area. Planner: Wayne Ludeman, North- west Forestry Association, Scott 11/20/89. Save the Metolius Committee took Beyer, Deschutes NF LMP Analyst: the Sisters District Management Mark Wigg, Consulting Forester Assistants, members of the Forest for Save the Metolius Committee Supervisor’s Office Staff, and (via FAX), and Dave Stere, Oregon several representatives of the Department of Forestry (FAX) met State on a tour of the Metolius regarding the proposed Metolius Area Visited several key sites that Conservation Area Purpose of Committee was interested in for meeting was to review silvicultural NCA Committee has been con- management scenarios proposed ducting this same tour for many by Mark Wigg, as well as standards other people, including the media, and guidelines proposed for congressional, and industry repre- Metolius Area Also modeled and sentatives. Forest Supervisor Norm compared for uneven-aged man-

Appendix J - 58 Appendix J Public Participation in Forest Plan Development

agement and management for ment Area, and two special interest scenic values. areas

Telephone conversation between Decrease General Forest Allocation Scott Beyer, Deschutes NF LMP by 13,000 acres Analyst and Mark Wigg, Consulting Forester for Save the Metolius Decrease ASQ by approximately Committee. Mark agreed to provide 3-5 MMBF in area. estimates of percentage of area harvested in first decade of plan- March - Forest Supervisor Norm Arseneault ning period and beyond as result designated a member of Old of implementing proposed Stand- Growth ards and Guid6linesfor Metolius. Estimates would be used in future April: Forest Education Steering Commit- analysis to clarify proposed man- tee, organized by Deschutes agement for Metolius County Extension Agency Agents for Oregon State University. Pur- 2/5/90. Meeting between Forest Service pose of the Committee was to personnel and representatives of deal with issues regarding man- timber industry (Northwest Forestry agement of old-growth timber Four meetings scheduled during Association) and environmental March and April woups.. (Oreaon - Natural Resource council, Ancient Forest Alliance) 3/12/90 Article in Bulletin discussed lower concerning old-growth issues on harvest levels under new Forest the Deschutes National Forest Plan Presentation of the old-wowth- situation from various perspectives 3/13/90: Save the Metolius Committee by ONRC, Ancient Forest Alliance submitted further refinements to and Northwest Forestry Associa- initial proposal which included tion. Old Growth Committee was some revisions to their original designated and charged to exam- map. Also contained proposed ine current direction, develop Standards and Guidelines for alternatives to protect old-growth, proposed allocationzones. Original and make recommendations to Recreation Zone was dropped Management Team in integrate and replaced with two new zones into Forest Plan. Metolius Zone and Highway 20 Zone. Standards and Guidelines 211 1/90: Meeting with Save the Metolius were included for the two new Committee, Forest Service and zones and the three other alloca- timber industry. Initiated process tions. Sustainable Forest Zone, of collaborative negotiation Forest Wildlife-Primitive, and Service proposed the following: Geothermal, as well as identifica- Establishment of 53,000 acres of tion of special management areas Metolius Heritage Area--proposed separate from their surrounding area would encompass several zones Rejected the Forest Service Draft Forest Plan management compromise proposal for smaller areas, such as visuals, RNA, Metolius Heritage Area Committee developed recreation, dispersed still included all of the originally recreation, Bald Eagle Manage- proposed area.

Appenduc J - 59 Appendix J Public Participation in Forest Plan Development

3/13/90: Long-range Regional Planning 3/27/90 Forest Supervisor Norm Arseneault Task Force created in connection and Forest Planner Neil Hunsaker with Central Oregon Economic met with Norm Johnson, Reis Development Council; Forest Hoyt and Gail Achterman from the Supervisor Norm Arseneault desig- Governor's office to discuss nated member of Task Force. changes in Management Areas in Meeting held concerning issues of the Forest Plan between the Draft Forest Plan relating directly to Environmental Impact Statement economy of local area. and the Final Environmental Impact Statement 3/20/90 Forest Service News Release 'Timber Management Report 3/28/90 Forest Supervisor Norm Arseneauit Highlights Change'. Contained made presentation to mixed information from the Deschutes audience of timber industry repre- National Forest annual report on sentatives and members of envi- timber management. Changes ronmental groups regarding malor include. increased use of uneven- issues of proposed Forest Plan aged management, decrease in clearcutting, aggressive thinning 4/2/90 Long-range Regional Planning for beetle prevention, and height- Task Force meeting. Further ened awareness of need to protect discussion of issues of Forest old-growth tree groves while Plan relating to economic deveiop- providing raw materials for forest ment in Central Oregon products manufacturing. Many changes were direct result of 4/4/90: InterAgency Scientific Committee's public comments received for the Report on the Spotted Owl re- proposed Forest Plan since its leased During course of question release in 1986 and answer session, Chief of the Forest Service Dale Robertson Y. Forest Supervisor Norm Arseneault was asked what effect the spotted interviewed by television news owl report would have on comple- team from Channel 21 regarding tion of Forest Plans in Region 6 Forest Plan and lower harvest Stated would proceed with plan levels completion based on language in Section 318 which placed expecta- 111 Meeting between timber industiy tion on Forest Service to complete representatives and Forest Service Forest Plans for Region 6 by regarding upcoming Forest Plan September 30, 1990 Stated would and timber harvest levels as need to provide management affected by Old Growth Manage- direction for other resources in ment Areas, Spotted Owl Habitat addition to spotted owl Forest needs, and other resource require- Plans, including Deschutes Forest ments Plan, contain set-aside acres for spotted owl which correspond to 3/23/90: Presentation of Forest Plan and decision of December 1988 that proposed Final Environmental amended Regional Guide for Impact Statement with preferred northern spotted owls alternative to Regional Forester.

Appendix J - 60 Appendix J Alternatives, Data Analysis, & Planning Process

Response to Public Comments on Draft Following the commentlopinion section are the Forest Plan and DEE comment and responses to the 1988 DElS Supplement. Comments include a section on Reaction by the public to the Draft Environmental those received from industry and from individuals Impact Statement and Forest Plan and responses to this comment by the Forest Selvice is document- ed in this AppendD: Ways in which both documents Alternatives were changed as a result of this comment are described COMMENT 'We are not lawyers," declared one reviewer, who asked for simplified documents and Appendix I supplements Appendix A, which better indexing. This respondent also objected to indicates how the issues, concerns, and opportuni- the presentation of a preferred alternative "et ties addressed by the Forest Plan were determned the public pick the preferred plan, without coersion and provides an account of public involvement or influencel" prior to and after publication of the 1986 Draft Environmental Impact Statement RESPONSE. Legal requirements are one of the reasons for the complexity of of these documents Deschutes NF planning was complicated by a but an effort was made to present the material decision to recall a 1982 version of the Draft more clearly Indexes in the Final Environmental Environmental Impact Statement and Forest Plan Impact Statement and Forest Plan include more This was occasioned by the promulgation of new entries A glossary of terms is also included directionsfor Forest Planning from both the national and regional office level Responses to the 1982 One of the legal requirements, from the National DElS were systematically analyzed and resulted Forest Management Act, makes the Regional in changes that were included in the 1986 Drafts. Forester responsible for selecting a preferred alternative A similar evaluation of responses to the 1986 version of the DEE and Proposed Forest Plan was also conducted The number, source, and COMMENT. The No-Action Alternative in the DElS nature of the more than 8,000 comments (1,611 does not meet the requirements of the National letters) is given after the section which summarizes Environmental Policy Act, according to a respon- the 1982 DElS dent. "New yield tables, new land suitability, and new minimum management requirements are According to Forest Service policy, 'substantive' elements of the new plan and should be excluded." comment is that which 'providesfactual information, professional opinion, or informed judgment ger- RESPONSE A Supplement to the DEIS, which mane to the action being proposed,' (Forest Service included a No-Change Alternative, was made Handbook 1909 15) Comments which questioned available for public review for 90 days ending the sufficiency of the 1986 DEE, proposed Forest January 6, 1989 This alternative is also presented Plan, and planning process required a published in the FElS and is discussed in Chapters 2 and 4 response by the Forest Service, and are included of the FElS below Statements of preference, value judgments, and opinions about the outcome of the process, e.g., opposition to the Preferred Alternative, are COMMENT Three reviewers asked for the evalua- also important They are summarized and respond- tion of one or more alternatives between the ed to after the following substantive section and preferred Alternative E and Alternative C, which were used by the Regional Forester in selecting calls for the highest level of timber harvest. the alternative which will direct the Forest for the next 10 to 15 years The selection is documented One declared. "All the alternatives except C will in the Record of Decision. result in a negative effect the number of jobs.... Why

Appendix J - 61 Appendix J Alternatives, Data Analysis, & Planning Process

are there no departure alternatives which result in between alternatives in acres available for pro- an increase in the number of jobs beside Alternative grammed harvest and 31 percent difference in C, which projects an increase of over 500? To acres which will be regeneration harvestlovewood some, the high commodity alternative will no doubt removal harvested was questioned be considered a 'straw-man. and not a viable alternative. If that is the case the Deschutes plan RESPONSE Given the amount of land committed would present no viable alternative that results in to other managment emphasis, the differences in a lob increase, when in fact the potential remains timber mpnagement between alternatives are to do so ' quite significant

Alternatives producing 100 to 400 jobs with corresponding increases in personal income and COMMENT A reviewer suggested this allocation payments to counties could be developed and of Management Areas No.l--15,800 acres, 'no major effects on wildllfe habitat conditions or No 2--8,000, No 3--22,000, No.4--16,500, production of other resource values would be No 5-31,300, No 6-1 8,250, No 7- 95,000, expected to occur; this reviewer asserted, adding: NO 8-657,000, N0.9--320,000, NO.lO-3,536, "By so doing, the Forest will more completely No 11--28,000, No 12-135,000,No 13--0(nordic meet the legal requirement for a full range of skiing areas to be included in No 9), No.14--42,656, alternatives.' No.l5--53,072, No 16-1 0,042. Total = 1,620,412 acres. Another respondent said 'there is a large area between Alternative E and C worth of intense RESPONSE Such an alternative would essentially exploration in search of economic shift 200,000 acres to Scenic Views management opportunities without making substantial environ- ... from General Forest The resulting level of goods mental compromises ' and services would be only a few percent different than Alternative A Such an alternative was not In echoing this proposal, athird reviewer suggested considered in detail in the FEE because it would 'changing the balance of programmed harvest fall well within the range of alternatives which among ponderosa pine and other available were explored The current version of preferred species.' Alternative E shows a significant increase in acres managed for scenic quality RESPONSE. The Forest Plan provides a system of management for all multiple uses of a unit of the national forest system. Alternatives prepared for consideration as a Forest Plan are to provide Analysis of Data for a wide range of reasonable managment scenarios for the various uses of the forest 136 COMMENT A respondent declared "It IS not CFR 219 12(f)] Therefore, alternatives cannot be clear to us that survival rates in the plantations completely specified by a single output. Displays will be anywhere near full stocking rates. Your of estimated output levels for the various resources constraints to the FORPLAN model are helpful, under the alternatives are presented to assist the but you should have a mortality factor, in addition public to better understand the possible conse- to a defect factor quences of implementing a particular alternative Output levels themselves are not subject to the RESPONSE. The average survival rate in planta- NEPA requirements for a reasonable range of tions on the Forest is approximately 90 percent. If alternatives. mortality is significant, plantations are replanted. (See Timber Management standards/guidelines in Chapter 4 of the Forest Plan.) COMMENT Another reviewer had a similar concern: 'We are suprised at the lack of variability COMMENT: A reviewer, referring to an Appendix among the alternatives ' The 23 percent difference B table which shows the benchmark analysis

Appenduc J - 62 Appendix J Alternatives, Data Analysis, & Planning Process

outputs, said it "seems to be close to what the Monitoring processes will keep data and informa- local timber industry wants right now.' The Forest tion more current than in the past Service "should make it clear what the results of industry requests for increases in Ponderosa right now will be down the road.' COMMENT 'Inventory should count 72 MMBF of turnback.' RESPONSE: The FORPIAN benchmark analysis was not performed to show 'what the local timber RESPONSE The timber inventory conducted in industry wants right now'. It is required by law to 1985 measured all existing timber conditions and define the outside limits of Forest Planning. The included timber turned back through the Timber effects of various levels of timber harvest are Sale Buyback Program. disclosed in Chapter IV of the FEIS. Suitability COMMENT: "Conservation of energy, capital, and labor should be assessed for each allocation; a COMMENT: Several reviewers questioned the reviewer said, and suggested the application of a DEB treatment of lands considered unsuitable for conservation standard or guideline. timber production. One asked for assumptions used to determined the classification and verifica- RESPONSE. The energy requirements and outputs tion of field inspections Another declared the for the preferred alternative are given in Chapter classification to be a major federal action requiring 4 of the Forest Plan. Chapter 2 of the FEE compares public review the difference in total costs and values for each alternative RESPONSE. The assumptions used to determine suitability are identified with Figure 3-7 of the FElS and discussed at some length in Appendix B. The Forest Inventory determination of lands unsuitable because of regeneration difficulty was based upon the Forest's COMMENT. Most comments focused on the need Soil Resource Inventory mapping, plant community to incorporate the new Forest inventory in the ('ecoclassO) mapping, and a historical analysis of Final Forest Plan. Some people also requested a artificial and natural regeneration success Detailed map showing species and stocking. maps of Forest land classified as unsuitable are available at District Ranger and the Forest Supervi- RESPONSE. The new inventory has been incorpo- sor's Offices rated into the FElS and Final Forest Plan. Inventory information is also available at the Forest Supervi- sor's Off ice in Bend. COMMENT Another reviewer noted that the Draft Pacific Northwest Region Plan considers land which annually produces less than 20 cubic feet COMMENT Every effort should be made to conduct per acre unsuitable for timber harvest Despite a thorough inventory of timber available by species this, he said, 139,800 of 164,100 acres of land in and maturity on both public and private lands. this category on the Deschutes NF are classified as suitable. 'Plant Associations of the Central RESPONSE The necessity for thorough timber Oregon Pumice Zone' by Leonard Volland was inventories is known. The Forest Service works cited as evidence that reforestation on many plant with other State/Federal agencies and private associations in this category is very difficult. industry to maintain inventory data, including species and age, on public and private lands. This respondent also cited a reference to 20,000 Emphasis on inventories of timber resources will acres requiring gopher control to achieve regenera- remain high as the Forest Plan is implemented tion. In another section of Appendix B, he said,

Appendix J - 63 Appendix d Alternatives, Data Analysis, & Planning Process

the cost of gopher control is considered too RESPONSE: Regulations for the implementation expensive yet the 20,000 acres is still considered of the National Forest Management Act address suitable. 'Also on page 70 (Appendlx B),' the the five year regeneration period for sheltewood reviewer said, 'IS the admission that 47,000 acreas, and seed tree cutting units It is permissible to which are too rocky to plant and require 15 years delay the beginning of the five year period until to regenerate naturally, will be considered suitable the trees which have been left are removed This for harvest On page 168 of the Appendlx the could be 20 or 30 years after the initial tree removal. Forest Service admits to claiming as suitable for The Forest and Regional Office, however, had timber harvest mountain hemnlock stands which decided that land should not be considered suitable are very slow to regenerate naturally (20 year for timber production if it is not capable of being estimated regeneration period) and too expensive naturally regenerated 15 years after the initial to regenerate artifically. entry

7he Forest Service claims that the National Forest Full stocking is not a necessary variable in yield Management Act has a big loophole. They claim calculations as suitable for timber harvest thousands of acres which they assure us will NOT be regenerated Slope was deleted as an analysis factor because within five years They say this is allowed because a relatively small amount of land within the by spending enough money and planting these Deschutes NF timber base is on sloping terrain areas repeatedly they could eventually achieve adequate stocking. Was this the intent of NFMA?'

RESPONSE. The Regional Office directed the COMMENT References to the extent of gopher Forest to change the criteria for determining problems on the Forest were considered inconsis- suitability from 20 cubicfeet/acre/yearto IO percent tent and confusing by one reader "How many crown cover The description of timber stratification acres are going to be affected by gophers under in the FElS has been clarified. The land cited in the alternatives? How many acres require control the comment is "tentatively' suitable. The amount measures? How many acres are unsuitable under of land actually available for timber harvest varies each alternative as a result of a gopher problems?u between alternatives according to management emphasis and investments. The National Forest RESPONSE. Twenty-thousand acres of suitable Management Act says timber can be harvested land have gopher problems which, while requiring when 'there is assurance that such lands can be extra expenditures, can still be managed for timber adequately restocked within five years after production. On 934 acres, the gopher problem is harvest ' This is not a loophole Areas which are so extreme that they were removed from the timber difficult to reforest are scheduled for hawest in base This situation is the same for all Alternatives alternatives which emphasize timber production and additional costs for reforestation must be payed. Yield Tables

COMMENT' Criticisms of timber yield tables ranged COMMENT. The discussion of regeneration on from too much personal judgement in adjusting rocky soils is 'not understandable,' according to a yields to inadequate testing of growth simulation reviewer 'Are you saying that it is OK to leave models The Oregon Department of Forestry, after them in the timber base even though 15 years conducting independent analysis using the Progno- may be necessary to regenerate? And what data sis mode1,declared that the DElS underestimated do you have to suggest that full stocking should forest yields by 13 to 15 percent The Forest's be used to calculate yields from the lands? Also, treatment of timber stratification, the stand density It is not clear exactly why slope is deleted as an index and growth basal area assumptions, and analysis factor.' fertilization and genetics were criticized

Appendix J - 64 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE One of the changes made between appears to be limiting the timber output from its the DEE and FElS has been to incorporate the yield tables significantly more than justified. The latest timber resource inventory into the Forest yield reduction is compounded by the assumptions Plan analysis. Prognosis was used to develop regarding wildlife trees and nonstockable openings new empirical and managed timber yield tables. These assumptions effectively double count yield This is the best available timber data and state of reductions. the art modeling for predicting future yields. First, volume growth of wildlife trees is deleted The Forest used the South Central Oregon/ from the yields because the yield tables supposedly Noltheastern California (SORNEC) version of assume full site occupancy A dead tree reduces Prognosis. This version of the model was further site occupancy and hence the Deschutes lowers ~ calibrated with published growth data to approxi- the yields However, not every established seedling mate timber yield on the Deschutes NF. The reaches rotation age. As the stand grows trees reliability of the new yield tables was tested with will die and become snags through the normal assistancefrom scientistsfrom the Bend Silviculture course of a rotation The full occupancy yield Labratory and biometricians from the Washington tables already account for the yield loss from Office of the U.S. Forest Service. Results are natural mortality. These trees are available for repeatable given the same data set, calibration wildlife and there is no need to reduce yields a values, and modeling of standards/guidelines. second time. This is especially true if the Deschutes assumes that commercial thinning will not capture 100 percent of the mortality. COMMENT Some respondents stated that the stratification of the managed yield tables was Second, the Deschutes duplicates yield reductions flawed and should have been based on the in another way when it reduces yields 5 percent stratification used in the existing Forest inventory. for nonstockable openings The ecoclass- community type-GBA approach discussed earlier, RESPONSE: The stratification used in the existing already reflects reductions in yields for sites that inventory was based on species mix and standing have natural limits on full stocking capacity. The inventory. Stratification of the managed yield tables explicit 5 percent reduction duplicates the existing was based on the productivity potential of the implicit growth limits incorporated in the yield land. Plant associations were used as a measure tab Ie s . of this productivity potential. RESPONSE One of the goals of our managed forests is to maintain a healthy and vigorous set COMMENT The Deschutes used Fred Hall's of stands. An outcome of this is the reduction of Growth Basal Area (GBA) model to predict yields naturally ocurring mortality through stocking level from the stratified timber classes. The GBA model control. The expected naturally occurring mortality included a mortality function based on stand may not provide the amount and size distribution density index. The plan says that full stocking of snags needed to provide wildlife habitat at the was assumed (Appendix B, page 168). However, recommended levels The reductions in yields the GBA model and stand density index inherently reflect that level of volume that will not be harvested include yield reductions for less than full stocking. in order to provide habitat In many cases, the reduction in yield is assumed to be directly proportional to the decrease in stand The 5 percent reduction in yields for nonstockable density. Also, the GBA method assumes 'stockabil- openings reflects that portion of the land base ity limits' of a particular site prevent attainment of that will be used for landings and skid trails full stocking. occurring from forest management. This reduction is necessitated as Ian and skid trails will be This approach fails to recognize that productivity reused. The yield loss occurs is additive to of the stand remains stable over a wide range of that loss which takes place under natural condi- stocking (Langsaeter). Therefore, the Deschutes tions.

Appendix J - 65 Appendix J Alternatives, Data Analysis, Planning Process

COMMENT: A different concern about the 5 percent accept slightly lower yields As new models are reduction was expressed by another respondent developed the Forest will test the existing assump- .The Forest does not follow the advice of the tions about the growth and yield of managed Regional Office and reduce yields by 15 to 20 stands. percent for roads, landings, and other unmapped unstockable areas.' COMMENT A reviewer said 1983 managed yield RESPONSE The 5 percent reduction was for tables were flawed because they were 'based landings and other unmapped unstockable areas. upon forest-wide productivity averages' and Additional reductions are made for items such as; consequently, the 'new yield tables rocky ground and roads (See Appenduc B of the (were) stratified to groups across the forest EIS for a discussion of this situation ) Essentially, the Deschutes has post-stratified their forest after the original inventory was complete a

COMMENT The same reviewer also declared that RESPONSE In the FEE, a more current timber the full stocking assumption was unrealistic This, resource inventory has been utilized, without he said, 'is made even more indefensible by the post-stratificationof the inventory plots as was assumption that most of the ponderosa sites will done in the DElS analysis. be fully stocked even though they will be planted to wide spacings to avoid precommercial thinning COMMENT. 'The July 15. 1985, Regional direction RESPONSE. Regional and local stocking guides to the Deschutes NF requires the forest to provide will be utilized to assess adequate stocking on all a table comparing the assumptions used in regeneration units prior to certrfying them as being development of the Forest Plan for Oregon with satisfactorily reforested. If a unit is not certified the assumptions used to formulate the DEE further efforts to attain reforestation will occur. alternative that most closely meets the FPFO objectives (Alternative C) The Department of Forestry was disappointed to find this valuable COMMENT Some respondents challenged the information has been omitted from the document use of the Growth Basal Area (GBA) model to To fulfill the NFMA requirements for coordination calculate managed yield tables The concern was with state government, this table should be added that this technique produced lower yields. to the final environmental impact statement

RESPONSE. It is recognized that the GBA model RESPONSE. This change has been made and is not well understood. However, in 1983 it was the corrected table appears in Chapter 2 of the the Regionally approved method for development FEIS. of managed yield tables on the east side of the Cascades The assumptions used in modeling acceptable rates of stand diameter growth account COMMENT 'The Deschutes managed yield tables for reduction in yield rather than the GBA model understate attainable timber yields by more than itself. On the Deschutes NF we assumed a rapid 10 percent,' said one respondent, adding "This rate of tree diameter growth to reduce the risk of statement is based on research and publications mountain pine beetle (MPB) mortality This strategy from USFS Bend Silviculture Laboratory, Oregon was based on recommendations from Forest Pest Department of Forestry, more than 1,500 perma- Management. The net result is a reduction in nent growth plots on Gilchrist Timber Company stocking levels and total yield. Although increased and Diamond International lands, and yield tables stocking could potentially produce greater yield, it on the Ochoco and Winema National Forests, I would place the stands at greater risk from the believe this underestimation results in inappropriate pine beetle. Based on our inabillty to control an land allocations, timber management intensities, epidemic, a management decision was made to and timber harvest levels "

Appendix J - 66 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE The managed timber yield tables RESPONSE The Forest has produced an entirely have been revised in response to the availability new set of empirical yield tables incorporating the of more current information and new modeling latest timber inventory data and utilizing the techniques. Prognosis growth and yield model. Minimum merchantability sizes for all but lodgepole pine in the first decade is now 9 inches diameter breast COMMENT "Why istherevirtually no sales program height and 6 inches at the top in mountain hemlock but the species is included in the yield tables," a respondent inquired. Planning Process RESPONSE. Empirical and managed yield tables are prepared for all working groups. When a stand COMMENT. "Many of the decisions made in the is harvested It is assumed to grow according to current planning process are based on data which the managed yield table. It if is not, it continues to is either outdated, of unknown precision, conflicting grow according to the empirical yield table. with data from other reliable sources, or derived Inclusion in the empirical yield tables has nothing solely from 'best professional judgement', accord- to do wlth when, or If, a stand is scheduled for ing to one reviewer 'Wildlife minimum management harvest. Future harvest may be possible if favorable requirements (MMR) formulation, predictions of economics develop. future recreational demand, yield tables, timber inventory, and new land suitablity analyses are all areas where a high degree of uncertainty exists in COMMENT. Regarding the yield tables, a reviewer the Deschutes DElS In addition, these decisions said the projected growth is contingent on numer- and assumptions have been finalized and incorpo- ous thinning in all but the mountain hemlock rated in all alternatives without the provision of working group. 'In a world of shrinking budgets, any opportunity for full public review." is it reasonable to assume that money will be available for such intensive management?' This RESPONSE This public comment to the DEE reader also asserted that current commercial provided an extensive review of the assumptions thinnings are not being purchased. "You should used in preparing the Forest Plan A Supplement recalculate the yield tables assuming that only to the DElS provided additional opportunity for about half of the projected thinnings may occur.' review of the formulation of Management Require- ments. The sensitivity analysis performed to test RESPONSE. The Forest is legally required to many of these assumptions was evaluated in base timber yields on the utilization of economically Appendix B of the EIS A new timber inventory prudent silvicultural practices, including thinning. was used in preparing this FEE Most commercial thinnings have been purchased on this Forest. When they are not and the treatment is considered necessary, thinning is accomplished COMMENT: A reader asked: "Are the population with service contracts, which can include salvage estimates reasonable for the recreation use rights. estimates? Between 1970 and 1980 the population of Oregon grew by 26 percent and that of Deschutes County by 100 percent. However, COMMENT. Two reviewers questioned minimum between 1980-1985 the state's population in- merchantability specifications of 5 inches diameter creased by only 1.6 percent. The Deschutes NF breast height and 4 inches at the top cited in the Plan assumes that recreation on the forest will DEIS. "My impression is that the Regional Guide rise at a rate commensurate with that of the state prescribes a 9 inch diameter breast height population The plan assumes that Oregon's specification,' said one, who added, "if a 5 inch population growth rate will average 2 to 2 5 percent specification is used, a working group stumpage annually. Given the dramatic slowing in population value for trees of that size is required.' growth over the past 5 years, the resumption of

Appendix J - 67 Appendix J Alternatives, Data Analysis, & Planning Process

annual rates of growth in the 2.0 to 2.5 percent large ponderosa pine timber harvest is sharply range seems somewhat unlikely in the near future. reduced.' The extrapolation of past annual growth rates for recreation on the forest ltself might have provided RESPONSE: Ponderosa pine harvest reductions a more reasonable basis for estimation.' displayed in the DElS alternatives are mainly the result of forcing harvest of dead and dying RESPONSE We agree, population growth lodgepole pine resulting from the bark beetle shouldn't be the only factor in estimating use epidemic The FORPLAN model, based on the levels, especially over the long term. The Forest is economics of maximizing present net value, tends currently considering other factors such as, types to harvest high value species as rapidly as possible, of use and recent trends in recreational activity. deferring the lower valued species

COMMENT A reviewer objected to the 'tone' of Public Involvement the DEE and said that it failed to stress the 'complementary nature' of timber management, wildlife and recreation. It was suggested that both COMMENT A reviewer felt the DEE was prepared Intensive Recreation and Dispersed Recreation in secret and that 'the involvement of interest Areas should remain scheduled haNeSt areas groups would have helped planners anticipate concerns and avoid much confusion, misunder- RESPONSE All alternatives were designed to standing, rewriting, and legal actions " Another take advantage of opportunities to provide timber said the comment period should have been and quality recreation on the same lands. Some extended timber will be removed from Intensive and Dis- persed Recreation when this enhances recreational RESPONSE. The National Forest Management opportunities. Timber will also be harvested in Act of 1976 requires 90 days of public review for Scenic View Areas. In some cases, however, all tho DES and Proposed Forest Plan. The Forest resources cannot be entirely accommodated and management team realized that the complexity of tradeofis are required. the documents would require time for study Two versions of the DElS were published. For the first, a reviewing period was set from Oct. 27, 1982 to COMMENT' A State respondent requested coordi- Feb 15 1983, 110 days nation of rare and endangered species and Research Natural Area locations, inventories, and Several 'Forest Plan Reports' were published evaluations with the Natural Heritage Advisory from 1980 thru 1986 In preparing new version of Council and Oregon's Natural Heritage Plan. the DEIS, the Forest had the benefit of the public comments on the first publication There were RESPONSE Proposals for establishment of regular contacts with interested individuals and Research Natural Areas and the protection of rare groups. The second DElS was made available to and endangered species will be coordinated with the public for 120 days from Jan IO, 1986 to May the appropriate agencies. 9, 1986. A Supplement to the DElS was made available to the public from Sept. 19, 1988 to Jan 6, 1989 a period of 100 days COMMENT According to one reviewer: 'The inherent weakness in the planning process for timber is built into the FORPLAN Model which is COMMENT Several correspondents objected to a designed to behave like a monopolist It tends to policy which precluded presentation of prepared hold high value timber for future higher prices statements during a public meeting in Eugene while liquidating low value species in the near They referred to the NEPA requirement for maxi- future market at a saturation rate. This situation is mum public participation and held that opinions apparent in all Deschutes plan alternatives where and conclusions, however expressed, should be

Appendix J - 68 Appendix J Alternatives, Data Analysis, & Planning Process

part of the decision-making process. Some felt other programs was lacking in the DEIS, according that reliance on written statements to permit citation to one reviewer. violates the 'inform and involve" requirement and is a return to past practices of 'ballot counting.' RESPONSE: Chapter 4 of the FEIS has been extensively rewritten to provide additional informa- RESPONSE: It is regrettable that some people tion about environmental consequences. expected an opportunity to present prepared statements. All publicrty for the meetings explicitly stated "no oral testimony will be taken'. The object COMMENT Regarding resource outputs, environ- of the meetings was to create an environment mental effects, activities, and costs, one reviewer that faciliated one-on-one discussion and furthered declared. 'You provide no references which the understanding of the planning process. Oral public can review to determine if the conclusions testimony was not judged to be the best way to you've put down are accurate, valid, or warranted. faciltate understanding and open discussion. You must do this pursuant to CFR 1502.21 [NEPA]. RESPONSE: See response to above comment In addition, Appendix B provides a detailed discussion Adequacy of the Document of the analytical process and explanations of how effects activities and costs were derived. COMMENT: A proponent of on site housing at Mt Bachelor said developments in the future may require such accommodations. The Winter Olympics or a training camp for for the US. Ski Monitoring Team were mentioned as possibilities It was COMMENT. Several reviewers criticized the pointed out that seasonal on site housing has monitoring program, as described in the DEIS. been available for years at the Beattie Summer Two decried the absence of provisions for informing Racing Camp. the public about progress toward meeting manage- ment goals "Monitoring must both inform and RESPONSE: The Forest evaluated the situation involve the public." said one, who requested and determined that existing facilities at Sunriver 'statistically sound methods for measuring goals and Bend fulfilled this need. The situation could for recreation, wildlife, fisheries, and watershed. be modified in the future by amending the Plan Monitoring surveys should be conducted by independent technicians under contract in order to insure the highest level of impartiality.' COMMENT One reviewer said the plan was vague and generalized. 'It's very hard to tell what you Another made the same point, declaring: 'How folks really want to do.' More specifically defined credible is a monitoring program in which compli- goals and simplier language were requested. ance is determined solely by the person who will be reprimanded if not in complian~e?~This reviewer RESPONSE. The Forest Plan is intended to provide objected to the #ambiguity"of the program. "Stating general management direction for the entire Forest that the accuracy of a review must be high, medium, during the next 10-15 years. Within this framework, or low is meaningless Every element monitored detailed, site specific planning will be required for should have a statistically sound method of individual projects An effort was made to state measurement and determing accuracy. "He added. goals more clearly and simplify the writing in the mMonitoringprograms should also contain contin- FEIS. gency plans for handling noncompliance."

Another reviewer faulted the monioring plan for COMMENT An adequate explanation of the effects failing to establish threshholds beyond which of timber management on wildlife, recreation and activities and practices must be modified. In

Appendix J - 69 Appendix J Alternatives, Data Analysis, & Planning Process

addition: 'A process is needed by which the Forest COMMENT One reviewer said the DEIS suggests will decide if and when a major plan revision is that timber management and recreation are warranted.' This respondent also declared. The mutually exclusive, 'a faulty assumption " economic parameters to be monitored should be expanded to include employment and personal RESPONSE: Some timber removal can occur in income in the forest influence zone: recreation areas and dispersed recreation is expected in General Forest. In large portions of RESPONSE. The monitoring section, Chapter 4 of the Forest, therefore, the two activities are compati- the Forest Plan, has been thoroughly revised in ble. In others, such as Wilderness. they are not the Final Forest Plan. It now includes additional monitoring elements and thresholds to determine when action is required. The process by which COMMENT' The Sierra Club declared. "only the amendments to and revisions of the Forest Plan most general treatment is given to such planning will occur is described in Chapter 4. components as winter recreation, trail manage- ment, stream protection, and geothermal develop- Public involvement will be an important element in ment. It is our hope that the final version of the the monitoring plan. Information about the results plan will correct these deficiencies ' of monitoring will be available to the public and cltizens will be invited to assist in the program. RESPONSE Management direction in all of these Contracting elements of the monitoring task is an areas has been considerably strengthened in the option but it is important to establish that a person revised standards/guidelines. responsible for implementing a project is never the sole arbiter of its success or failure. Several levels of peer review are involved in Forest Plan COMMENT The Black Butte Ranch Association monitoring. requested that the FEE and Plan include provisions requiring consultation with the association prior to Non-compliance is delt with by modifying activities initiating significant activity on lands in the vicinity or amending the Forest Plan This is described in of Black Butte Ranch. This area of interest can Chapter 4 of the Plan generally be described as township 145, Range 9E,the Metolius Basin, and Black Butte along with While the Deschutes NF does not have a goal to other high elevation locations visible from within maintain employment or personal income at a and around the ranch given level, the economic consequences of Forest management are obviously important. The effect RESPONSE. Such consultation is aiready a part of different management approaches on employ- of standard Forest Service practices Public ment was an important factor in the development involvement guidelines in the National Environmen- of alternatives Assumptions about the effect of tal Policy Act specifically requires Forest Service the Preferred Alternative on jobs will be monitored to involve interested citizens in the planning process. Adjacent landowners are obviously interested. The Sisters Ranger District has long COMMENT A reviewer asked what would happen recognized that this is a sensitive area to many if there are Wilderness additions or a ban on individuals and organizations, including the Ranch roading in roadless areas. A clear showing of Association trade-offs was requested.

RESPONSE. It IS not possible to anticipate COMMENT One reviewer said it was difficult to Congressionally mandated changes in Deschutes determine the actual prescriptions that would be NF land allocations. The display of trade-offs in implemented in the different management areas Chapters 2 and 4 of the FElS has been substantially "More details of exactly what you propose to do," expanded. was requested

Appenduc J - 70 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE Chapter 4 of the Forest Plan now were unsufficiently detailed It was suggested that provides additional detail about direction in each the use of more identifiable colors would more management areas and Forest-wide standards/ clearly delineate management area boundaries. guidelines. The Forest Plan, however, is a over-all management guide. The requested level of detail RESPONSE: Maps have been revised and are will be providing during site specific project more legible in the FEIS. The use of color has planning. been improved Larger scale maps containing more detail are part of the planning records and can be inspected at the Forest Supewisor's Office COMMENT. The criteria for selecting a Preferred Alternative should have been disclosed. Weights given the individual decision criteria should be COMMENT. One reader objected to the absence explicit. of a base map of existing resources and situations. "1 found it very difficult to visualize the potential RESPONSE: The criteria and rationale for selecting effects of most issues without appropriate maps a Preferred Alternative are explained in the Record showing the existing situation from a plant commu- of Decision, which accompanies this FElS and nity standpoint and a summary of those natural Forest Plan. The FElS describes the process of resources.' A map was requested showing major developing and comparing alternatives and and critical natural resources, 'I e., where and discloses environmental effects. The Regional how many acres of non-forest, sub-alpine, mountain Forester selected the Preferred Alternative and hemlock, mixed conifer, lodgepole, ponderosa pine, and meadows This reader also asked for a explains why in the Record of Decision map indicating 'existing timber management areas; i.e., clearcuts, thinned stands, sold sales, proposed sales, pine beetle areas, and unmanaged stands " COMMENT' More explicit coordination of the Forest It sould be accompanied by "a summary table of Plan and the Clty of Bend and Deschutes County acres of different plant communities by seral stages comprehensive plans was sought by one reviewer. (grass forbs to old growth)."

RESPONSE This coordination with city and county RESPONSE. The detailed maps providing this plans has occurred. information are to voluminous to publish. but are available for public review as part of the planning records COMMENT There was an objection to the use of drawings in the description of each alternative in the DEIS. They were described as 'very subjective" COMMENT There were many comments request- by the revewer, who continued 'The high commod- ing certain additional maps be included in the ity alternative is made to look unappealing while FElS the remaining alternatives have very similar and more visually appealing drawings ' RESPONSE. A map of the estimated geothermal potential was included Maps of current geothermal RESPONSE. The sketches are considered an leases are available at the Forest Supervisor's accurate and useful representation of expected Office. It was not included in the FEiS because future conditions and were retained. the situation changes rapidly and maps are quickly obsolete. Areas where leasing will not be allowed and where development is restricted are indicated Maps in Management Area descriptions and the minerals section of Forest-wide standardslguidelmes, COMMENT One reviewer said alternative maps in Chapter 4 of the proposed Forest Plan. They are the DEE were inadequate; another said they displayed on the map for the Preferred Alternative

Appendix J - 71 Appendix J Social and Economic Considerations

A map of sales below cost was also requested. It Jobs/lncome/Economics was not included because the issue of sales below cost is being reviewed at the national level. As a COMMENT The social analysis presented in the general rule, the only sales below cost on this DElS was faulted for being insufficiently scientific Forest occur in in stands of lodgepole pine which and unsupported by referrence. contain a large amount of dead wood. Efforts are made to reduce the costs of such sales. This can be done where adequate stocking can be achieved RESPONSE. Social analysis has been updated in with natural regeneration and with more efficient the FElS methods of preparing and administering sales. Such reductions, however, will not be achieved at the expense of resource protection COMMENT Economic indicators were described as obsolete by a reviewer, who said: "You calculate Other reviewers asked for maps of livestock grazing only jobs and income in relation to direct affects allotments, range conditions, trailless areas in of logging and recreation.' Additional comments Wilderness, and timber working groups Considera- suggested jobs and income should not be the ble expense is incurred in publishing maps with primary basis for evaluating social effects. the planning documents and these were not major issues indentiied by the public. They are available RESPONSE Job and income effects were calculat- atthe Forest Supervisor and District Ranger Offices ed using the IMPLAN model, which determines the direct, indirect and induced effects of changes The map of old growth, included with the DEIS, has been revised for the FEIS. in timber, recreation, and grazing outputs This analysis is described in Appendix B of the FEIS The Preferred Alternative will be implemented and Job and income effects are one quantitative monitered using a map scale of 2.64 inches per measure of social and economic effects of any mile, which is too large for publication in the Forest alternative. Qualitative effects are estimated and Plan Management Area boundaries will be more presented in the FEIS, Chapter 4 and Appendix precisely located on a map of this scale. H.

A map of the location of units within timber sales was not published because unit locations are not COMMENT The Forest Sewice failed to make an fixed until sale preperation is near completion. adequate assessment of the essential requirements of tributary dependent mills to determine their requirements and the necessary material that remanufacturing facilities must have in order to Resource Planning Act (RPA) maintain their high level of employment They felt no alternative addressed these considerations COMMENT One reviewer called attention to a and that our data demonstrated that this demand discrepancy between the RPA goal for the Forest could be met. in the Regional Guide (214 MMBF) and the one used in the DElS (196 MMBF). RESPONSE: Information is currently lacking in RESPONSE The 214 MMBF figure includes all terms of the structure of the remanufacturing categories of timber volume and is a conversion industry in the Central Oregon area. Studies are from 46 MMCF (from the board feet measure to presently underway which will provide a better cubic feet). Alternative B (RPA) achieves the 46 assessment of this demand. Results of such studies MMCF figure when both chargeable and non- will be evaluated as part of the monitoring and chargeable harvest is taken into account. amendment process for the Forest Plan.

Appendix J - 72 Appendix J Social and Economic Considerations

COMMENT One reviewer said more emphasis and demand patterns within the state? Are we should be given to short term economic impacts entering another penod of rising demand and on local communities, including Prineville. competition for public timber supplies as the result of a downward cycle in private timber resources? RESPONSE: Alternatives which call of high levels The plan notes that over the past couple of years of commodity production and the use of departure a dramatic change has occurred in timber sales harvest schedules to maintain higher short term on the Deschutes -- from over 80 percent to local outputs provide such emphasis. Timber from the processors to 44 percent last year Over the nsxt Deschutes NF is a relatively insignificant supply two decades the plan calls for a 10 percent factor for mills in Crook County (Prineville). reduction in the harvest volume of Ponderosa pine, but a more than offsetting increase for less-valuable subspecies, particularly lodgepole COMMENT Conversely a reviewer said the DEE pine. Will area mills adjust to this change? was biased toward timber production. RESPONSE: The Forest Plan was prepared using RESPONSE A variation of response to the above the best available data on the ability of the comment applies here. The analysis of alternatives Deschutes NF to produce timber. Many resource which deemphasize timber production enabled considerations went into establishing the proposed the decisionmaker to evaluate tradeoffs inherent harvest levels Much uncertainty does exist relative in this approach. to future economic conditions in Oregon A basic change in the structure of the timber industry will have to occur as the older forest is harvested and COMMENT Canadian timber imports and the replaced with younger and smaller trees high bidding for logs by foreign timber interests should be taken into account in the economic analysis, according to one respondent. COMMENT There was a request to display "the RESPONSE: A more complete assessment of complete economic calculation used to figure job timber supply and demand has been included in impacts Chapter 3 of the FEIS. RESPONSE. Appendix B of the FEIS describes how the lob related effects were calculated COMMENT The significance of secondary forest products (mushrooms, herbs, flowers, pharmaceu- tical plants, and others) was not taken into account Non-Priced Benefits in the DEIS, one reviewer declared, adding that 'intact ecosystems' are required to sustain them. COMMENT Several reviewers said the recreational resources of the Deschutes NF are underestimated. RESPONSE: Many of these secondary products According to one: 'The DElS assumes that were acknowledged in the DElS but a lack of stumpage values will increase by 1 percent per information precluded detailed evaluation of their year over the 50 year planning period while economic significance. There have been no reports recreational resources will not increase over the that those existing on the Deschutes NF are being same period The contribution of recreational threatened by management activities. values to the present net value were reduced by 37.4 percent because the present administration was dissatisfied with the travel cost methods of COMMENT: Overall coordination of timber harvest determining recreational activity values Another within a given area could greatly assist in preventing reviewer declared: 'These documents seriously cyclical harvest patterns from developing, or at underestimate the economic value of key recre- least assist industry in adapting to changing harvest ational and scenic qualities of the forest." Downhill by volume and species. What are overall harvest skiing and driving for pleasure were cited as

Appendix J - 73 Appendix J Social and Economic Considerations

examples. A third said recreation values used in the 'beauty of the area' as their primary the FORPLAN are "consistently underestimated ' reason for purchase, a respondent declared Consultation with the State economist was recom- 'Presently (July 1, 1985), Black Butte Ranch mended. has a valuation of $141,247,849 and is assessed at $1,987,357. It would therefore RESPONSE: The values used for resources other seem to me that a direct correlation of than timber were provided by national direction visual quality valuation could be included for all National Forests. These values were based in your PNV calculations on the 1985 Resource Planning Act (RPA) assess- ment made at the national level. Timber values 'As the Deschutes National Forest has a were based on specific historical data for this plan for clear-cutting and scarring the and regional data supported a 1 Forest. National foothills, that plan could be responsible, in percent annual increase in the value of timber part, for a prospective purchaser of De- stumpage over time Similar data was not available for recreation and other resources which are not schutes County real estate to look else- valued based on market place transactions but where. This could have far-reaching effects rather on the basis of a willingness to pay. when one considers the jobs and payroll lost to another country - including the Although this is the best available data, there is multiplier effect resulting from those jobs " uncertainty about the future value of all resources. Consequently, sensitivity analysis was conducted 'There is absolutely no question in my and displayed in Appendix B of the FEIS. It shows mind that a pleasing scenic view dramatically the impact of using assumptions other than the 1 enhances both the value and marketability percent trend Additionally, the relative economic of real estate.' value of the various resources was not the sole criteria used Based on the public issues identified RESPONSE: While a spectacular view can add during the planning process, a range of alternative considerable value to residential and commercial management schemes for all resources was property, it would be very difficult if not impossible formulated and analyzed. Population trend projec- to place a dollar value on the appearance of the tions and their effect on recreation have been Forest from locations around it. One of the major reviewed by the State economist and revised. elements of the Visual Management System, however, is 'sensitivity,' which gives special attention to portions of the Forest which are seen COMMENT. Numerous realtors submitted detailed by a large number of people. While visual quality arguments for placing a monetary value on scenic is a 'non-priced' value which is not included in views Here are some of the comments. calculating the Present Net Value of a management alternative, it can be decisive in arriving at Net "A parcel of land with no view is worth less Public Benefit This explanation is from Chapter 2 than a similar parcel with a view of the countryside, and the country side view is of the FEE not as desirable as a mountain or water (river, lake, etc) view: 'Subjective judgments are necessary in assessing whetner the benefits of producing 'Because the Cascade Mountain view is a the non-priced value exceed the opportunity critical value factor in real estate sales, it is costs associated with reducing priced of paramount concern that view be weighted outputs If the Present New Value tradeoff as an economic benefit.' is judged acceptable, Net Public Benefit has increased and the alternative is more Citing a sulvey indicating that 45 percent efficient overall ' of Black Butte Ranch owners considered

Appendix J - 74 Appemdix d Alternatives, Data Analysis, & Planning Process

A supplement to the Draft EIS was issued in October In response to these and other public comments of 1988. It contained additional analysis of some addtional lands have been assigned to the primary constraints, the Management Require- retention and partial retention visual quality ments. This information has been included in the objectives in the Preferred Alternative. A new FEIS. Front Country Management Area will protect visual quality in the portion of the Forest cited by the Economic Analysis the above respondents.

COMMENT The public has not been fully informed COMMENT One reviewer disputed both market about the wildlife, recreational and scenic values and non-market values used in the DEE, declaring that are currently being produced through land that costs were overstated. "The methodology allocations such as wilderness, RNAs, and the used to combine market and non-market values OCRA which limit or prohibit timber management. is fundamentally incorrect, thus casting doubt Timber values that have been lost tc these and about all of the economic conclusions and other management designations are not presented recommendations Major changes are needed to in the plan analysis. Therefore, the public cannot correct the Forest Plan to make it economically easrly determine the actual level of values provided correct. In the Appendix B of the DEIS it states by the National Forest, nor can they trace the (p.190) that stumpage values were derived from continued erosion of the commercial forest land an average of "cut" or harvested sales from fiscal base. To leave out a discussion of the valuable years 1977 through 1982 calculated in 1982 dollars contributions to recreation, wildlife habitat, water- The logging costs were derived from an average shed protection and the non-market values that of 'soldn but not harvested sales from the calendar accrue to the public from legislative and administra- years 1973 through 1982 tive designation and from management stratagies that are not decided through the Land Management RESPONSE: The cost and value data used in the Planning process is doing the public a great analysis followed regional and national direction disservice and may violate NEPA and NFMA Methodology is acknowledged to be less than requirements. perfect but very few acres are being allocated based purely on economics. RESPONSE: The planning documents do not present the timber resource values foregone as a result of these designations because they have COMMENT "The results of the price trend bench- not been inventoried. Resource values contributed mark analysis are significant,aa reviewer declared, by these areas are described in Chapter 3 cf the FEIS and Management Area descriptions in adding that they "have a major bearing on the Chapter 4 of the Forest Plan management intensities, unsuitable acres, Present Net Value, and pine harvest.O The implications of price trends in every alternative, especially the COMMENT 'When trade-offs are necessary,' said preferred, must be analyzed, according to this one respondent, 'they should be clearly explained. reader. The opportunity cost (shadow price or reduced costs) of the major constraints should be displayed RESPONSE. It is assumed that price trends in the so the public could get an idea of the cost of alternatives mirrorthose indicated in the benchmark non-priced benefits.' analysis. They should not be used to predict the future but to suggest which long range investment RESPONSE: Opportunity costs or tradeoffs for decisions may be unreasonable. If they called for various levels of resource emphasis are displayed the removal of large parcels of land from the timber in Chapter 2, Chapter 4, and Appendix B of the base, for instance, it would be prudent to consider FEIS. other criteria

Appendix J - 75 Appendix J Alternatives, Data Analysis, t? Planning Process

COMMENT: A comparison betweenthe percentage COMMENT. 'I would like to know what assumptions of logs from the Forest bought by Deschutes were made for inflation, population growth, etc ', County mills and timber processed in the county a reader declared ' In other words, how cloudy is was 'incorrect,' according to one reviewer. 'The your crystal ball?' percentages given in the text have no relationship ' RESPONSE A detailed discussion of economic RESPONSE: This discussion has been updated assumptions is given in Appendix B of the FEE and clarlfied in the FEIS and Appendix B Receipts to the Forest Service/Federal Government COMMENT A reviewer faulted the DElS for failing to fully address the changing timber supply COMMENT More information, including a table, situation in Oregon. 'Inventories on private industry showing The cost to the public of road building, lands are falling. Adjacent National Forests will deficit timber sales, and other federally subsidized Forest Service activities' was requested This was likely be lowering hawest levels as a result of the considered necessary to permit accurate decisions new plans currently process. Ponderosa pine in effecting timber production and other Forest availability on all ownerships is decreasing. In resources. light of these trends, it is unrealistic to assume that the Deschutes National Forest faces a RESPONSE: The cost of road construction and horizontal demand cuwe for timber and that the reconstruction needed to harvest a timber sale number of jobs, personal income, and payments are commonly defrayed by a portion of the value to counties will not be affected by these other of the timber harvested Information about these trends and factors outside the National Forest purchaser credits is available at the Forest boundaries. The economic analysis for the DES Supervisor's Office. See below for discussion of should take into account the dynamic social and 'deficit' timber sales. economic environment in which the forest operates instead of maintaining the false premise that the Deschutes is an isolated, independent entity. COMMENT. "All below cost sales should be eliminated from the timber harvest base," one The Forest Service should widen its scope of reviewer declared, and was one of the respondents economic and social analysis to include the entire asking for a map showing below cost sales and state of Oregon rather than just Deschutes County. unsuitable lands. Since more than one-half of the timber logged from the Deschutes National Forest now leaves RESPONSE: While economics is one of the the county, other areas of the state are also deeply important considerations in both the selection of affected by Deschutes National Forest ' a Preferred Alternative and in the design of individual timber sales, it is not the only considera- tion. Sales may be designed to meet management RESPONSE The discussion of timber supply and objectives for other resources or the management demand has been revised in the FEIS. The effects of insect and disease problems Contending with of the proposed plans on the state of Oregon has trees killed by the bark beetle epidemic has been examined by the Regional Forester. Each produced below cost sales on this Forest Thinning Forest has assessed the more localized effects in sales, needed to achieve growth of crop trees, accordance with the requirements of NFMA. While frequently have costs exceeding revenues. The it can be argued that the Deschutes NF could future value of crop trees, however, is enhanced. change the amount of volume offered for hawest to the extent that it affects the price, it is not currently A generalized map of land unsuitable for timber possible to quantify such a price/quantity relation- production is part of the process records for the ship reliably at the local level. Forest Plan. A map of below cost sales would

Appendix J - 76 Appendix J Alternatives, Data Analysis, & Planning Process

require a determination of the economic efficiency or indirect jobs. It is also unclear whether the job of individual sales. This site specific information is losses are quantified only for Deschutes County beyond the scope of the Forest Plan and FEIS, or for the whole market area.' which establish broad direction for activities on the Forest. RESPONSE The job changes are across all sectors of the local economy and Deschutes County was used as a surrogate for the entire zone of influence. COMMENT The Forest Service should conduct a The estimated changes in employment and income profitable operation, a reviewer declared. 'One would not change if additional counties were solution would be to set your minimum bids at included in the zone of influence. more realistic rates and then to set the rates for Gmber to be removed on a yearly basis rather than on a sale-by-sale basis. COMMENT A stronger effort needs to be made to 'increase job numbers, personal income and RESPONSE Revisions in timber sale contracts in payments to counties by modifying the harvest last few years allow for price adjustments over scheduling and improving the reliability of the time to reflect changing market conditions. Ap- data and economic analysis," a reviewer said. praised rates are based on current values and the estimated cost of timber removal. Minimum RESPONSE: Timber harvest scheduling has been rates are only established if the appraised value reevaluated in light of a new timber inventory. is negative or very low. The Forest Service will not Cost benefit and other elements of the economic analysis have also been reviewed and adjusted sell stumpage below the minimum rate. Competitive for the same reason. bidding usually results in sales significantly above the appraised rates. COMMENT The coefficients used in Table B-V-3 (Appendix B, DEE) were questioned by a reviewer COMMENT: A reviewer said it was difficult to 'Actually, they appear somewhat conservative. evaluate alternatives because the assumptions for Current output generates an employment re- economic values are not presented. 'For example, sponse, including direct, indirect and induced, of when you say 'revenues returned to the govern- 1,566 jobs In 1985 employment in wood products ment', do you also include income taxes from alone averaged 3,100, with wages averaging about businesses statewide that benefit from people $19,500. Total income estimated per job was visiting the Deschutes, buying food, fishing about $25,000. How many of the industry total licenses, etc.3' jobs are generated by Deschutes National Forest timber is not known, but the area's sizeable mill RESPONSE In Appendix B of the FEIS, assump- work industry very likely IS a net importer of pine tions used in the economic analysis are described. lumber. Using 1977 data in the model, when Only revenue returned to the Treasury from timber employment in wood products was only 2,690, sale receipts, campground fee collections, grazing may also be a problem. Obviously, given the use fees and special use permits are included in range of possible responses to any changes in the calculationof revenues returned to government. harvest policy on the part of the Deschutes National Forest alone, predictions regarding effects on jobs and income must be highly subjective in Employment nature

COMMENT One reader held that impacts on jobs RESPONSE. The data used was the best available by alternative are not explained adequately in the at the time and using it was in conformance with DElS or appendices. 'It is unclear if the 21 jobs the Regional and National direction to use IMPLAN. lost by implementation of the Preferred Alternative The basic data has been changed as is shown in would be direct lumber and wood products jobs Appendix B.

Appendix J - 77 Appendix J Alternatives, Data Analysis, & Planning Process

COMMENT None of the Forest Service alternatives Long Term Benefits addresses the number of jobs already lost and the impact on local economies by the reductions COMMENT. More complere information about of allowable harvesting of ponderosa pine in the tourism and recreation was sought by a respon- Deschutes National Forest. dent, who asked how much money is generated and how many people are employed by Sunriver RESPONSE Forest Plan alternatives were intended and Inn of the Seventh Mountain. A chart showing to address the future but past supply and demand where money generated by the resorts is spent for timber on the Forest is discussed in Chapter 3 was requested. It should 'combine these monies with revenues from hunting, fishing and other of the FEIS. recreations The combination of all the above factors dwarfs by leaps and bounds the revenues brought in by timber. These factors look even COMMENT A respondent pointed out that Alterna- more promising because their influence is increas- tive C is identified as the Preferred Alternative in ing each year and the forest can provide them in the Reviewer's Guide and Alternative E elsewhere perpetuity. It was also noted that *The potential impact on number of jobs changed in the local economy RESPONSE The FElS has been updated with (step 2, response form) is presented in numbers information regarding tourism and recreation. apparently based only on timber board feet. The Financial and employment information for SUnriVer numbers appear to directly coincide with MMBF. and the Inn of the Seventh Mountain is unavailable Is no consideration given for jobs which will occur to the Forest. There is ongoing research into the in the tourist and service industries as Bend and revenues for recreation and timber and their the surrounding areas increases as the summer relationship and winter playground for most of Oregon and parts of southern Washington? No account appears to be given for the probable loss of jobs to the Forest Coordination Efforts economy due to factors beyond available MMBF.' Increasing competition from the southeastern COMMENT The representative of the State Unlted States an6 Canada, mill modernization, Department of Forestry said the Forest should be and employment in the recreation sector encour- commended for coordinating the planing effort aged by emphasis on visual quality, wildlife and with the State This respondent, however, request- recreation were mentioned as examples ed a better presentation of the issues which were presented to the Forest by the State.

RESPONSE The Review's Guide was incorrect in RESPONSE This issues and the Forest's response identifying Alternative C as the Preferred Alternative are indicated in this Appendix to the FElS Impact on jobs is the effect of changes in timber, recreation, and grazing outputs whether they are direct, indirect or induced. The most dramatic COMMENT Concern about the cumulative effect changes are produced by increases or decreases of timber harvest plans by all tree producers in in timber production. In Table B-V-3, Appendix B, Oregon was expressed by one reviewer The level one can compare the response coefficients for of harvest on the Forest should be considered 'in timber outputs with those for the other resources conlunction with that proposed by other National menticned Comp?tition from other regions, mill Forests, the Bureau of Land Management, and on modernization, and the number and value of jobs private lands.' Implementation should be delayed which may be created by increased recreation until "the total impact' on the lumber and wood are more fully discussed in Chapter 3 of the FEIS. industry in Oregon can be evaluated.

Appendix J - 78 Appendix J SOB,Water and Riparian Management

RESPONSE National Forest Plans in Oregon will on recreation and tourism development when not be implemented until the Governor's office compared to timber harvest " has an opportunity to review them and make recommendations. The levels of goods and RESPONSE. Congress decides how funds for services which all National Forest Plans in the Forest Service actwlties will be allocated Budget Region 6 propose were totaled and taken into requests by the Forest will now be based on consideration by the Regional Forester in his oblectives established by the Forest Plan, which evaluation of each Forest Plan. This provided the is the product of an extensive effort to achieve larger context for more local decisions. the appropriate balance between all Forest resources. Budget (In General) COMMENT: One reader was suprised by budget COMMENT The Preferred Alternative calls for a figures published in the Reviewer's Guide. "I see 15 percent increase in funding to implement the a range of $661,300,000 to $1,285,800 ...... if It Forest Plan. Several reviewers expressed concern takes that kind of money to run the Deschutes about the likelihood of this level of funding in light the only proper plan would be to dispose of It or of the nation's budget deficit and Congressionally shut it down " imposed spending limits. Five asked about the consequences of a shortfall in funding 'In the RESPONSE. This was a misprint which has been past,' said one, "a lowered timber sale volume corrected. package results This causes much speculation and uncertainty in the wood products industfy.' Another observed The key question is will the COMMENT The State Department of Fish and Deschutes National Forest have the budgetary Wildlife said funding for timber harvest, particularly resources to carry out proposed (recreation) facility in lodge pole pine, should be contingent upon development.' funding for wildlife habitat protection and improve- ment RESPONSE Congress controls the budget pro- cess The effect of budget limitations would be to RESPONSE: The Forest Plan calls for funding increase the length of time required to reach the desired future condition propcted by the Forest which would achieve the balance sought by the Plan. It could also effect some outputs. If funding State. Congress, however, has the final word on for intensive tlmber management is reduced, for appropriations instance, adjustments would have to be made in the allowable sale quantity. It could also slow the process of harvesting beetle killed lodgepole pine Volunteers to make way for healthy new stands Delays in the construction of recreation facilities might be COMMENT' "I believe we need to take advantage offset by partnerships and the efforts of volunteers of these youth groups that want to get out and Effects of budget levels will be adjusted through help make new camping areas, trails and such," monitoring processes. one reader declared. Another encouraged the use of volunteers to clear trails.

COMMENT. *The National Forest Planning process RESPONSE: The Forest has always taken advan- seems to be improving,' a reviewer remarked, tage of volunteers and youth groups to accomplish adding: "There are more opportunities for public much needed work on the Forest. In a period of involvement. Yet funding is still basically single constrained funding, this assistance has assumed use, not multiple use. Very little money is spent large importance.

Appendix J - 79 Appendix J Range Management

Riparian Management Water

COMMENT A reviewer criticized the adequacy of COMMENT. Cooperation between the Forest measures called for in the DElS to protect riparian Sewice and the watermaster during drought was areas. 'Most big game biologists stress the pledged in the Draft Forest Plan A reviewer asked importance of riparian habitat as fawning and that this be expanded to include cooperation with calving areas for deer and elk. Additionally, vital any state task force established to respond to habtat for both water fowl and non-game species drought conditions. are contained here Oregon Hunters Association recommends that all perennial streams within the RESPONSE This change has been made in the forest be managed to optimize riparian habitat. Final Forest Plan. The Forest intends to meet it's This may mean exclusion of logging activities in coordination responsibilities stream corridors, and exclusion of grazing activitiy.'

RESPONSE StandardslGuideIines for riparian management have been significantly strengthened COMMENT Livestock grazing should not be and refined See Chapter 4 of the Forest Plan. allowed in the Oregon Cascade Recreation Area Riparian dependent resources will be maintained (OCRA), especially in Big Marsh Grazing is not or improved. When conflicts occur, the decision compatible with the recreation and wildlife values will be made in favor of riparian dependent of the OCRA. resources . RESPONSE While cattle grazing is permitted in legislation which created the Oregon Cascade Soils Recreation Area, an Environmental Assessment prepared for Big Marsh recommends terminating COMMENT. A reader said soil permeability in the the allotment there area means that groundwater is vulnerable. 'What is the quality of groundwater on the Forest? Have there been instances of contamination?' COMMENT An increase of 3,000 animal unit months of grazing by domestic livestock, called RESPONSE To date, more than 3,000 water wells for in the DElS Preferred Alternative, was opposed have been drilled on or within 10 miles of the Both this projection and increased spending for Forest. Planners concluded that the quality and range improvements, according to this respondent, quantity of ground water tapped by these wells fail to recognize the decline in cattle production would not be significantly affected by activities since 1975 Because of this decline and the need called for in any alternative. for additional wildlife forage, the respondent proposed abandoning allotments which are unused for three years. COMMENT 'No rationale or research is presented for stating that there are no significant problems RESPONSE. The increase in AUMs in the FEE is associated with soil, water, and riparian resources a reflection of possible capacity Only the more requiring special restrictions,' one respondent productive grazing allotments are expected to be declared. utilized The actual amount of grazing will depend on the demand for the forage by the local ranching RESPONSE. Standards/Guidelines for these communities. resources have been made more explicit in the Final Forest Plan (see Chapter 4). Numerous Range imrovements will be constructed on a cost references to scientific literature regarding these effective basis, usually on the most productive resources are now included in Chapter 3 of the allotments now being used Improvements such FEIS, the Affected Environment. as water development, seeding, and burning will

Appendix J - 80 Appendix J Range Management

benefit many wildlife species as well as livestock. Prescriptions must be written for any project Fencing will provide better control of cattle, burning on the Forest producing more uniform forage utilization. We assume, "burning to reduce fuel loading," refers to understory burning, such as that which COMMENT You state that grazing allotments will is done in the Swede Ridge Area west of Bend. be managed at fair or better condition. ONRC This area has historically had wildfires of 100 believes that good condltion should be the acres or more. Understory burning in this area is minimum objective for ecological condition in any an attempt to reduce the fire hazard that has the allotment open to commercial livestock grazing. potential to threaten homes and other improve- ments close to Bend. RESPONSE: Forage objectives are identified in grazing management plans which are prepared for every allotment. The Forest Plan standards/ COMMENT Power crushing of slash from thinning guidelines note general utilization limitations for #seemsto do nothing but create a tremendous grasses and shrubs. source for potential wild fire," said one reviewer

RESPONSE Crushing will only be used where COMMENT: 'Please include the RO memo that total fuel loading after crushing will be within relates to AUM values on the Forest in the revised acceptable limits and where results will meet land 'If an AUM of Plan,' a reviewer requested adding: management objectives for fire suppression (see forage on the Deschutes National Forest is worth Chapter 4, Forest Pian). Generally, crushing is $10.73, why do ranchers only pay $1.35 per AUM? used where total fuel loading is acceptable but We believes that fair market value should be the arrangement of the fuels poses a fire hazard. charged for market goods.' Crushing greatly reduces this hazard RESPONSE Grazing fees are established at a national level and are beyond the scope of the Forest Plan Air Quality

COMMENT: There was concern expressed that COMMENT "There are isolated overgrazing burning causes air quality problems and that the problems and there should be addrtional standards DEE did not address the health impact of smoke to protect these systems,' a reader declared. emissions and their effects

RESPONSE. Standards/Guidelines have been RESPOSE: Maintaining air quality is an important revised to provide additional protection, especially Forest objective and discussion of the subject in riparian areas has been expanded in Chapters 3 and 4 of the FElS Health hazard as well as visibility problems are considered Fire Compliance with the State Smoke Plan on pre- COMMENT "Burning to reduce fuels loading is scribed burn days is considered assurance that probably a waste of time; adding: 'It's just the the Forest is meeting the 24-hour standard latest fad. Burning for slash elimination is an Protection of recreational and rural residential acceptable practice.' populations is given special attention. All means of smoke management (reduction, avoidance, RESPONSE The Forest does no burning where a and scheduling) is employed to assure compliance need and purpose have not been identified. with the standard for these areas.

Appendix J - 81 Appendix J Recreation Management

Statewide, emissions from Forest Service pre- Areas will not be included in the base used to scribed burning are being reduced This reduction calculate the Forest's Allowable Sale Quantity occurs because the Forest is employing tested and proven techniques to reduce emissions and burning less tons per acre COMMENT A response from the Oregon Depart- ment of Transportation's Park and Prescribed burning is guided by the objectives of Recreation Division stated a number of concerns State Smoke and Visibility Plans to avoid and They included: minimize impacts on the public. An apparent erosion of primitive and A recently published Vegetation Management semi-pnmitive recreation opportunities The park division requested a projection of the Plan for Region 6 emphasizes human health issues. anticipated demand for dispersed recreation and information about how it would be met.

An understatement of the role which the Recreation (in General) Forest Service plays in providing outdoor recreation in Oregon COMMENT Many respondents felt the importance of recreation on the Forest was slighted in the The emphasis on developed recreation DEIS. One asserted that recreation is 'Central (the 1983 Statewide Comprehensive Out- Oregon's number one growth industly and an door Recreation Plan indicates an oversup- integral part of Its economic development plan'. ply of camping and picnic sites in Deschutes, Some said recreation, rather than timber, was the Jefferson, and Klamath Counties). A future of the Forest. Several said that Deschutes reduction of service levels at developed recreation has both State and national significance. sites, however, was opposed by the State Most of these respondents advocated measures to maintain or increase the level of recreational A need for 30 miles of walking and 20 horse visitation. Others, while recognizing the value of trails by the year 2000 recreation, cautioned that it will not replace the forest products industly as the economic mainstay A recommendation that Fall River be of the area Lower salaries for work in recreation managed to retain the option of state related businesses was often cited in this connec- designation. tlOR The state also made recommendations for Wild and Scenic River designation, an issue which was RESPONSE The treatment of recreation in the resolved for this planning period by the Oregon FEE and Final Forest Plan has been considerably Wild & Scenic Rivers Act of 1988 A challenge to expanded as a result of these and similar com- recreation values used in the DEE economic ments. Recreation is a primaly factor in Central analysis was addressed above under Non-Priced Oregon's economy. Both Oregonians and many Benefits. vacationers from elsewhere visit the Forest. The annual contribution to the local economy from RESPONSE, Dispersed Recreation: The demand recreational activities is approximatly 375 million for dispersed recreation is expected to grow at dollars about the same rate as the population. A growth rate of between 2 and 2 5 percent annually during The Forest Plan calls for expanding recreational this planning period was projected in the FElS facilities to meet a growing demand. This will slightly reduce timber harvest. Timber in Intensive, While several of the Roadless Areas would Dispersed, and Winter Recreation Management ultimately be roaded during implemention of the

Appendix J - 82 Appendix J Recreation Management

Preferred Alternative, this would not occur during modated winter recreation and geothermal devel- the first decade. It will be possible to reassess opment, were in conflict recreation supply and demand before development occurs. RESPONSE In view of these comments, geother- mal development was removed as a specific Developed (Intensive) Recreation: The use of objective in the Winter Recreation Management many existing sites (primarily campgrounds, picnic Area. There would, however, be few restrictions and boat launching areas) exceeds the desired on geothermal projects in these areas. occupancy rates of 40 to 50 percent. For this reason, the Plan calls for the rehabilation and expansion of some of these sites and the develop- COMMENT Most readers favoring more dispersed ment of others. Full service will be maintained at or undeveloped recreation opportunities mentioned fee sites and, while non-fee sites will be operated the need for separation between motorized and at reduced levels, they will be maintain to standard. nonmotorized recreation areas. The quality of recreation is expected to remain high. RESPONSE: Separation of motorized and nonmo- torized use has been emphasized in both trail A planned schedule for Intensive Recreation sites system management and standards/guidelines for and trails has been included in the FEIS. It calls the Winter Recreation Management Area for the construction of more trails than has been requested by the State.

The Forest portion of Fall River is allocated to COMMENT One respondent thought the DElS Scenic Views in the Preferred Alternative, which and Draft Plan did not sufficiently acknowledge will leave the option of future designation open the high dispersed recreation use along the Deschutes and Metolius Rivers

COMMENT A reviewer called attention to an RESPONSE. Additional standards/guidelines have inconsistency in the 'Need to Establish or Change been written to guide management of Deschutes Direction' portion of the Draft Forest Plan. One and Metolius River corridors (see description of passage reads 'Visual or protection management the Wild and Scenic River Management Area and areas with the potential to handle intensive direction for activities in riparian areas) recreation uses should be managed with recreation emphasis to provide more opportunities' Another states: 'Many areas currently in protection manage- COMMENT. The issue of new road construction ment should be considered for a land allocation in the Dispersed Recreation Management Area that would emphasize management for undevel- was raised by one respondent, who said. "no new oped or dispersed use'. The respondent observed roads.' that these goals "are not mutually exclusive, but ways and means to accomplish them are unclear.' RESPONSE Added direction in standards/ guidelines calls for maintaining roads for recreation RESPONSE The wording in the first passage was at the current level of mileage and density. incorrect and has been changed to refer only to Visual Management Areas. Areas which can accommodate intensive recreation are now classi- COMMENT. Several respondents asked that plans fied accordingly. The wording in the second for future development of nordic skiing areas be passage was expanded. made publicly available.

RESPONSE A number of additional nordic trails COMMENT Several reviewers said the objectives and sno-parks have been added to a trails of the former Management Area 13, which accom- implementation schedule in the final Forest Plan

Appendix J - 83 Appendix J Recreation Management

Trails management (a crisis situation) or long-term management. Standards/Guidelines were devel- COMMENT. Several reviewers faulted the DEIS for oped to comply with these laws. They do not failing to resolve conflicts between trail users 'resolve' problems but are expected to integrate Some favored development of trails for nonmotor- the treatment of cultural resources into day-to-day ized use only; others asked for the creation of a management mountain bike trail system.

RESPONSE The revised Standardsjguidelines COMMENT A correspondent noted that timber contain several measures to reduce conflict harvest is being extended into areas previously between hikers and bikers and snowmobilers and avoided because they contain cultural resources. nordic skiiers. The Forest Service will be required to accelerate evaluation and mitigation. Manage cultural re- sources rather than avoid them.' COMMENT: Trail protection and relocation was insufficiently treated in the DEIS, according to a RESPONSE. Evaluation and mitigation has already number of readers. increased, both because of these circumstances and due to interest expressed by the public In RESPONSE The FElS and Forest Plan now include addition to gathering data, information obtained in provisions for locating and relocating trails to carrying out this program is being shared with the avoid harvest areas and roads. Measures expedit- public ing cleanup and restoration of trails unavotdably disturbed by harvest activities have also been added. COMMENT The Forest Service gives inadequate consideration to historical resources, according to two reviewers COMMENT. None of the offered alternatives present detailed information regarding the current RESPONSE. This impression may be attributable status of the trail system on the forest or proposals to the fact that prehistoric resources outnumber for future development and maintenance historic ones and are more likely to affect prolect planning. Many historic sites are protected through RESPONSE. This information has been included continued use. Preservation in place and adaptive in the Final Plan and EIS reuse are always the preferred treatment for historic structures. Cultural Resources Off Highway Vehicles COMMENT: Regarding the impact of cultural resource programs on management activities, a COMMENT One reader said "very little attention" reviewer said: 'these concerns and problems was paid in the DEE to conflicts between trail should be reflected in the Forest Plan so that it and backcountry users with different preferences, responds tolhe day-to-day sltuations on the ground primarily hikers and off-road vehicle users Another and short and long-term Forest management said 'wheeled off-road vehicles' should "be problems Lacking such integration, cultural restrictedto designated roads and trails throughout resources will remain a controversial and difficult the Forest ' resource for the Forest Service to manage.' RESPONSE Management Area standards/ RESPONSE: Federal laws require that cultural guidelines in the Plan now provide direction to resources be considered when any ground minimize conflicts between different classes of disturbing activity occurs. This includes short-term trail and backcountry users.

Appendix J - 84 Appendix J Real Estate Management

COMMENT: A national association of off-highway a respondent. "You have a objective statement vehicle operators proposed 'adopt-a-trail/roado which sounds good But, it may not have any real projects involving local organizations in lieu of operational meaning Let's make some of those closing areas to these vehicles. decisions now rather than fighting never ending piecemeal battles later on " RESPONSE Areas of the Forest open to off- highway-vehicles in the Preferred Alternative are RESPONSE Since each powerline prolect has expected to meet demand The rehabilitation of different requirements, site specific decisions will roads and trails by user groups is encouraged. be made through the NEPA process if and when a project is proposed. Specific powerline Standards/Guidelines, other then the identification of locations where power lines are not permitted, Special Uses are not included in the Forest Plan.

COMMENT A reviewer asked that standards/ COMMENT 'Transmission line siting is only guidelines be revised to reflect State policy on minimally addressed, a revlewer remarked, adding: small hydro-electric projects. 'This is appropriate. The plan cannot at this time predict how many transmission lines will be needed. RESPONSE: The State policy has been acknowl- However, the plan should reflect that existing edged in the Final Forest Plan, which also spells transmission corridors will be used for new out provisions for coordination. transmission line capacity where possible."

RESPONSE. In power line sting, first prlorlty will Utility Corridors be given to the use of existing Corridors. Second priority will be to expand existing corridors. COMMENT Regarding a map indicating utility corridors, a reviewer asked nShouldmajor phone lines also show? Does 14.4 KV indicate major Small Hydro Development corridor? If so, more exist How about showing power lines currently serving electronic sites? COMMENT: A reader said the Forest Plan should Substations, compressor and capacitor stations 'identify sites where hydro projects can be don't show. More potentials exist. Midstate is developed with minimal and/or no impact on other currently proposing 115 KV LaPineSunriver line. resources or where there would be a positive Existing PGE line shows or should show.' Another impact.' respondent had trouble with the utility corridor map, declaring them 'confusing (different length RESPONSE Wild and Scenic River legislation has of dash lines): limited the number of sites where hydro projects can be developed on the Forest. It can occur at RESPONSE: Utility corridors as identified in the existing impoundments such as Wickiup, Craine plan are limited to major transmission lines (69 KV Prairie, and Crescent Lake and over, railroads, and gas lines). The map has been revised to show only major existing utility corridors and windows for future corridors. The COMMENT A reader suggested "hat the list of different types of use were not shown on the projects in Table IO, Appendix E, be modified to corridor map. reflect current hydro policy in the Deschutes as stated in ORS 543.165 and other State require- ments such as water rights (the upper Basin COMMENT 'An attempt should be made to develop Withdrawal Order and Hydro Rules OAR 690, specific powerline standards/guidelines now," said Divlsion 50.'

Appendix J - 85 Appendix J Minerals

RESPONSE The appendix on Wild and Scenic COMMENT Several reviewers faulted the DElS for Rivers has been updated to reflect the current underestimating the importance of minerals One situation. asked for 'meaningful inventory data for minerals and oil and gas' and said the Plan should "include the current status and proposed future procedures COMMENT References to a 1/12/1914 power site and stipulations for minerals on your National Forest.' He added. 'The plan should provide withdrawal and possible withdrawal in T25S, R7E, direction for minerals policy and future minerals Sec. 7 and/or 18 were questioned by a respondent. management and indicate how minerals manage- ment is coordinated with other resource uses: RESPONSE: The 1914 withdrawal is no longer in effect There are no records of a withdrawal in One said a general mineral inventory performed T25S. R7E in 1977 should have been cited. "The alternatives have largely ignored non-energy minerals. Provi- sion should be made for exploration under several COMMENT Power site withdrawals Twn 24 S., R of the Management Areas Establish standards 7 E Sec 14, NW 114, N 112, SW 114 BLM records that determine what areas should be withdrawn show power site reserve 3412-EO SO INTPR 101 from mineral development." - entry 1/21/1914 -Action 8/2/27. to conform to RESPONSE. There are no known deposits of gold survey. A dam at this location would flood the and other precious metals, strategic metals, and county road and new USFS campground Possible base metals on the Forest. There are, however, a power or irrigation slte are Twn. 25 S., R 7 E., number of mining claims located on the Forest. sections 5 and/or 18, SW 114 and NW 114 The only active claims are pumice, aggregate, respectively. A survey was made years ago and and cinder claims that were located before 1955 an azimuth mark set on west side of Big Marsh There are some claims for gold and other precious Creek opposite the location of John Harrisan metals but there is no evidence that minerals cabin - since burned No entry in BLM records of have been found. The numbers and locations of a withdrawel -at least in the records I have. Suggest claims vary considerably each year as new claims this be investigated as well as the withdrawal are located and old claims are relinquished. A list noted above. of claims with locations can be obtained at the Forest Supervisors office RESPONSE: State law, in 1987, placed a moratori- um on all hydro projects in the Deschutes Basin. COMMENT A reviewer declared. 'Not all sources on the Ft Rock are shown on the plan map. Many We do not have any records of power site prospects and borrow pits are not shown and withdrawals in T 25 SIR. 7 E in our files or at may be needed in the next 10 years A hard rock our Regional Office. source is proposed in the Arnold Ice Cave and this does not appear on the mineral plan map Sand Flat cinder pit is used by the public occasion- Land Status ally: RESPONSE The list of pits on the Forest has COMMENT 'Change the classification in the been updated All of the existing permits should Meadow Camp area to preserve these land for now be included on the map, including the Sand wildlife,' said one respondent.' Flats pit. Provisions for new mineral materials sources have been included in Chapter 4, Forest RESPONSE The classtication of Meadow Camp plan standardslguidelines. The hard rock source was changed from 3-C to 2 in the Land Adjustment proposed for Arnold Ice Cave was over a mile Plan. This retains the area in public ownership. from the cave. Known caves will be protected

Appendix J - 86 Appendix J Minerals

(see Cave Management standards/guidelines, include an analysis of economic and resource Chapter 4 of the Plan values

Geothermal Development COMMENT "The Deschutes National Forest Plan in Its final version should concur with the State Energy Facility Siting Council and Deschutes COMMENT One reader said the DEE 'IS vague and inaccurate in its treatment of geothermal County in prohibiting development over 18,100 acres called for at the State and local levels. potential Without inventory data specific to the area the plan is misdirected in its assumptions of RESPONSE: Based on public comments received potential, impacts of development, and tradeoff on the draft plan, support for the lease denial judgements ' area within the Caldera was strongly supported Through further environmental analysis the Forest RESPONSE: The geothermal sections of the Final will determine what additional lands within the Plan and EIS have been revised. Known Geothermal Resource Area would be available or closed to geothermal development. This analysis will be conducted subsequent to the COMMENT A reviewer said the DElS suggests Final Plan. that only Environmental Assessments will be required for geothermal leasing once the Forest Plan is implemented "The DElS and Plan are too COMMENT The DElS IS not specific enough in general to exclude the need for Environmental describing the environmental consequences of Impact Statements on specific projects that have geothermal development, a reviewer declared, the potentital to significantly impact the environ- particularly those effecting groundwater ment:

RESPONSE The Environmental Analysis process RESPONSE: The Forest has a vast supply of high could result in a catagorial exclusion, an Environ- quality ground water. Accidents during geothermal mental Assesment, or an Environmental Impact development and operation could put local ground Statement, depending on the magnitude of the water at risk Regulation and monitoring, by both proposal and potential environmental and social the Forest Service and State, reduce this risk to a impacts. It is clear that the public, community very low level. The geothermal industry has a good record in protecting groundwater groups, and many others will need information about geothermal energy in order to offer informed responses to proposals. COMMENT A reviewer suggested that NSO (what is it?) be used instead of leasing denial in the Bend Watershed, Research Natural Areas, the COMMENT 'The plan gives to much leeway to Experimental Forests and other areas where this the lease holder after the lease IS given," according activity is precluded. 'Denial decisions should to one reviewer. "Economic justification of a only be made with a fully weighted analysis of all development is not described, so there is no way resources " to be sure that society needs the development before the final work is undertaken.' RESPONSE For different reasons, the primary objective in Wilderness Areas, Newberty Crater, RESPONSE Once a lease is granted, the lease Research Natural Areas, the Bend watershed, holder cannot simply begin full scale geothermal and the Oregon Cascades Recreation Area is to development. Another Environmental Analysis retain natural or near natural conditions Geother- must be done for each proposed development. mal development is not considered compatible This analysis, which again involves the public, will with this objective Experimental Forests are not

Appendix J - 87 Appendix J Special Interest and Designated Areas

required to remain in natural condition but geother- COMMENT A reviewer questioned a statement in mal development could interfer with research. the DElS which indicated that land in geothermal When possible, tradeoffs which are the conse- lease areas could be used for other purposes quence of this decision have been calculated and during the construction phase weighed. RESPONSE This statement has been removed from the EIS. COMMENT: A reviewer inquired about compliance with State requirements, OAR Chapter 6&0 Division 65.) COMMENT' Statements about the life of geothermal fields in the DElS were questioned 'Comparison RESPONSE. Reference will be made to State of adjacent reservoirs is usually inconclusive: permiting requirements for deep wells and plant sighting in the EIS. RESPONSE Reference to other fields has been changed in the EIS.

COMMENT Figures on the generating capacity of the Geyers facility in California were questioned COMMENT One reader pointed out that geother- by a respondent. The number of acres a 50 mal wells cannot be 'removed' when they are megawatt geothermal plant would require was depleated, as was suggested in the DEIS. "Wells also disputed. are plugged and abandoned, not removed.

RESPONSE The FEE was revised to reflect current RESPONSE: The reference to removal was capacity figures. The discussion on plant size is removed. now written to describe a typical geothermal development rather than one with specified capacity COMMENT Current geothermal leases should be made to conform to stipulations in the new Standards/Guidelines, a respondent declared COMMENT The construction of housing, which would include sewage facilities, at the site of RESPONSE Notices and stipulations in current geothermal facilities was opposed by a reviewer. leases predate the new standards/guidelines and be changed only if the lease holder agrees An RESPONSE The FEE was revised to indicate effort to gain such approval will be made if that most, if not all, geothermal projects on the conditions imposed by the current leases fail to Forest would be within commuting distance of sufficiently mitigate environmental impacts. nearby communities and would not require on-site housing. Special Interest Areas COMMMENT A reviewer called attention to a statement in the DEE indicating that geothermal COMMENT A respondent requested the addition well pads would range from one to four acres of the Horn of the Metolious, located in the Metolius depending on the number of wells Four to five Breaks Area, to the list of Special Interest Areas acre pads, it was suggested, would be more in the Preferred Alternative Another agreed and efficient and require less overall disturbance. also proposed the addition of Castle Rock, Balancing Rock, Head of Jack Creek, Black Crater, RESPONSE: The FElS includes the option of Squaw Creek Falls, McArthur Rim, and Davis using larger pads and fewer stes. Lake. There was also a request for a Special Interest

Appendix J - 88 Appendix J Special Interest and Designated Areas

Area which would include Boyd, Skeleton, Arnold, cave roofs and cave entrances, call for vegetative Charcoal, Hidden Forest, and Wind Caves. buffers around entrances, and regulate slash disposal, road construction and recreation. More RESPONSE Special Interest Areas were reevaluat- specific protection is given to caves inhabited by ed and Balancing Rock, Castle Rock, and Davis the Townsend's bigeared bat. Standards/ Lake were added These existing and proposed Guidelines also call for an information and educa- Special Interest Areas are considered adequately tion program to contend with the problems cited representative of features the classification was above Studies are required to preclude inappropri- intended to include. ate management; e.g., a gate which harms cave biota by changing the temperature, blocking access, or simply creating a disturbance. A new COMMENT This list of measures to protect caves Special Interest Area was not considered appropri- was presented by a reviewer. (1) classify caves ate at this time for this group of caves but could by user level and prepare management plans for be designated at a later date. important caves: (2) install a security entrance at Lavacicle Cave Special Interest Area; (3) avoid obtrusive fencing; (4) initiate an education program COMMENT Another request for a Special Interest to eliminate or reduce littering, graffiti, and pot Area was registered by a reviewer seeking to hunting; and (5) protect biological communities in protect a stand of ancient juniper north of Sisters. caves. RESPONSE: Since no activitieswhich would disturb RESPONSE. A security door is in place at Lavacicle this area are scheduled during this planning period, Cave. Standards/Guidelines in the FElS have it was not considered necessary designate this been extensively revised and provide direction on grove. inventoring, planning, and managing the unique resources of each cave. They limit activities on

Appendix J - 89 Appendix J Alternatives, Data Analysis, & Planning Process

for buffer areas in the Wilderness Act Chapter 4 Wilderness of the FElS now includes additional information on the effects of activities on Wilderness recreation COMMENT A reviewer declared that the Wilder- Wildernesses have been withdrawn from mineral ness Recreation Opportunity Specterm zones leasing but adjacent mining activity, road construc- were not displayed on a map and the Plan is not tion, timber harvest, and recreation may be heard specific enough about acceptable levels of use in and seen from within Wilderness Standards/ in different areas. An examination of alternative Guidelines and State restrictions on burning levels of use in different areas was requested. regulate air and visual quality Wilderness bound- aries were set by Congress and could be changed RESPONSE A map has been included that shows by future legislation. the Wilderness Recreation Opportunity Spectrum zones. Wildneress Plans for each area describe COMMENT: A reader observed that wording in how capacity will be dealt with, particurly If over the Wilderness Standards/Guidelines carries the use is beginning to occur. Management will be by implication that animal packing into the wilderness Limits of Acceptable Change (see Management for the purpose of hunting is considered "neces- Area 6, Chapter 4 of the Forest Plan). sary," while other activities, not specifically stated, are unnecessary. 'The very first of the Forest management goals is to provide equal opportunity COMMENT 'No mention was made of the Mt. My interpretation of this goal lead to a broad Thielsen Wilderness,' a respondent observed. definition of what is 'necessary" since a broad spectrum of the populace that would like to use RESPONSE. A plan for the Mt Thielsen Wilderness the wilderness are not able to do so without the has been developed jointly with the Umpqua and services of a commercial outfitter" Winema National Forests and has been included in Appendix 4 of the Forest Plan RESPONSE: In the FEE, language suggesting that animal packing by hunters is more "necessary" thanthe use of stock by others has been eliminated COMMENT 'Wilderness boundaries should be adjusted so they could be located on more definable features,' said a reviewer. As an example, COMMENT. A respondent said the Plan "appears it was suggested that the boundary near Three biased against commercial uses" in Wilderness Creeks Lake be moved from Snow Creek and Llama packing and mountain climbing were given placed on a ridge to the east of Snow Creek. 'A as examples of activities which were not acknowl- buffer should be provided between Wilderness edged. and conflicting uses.' Another reader said the DElS did not sufficiently discuss the impacts of RESPONSE: Both of these activities may ligitimately management activities adjacent to Wildernesses. occur in Wildernesses Limits on commercial "This should include noise impacts on Wilderness OutfitterS are imposed only to protect the resource values, gas and oil drilling under Wilderness, and and the quality of the Wilderness experience air quality and visual impacts from prescribed buring COMMENT Noting provisions for helispots in RESPONSE Placing boundary lines on identifiable Wilderness areas, a reviewer asked about the use features does make the the administration of an of this aircraft in Wilderness area easier. Boundaries were placed on identifiable features when this met the intent of Congress as RESPONSE Helicopters are permited in Wilder- expressed in the Oregon Wilderness Act of 1984. ness when human life or injury is involved and in While activities adjacent to Wilderness are planned some limited cases to deal with forest fires. They to minimize disturbance, there was no provision are limited to these emergency situations.

Appendix J - 90 Appendix J Alternatives, Data Analysis, & Planning Process

Roadless Areas permitted in Retention areas. One added that harvest units should not exceed 10 acres in size. COMMENT 'Why is the Forest Service staying out of roadless areas for the first decade?,' a RESPONSE: As indicated elsewhere, in response reviewer asked, noting that Congress 'decided in to comments about timber management, the FElS 1984 what was suitable for Wilderness and what calls for an increased emphasis on uneven-aged was not." Failure to enter roadless areas in the timber management. It will be the preferred harvesting method in Ponderosa pine and mixed first decade was described as a violation of NEPA conifer stands, in sensitive viewsheds, and else- 'because none of the alternatives road the roadless where. There are, however, some places where areas in the first decade." small clear-cuts can be used to enhance a landscape feature, open a vista, or meet other RESPONSE: Of the approximately 145,000 acres and safety needs of existina roadless areas. 54.700 will remain unroadeiin the Preferred Alternative. This is to Sheiterwood units in Retention allocations should provide undeveloped recreation outside of Wilder- be kept to under ten acres. This produces a ness These areas are closed to vehicles in the relatively small scale ommosaic" effect of even-aged summer but are open to snowmobiles in the winter. stands Uneven-age management standards/ Approximately 32,600 acres will be available for guidelines also provide for shelter trees after the winter recreation activlties which include roads initial regeneration treatment wherever possible. and trails These areas are basically open to This will result in a variety of size classes and vehicles in the summer and winter. species in the islands of reproduction

In the first decade, timber harvesting has not been scheduled on 58,000 available acres because COMMENT 'The provisions for visual quality may of economic efficiency, a National Forest Manage- create unwarranted constraints on timber harvest- ment Act requirement. Harvesting is not scheduled ing in future years,' a reader declared "The final to begin until the second or third decades Roads plan should not contain language that would could be built for geothermal exploration or prevent achieving planned timber outputs ' firewood cutting on all but the 54,700 acres. There is no requirement that roadless areas be entered RESPONSE In Scenic View Management Areas, in the first decade. Since it was not needed to visual quality is the objective and timber production meet the objectives of the alternatives, forcing is a secondary benefit. Some harvest may be roads into these areas in the first decade was not necessary in even the most visually sensitive considered appropriate. areas but the primary focus will remain visual quality, not timber production. Because it will not immediately be linked to timber hawest, the rate of road construction in roadless areas is difficult to predict. At the end of the planning COMMENT "Major roads through the Forest are period, 10-15 years, portions of the Forest that used for destination driving, more than sightseeing, are still roadless can be re-evaluated for Wilder- a reviewer asserted. "What evidence suggests ness that visual considerations are more important along these roads than along other travel routes?"

RESPONSE. One of the premises of the Forest Visual Resource Management Sewice Visual Management System is that the number of viewers is critical. As a general rule, Scenic Views different parts of the forest are considered more visually sensitive as the number of viewers COMMENT: Several respondents said shelterwood increases All areas viewed from primary travel harveting should be the sole tree removal method routes, especially roads that have been classified

Appendix J - 91 Appendix J Alternatives, Data Analysis, & Planning Process

by State or other agencies as 'scenic highways', Retention obiective was never intended to protect have relatively large numbers of viewers. While every element of an existing forest stand many motorists are commuters or commercial travelers, a considerable number are traveling for pleasure and place a high premium on scenic COMMENT "The maximum visual benchmark quality Management activities which can be seen should be assessed on the assumption that all from these malor roads are normally designed to roads and trails that are part of the transportation be unobtrusive. Large diameter, yellow-barked system should be bordered by Retention," accord- ponderosa pine trees are an important element in ing to one reviewer, "and all visible locales from these landscapes, especially in foreground viewing any visited areas should be Partial Retention " distance zones The Forest Service will perpetuate this character on all primary corridors. Along RESPONSE The visual benchmark was based on secondary corridors that receive substantially less a complete visual resource inventory of the traffic and are used primarily for log hauling and Deschutes NF Visual Quality Objectives range Forest administration, visual quality is a less critical from Preservation through Maximum Modification. consideration The visual benchmark was a total of all Forest lands in the Retention and Partial Retention inventory classifications. (Preservation applies COMMENT' The practice of removing trees to only to designated Wilderness areas) Many roads, provide views into meadows was questioned by a trails and visible portions of the Forest are within reviewer. 'What studies have been done here to areas inventoried as Modification and Maximum suggest that opening up vistas to meadows will Modification Since we do not allocate lands to not have an adverse impact to wildlife?' Scenic Views within these two classifications, they were not included in the benchmark acreage RESPONSE. The wildlife biologist is a key member of the viewshed planning team. Before any meadow vistas are enhanced, the wildlife biologist is COMMENT. A respondent said the Upper Metolius consulted. The potential effects on wildlife re- should have a Retention Visual Quality Objective, sources are carefully studied If it is determined adding: 'A new category - Watchable Wildlife that there may be adverse effects, the vista would Emphasis - should also be created for riparian not be opened up. There are no general rules as and similar diverse areas that are used by to whether or not view enhancement will have an recreationists ' adverse effect on wildlife resources. Each meadow, and each vista enhancement project must be RESPONSE The Upper Metolius was inventoried studied individually. as Retention because of its unique scenic beauty and attractive riparian vegetation Because of the amount of development which has occurred Areas COMMENT Forest management in areas where outside of campgrounds and picnic sites are the Retention Visual Quality Objective has been required to remain essentially natural Retention applied was criticized by a respondent, who said: would not permit the summer homes, camp- "Retention should protect the form, line, and color grounds, roads, trails, and other facilities that of the existing forest stand If you aren't going to currently exist. Intensive Recreation also pen" comply with the Visual Resource Management site protection such as designated roads, vehicular guidelines, then don't use the terminology.' controls, and trails.

RESPONSE: Retention requires that activities be Watching wildlife is a popular activity along the conducted in a manner which repeats the form, Upper Metolius. It is provided for by current and line, color, and texture which are frequently found projected allocations, Wild and Scenic River and in a given landscape. Management activities should Intensive Recreation, and standards/guidelines for not be evident to the casual forest visitor. The riparian areas

Appendix J - 92 Appendix J Alternatives, Data Analysis, & Planning Process

COMMENT: Refering to the DElS discussion of Retention areas should be replaced with the visual quality, a reviewer noted that powerlines following. and roads can reduce visual quality 'Are there opportunities to use existing rights of way?' 'To retain or create the overall character of yellowbark pine in open stands, the goal is RESPONSE As indicated above, the first priority to have 24 yellowbark pines of 300 years in locating utility lines is to use existing corridors; and of 30 inches diameter or greater per second priority is expansion of an existing corridor. acre'.n

RESPONSE There would be a lack of visual variety COMMENT: 'There are significant problems in d every acre of Retention was occupied only by both the definition of visual management goals in old-growth trees. The natural character of pon- the Proposed Plan and the application of visual derosa pine stands includes several size classes. guidelines in the field,' a reader asserted. Large diameter ponderosa pine is an essential RESPONSE The standards/guidelines on visual element in the characteristic landscape but we do quality management have been expanded and not agree that every acre should be managed to clarified. They now require that uneven-aged timber contain a prescribed number Standards/ management be employed in pondorosa pine Guidelines have been changed in the Plan to stands whenever circumstances permit. Monitoring place a greater emphasis on uneven-aged manage- will improve compliance with visual management ment. This halvest method provides for the goals. The visual management objectives for every long-term maintenance of trees as large as 30 Management Area are now shown on a map. inches in diameter as well as smaller trees The actual number of larger trees which are retained will be based on both visual and biological needs. COMMENT A reviewer said the following passage The minimum standard of five large diameter is too general for either Retention or Partial trees per acre has been deleted in the Plan Retention.

"Insect and disease activity or catastrophic COMMENT 'Increasing the growth rate of young occurrences may require short-term devia- trees should not supersede the overall goal of the tion from visual objectives ' yellowbark pines in Retention areas," a reviewer de cI a r e d RESPONSE Standards/Guidelines have been rewritten to clarify this matter. Short-term deviation RESPONSE. The new standards/guidelines specify from visual objectives are permitted only where thinning-out the smaller trees to promote the health insect and disease activity would result in the loss and vigor of the larger trees. Thinning for a variety of large amounts of vegetation. For example, d of size-classes is called for in uneven-aged mountain pine beetle activity is threatening large management activities acreages of trees adjacent to a major recreation road, clearcutting may be the only silviculturally acceptable treatment to prevent a catastrophic COMMENT' One reader declared that the reference loss. On the other hand, a mistletoe infestation in to rotation age and number of trees left should be large, overstory ponderosa pine is not considered dropped in the discussion of mixed conifer catastrophic: the removal of these larger trees foreground categories. would not be warranted. RESPONSE Standards/Guidelines have been rewritten to better describe a 'desired condition" COMMENT. A respondent suggested this change: for these stands in terms of the numbers of trees 'The specific guidelines for ponderosa pine in and their sizes. This changes the emphasis from

Appendix J - 93 Appendix J Alternatives, Data Analysis, & Planning Process

timber production to a more visually oriented classified as Retention Middleground The percent- objective. age of a viewshed in 'a disturbed condition" has been eliminated because partial-cut management activities will be spread over many acres. There COMMENT There should be a difference between will be very little, iany, visual disturbance when Middleground Retention and Middleground Partial these areas are viewed as middleground. Retention,' a respondent observed

RESPONSE: The distinction was unnecessary in COMMENT 'Visual Quality Objectives should not the DElS because no land was classified as only be considered from viewpoints looking up to Middleground Retention. In the Final Forest Plan, the Forest,' said a reader, 'but also viewpoints several areas were allocated to Scenic Views with looking down from the Forest, and in particular this Visual Quality Objective and a distinction has from Wilderness ' been made RESPONSE: The original visual quality inventory considered viewpoints where relatively large COMMENT Only 10 percent of land in Partial Retention areas may be disturbed at any given numbers of recreationists were 'invited" to higher time A reviewer said there should be a requirement elevation locations This included Black Butte, that this disturbance be widely distributed. Paulina Peak and Lava Butte, which are obviously sensitive viewer locations Some major trails in RESPONSE Whenever possible, uneven-aged Wildernesses are also sensitive. Except for some timber management will be practiced in Partial lands viewed from Black Butte, however, the Plan Retention areas. This will result in a widely does not establish Visual Quality Objectives based distributed treatment which will not visually domi- on this perspective nate the landscape. The '10 percent in a disturbed condition' guideline will only apply where uneven- aged management is not practical. The need for Timber Management a distribution of disturbance is now reflected in the standardslguidelines. Departure/Non-Declining Sustained- Yield COMMENT The Partial Retention Visual Quality Objective was proposed along the scenic portions COMMENT Many respondents were opposed to of Black Butte, Odd1 Butte, and Green Ridge departure from non-decling flow sustained yield for lodgepole pine or any other species Some RESPONSE: These areas are in a Scenic Views thought it would harvest too much ponderosa Management Area and have a Partial Retention or pine Road construction called for in the departure Rf?tC2ntJOn Visual Quality Objective. alternative, reductions in wildlife habitat, and increases in management costs were mentioned as concerns Several readers objected to what COMMENT No more than 3 percent of Retention they considered a violation of the principle of Middleground areas which can be seen should long-term sustained yield. be in a disturbed condition, a reader declared, adding. .The emphasis should be on creating RESPONSE The Preferred Alternative in this FEE stands of 300 year old yellowbark pine stands of no longer calls for departure 30 inches or greater. No portions of clearcuts should be visible COMMENT Departure is all right if it ISnecessary RESPONSE: The new standards/guidelines pre- to remove timber in areas that would lose value scribe uneven-aged timber management in areas by delaying harvest.

Appendix J - 94 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE: The initial objective of the departure In all other management areas, uneven-aged alternative was to harvest green lodgepole pine management will be given equal consideration before it was killed by the mountain pine beetle. with other silvicultural methods It will be the Since most of the lodgepole pine is now dead, preferred method for managing mixed conifer however, this situation is best dealt with by stands but topography and insect and disease salvaging it as rapidly as market conditions will problems are expected to limit its application to allow. The effort will be to utilize the material before approximately 50 percent of this timber. it deteriorates and to reduce the fire hazard. This strategy does not require a departure alternative. COMMENT 'Are you removing the shelter cut barrier around Black Butte Ranch?" a reviewer COMMENT "Manage mountain hemlock better,' a asked. respondent declared. RESPONSE: Most of these lands are in the General RESPONSE Mountain hemlock management Forest Management Area but some of the shelter- does need more attention. Management experi- wood trees may be retained to accelerate an ence, particularly that having to do with regenera- eventual conversion to uneven-aged management. tion, is limited, and demand for the species has been slight. Mature mountain hemlock is normally quite defective, making it unattractive for manufac- COMMENT 'Do not harvest on steep slopes, ture. within 300 feet of Class I streams, or 150 feet of a Class II streams,' a reviewer declared

Timber Harvest Methods RESPONSE Standards/Guidelines for soil protec- tion and riparian management require special COMMENT. One of the largest number of respons- measures in these areas Cable or helicopter es came from people opposed to clearcut timber logging are commonly employed on steep slopes. harvesting. Many objected to clearcutting in stands Steepness, however, is only one factor considered of ponderosa pine, some in mixed conifer, and a when determining whether harvest can occur on few rejected the method entirely. Reasons included a hillside. Soil characteristics, economic feasibility, the charge that it reduces biological diversity, potential damage to residual vegetation, and creates a monoculture, destroys wildlife habitat, visual impacts are also evaluated and seriously reduces visual quality. All Class I and II streams on the Forest are in While these expressions are essentially opinions, Streamside Management Units (SMUs) Many which were summerized at the begining of this have been included in the nation's Wild and Scenic appendixand considered in the Record of Decision, River System Harvesting timber is not a manage- the issue will also be discussed here. This is ment objective in these areas. Standards/ because it is a major controversy and accounts Guidelines for riparian areas and Streamside for one of the most significant differences between Management Units describe the circumstances in the DEE and FEIS. which limited tree removal can occur.

RESPONSE. Uneven-aged management has been adopted as the preferred method of managing COMMENT: A reviewer declared that the descrip- ponderosa pine stands in the General Forest and tion of small clearcut units and multiple thinnings Scenic Views Management Areas, more than half cast doubt on the assertion, in Appendix I of the of the Forest. It is expected that 70 percent of DEE, that even-aged management requires less stands in these areas will be harvested by this roads and fewer entries than uneven-age manage- method. ment

Appendix J - 95 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE There are clearly more entries in than 30 percent of an analysis area be harvested uneven-aged management, once every 10 to 20 in any one decade 'to achieve diversity objectives.a years, but the difference in roading is probably negligible. RESPONSE. The 58 percent per decade projection is neither an oblective or guideline. When the Forest's goal was to rapidly harvest beetle killed Conversion Ratio lodgepole pine, a study determined that 58 percent of an area could be harvested within Region Six COMMENT 'Why does the Forest Service use dispersal guidelines if units were separated by a cubic feet to calculate Culmination of Mean Annual 220 foot leave strip. (This only applies on land Increment (CMAI) and board feet to calculate with slopes of less than 30 percent.) As indicated Allowable Sale Quantity (ASQ)?,' a respondent in many portions of the FEE, the Forest's objective asked. has changed Very few, if any, analysis areas are expected to have 58 percent timber removal in RESPONSE Both CMAI and ASQ are calculated any decade. in cubic feet because this is a more accurate method ASQ is subsequently converted to board StandardslGuidelines for biological diveristy, feet to accommodate the more traditional measure Chapter 4 of the Final Forest Plan, include for timber used by the Forest Service and the provisions for achieving diversity objectives. timber industry. Timber Stand Improvement

Timber Harvest Levels COMMENT: Thinning should be discontinued, a reader asserted. 'It negatively affects the Culmina- COMMENT The potential yield for the existing tion of Mean Annual Increment (CMAI), is expensive, timber management plan is 219.2 MMBF annually and increases cumulative effects from ground The 'current direction' alternative the DEE lists in disturbance.' chargeable timber volume as 190 MMBF. This 29 MMBF under-statement the no-action alternative of RESPONSE. Thinning extends CMAI, produces distorts the comparison with other alternatives. larger trees, retains proportionately larger tree crowns, reduces mortality risk from insects and RESPONSE: The DEE was suplemented to add a disease, develops earlier old-growth tree character- No Change Alternative, which called for a continua- istics, produces greater quantities of harvestable tion of the 219 MMBF harvest level. This Alternative material, and improves the quality and accessibility is evaluated in the FEIS. of forage Cumulative effects from ground disturb- ance, when carefully controlled, are not serious enough to offset these advantages. Diversity

COMMENT: A reviewer was concerned about COMMENT. 'It is a waste to take out 3 to 4 inch provisions for the dispersal of harvest units set trees along with larger trees and then leave them forth in the DElS This passage was quoted. lie; a reviewer declared

Up to 58 percent of an analysis area can RESPONSE. Thinned trees of this size have little be harvest in a decade and still leave a or no commercial value. They are not attractive to 220 foot leave strip between units. firewood gatherers, particularly the more resinous ponderosa pine and true fir Left to dry and machine 'IS this an objective, guideline, or statement of crushed or cut up into smaller pieces, they have fact?,' the reader asked, proposing that no more a positive affect upon soil fertility and nutrient

Appendix J - 96 Appendix J Alternatives, Data Analysis, & Planning Process

transfer. They also enhance habitat for smaller RESPONSE The Forest now charges a $7/MBF wildlife species, which are important elements in minimum rate for lodgepole pine timber sales, the the natural food chain. same as for firewood. This is intended to cover the costs for program administration, road mainte- Fire hazard is temporarily increased by this practice nance, brush disposal, and reforestation This and insect attacks upon this material occasionally rate may change with increased costs or increased extends into the surrounding live trees. Both of demands, extensive program abuses, or new these problems, however, are short-term risks. economic factors.

Lodgepole Pine COMMENT: A number of correspondents asked that the firewood program be taken out of the Forest's Allowable Sale Quantity (ASQ). COMMENT: A reviewer questioned the accelerated harvest of lodge pole pine called for the Preferred in RESPONSE: The inventory used to develop the Alternative 'What If there is no market?' DElS and Proposed Forest Plan was completed priorto the Mountain Pine beetle reaching epidemic RESPONSE The departure harvest schedule levels. Also, an epidemic infestation was not calling for an accelerated removal of lodgepole projected in the yield tables Therefor, the dead pine has been eliminated in the Final Plan Dead lodgepole presently being cut for firewood was lodgepole pine will be sold at a rate that reflects included in the Allowable Sale Quantity (ASQ) market demand. calculations. shown in the DEE and Proposed Forest Plan. However, when the forest stands were reinventoried, dead trees were tallied sepa- COMMENT Noting that wildlife needs all age rately and not included as part of the standing classes of lodgepole pine, a reviewer declared inventory. As growth projections were made for 'Proposed liquidation is a serious ecological the yield tables, an estimate of future mortality blunder 'Selective cutting was suggested to reduce was also made. Therefor the existing and projected the risk of beetle epidemics. mortality was not included in the ASQ calculations shown in the Final Forest Plan Since firewood will RESPONSE: The rate of lodgepole harvest has only be taken from dead trees, it will not now be been reduced in the FElS (see above response). considered part of the AS0 'Liquidation' of the species was never intended. It is recognized that wildlife need lodgepole of all ages, living and dead. Expanses of beetle killed COMMENT The State Department of Environmen- lodgepole, however, is of little value to wildlife. tal Quality was one of the respondents Objecting Shelterwood harvesting is being employed to to the cost of firewood "It is our understanding reduce both vulnerability to bark beetles and the that wood cutting permit fees do not fully reflect cost of reforestation. the market value of the fiber or the cost to the Forest Service to provide the firewood to the public This subsidy of firewood makes firewood appear Firewood to be more economical energy source than it really is. If one considers the public health costs COMMENT: Many readers commented on the associated with woodsmoke in urban areas of cost of firewood. Some consider it too high, others Oregon, it clearly IS not appropriate to encourage too low. The fact that firewood gatherers have to the residential use of firewood through subsidy." pay more for firewood than timber sale contractors The DEQ recommended increasing firewood do for the same material was questioned; i e. cutting permit fees and contributing this addition $7/MBF for firewood versus $I/MBF for timber revenue to local agencies which are attempting to sales. mitigate the woodsmoke problem.

Appendix J - 97 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE On the Deschutes NF, revenue from old) ponderosa pine. A major thinning program is firewood cutting permits greatly helps defray the underway in these areas to improve tree vigor, cost of administering the program. It is illegal for which should make them less vulnerable to the the Forest Service to dispense National Forest beetles revenues to local agencies other than by means of the payments to counties from timber harvest receipts. A program such as that suggested by COMMENT 'How will the various alternatives the DEQ would require new legislation. affect potential future insect and disease prob- lems7; a respondent inquired

Reforestation RESPONSE All Alternatives include provisions for responding to catastrophic insect or disease COMMENT 'Use natural regeneration when conditions. In terms of the ability to contend with possible,' a reviewer declared. future insect and disease problems, they are indistinguishable. RESPONSE Natural regeneration is the predomi- nate reforestation method used with lodgepole pine, true firs, and mountain hemlock It is not as COMMENT 'Your definition of 'catastrophic event' dependable with ponderosa pine. Because of does not comply with NFMA; a reader declared, inconsistent cone production, species replacement adding: 'poor economic criteria' were used cannot always be assumed. Natural regeneration will be common, however, in ponderosa stands RESPONSE. The National Forest Management where uneven-aged management occurs Act (NFMA) does not define 'catastrophic condi- tions'. On this Forest, certain types of stands are considered to be in a catastrophic condition if COMMENT 'Artiicial regeneration drives up the more than 30 percent of the trees have been cost of timber sales,' according to a respondent, killed or if the stand is growing at less than 70 who added: 'Planting ponderosa pine is a waste percent of its normal rate. These criteria are not of money and reduces genetic diversity.' economic: they are a measure of the impact of conditions on the sustained yield of timber on the RESPONSE In some areas planting is the only Forest way reforestation can be assured. Although It is more costly than natural regeneration, planting ponderosa pine has consistently been shown to Tree Improvement result in a positive net worth. The seed procurement program retains genetic diversmy for given seed COMMENT 'The Forest should justify rejection of zones the conservative 10 percent genetic gain figure,O a reviewer declared, 'especially in light of the genetic improvement efforts occurring on the Insect and Disease Deschutes today.'

COMMENT A reader was concerned about the RESPONSE. Increases in growth attributable to impact of the mountain pine beetle epidemic on the genetic improvement program are 8.67 percent ponderosa pine. That is present condition of old for ponderosa pine, 1 73 percent for lodgepole growth pine?' pine, and 8 67 for mixed conifer The small gain for lodgepole pine is due to the fact that 80 percent RESPONSE Increasing numbers of pondorasa of the lodgepole pine stands will be regenerated pine, including old-growth, have been killed by naturally by seed tree or shelterwood cutting. The beetles in recent years. Beetles are also moving 8 67 gain for ponderosa pine and mixed conifer is into large stands of young (approximately 65 year less than the 10 percent projection in the Douglas-fir

Appendlx J - 98 Appendix J Alternatives, Data Analysis, & Planning Process region because of the relative recent establishment Wildlife and Fish Management of the program on this Forest. Since seed orchards will not be producing seedlings for 20 to 40 years, Fisheries increases in growth can only be claimed for, at best, 13 of the next 15 decades. COMMENT: A number of respondents felt that insufficient attention was paid to fish and fish COMMENT Another challenge to the less that 10 habitat in the DEIS. The longstanding fame of the percent projection was based on the claim that Deschutes NF fishery was mentioned. "We found gains from using phenotypically selected 'plus' no evidence in the Plan for projects to exclude tree seeds would achieve a greater than 8.7 percent caltle from important riparian areas of the Forest,' increase in growth. one noted.

RESPONSE 'Plus' tree seed collection is inade- RESPONSE: Discussion of the fishery has been A fish habitat quate to meet the needs of reforestation. Most of considerably expanded in the FElS inventory is being conducted, a habitat improve- the Forest's tree seed supply is derived from ment program is being developed and new general seed collections. standards/guidelines for riparian areas added

COMMENT One reader thought the prolected COMMENT A reviewer stressed the importance increase was too high. .The yield estimate for of cooperation with other agencies in fish stocking, genetics should be reduced because we have trapping, and providing winter range for mule planted thousands of acres with uncertlfied trees deer and because we do not have any genetic informa- tion for establishing our present breeding zones. RESPONSE The Forest coordinates with Oregon Department of Fish and Wildlife on fish stocking RESPONSE. Forest silviculturalists are convinced and has discussed beaver trapping in areas where the reduction from 10 percent sufficiently takes beaver is scarce. The Forest, the Bureau of Land these circumstances into account Management, and ODFW coordinate in providing winter graze for deer.

Use of Fertilizer Old Growth COMMENT 'Fertilizer should be used as an option in some timber prescriptions,' said a respondent. COMMENT' A number of respondents proposed 'Data show 50 percent growth increases in specific portions of the Forest where they believe lodgepole and ponderosa pine and that it is not old-growth should remain any more expensive than precommerical thinning RESPONSE The distribution and specific locations RESPONSE Fertilization is not considered a useful of Old-Growth Management Areas were based silvicultural tool on this Forest because of porous upon the habitat needs of dependent wildlife soils and the dry climate. In any case, It would species The size of the stands and their distribution not be a substitute for precommercial thinning were both major considerations. Other site-specific The purpose of thinning is not to increase total areas will be managed according to other empha- fiber production but to grow large trees as rapidly sis. Old growth will be retained in some and will as possible. not in others

Appendix J - 99 Appendix J Alternatives, Data Analysis, & Planning Process

COMMENT A reviewer wondered now more old tations, was imprecise and definitions of old growth growth could be retained in Alternative H than vary. Alternative G when the harvest level in the former is higher COMMENT A reviewer said "specific unique RESPONSE: Alternative G will provide more old qualities, such as ecotype representations." should growth than Alternative H. have been considered

RESPONSE: Old growth areas were mapped on COMMENT 'Can damage or harassment from the Forest based on ecoclass diversity during the off-highway vehicles in old growth be proven?', a late 1970s The Draft Forest Plan assigned Old respondent asked. Growth acres by constraining the Forplan Model to set aside certain percentages of each working RESPONSE Research has shown that old growth group for each alternative. These acres were not associated species like the northern goshawk are site specific In the Final, Foreplan deals with site veiy sensitive to human disturbance, especially specific Old Growth Management Areas that are during the nesting period. based on the original old growth mapping

COMMENT Plan has no map showing old-growth COMMENT One reader objected to the wording allocations. of the Old Growth goal. RESPONSE. The FElS contains a map of Old- Growth Management Areas. RESPONSE The goal statement has been revised

COMMENT' A reader asked these two questions: COMMENT Deer and elk will have inadequate '(1) What proportion of Old-Growth Management hiding and thermal cover because of the harvest Areas will actually be old growth at any one time? of old growth, a reviewer declared (2) What proportion is currently old growth?' Another wished to known whether these areas will RESPONSE Hiding and thermal cover are provided be managed or left undisturbed. for deer and elk not only in old growth areas, but also in timber stands managed to meet big game RESPONSE: Standards/Guidelines preclude timber objectives. Standards/Guidelines will ensure that management in Old-Growth Management Areas hiding cover is available both in deer management until research indicates that the structure and areas and General Forest and thermal cover is function of old-growth forest can be artificially available in deer habitat created or maintained. With the exception of the Lava Pass and Glaze Old-Growth Management Areas, there would be no tree removal during this COMMENT 'There are no old-growth stands planning period. (The option to remove trees m designated outside of commercial forest land," a these two areas was retained to permit adjustments reader commented, 'so there will be inadequate in species composition ) old growth distribution to maintain old-growth dependent species.' It is estimated that approximately 74 percent of the land area within Old-Growth Management RESPONSE. Old growth isn't designated in areas Areas is currently mature or overmature forest. such as Wilderness and Dispersed Recreation The proportion of 'old growth' within this mature/ because no timber harvest will occur there Thus, overmature condition is difficult to establish. The old-growth stands will occur outside of as well as estimate, derived from aerial photography interpre- within commercial timber lands

Appendix J - 100 Appendix J Alternatives, Data Analysis, & Planning Process

COMMENT: 'Preserve ponderosa pine in areas COMMENT: The comparisons of the amount of with no roads at present,' a reviewer said. old growth maintained by alternative is misleading

RESPONSE During the period covered by this RESPONSE. The plan only displays areas specifi- Forest Plan (IO to 15 years), timber harvest is not cally allocated to Old Growth Management They planned in areas which are currently unroaded provide the distribution and habitat requirements of mature/old-growth dependent wildlife species. Additional old growth is provided in a number of COMMENT This reader also doubted that old other allocations and the total for each alternative growth in 12 percent of the Forest would maintain is indicated in Chapter 2 of the FEIS, Comparison current populations of old-growth dependent of Alternatives. species

RESPONSE: The Forest is required to provide for Wildlife (General) "viable populations' of wildlife species which, in some instances, could be less than current populations. COMMENT: 'The indicator species concept is not a good indicator of the health of the Forest's COMMENT "No provision IS made for retention of habitat types," a reviewer said. old-growth habitat in areas which are logged,' a reader declared. RESPONSE: The indicator species concept was developed and mandated in regulations for RESPONSE The Preferred Alternative provides implementing the National Forest Management for stands of old growth that are located in areas Act. that will be managed for timber production.

COMMENT A reader proposed greater reliance COMMENT One reader asked for the data which on techniques which can mitigate the impact of indicates that the old-growth program will be roads on wildlife adequate to maintain a diverse old-growth commu- nity structure and assorted old-growth dependent RESPONSE: Many of these techniques are being plant and animal species. incorporated into the Forest travel plans and District road management planning. Vehicular harassment RESPONSE No scientific data is available. Plant is one of the factors taken into account in determin- and animal diversity can be maintained in old- ing whether an area can provide habitat for deer growth areas in the best professional judgement and elk. A reduction of open roads increases of wildlife biologists. Research in regards to this effectiveness. situation is in progress.

COMMENT There were a number of expressions COMMENT Habitat requirements of old-growth of concern about wildlife species not provided for dependent species are not indicated in the Draft by a specifically designated Management Area. EIS, a reviewer declared. Included were the goshawk, great grey owl, great horned owls, long-eared owl, cooper's hawk, RESPONSE Published data on wildlife habitat sharp-shinned hawk, red-tailed hawk, elk, antelope, relationships of species occurring on the Forest grouse, peregrine falcon, wolverine, great blue are available (See Wildlife Habitat Relationships of heron, wild turkey, pine marten, white-headed South Central Oregon, 1976 and Wildlife Habitats woodpeckers, 3-toed woodpeckers, and in Managed Forests, the Blue Mountains of Oregon Townsend's big-eared and the silver-haired bats and Washington, 1979). One reader asked for a map showing the distribu-

Appendix J - 101 Appendix J Alternatives, Data Analysis, & Planning Process

tion of black bear, antelope, and mountain lions the 60 percent level where mountain pine beetle and an assessment of the impact of timber harvest killed trees have fallen down, until regeneration on them. can provide snags

RESPONSE The indicator species approach to If a wolverine sighting is determined to be authentic, wildlife management uses a single species with an environmental analysis will be conducted to particular habitat requirements to stand for other decide whetherthe site is essential habitat requiring species with the same requirements All are special designation. accommodated when this habitat is preserved or created. Most of the species listed above have Habitat forthe northern waterthrush will be provided the same requirements as one or another of the by riparian area standards/guidelines, which have indicators. Management Areas providing for an been revised and expanded in the FEiS indicator species is, in fact, a Management Area for all associated species. There are also Standards/Guidelines afford protection to Standards/Guidelines which address the special Townsend's big-eared bats by: (1) restricting needs of individual species unacceptable human disturbance during winter periods (2) restricting public knowledge of these Some habitat for great grey owls will occur in locations; (3) protecting forest vegetation at the lodgepole pine stands where there are meadows. entrance of important caves; and (4) habitat Measures providing for goshawks were modified enhancement. The sdver-hared bat is a cavity in the FElS to increase suitable nesting habitat. A nester and will be maintained by the Forest's significant decrease in the goshawk population is snag policy expected, however, when trees killed by the bark beetle fall. Information about the distribution of bears, ante- lope, and mountain lions is available at Ranger Goshawk, Cooper's hawk, and sharp-shinned District offices. Timber harvest has no effect on hawk nest sites and pine marten will be protected antelope because they occupy treeless portions within Management Areas emphasizing Old of the Forest. Its effect on lions ISindirect. They Growth, Wilderness, Dispersed Recreation, Re- prey on mule deer, which can benefit from timber search Natural Areas, Spotted Owls, the Bend harvest. Bears can be adversely affected when Municipal Watershed, Winter Recreation, the berly growing shrubs are replaced by grasses by Oregon Cascades Recreation Area, and wildlife timber harvest and hiding cover is removed. management There are no standardslguidelines for great horned owls, and long-eared owls. Cavity nesting hawks and owls will be maintained at 60 COMMENT 'Funding for timber harvest should percent of maximum population potential. be contingent upon funding for wildlife habitat improvement;said a reviewer, .SO if timber harvests Standards/Guidelines for elk management were increase then wildlife habitat projects also increase significantly expanded The requirements of other proportionately game species, such as antelope, wild turkey, and grouse, will be taken into account in project RESPONSE. The Forest is developing a Wildlife planning when they are found in a project area. Funding Program Action Plan, which is not tied to the timber harvest associated K-V funding It will When the nesting sites of peregrine falcons, redtail use appropriated funds for habitat improvement, hawk, and great gray owls are found they will be particularly in lodgepole pine areas maintained The vegetative character of great blue herons rookeries and their nest trees will be protected In managed forestland, snags will be COMMENT: The Forest should make every effort maintained to provide for 60 percent of the potential to determine the existing prey base for eagles population levels of woodpeckers Naturally and the competition between eagles and osprey occuring snags may diminish in numbers below on this prey base,' a commentator submitted

Appendix J - 102 Appendix J Alternatives, Data Analysis, i? Planning Process

RESPONSE: Recent studies on the Forest have COMMENT The decrease in osprey habitat in the determined food habits of bald eagles and ospreys Preferred Alternative was not acceptable to several and the level of competition between the two reviewers. 'Every effort should be made to maintain species. or even increase the population," said one

RESPONSE The Preferred Alternative now pro- COMMENT: The Forest Service should address vides for protection of all existing nest sites. Many deer migration corridors between summer and nests are lost to natural causes, however, and an winter ranges in future land management plans, a artificial nesting structure program may be required. reader stated.

RESPONSE: This is a sound suggestion and COMMENT: The discussion of wildlife in General such studies will be conducted. Forest is confined to deer and elk, a respondent complained. "Even General Forest should be managed for multiple use " COMMENT Evaluation and report periods called for in the monitoring program for the bald eagle, RESPONSE. In the Preferred Alternative, habitat spotted owl, osprey, northern goshawk, and for species using dead and downed trees will be woodpeckers are too far apart, according to a provided in General Forest. Osprey, golden eagle, respondent Dangerous population trends may and great gray owl nest sites will be maintained not be documented until they have reached a where they are found. Great blue heron rookeries critical level. will be protected. There are provisions to manage lodgepole pine, mixed conifer, or mountain hemlock RESPONSE The monitoring program was revised forest to provide interconnecting forested corridors and expanded in the FEIS. Monitoring worksheets for pine marten. Caves where Townsend's big- now provide the following evaluation and report eared bats occur will be protected Fuel concentra- periods in the Preferred Alternative: tions will remain within many logged areas to provide habitat components for wildlife 1. Northern goshawk - Examine 5 percent of habitat areas every year to sample for maintenance of habitat suitability. Report annually. Review all COMMENT "The Deschutes National Forest has project plans to determine if standards/guidelines not provided an adequate program for nongame have been applied appropriately. wildlife species,' a correspondent said.

2. Bald eagle - Annual interagency survey of nest RESPONSE. Habitat will be maintained for viable sites. Review of project plan to ensure compliance populations of all vertebrate species in the Forest. with standards/guidelines Field survey of potential sites. Review of trends every five years COMMENT A need for inventories of wildlife 3. Osprey -Annual review of project plans to species and their habitat requirements was determine if standards/guidelines are being expressed. implemented Population sample every two years Review of trends every five years RESPONSE: Inventories and studies of wildlife habitat relationships of vertebrate species on the 4. Spotted owl - Population survey every year. Forest are available at the Forest Supervisors Nesting capacity every two years. Review of trends Office in Bend, Oregon every five years.

5. Three-toed woodpeckers - Population sample COMMENT The Forest Service claim that timber every other year. Review of trends every ten years. management will impact osprey is unsupported, a

Appendix J - 103

~ Appendix J Alternatives, Data Analysis, & Planning Process

respondent said, adding 'fish prey base is limiting. RESPONSE Standards/Guidelines include provi- not nest sites because platforms can be provided.' sions for deer thermal cover. Timber harvest will create forage. RESPONSE: An artificial nesting structure program may be required to provide nest sites. The Forest COMMENT 'Elk and deer must be provided with Service works cooperatively with the State on habitat areas that will be free of logging activities,' trash fish control and we can develop guidelines a respondent declared. for prey base retention. RESPONSE: Habitat for elk and deer will be available in both areas where harvest occurs and BIG GAME lands where it will not Timber harvest creates forage for big game. COMMENT: A reader was concerned about a herd of approximately 60 elk that winters in the COMMENT A reader was not satisfied with the Benham Falls area. deer population projected in the Preferred Alterna- tive and said Tradeoffs between resources need RESPONSE: These elk will be managed according to be recognized.' to standards/guidelines established in Chapter 4 of the Forest Plan. The extent and importance of RESPONSE: The Oregon Department of Fish and the Ryan Ranch elk range will be determined Wildlife has developed population objectives for through the interdisciplinary process at the project deer on the Forest and the Forest Service works level. The Eastside Elk Habitat Capability Model toward providing habitat to meet them. This effort will be used. involves. 1) manipulation of timber stands for thermal and hiding cover; 2) use of prescribed fire and mechanical methods to improve forage COMMENT: Wildlife direction for General Forest condition; and 3) management of roads to increase emphasizes hiding cover, a reviewer observed. habitat effectiveness Tradeoffs between big game "Forage and thermal cover are just as important, d and other resources are carefully evaluated. not more important, than hiding cover.'

Appendix J - 104 Appendix J Alternatives, Data Analysis, & Planning Process

COMMENT The State suggested that the Forest Winter Range use a five year average population for deer instead of the 1984 population. COMMENT "Crown closure should be more than 40 percent," said a reader, who believes that 70 RESPONSE This suggestion was accepted. to 80 percent is necessary to provide protection from winter weather and snow This cover IS elemental for survival.' COMMENT 'It seems imprudent to analyze the elk situation in the Deschutes without coordinating RESPONSE. The 70 to 80 percent crown closure the elk management plan in the Willamette National is optimal for winter range It is also rare, even in Forest, where most of our elk winter,' a reviewer portions of this Forest which have not been declared. Planning for elk should be coordinated managed. Implementation of the Preferred Alterna- with the Willamette, Ochoco, Winema, and Fremont tive is expected to provide an average of 40 percent, National Forests. which means there will be more in some portions of the winter range. RESPONSE Coordination is occuring now. We are jointly monitoring elk population distribution and habitat use with radio-telemetered animals. COMMENT "Alternatives vary significantly on Our population Objective is low enough that the carrying capacity for deer,u a reviewer observed influence of managment on adjacent Forests is "Are differences a resuit of harvesting on summer problably low. We are working together with ODFW range or habitat improvement on winter range?" and adjacent Forests on elk managment coordina- tion. Deschutes elk do not mix with Ochoco elk. RESPONSE: Difference in carrying capacity are Umpqua NF elk do mix with the Deschutes group primarily the result of harvesting on summer range, and are included in the coordination effort along although winter range harvesting can have some with the Willamette. Winema and Fremont Forests. effect. Harvesting on winter range IS limited by the need to retain thermal cover

COMMENT: Several hunting groups were unsatis- fied with provisions for providing elk habitat. The COMMENT Thermal cover on deer winter range Oregon Hunting Association said a herd of 2,500 should be 50 percent not 40 percent Timber elk could be accommodated. production is too high in deer management areas If cover cannot be maintained at 50 percent the RESPONSE. Standards/Guidelines for elk manage- area should not be included in deer management ment have been substantially revised, reflecting areas. Visual management in deer areas should public reaction to the DEE It is expected that the meet deer habitat requirement. Preferred Alternative will eventually support an elk population of 1,500 animals. RESPONSE: Much of the deer winter range is dominated by shrubs (sagebrush and bitterbrush). These areas will never support a stand of conifers COMMENT Conflict between roads and wildlife is which could qualify under a strict definition of a major issue, according to the State Department thermal cover. Where these stands do exist, the of Fish and Wildlife. A comprehensive road Forest will manage them to retain thermal cover in management plan was requested. an optimal mosaic with forage areas Very little timber harvest is projected in winter range RESPONSE: New standards/guidelines impose road density requirements to reduce conflict In General Forest, deer habitat management is Deer and elk habitat simulation models, which will part of timber management Timber production soon be available, will permit more accurate and maintenance of deer habitat quality require assessment of impacts of roads on elk habitat. compromises. Habitat improvement can be com-

Appendix J - 105 Appendix J Alternatives, Data Analysis, & Planning Process

patible with visual quality objectives wbh few overmature forest. However, there is a threshhold modifications or by using vegetative screens. beyond which additional timber harvest diminishes diversity by removing the mature/overmature successional stages of forest The statement Wildlife Diversity referred to the first phase

COMMENT The diversity of both forest and Wildlife Habitat nonforest communities needs to be monitored, a respondent said. COMMENT 'No provision is made for retention of snags in areas which are logged,' a reader RESPONSE. The diverslty of vegetation on the declared. Forest will be monitored. Diversity is also protected by the monitoring of indicator species and sensitive RESPONSE Enough snags to provide habitat for plants and animals. 40 percent of the maximum population of cavity nesters will be retained in uneven-age management in the Preferred Alternative, and 60% or more in COMMENT U.S.C 1604(G)(3)(13) requires diver- other areas of the Forest sity of plant and animal communlties. 36 CFR 21 9.27(G) reductions in diversity may be prescribed only to meet multiple-use objectives All alternatives COMMENT "The plan should display effects of destroy large quantities of old growth. Alternative bald eagles and osprey management area prescrip- E reduces old growth by 24 percent which would tions on timber harvest,' a reader said. prevent Forest from meeting diversity criteria.

RESPONSE: The Regional minimum management RESPONSE: The effects of managing portions of requirements contain criteria required in selecting the Forest for wildlife are evaluated at several Old-growth Management Areas. These Regional stages in the planning process Since the eagle is criteria, which have been followed, emphasize an endangered species, tradeoffs associated with biological requirements needed to maintain its management are not negotiable and were not diversity. quantified There is general discussion of tradeoffs in Chapter 2 and Appendix B of the FEE

COMMENT 'Hardwoods and minor conifer species are not addressed in the plan,' a respondent COMMENT. The Oregon Department of Fish and said. Wildlife recommended leaving all dead and down logs in timber harvest area RESPONSE. Provisions for managing land in riparian areas have been expanded in the FEE. RESPONSE. In some areas it is possible to leave They call for the retention of hardwoods and minor all dead and down logs To reduce the potential conifer species. of catastrophic fire, however, the fuel loads in many harvest units must be reduced.

COMMENT This statement in the DElS was questioned 'The higher the harvest levels would Snag-Dependent Wildlife Species be in an alternative, the sooner diversity will occur:

RESPONSE The DElS statement is true as far as COMMENT A reviewer 'strongly disagreed" with b went Timber harvest will enhance ecosystem the 10 to 12 inch minimum size for cavity nester diversity in areas of predominatiy mature/ leave trees and proposed a 16 inch average.

Appendix J - 106 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE Minimum size of snags is based on Spotted Owl Management use needs of various cavity nesters. Larger snags are left when they are available. Green trees of the 10 to 12-inch size class will eventually grow COMMENT Forest management is inadequate to into the larger size and snags needed by some maintain habitat for the spotted ow/, according to cavily nesters. Standards/Guidelines requiring a respondent. cover for big game will also assist RESPONSE Nesting areas (at least 1,500 acres in size) for 14 pairs of spotted owls are provided in the Preferred Alternative There will be no timber COMMENT 'Sixty percent maximum population harvest in these areas during this planning period. potential of cavity nesters is inadequate because As more information is gained about spotted owls of past management practices,' a respondent and their habitat requirements, this program can declared. be modified.

RESPONSE: During the short term, the Forest may fall below the 60 percent level because of COMMENT 'Spotted owls are adaptable to conditions other than old growth," a reader past management measures. the long term, In asserted. replacement snags should make It possible to provide the appropriate habitat RESPONSE While instances of owls nesting in second growth stands have been observed, most scientists agree that an old-growth stand structure COMMENT A respondent asked for an inventoly is preferred. It reduces invasion by predators, of snag densities 'to determine which areas of the such as goshawks and great horned owls, provides Forest may be below the 60 percent level today.' thermal cover to buffer changes in air temperature, and supports a prey base for feeding RESPONSE: The new timber inventory recorded snags on the plots that were measured and this COMMENT The Forest projects some timber information could be extrapolated to various harvest in Spotted Owl Management Areas," a sub-components of the Forest. respondent said.

RESPONSE The possibility of managing larger Management Requirements (MRs) spotted owl areas with long rotations was consid- ered but not implemented. Timber harvest will not occur within spotted owl management areas COMMENT A reviewer questioned the imposition of management requirements which do not valy between alternatives. T & E Plants and Animals

RESPONSE: The management requirements were COMMENT A reviewer said it was unclear whether developed to comply with the National Forest Sensitive plant species are considered "Listed' in Management Act. The use of a single set of the Standards and Guidelines requirements was explained in a Supplement to the DEIS, which has been incorporated into this RESPONSE: They are and this is stated more document. clearly in the Final Forest Plan.

Appendix J - 107 Appendix J Alternatives, Data Analysis, & Planning Process

COMMENT 'The Deschutes National Forest should COMMENT Listing of sensitive plants in FElS develop species management guide for Botlychium should include the degree of "threat' designation pumicola detailing management needs and for each species, according to a reviewer. protection strategy,' a respondent declared. RESPONSE Information about the vulnerability of RESPONSE: This species management and sensitive plant species is available to project monitoring plan is in preparation. planners. Because circumstances and information frequently change, it was not included in the FElS COMMENT: StandarddGuidelines for Endangered, Threatened, or Sensitive plants are inadequate,' a reviewer said, adding 'onsite searches by a competent field biologist for ground-disturbing Public Comment/Opinions activity must be required rather than depending on office records and data only.' Another reviewer The following comments and responses are those asked for a comprehensive survey of the Forest's which were determined to be opinions not "provid- botany by trained botanists. ing factual information, professional opinion, or informed judgement germane to the action being RESPONSE Standards/Guidelines do require proposed (see Forest Service Handbook 1909.15) field-searches where these plants are known to If part of a comment was considered substantive, exist or are suspected Further surveys for sensitive the comment appears, ail or in part, in this and plants are planned to determine distribution of the preceeding section. species across the entire Forest. It is impractical to field-survey each prolect site if there is no reason to suspect the presence of sensitive species. Alternatives Standards/Guidelines now require bontanical surveys by trained botanists. COMMENT Alternative E - According to literature which I have read, the Forest Service preferred alternative would not be a program which would COMMENT. There should be consuitation with be conducive to strong business or future the state when projects may affect plant or animal species listed by the state, a reviewer declared. RESPONSE. Alternative E, as presented in the RESPONSE The Forest consults with the Oregon DEIS, was designed to maintain present harvest Department of Fish and Wildlife when any project levels of ponderosa pine and rapidly harvest the could affect species listed by the state. lodgepole pine which has been killed by the mountain pine beetle As such, it attempts to mitigate short term impacts on the local economy COMMENT A list of plant communities (eco- classes) and their present condition should be published in the FEE, a correspondent said COMMENT Alternative G -This alternative is the antithesis of Alternative C, and may also be the RESPONSE A list of plant communities (eco- result of FORPLAN checking out boundary condi- classes) is available in a separate Forest Service tions in its program This is a conservationist's publication Specific information concerning the dream, but with its impact on employment and current condition of each eco-class is not available low present net value, it is unrealistic to expect for upland forested eco-classes In general, this alternative to achieve consensus From a however, most are in late-seral or climax ecological purely selfish point of view, this would be my first condition. Riparian plant communities have recently choice. However, I recognize the need to have a been described in detail for Area 4 National Forests multiple-use forest that can be utilized giving by Kovalchik. equal weight to economic and recreational uses

Appendix J - 108 Appendix J Social and Economic Considerations

RESPONSE: Alternative G was designed to removing the dead and dying lodgepole pine emphasize amenity values while Alternative C was The most current timber inventory data indicates designed to emphasize market values. These two a significant reduction in available ponderosa alternatives represent the opposite ends of the pine volume on the Deschutes NF The final range of alternatives presented in the DEIS. preferred alternative addresses the issue of reduced ponderosa harvest levels and the insueing I believe areas designated for 'intensive recreation" effects, including returns to counties and 'dispersed recreation' should remain in the scheduled timber harvest category. The best way to ensure the long-term ability of these areas to COMMENT The economic gains from timber provide quality recreation is to manage them on a harvests must be weighed realistically against scheduled basis. resource and environmental costs. The forest should be managed for sustainability, biological diversity, and human well-being, not for the exclusive benefit of lumber companies. Recreation JobsIlncomelEconomics and wilderness will not support our economy

COMMENT. Concern was that there may have RESPONSE. The economic well being of the local been a significant cut in the economic value area is dependent upon all existing industries as ascribed to visitor daysltourism. Our local economy well as future growth and influx of new industry is becoming more linked to the recreation industry. The Structure of the local economy will change as Not only do our tourists spend a considerable supply and demand for all resources changes It amount of money in this area, the amount seems is necessary in the planning process to examine to be increasing every year. The rate of this increase the effects on all resource related sectors of the could be crucial in determining the present net economy. value of the forest in an undeveloped state. An impartial and accurate value of visitor days IS extremely important. It was felt that recreation COMMENT Looking back at the forest record values were consistently underestimated and that since 1980, the ponderosa pine availability at the if recreation values are refigured, a new array of market place has been short of (the amount) alternatives might result which depicted recreation proposed in the plan It has tended to run up the more favorably. price of stumpage as any shortage would If we allow this trend to continue we will be back at the It was felt that the USFS would have to change its price level that caused the buy-back procedure to management strategies for timber and the forest become necessary and an expensive added as a whole and that the current lifestyles of people burden to your timber management people involved in forest products production and export is artificially high (as based on timber alone) and RESPONSE: The FEE is based on the most recent can be maintained for only short periods. Some timber inventoly. The results indicate a significant felt that the long term economic future for Oregon reduction in the total volume of ponderosa pine lies in attracting tourists and recreational users, over estimates made in the past. It IS not biologically including those who are interested in wilderness. possible to sustain historical ponderosa sale levels indefinitely in the future. Adjustments can be made This concern was that the preferred alternative to ease the impact of the proposed reductions, altered the sale of lodgepole and ponderosa pine but inevitably, ponderosa pine supply is reduced. timber types such that the anticipated revenue to Klamath county will be greatly reduced COMMENT Many felt that the proposed forest RESPONSE An effort was made in the DEIS plan would result in a decrease in receipts and preferred alternative to maintain historical pon- thus a decrease in the amount of money returned derosa pine harvest levels while simultaneously to the counties for schools and roads and that if

Appenduc J - 109 Appendix J Social and Economic Considerations

the amount of money returned to the county concept. This concept has some validity but must decreased that personal properly taxes would be used properly or else the results derived may increase. be incorrect

RESPONSE. Any decrease in harvest levels or RESPONSE We agree that the willingness-to-pay decline in stumpage prices will have an effect on concept involves some uncertainty in valuing county receipts. The alternatives examined includ- resources. To help alleviate the kinds of problems ed ones which would increase as well as decrease that can arise from driving economic analysis with from present harvest levels. these values, criteria in addition to economics were employed in developing alternatives and selecting a preferred. COMMENT It was questioned rather local planning was consistent with greater emphasis on recreation in the proposed Deschutes National Forest plan COMMENT The Forest grows approximately 140 MMBF of ponderosa pine each year. If we have RESPONSE Proposed expansions in motel and an allowable cut of 120 million board feet each resorts are based on a steady and significant year, this will allow our forest to rebuild itself and increase in recreation/tourism over the next several grow yearly. This could be harvested year after years. year from now on. This is needed to sustain the economic growth of central Oregon. The allowable cut needs to be up around 120 MMBF, to be able Economics in General to provide adequate funds for schools and county improvements Last year, the Deschutes National COMMENT There was a concern that holding Forest paid $8.2 million dollars to counties and ponderosa harvest allotments down would drive school districts. $2 million went to our schools. the stumpage prices up again and that the We can’t afford a loss or a significant decrease in Deschutes National Forest might force the busi- these funds. Many believed that the Forest Service nesses associated with wood products into another should select an alternative which maintained the economic recession There was a desire to select jobs, receipts returned to the counties by the an alternative which had a positive economic selection of the Central Oregon Alternative. Local impact on our local area both in the short and governments will receive % less revenue in long run They stated that the forest products 5 5 terms of gross receipts under the Forest’s Preferred industry is still the backbone for employment and Alternative E compared to the current direction income locally. There was concern that reduced Alternative A. ponderosa pine levels would have a devastating effect on central Oregon economy Many wanted RESPONSE. The FElS has incorporated new the ponderosa pine levels to be maintained at timber inventory data which indicates that these 130 MMBF annually. levels of production are not sustainable over time RESPONSE An alternative has been examined Alternative C was developed to address these which local industry feels is desirable and commen- issues surate with the Forest’s ability to sustain that harvest level indefinitely. Refer to Chapter 2 of the FEE for a discussion of this alternative Receipts to the Forest Service/Federal Government

COMMENT. Non-priced outputs such as recreation. COMMENT. The commentor believed the Forest and wildlife are given values in the analysis. These Service must be a profitable operation One solution values are derived from the 1985 RPA Program would be to set your minimum bids at more realistic and are based upon the ‘willingness-to-pay’ rates and then to set the rates for timber to be

Appendix J - 110 Appendix J Social and Economic Considerations

removed on a yearly basis rather than on a and moved toward 'dominant use"? Conflicts in sale-by-sale basis. forest use seem to be stressed, not harvest strategies which maintain the current forest RESPONSE Revisions to timber sale contracts character. The concept of "multiple use" on all have been made in last few years to allow for forest types except of course the 11% in wilderness price adjustments and time frames to help deal should be practiced with changing market conditions. The majority of all timber sales sell for far more than the minimum RESPONSE. Multiple use is practiced on all forest bid rates. Appraised rates are established based types and in all management areas, however not on current values and estimated extraction costs. all areas have the capability to accommodate all Minimum rates come into play if the appraised resource, ie not all lands are suitable for timber value is negative or very low. The USFS will not production Management areas tend to emphasize Sell stumpage below those specified minimum certain uses but not to the exclusion of other rates. It is the competitive effect of the stumpage uses. Not all resources uses are mutually exclusive, market which influences prices above the appraised however some are. rates.

COMMENT At least for the foreseeable future, all COMMENT The greatest economic value for our federal agencies must face the grim reality of area lies in preserving the scenic, recreational funding cuts. Any alternative which is adopted and wildlife qualities of the area. These far exceed must be realistic as to the budget outlook. the short term exploitation of the forest for economic gain for a few corporation and government RESPONSE: Each Alternative considered in the interests. We must maintain the aesthetic and DElS meets laws and regulations governing the recreational qualities of the forest. Others think Forest Service and is attainable The Forest Service that in the long range a healthy utilization of the funding process requires the Forest to request main money source, the ponderosa pine, needs funds to finance the alternative selected to become to continue as the most important priority. Still the Forest Plan It is up to Congress and the others commented that all resource value of the Administration to make the decision on how much forest should be managed for the long run yield. or to what level to allocate funds. Other comments suggested that the recreational and industrial uses of the forest have coexisted together in relative harmony in the past and with Volunteers the properforest management practices thisshould continue into the future. COMMENT I believe we need to take advantage of these youth groups that want to get out and RESPONSE: The range of alternatwes developed help make new camping areas, trails and such. in the EIS are intended to look at these different We need to encourage these kids today for they views and uses of the National Forest are our leaders of tomorrow.

Promote volunteer assistance in helping to keep Forest Coordination Efforts the trails clean and clear, remembering of course, that the volunteers work for a living at other jobs COMMENT: There seems to be an effort to limit too, as well as try to clear trails. the uses allowed on the various parts of the forest A quick calculation shows that roughly 1/3 of the RESPONSE: The Deschutes does now and will forest is reserved from timber harvest with only continue to take advantage of volunteers and one alternative as low as 18%. Has the Forest youth groups to accomplish much needed work Service abandoned the concept of 'Multiple use' on the Forest.

Appendix J - 111 1 Appendix J Social and Economic Considerations

Riparian Management and thinning to remove the trees The Forest Service should attempt to recreate the large COMMENT: Alternative 'E' - Riparian Management. park-like stands of ponderosa pine The significance of streamside vegetation to wildlife can not be overstated Most big game biologists RESPONSE The Management direction, prescrip- stress the importance of riparian habitat as fawning tions, standards/guidelines can be found in the and calving areas for deer and elk Additionally, Deer Habitat Management Area in Chapter 4 of vltal habitat for both water fowl and non-game the Forest Plan species are contained here Oregon hunters association recommends that all perenial streams within the forest be managed to optimize riparian Road Management habitat. This may mean exclusion of logging activities in stream corridors, and exclusion of COMMENTS, Maintain adequate road access for grazing activitiy. recreation, fire protection, and pleasure driving for older citizens. RESPONSE. Standards/Guidelines for the manage- ment of riparian Habitat can be found in Chapter Utilize flexible road designs to meet Forest needs but minimize the impact on the land and wildlife 4 of the Forest Plan. Do not allow logging or utility companies to build roads with steep grades and poor locations that Fire and Air Quality cause erosion into streams

COMMENT Alternative 'E' -- I do not approve of Close more roads after logging use to protect the increase in management area 7 for two reasons wildlife and obliterate roads that were intended for 1) increasing burning, wood products use, and short-term use grazing would lead to a less diverse ecosystem, because some more valuable species (Le. game) Provide vegetative screening along main access are favored at the expense of others. 2) Oregon's roads air is not so pristine that we can afford to increase burning for the sake of forest 'management'. Obliterate roads within one mile of the wilderness boundary. RESPONSE. The Oregon Department of Fish and Wildlife developed population objectives for deer Build no more logging roads and build no more on the Forest The prescribed use of fire will be high speed cinder roads necessary to maintain diversity within the plant communities. Habitat management will be designed RESPONSE. All of the above concerns are valid to provide a mosaic of forested conditions (see objectives for road construction and road manage- Management Area 7, S&Gs) The Forest must ment Several years ago the Forest Service adopted comply with the Clean Air Act, the Oregon Clean new guidelines for establishing road design Air Implementation Plan, and local air quality standards by Service Level which assures the regulations. minimum standard to serve the resource will be constructed. Access to developed sites will be maintained for passenger cars Additional roads COMMENT Alternative "E' -- In terms of underburn- will be maintained open for high-clearance vehicles ing (along the eastern flanks of Ft Rock district), Where justified for soil erosion, economics, or The forest service should adopt an aggressive wildlife concerns: roads will be closed or obliterated. policy of removing younger stands of trees that Eventually, all roads on the permanent system will are growing up under the large ponderosa pine. have written management objectives based on a The forest service should examine both burning transportation planning analysis

Appendix J - 112 Appendix J Social and Economic Considerations

Todd Lake-Three Creeks Road between Eugene and Bend, it would become a bipass to the Highway 58 route during the snow-free COMMENT: The City of Sisters and some of the months. The impacts and benefits of this option Sisters community would like to have the road will be evaluated through an environmental review constructed to a two-lane paved standard to process before considering improvement to a provide a direct link with their community and the two-lane paved standard. Mt Bachelor ski area. Other respondents would prefer to have the road remain in its current Windlgo Pass Road condition which offers a 'primitive' driving experi- ence. The ODFW believes the elk and wolverine COMMENT A few comments were received habitats would be affected by high use Others indicating the desire to keep the existing standard would prefer to have the road closed. open for use.

RESPONSE: The impacts of constructing atw0-m RESPONSE: This road 1s one segment of an earlier pavedroad throughthis areawouldbe environmen- plan to build a Nofih-South cascade lakes Scenic tally significant. Considering this, the road will drive. Aformal plan no longer exists but the concept remain in a primitive condition with maintenance has been perpetuated to degree. activities limited to those required for high- clearance vehicle passage and erosion control. During this plan period the road will continue to be maintained at its current standard, for passenger Irish-Taylor Road cars at low soeed This road mav be imoroved as needed to handle traffic needs subject to required COMMENT. There was no public response for environmental reviews improvement of this road to a higher standard. Some respondents prefer to keep the road open to its current standard while others would prefer to have it closed. Recreation Management

RESPONSE The present condition of the road is Recreation (In General) causing some environmental impacts due to steep grades and traffic use. The road will receive spot COMMENT Special users generating unique improvements to correct the problems, but other- costs ought to accept realistic fees for such wise will be maintained at its current standard, privileges. A case in point is the nordic trail system which is for high-clearance vehicles at low speed. Not all nordic trails, but those more intensely developed such as the swampy lakes nordic area, Waldo Lake Road could be fee areas, and with fees should come a degree of privacy COMMENT: The comments received ranged from, "it was a mistake from the beginning - close it,' to RESPONSE: Congress is considering charging 'build a two-lane paved road so thousands of fees for recreational use The additional develop- recreationists do not have to drive an extra 50 ment for areas such as the Swampy Lakes Nordic miles to the High Cascades.' Other respondents Area has been in part due to volunteer work would prefer to maintain the existing standard Snow Park permits (State fee) defray the cost of maintaining the parking area Trails are available RESPONSE. Improving the Waldo Road to a for people seeking a more private experience two-lane standard would provide a shorter route for traffic traveling from the valley (Eugene) to the Cascade Lakes Highway (46). It would also provide COMMENT: There is not enough emphasis on the better access for recreationists in the Crane Prairie important role the National Forest will have in area to travel to Waldo Lake. However as the supporting the tourism segment of the future route became known to the public traveling economy. There is a concern that there has been

Appendix J - 113 Appendix J Social and Economic Considerations

too little emphasis in the plan for the the future of do not want the Deschutes to 'be one big parking tourism in Deschutes County and Central Oregon lot.' They favored more undeveloped opponunities and less developed recreation. Others favored RESPONSE: The treatment of recreation in the more recreation because the population is increas- FElS and Forest Plan has been considerably ing and because more is needed within an hour's expanded as a result of this and similar comments. drive of population centers

RESPONSE: The Plan recognizes that there will COMMENT Numerous respondents indicated be an increase demand for both developed and that recreation is 'Central Oregon's number one undeveloped recreational activities. It should be growth industry and an integral part of its economic made clear that just because an area is identified development plan'. Some indicated that recreation, as Intensive Recreation every acre will not be rather than timber, was the future of the Deschutes developed. Some recreation areas on the Forest National Forest One respondent pointed out that are already at peak recreational use or development recreation on the Forest was very important to the and additional development would only cause State of Oregon and even nationally. Most of environmental damage. There are, however, areas those who pointed out the importance of recreation that can accommodate additional recreational to the local economy advocated careful allocation development. The Forest is now working on of resources to reflect this relationship and wanted implementation plans and doing intensive recre- recreation levels to be maintained, if not increased ational planning to properly manage this develop- Others recognized the value of recreation but felt ment The Plan calls for development of trail and it will not replace the forest products industry as trailhead facilities in the Undeveloped Recreation our mainstay. They said 'don't increase recreation Management areas to accommodate the increase unless It can be done without reducing the timber harvest ' recreational activities that are expected to occur in these areas. RESPONSE The Plan recognizes that recreation is becoming a mainstay of Central Oregon's economy. It involves both Oregonians and out of COMMENT Alternative "E" -- Do not approve of state visltors Annual contribution to the local increase in management areas 13 or 7 in this economy from recreational activities is around alternative. the objectives of Management area 13 375 million dollars The Plan recognizes that conflict -- I do not see how nordic skiing will be recreation is and will continue to be an important improved by geothermal development It appears part of the areas economy and directs that as if winter recreation has been used to disguise recreational facilities will be expanded in order to the real 'management' intent for these areas (I e. geothermal). Concerns about the Winter meet the growing demand. It also recognizes that - the expansion of recreational facilities may ad- Recreation-Geothermal land allocation Winter versely affect the total Forest's timber harvest recreation and geothermal development should The Plan now directs that the Intensive, Undevel- be separate management designations that may oped, and Winter Recreation Management Areas or may not overlap Geothermal development and will not be included in calculating Forest's Allowable winter recreation are not compatible. Sale Quantity. The loss of timber halvest is considered minor. These Recreation Management RESPONSE Geothermal was removed from the Areas are not, however, closed to timber harvest prescriptions for Management Area 13 It is shown as long as the harvest practices meet the standards in the StandardslGuidelines as being an area that and guidelines of the respective management would likely have minimal restrictions applied to areas. leases however Exploratory activities, which are all that is likely to occur during the life of the Plan, should not detract from winter recreation and COMMENT Some respondents felt there are could be compatible with winter recreation. If at 'plenty of recreation opportunities now' and they some future time, development is proposed, an

Appendix J - 114 Appendix J Social and Economic Considerations

environmental analysis will be made to prior to The Plan does not propose to elimate recreation development. residences. They are a ligitmate use under National Forest System permit. The plan prohibits new recreation residences from being established Recreation Resldences

COMMENT Retain and protect summer homes COMMENT Give Recreation Residence owners and make no classifications to the Metolius River an opportunity to purchase their lots. that would jeopordize summer homes. Make a tie to the 'Future Use.' RESPONSE The Forest Service has no authority to sell lands to individuals Lands would have to RESPONSE: The Plan does not propose to be declared surplus to National Forest needs for eliminate recreation residences (summer homes) disposal through GSA Summerhome lots are not unless, on a case by case basis, a site is needed considered surplus to National Forest needs. for a higher public value. Higher needs are determined through future use determination. There are no proposed future use determinations Developed Recreation proposed during this plan period. Refer to Standards/Guidelines for Special Uses. Classifica- COMMENT. Many respondents mentioned that tion of the Metolius River into the Wild and Scenic recreation is what central Oregon is all about and River system would not in itself change the status that more developed recreation should be offered of recreation residences. to meet the demand. One respondent wanted more developed recreation also but added that the service levels could be reduced Several people COMMENT: Buy out Norcott and Bpowersox added that more developed recreation was residences at the Crescent Lake townsite and preferable to more roadless areas or more wilder- enlarge the snow park ness Others were advocating more developed recreation if the quality of recreation would remain RESPONSE The suggestion refers to Community commensurately high and were concerned about Residences rather than Recreation residences. quality enough that they felt fees were okay in The Forest Plan has no plans to expand the order to ensure that high quality experience. snowpark at this time The permittees have life Several of those who wanted more developed tenure permits. recreation felt that a good reason for placing more emphasis on developed recreation was because more people can drive than walk to go COMMENT Get rid of recreation residences. camping. Save a few for historical purposes and run a lottery for general public use. RESPONSE. The Forest Plan recognizes that developed recreationsites will become increasingly RESPONSE: Some years ago the Forest Service popular and calls for the development of new, recognized the potential conflict between public expansion of current and the rehabilitation of recreation use of the National Forest and the existing sites Standards/guidelines for Intensive exclusive use provisions of recreation residence Recreation Management areas call for management permits and decision was made to not make any of fee sites at the full service or high level additional sltes The Forest Service also recognized maintenance while the nonfee sites would be the recreation Residence use as a continuing managed at the reduced service levels The Plan program until such time It was determined there calls for development of overnight and day use is a need to utilize the areas for public recreation. facilities and this development is to reflect the Such a decision will be made through a 'Future changing needs of the public It is recognized Use Determination: study which will determine that both intensive and undeveloped recreation when or if the sites are needed for public recreation. will grow. In order to provide more information on

Appendix J - 115 Appendix J Social and Economic Considerations

the planned growth of facilities in these manage- RESPONSE The Plan recognizes that the needs ment areas, implementation tables for the Devel- of the recreating public are changing and directs oped Recreation and Trails Capital Investment that, where ever possible, new facilities will be Programs have been included in the Plan. The designed to meet these new needs Several group emphasis of the Plan is to provide a range of facilities are currently being planned or constructed 'quality' outdoor recreation opportunities and The Developed Recreation Capital Investment current facilities are being brought up to standard Program implementation table, in the Plan, identifies to maintain this 'quality' experience. those projects that are being planned

COMMENT Several respondents commented on Campgrounds fees. Generally they felt fees were all right and should be charged, otherwise the Forest Service COMMENT Of those respondents who preferred competes unfairly with private campground opera- more campgrounds, many mentioned present tors. Others felt they were necessary to keep the crowded conditions in popular sites, the importance quality of facilities high and others mentioned that of day use of campgrounds, need for campsite the program should be expanded to include maintenance, and the need to recognize the charging for day use. average person who prefers roads and camp- grounds over dispersed recreation or wilderness RESPONSE: The Plan recognizes the criteria for areas. fees on developed sites is based on the Land RESPONSE. The increasing demand for developed and Water Conservation Fund Act. Briefly, direction recreation sites is recognized by the Plan Manage- is that 'fees must cover, as nearly as possible, ment direction calls for development of new the costs of operating and maintaining fee sites campgrounds and/or expansion of existing ones and facilities However, the amount charged should ' The objective will be to keep occupancy rates at be comparable for facilities and services provided current levels of 43 percent This calls for the by the private sector, other Federal, State, and addition of 65 units annually The direction also local agencies and should not present unfair calls for development of more day use facilities competition to them The possibility of charges for such as boat ramps, picnic areas, and interpretive day use is currently being examined to see if they sites. Their development will reflect the changing can be expanded. needs of the public Management direction will be to maintain fee sites at full service level which nonfee sites will receive reduce service level or COMMENT Some respondents felt that developed minimum standard of cleaning and maintenance recreation should be decreased.

RESPONSE. The Plan recognizes that recreation COMMENT. Some who favored continued develop- use will increase in the future. Direction is that ment of campgrounds emphasized that most of developed sites will become increasingly popular the unique areas of the Deschutes National Forest and will be managed to keep occupancy rate at are saturated Moderate expansion would be current level of 43 percent. This will require the preferable and should occur in areas such as Fall addition of 65 units a year River, Hosmer Lake, and Deschutes Crossing Separation of horse camps and hiker campgrounds was also a concern COMMENT' Many respondents recognized the need for development in intensive recreation areas RESPONSE: The Plan recognizes that in order to but pointed out that some campers with self- meet the growing demands for developed recre- contained RV's would prefer a site that allowed ation, expansion of current facilities will be needed them to camp together with a place for the children While some new sites will be constructed, expan- to play over crowding into the 'beautiful spots.' sion of present campgrounds along with the

Appendix J - 11 6 Appendix J Social and Economic Considerations

continued emphasis on rehabilitation and heavy Dispersed Recreatlon maintenance of existing sites will meet the growing demand We are currently developing implementa- COMMENT Numerous comments advocating tion plans and doing intensive recreational planning protection of Squaw Creek wanted it to be changed for areas on the Forest in order to meet the growing from a General Forest Management Area to an demand for additional facilities. The Plan recog- Undeveloped Recreation Management Area They preferred implementation of the proposed 23 mile nizes that the private sectorwill also be constructing scenic loop and possible boundaries of 3 Creeks new campgrounds. There will also be a partnership- Highway on the southeast and Road 1514 on the ping of operation and maintenance of existing northwest. facilities wth the private sector Current Forest direction is to identify horse campgrounds as RESPONSE The Squaw Creek drainage has such and to basically separate the horse/hiker been examined and reexamined for visual designa- camping facilities. tions and for development of recreation values. Wth high potential for the potential failure of Carver Lake attracting people into the Squaw Creek COMMENT Some respondents felt that enough drainage with additional recreation development campgrounds exist now and that primary emphasis or special designations would not be desirable. should be on filling them to capacity rather than Some additional visual allocations were made expanding and on upgrading overused camp- where flood hazard could be avoided Additional grounds along Cascades Lakes Highway direction was added to the Riparian Standards/ Guidelines to protect the drainage during timber hawesting operations. Squaw Creek has been RESPONSE. The Forest Sewice is mandated to Designated as part of the Wild and Scenic Rivers so that overuse manage Its recreation facilities System. and site degradation does not occur. Research has found that management of campgrounds at current levels of 40 to 45 percent will not adversely COMMENT: Several respondents were concerned impact the sites; however, where sites receive 70 about the concept of Management Area 13 and to 100+ percent use definite site deterioration the 'lumping of winter recreation with geothermal." takes place. The Plan recognizes that rehabilitation Others felt that mixing snomobiles, nordic skiers, and heavy maintenance of existing sites is only snowshoers, etc , was irrational and impractical. part of the answer to meet the growing recreation demands. Additional unts are also part of the RESPONSE: Management Area 13 (Winter answer Recreation/Geothermal) did not work The prescrip- tion and the management goal for it has been rewritten to emphasize winter recreation with some Downhill Skiing development permissible to enhance visitor satisfaction. Geothermal development could occur within portions of this allocation but proposals COMMENT Expansion of Mt. Bachelor alpine would be evaluated through the NEPA process facilities appear okay. Would like to see it go to and would conform with new standards/guidelines capacity. One person cautioned against allowing for energy resources. S&Gs for the winter recreation overnight lodging, shops or villages. allocationemphasize separation of uses to optimize quality recreation experiences. RESPONSE: The Forest evaluated the situation and determined that existing facilities at Sunriver and Bend fulfill the need for lodging etc. at Mt. COMMENT Advocated controlling vehicle traffic Bachelor. in the OCRA.

Appendix J - 117 Appendix J Social and Economic Considerations

RESPONSE The Oregon Cascades Recreation done will become more specific as the Plan is Area legislation specifically directs the Forest impI em ent ed . Service to 'provide for the use of motorized recreation vehicles: Specific planning for the OCRA will indicate areas and/or trails where ORV's COMMENT Any banning of over-the-snow vehicles may be used. Some areas with the OCRA, such from using certain areas is discriminatory and as Big Marsh, may not offer ORV opportundies. uncalled for. The economic benefits to the areas around the Deschutes National Forest from snowmobiling and grooming of trails for the use COMMENT One respondent specifically said no of snowmobiles are many. gas purchases, lodging/ new roads in Management Area 12 It would be a motels, lodges such a Paulina, Crescent and Elk waste of money and would degrade the undevel- Lake lodges reap many dollars from area and oped character of these lands. out-of-area snowmobilers' purchases of goods and services, money spent in these areas to RESPONSE Added direction in standards/ maintain and operate the three pieces of grooming guidelines that roads will be maintained for equipment, and money spent by local and out-of- recreation uses at a level where mileage and the-area snowmobilers on equipment and mainte- dens@ is no greater than what currently exists. nance of equipment. RESPONSE The S&Gs for winter trails state that, 'expansion opportunrties will be sought in areas COMMENT: On the side of less undeveloped that will not reduce snowmobiling opportunities recreation, a respondent pointed out that there and which can provide for a seperation of uses: already are other areas where dispersed recreation Safety is an important consideration here can occur such as the OCRA, Wilderness, Bend Watershed, and Research Natural Areas. Other Developed Facllltles RESPONSE: While the comment is true, the rate of roading and development on the Deschutes COMMENT: Numerous comments concerned will make undeveloped areas an increasingly future expansion of Mt. Bachelor. Some respon- valuable resource for many people toward the dents felt it should be developed to meet the end of the planning period demand: others did not want intolerable visual impacts in the area to be created or overnight accommodations to be allowed since they would COMMENT Alternative 'E' - Skiing: I'd like to see ruin the forest environment atmosphere the forest service make detailed and specific plans for new nordic ski facilities in addition to swampy RESPONSE The Mt. Bachelor Master Plan, which lakes nordic area. Snowmobiles and nordic skiing is subordinate to the Forest Plan, provides for are not compatable and exclusive areas must be staged development Development is driven by set aside for non motorized winter use. Since the ski areas cash flow--an expression of demand wilderness areas are already set aside for nonmo- Visual objectives are specified in standards/ torized use better winter access should be created guidelines and are routinely monitored Prolects to make them more accessible than they are now are reviewed and approved on a case-by-case for day use. I'd specifically like to see more snow basis. Overnight accommodations are not currently parks further out Century Drive at Devils lake and included in the Master Plan and are not permitted Sparks lake. in the final Forest Plan

RESPONSE: The Forest Plan specifically provides for expanslon of nordic ski trails. Providing for COMMENT One respondent suggested that toilets more winter recreation is the purpose of Manage- be added to the Green Lakes Basin or that the ment Area 13. Exactly where and how that will be area be limited to day use only.

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RESPONSE. Some toilets have been placed in RESPONSE: The number of miles of trail to be the Green Lakes Basin. Limits of Acceptable constructed annually and shown in the Plan's Change (LAC) standards will be monitored to output tables has been increased from five to ten provide a basis for evaluating trends in the Green miles of winter trail and ten miles of summer trails. Lakes Basin. A shift to day use only could come as soon as condrtions dictate. Fires are not prohibited wrthin one mile of this Basin COMMENT Some favored development of trails for nonmotorized use only; while others indicated a need for a mountain bike trail system. Trails RESPONSE An additional statement was added COMMENT: Several respondents were against to the standards/guidelines to reduce the potential location of mountain bike trails near wilderness conflict between trails developed for bikers and areas or trails. Numerous respondents would like trails used by hikers. Statements have been added to see loop trails adjacent to campgrounds, encircle to separate winter motorized and nonmotorized lakes, and include destinations such as falls or winter use. other scenic vistas. Others did not want the trail system to be degraded through timber harvesting, roading, or geothermal development. COMMENT Some respondents wanted to restrict ATV and mountain bike use and to allow them RESPONSE Motorized use and bikes will generally only on roads. Others advocated restricting horses not be permitted on trails that access the Wilder- from certain trails and especially from Wilderness ness and are not permitted in the Wilderness. stating that horses have more impact than bikes Motorized use is also banned from the Pacific or llamas. Crest Trail and various other trails with heavy hiking use. An additional guideline was added to RESPONSE: ATV's are currently restricted from focus on loop trails and trails to special features. using public roads by state law. They are also Most of the hiking trails are located in areas which restricted from using certain areas on the National are not scheduled for timber harvesting and Forest to protect wildlife by area prescriptions geothermal activity will likely be exploration so and for a variety of other reasons identified in the these activities should not degrade the character Plan. Mountain bikes are restricted within wilder- of hiking trails. A ten-year trail construction activity ness. Wording has been added to restrict their schedule has been added. use on heavily used hiking trails, on wilderness access trails, and on trails where their use would cause unacceptable damage. COMMENT Many respondents commented on trails and most favored adding more trails.

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COMMENT: Several respondents were more COMMENT Maintaining existing trail system and concerned about protecting or reopening existing restricting motorized vehicles and bicycles from trails They specifically mentioned preserving the access to roadless areas Maintaining a sufficient scenic qualities of these trails and in some cases amount of the Forest in an unaltered state for advocated relocating the trails away from develop- visual quality and 'cross-country' hiking opportuni- ties providing buffer zones between wilderness ments to ensure the high quality experience and developed areas.

RESPONSE Direction has been added in the Attention should be paid to providing a trail System Plan to locate and relocate trails where they will that places major emphasis on motorized uses. not be adversely affected by development activities, Each campground should provide opportunities e.g., logging and road building Language added for trail hiking Loop trips of various lengths need to expedite cleanup and restoration of trails in to be developed outside of existing wilderness situations where disturbing a trail during logging areas Designation of trails to scenic areas and or road building is unavoidable points of interest should be more numerous

RESPONSE. The goals and S&Gs for trails and COMMENT: Many respondents favored a visual visuals have been rewritten for the Final Plan. emphasis along the Metolius-Windigo horse trail Effortsto evaluate areas for motorized use are and other trails especially within Management being made Area 8 (General Forest). Cultural Resources RESPONSE Maintenance of a visual corridor along the Windigo-Metolius Trail, and other trails, COMMENT. Departure/old growth in ponderosa was reexamined in preparing the FEE. Although pine is an issue that will additionally pressure very desirable from a trail viewer's standpoint Forest Service managers concerning cultural visual corridors are awkward and expensive when resources Presently prehistoric sites in old-growth dealing with other resource values Therefore, the ponderosa pine are protected by avoidance trails implementation schedule includes projects Departure will force resource tradeoffs such as to relocate portions of the Windigo-Metolius to cultural resources versus timber or roading Forest better avoid timber harvest or other disruptive Service will be required to accelerate evaluation activities Direction has been added to the Plan to and mitigation Manage cultural resources rather require faster restoration of trails after logging, than avoid them. etc. RESPONSE This effect has already begun as timber managers move into areas of cultural COMMENT Some respondents indicated trails sensitivity which were previously avoided There is already increase in evaluation and mitigation should not be built for bicycles, AWs, and an because of this Evaluation and mitigation are motorcycles because the terrain not suitable IS also increasing due to public interest in the and it would be too expensive. Others indicated resource. We are beginning to share the information trails should not be built for mountain bikes until gleaned from Forest cultural resource sites, rather there is enough demand. than simply amass more data

RESPONSE. Demand for mountain bike trails is increasing more rapidly than any other form of COMMENT. Save old buildings as long as possible. trail use A variety of abandoned roads, lightly 'Saving them through pictures is not the same." used suitable trails, abandoned railroad grades, and low standards roads have been identified to RESPONSE. Preservation in place and adaptive make good mountain bike trails at very low cost reuse should always be the preferred treatment.

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This alternative must be presented with others as nized and the development of the Forest's travel soon as the need for a change in a building's plan/map will help identify those areas closed to management or status is perceived Cultural ORV use (ORV is referred to as Off-Highway Vehicle resource managers and the Advisory Council on or OHV is the Final Plan) Historic Preservation must be able to comment on a full range of alternatives before decisions are made. COMMENT. Generally, people felt ORV users should be controlled more. Comments ranged from totally banning snowmobiles from the Forest Off Road Vehicle Use (partly because they blatantly take excursions into the Wilderness) and keeping them out of Bend COMMENT. Natural Forests should not include Watershed to saying winter ORV use is okay. One any recreational activity (any use of motorized person felt ORV use, including snowmobiles, vehicles), that destroys public lands and disturbs should be kept out of special interest areas because the wild inhabitants of the forest. they detract from resource values being protected and possible destruction of those resources Many RESPONSE: Revised S&Gs in the Forest Plan also indicated that summer ORV use should be address motorized use on the Forest. Their restricted and pointed out that they are "wreaking direction includes protection of public lands and havoc on flora and fauna," climbing steep hills, minimizing disturbance to wildlife. etc., and should be confined to roads

RESPONSE: As a general rule, direction is that COMMENT Most of those who responded on this the Forest will be open to ORV use except where topic stated that motorized and nonmotorized specifically closed Development of a Forest travel activities were not compatible Most referred to map will identify areas where ORV's are permitted the need to separate nordic skiers and snowmobil- or restricted. Wording has been added to restrict ers. Skiers referred to the sight/smell/hazards of motorized-mechanized vehicle use on Wilderness the combination and snowmobilers indicated the access trails Portions of the Forest can be closed need for longer trails and larger areas due to the seasonally or year long to protect vegetation, distance they can cover Others referred to summer wildlife, and other management concerns Special activities and felt camping and hiking experiences interest and other management areas have were disturbed by Off Road Vehicle (ORV) and identified ORV restrictions. In addition, the Forest "the damage they do.' Supervisor has authority to impose special Forest closure orders if damage to flora, fauna, soils, RESPONSE. To reduce conflicts that exist between etc., take place. motorized and nonmotorized use on winter trails the standards/guidelines direct a restricting of motorized use on nordic trails rather than closing COMMENT Black Butte Ranch agrees with the entire areas to motorized use. Individual roads ORV restricted area east of the Ranch but recom- and trails can be designated for separate uses mends making the boundaries coincide with the which would satisfy some of the comments. Old-Growth Management area Restriction of ORV's Management direction is to expand or add trail should also be considered in portion of Section and trailhead facilities to provide more snowmobile 22, T14S, R9E that lies between Road 300 and activities. Direction in plan restricts motorized- the Ranch property line. mechanized vehicles use in intensive and undevel- oped Recreation management areas to designated RESPONSE: ORV restrictions already exist for routes or areas. The plan also restricts them from Old-Growth Management areas. The plan also using certain ares of the National Forest to protect closes meadows, marshes, and steep slopes to wildlife, vegetation, and a variety of other reasons. ORV use and the area in Section 22, T.14S., R 9E, The conflict between hikers and ORV's is recog- adequately fits under this description

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COMMENT Of those commenting on the amount COMMENT. Wants no additional permits for of ORV opportunity, several indicated the need concessions on National Forest Lands except for for areas that would allow a hundred mile round Mt Bachelor trip and another respondent wanted winter ORV use in Management Area 12 One person wanted RESPONSE: We plan to respond to public needs Forest Service Road 41 to Dillon and Benham when issuing permits for concessions on the Falls to be open to snowmobiles. One person National Forest In some cases we may be issuing 'saw no need to spend money to develop new new permits or expand existing permits. Guidelines ORV trails when we could allow ORV users to use for expanding new permits or issuing new permits low standard roads since ORV's disturb many are given in the Standard/Guidelines section of and benefit few' while another said the Forest the plan. Seivice is not mandated to provide lands for dirt bikes, motor bikes, motorcycles, 3 -wheelers, dune buggies, four-wheel pickups, and jeeps. Utility Corridors

RESPONSE Forest management direction is to COMMENT. Roadless areas must continue to be offer additional opportunitiesfor All Terrain Vehicles left in an undeveloped condition There should be (An3 and ORV use. Development of these facilities no power transmission lines allowed in these will be accomplished in partnership with the Oregon areas. ATV fund. Direction is also given that part of the Forest Service road system that is not maintained RESPONSE: Management direction is to use existing corridors. Expansion of these corridors is for public use and is not involved in logging permitted. Expansion may require a site-specific operations will be open for this use. Snowmobile analysis in accordance with NEPA. and ATV's are permitted in the undeveloped Recreation Management Area 12, except where it Three windows have been identified for future is specified as nonmotorized Restrictions have power transmission lines that may be needed to been placed on larger ORV's to protect groomed cross the Cascades When new corridors are snowmobile trails from damage where they exist. needed, evaluations and analysis of the projects Forest road 41 is open to snowmobile use when will be done in accordance with the NEPA process sufficient snow is available. The Forest Service is and with procedures set forth in the Regional mandated to manage the Recreational use on Guide. National Forest lands and motorized recreation is part of this management. The plan cannot at this time predict how many transmission lines will be needed. It depends on the number of new resoures which will need to be Lands, Minerals and Energy connected to the grid The plan does not separate out the amount of land projected for transmission Special Uses lines from othe non-timber uses. The goal for transmission line planning is to minimize environ- COMMENT Special use permits should be mental impacts. This includes locating transmission minimized in roadless areas. lines outside sensitive areas like 'old growth" forest and avoiding impacts to birds of prey in RESPONSE. Permit issuance is based on public areas important for them Our concern is that need Decisions on issuing a permit, along with adequate transmission line capacity can be sited the conditions of the permit, will consider the in an acceptable manner to service the needs of Management Area prescription including the extent future resources. We do not know how much to which roadless characteristics need to be transmission line capacity will be needed. Given preserved. In some instances, special use permits that limitation, we conclude the Plan in general may be permitted in these areas. adequately allows for transmission line planning.

Appendix J - I22 Appendix J Alternatives, Data Analysis, & Planning Process

Small Hydro Development Sunriver, and areas that have been developed for residential purposes. COMMENT Wants no hydro projects on the Deschutes, Metolius, ortributaries to protectfishing, The Forest Service cannot make inholders Sell water quality, recreation, long term economic their land. In many cases the only way to acquire welfare of state, etc. inholdings that would be beneficial to National Forest programs is to exchange National Forest RESPONSE The Deschutes and Metolius Rivers lands for the inholdings. Therefore, some lands as well as many of their tributaries have been must be give up in order to acquire the inholdings. included in the recent wild and scenic rivers bill. These streams are to be kept as free flowing The lands that are proposed for disposal Contain waters. Only hydro projects that can occur are at no unusual or unique features. Lands with high existing impoundments or irrigation systems such recreation, wildlife, scenic, or water values have as Wickiup and Crain Prairie dams and irrigation been identified as lands to be retained diversion sites. COMMENT Change the classification adjacent to Black Butte Ranch so the lands are retained in COMMENT: Power lines are a problem. public ownership.

RESPONSE: Power lines related to hydro projects RESPONSE' Both private and public lands can can be constructed in such a manner to mitigate be managed more effectively if ownership is in effects on other resources. large contiguous blocks rather than isolated parcels. The isolated tracts in the vicinity of Black Butte Ranch will remain available for exchange if COMMENT: The north forest boundary to mill the oppoftunity arises. The lands Contain no pond should be hydro project for irrigation. unusual or unique features. In the event the lands were proposed for exchange, the public would RESPONSE This area is outside the National have the opportunity for input. Should the lands Forest administration area. The Forest Service go into private ownership, development would be has no decision making authority for this area. guided by County Zoning regulations.

COMMENT: Deschutes river hydro facilities are a COMMENT There are several parcels of land in must for central Oregon. State ownership which could be exchanged in a effort to block ownerships RESPONSE Hydro activities on the Deschutes are limited by new wild and scenic river legislation. RESPONSE The Land Adjustment Plan provides As a result of the new legislation only limited hydro for the exchanges with the State to block up projects can occur on the Deschutes National ownerships. Forest. The areas are limited to existing impound- ments. Minerals

Land Status COMMENT. Charge the State for setting up the mineral permits. COMMENT: Acquire all inholdings with no disposal. RESPONSE: The State is required to share in the RESPONSE The land adjustment plan allows for cost of permit preparation They pay for their acquisltion of all inholdings except those tracts share of pit reclamation. Fees are waved for the that have been developed, ie Black Butte Ranch, mineral materials.

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COMMENT Concerns about water quality, air are the same areas that provide an unsurpassed quality, heavy metals recreational opportunity to our citizens, and with that opportunity a potential for a sustained and RESPONSE The regulatory process (BLM and healthy economy in central Oregon State) has adequate mechanisms to protect and presewe water and air quality. These will be RESPONSE: Indeed, there are areas of important diligently adhered to by all authorizing agencies. recreational opportunity However, royalties from The concerns pertaining to heavy metals are selling electricity from geothermal power plants included in the regulatory process. can produce a substantial income to the State of Oregon and county in which the electricity is produced This economic advantage must be Geothermal Development taken into account as well as your important concerns about a healthy recreational economy COMMENT Geothermal development may follow the same route of infeasibility as oil shale did in The biological systems you refer to in areas where the 1970's. With the increasing impotence of OPEC, geothermal leasing could lead to development and declining energy prices, the costs of geother- are certainly taken into account in future environ- mal energy probably outweigh the benefits. This mental analysis of specific proposals for develop- is especially true when taking the cost of en- ment. Once a lease is granted, the lease holder virnomental disruption into account. To much cannot simply begin full scale geothermal develop- land is made available for geothermal leasing. ment. Another Environmental analysis must be The plan gives to much leeway to the lease holder done for each proposed development This after the lease is given assessemnt involves the public and could lead to either denying, limiting, or allowing full develop- RESPONSE. Large areas of the Deschutes National ment Forest have already been leased to people and companies This Forest Plan deals with those areas not yet leased and those areas that could COMMENT Concerns about leasing adjacent to be leased again d earlier leases are abandoned recreation areas, both public and private, ie Black The areas already leased were leased only after Butte, Mt. Bachelor, Bend Watershed, and Wilder- an environmental analysis and public involvement ness areas. in preparing appropriate environmental documents. Once a lease is granted, the lease holder cannot Comments on leasing in roadless areas, critical simply begin full scale geothermal development fish and wildlife habitats. and ecologically sensitive Another environmental analysis must be done for areas each proposed development This analysis again involves the public It could lead to either denying, Geothermal leasing and development should only limiting, or allowing full development. be permitted where conflicts with other manage- ment designations do not exist These included As you can see, there are several places where such areas as lakes, streams, trails, scenic areas, your comments on economic justification and special interest areas, recreation areas, critical environmental concerns can help guide leasing fish and wildlife habitat, ecologically sensitive and development However, only one proposal for areas, and roadless areas Additional comments development of a lease has been made to date stated that geothermal leasing and development (9/88). should not be permitted within five miles of major public and private recreational areas such as the Metolius area, Black Butte Ranch, Mt Bachelor, COMMENT. Concern IS about the geothermal and Wilderness areas development in the Forest. This sort of development has the capacity to permanently destroy the fragile RESPONSE. Leasing and development options biological system of the high alpine areas These range from denial of leasing to full development

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with very limited restrictions. Denial is used when Geothermal should be developed to the fullest the conflicts between leasing and development cannot be resolved or geothermal leasing is RESPONSE One of the responsibilities of the incompatible with other resource values The draft National Forests is to help provide for the Nation's plan has been revised to identify areas where energy needs. This can be done on the Deschutes geothermal leasing will be denied and where National Forest by possible development of the special stipulations will be used: (1. No Surface geothermal resources. With careful planning this Occupancy, 2. Conditional Use Stipulation, and 3. can be accomplished compatible with the many Seasonal Restrictions). The standards/guidelines other resource values on the Forest. Leasing will in Chapter 4 of the Plan direct where leasing is be restricted or denied to protect such values as appropriate and the stipulations that will be used. Wilderness, the Bend Watershed, and other sensitive areas Leasing direction is provided in the geothermal standards/guidehnes in Chapter 4 Geothermal leasing is denied in the interior of the of the Forest Plan Newberry Crater, Wilderness, The Oregon Cascade Recreation Area, and the Bend Watershed. It is It takes several years to put a power plant on line, also denied in Management Area 12 except for therefore it is important that we consider geothermal the exterior boundaries where a no surface leasing at this time, even though there is a current occupacy stipulation would apply. Leasing is surplus of electrical energy. We must plan for denied in developed recreation sites as well future needs. Leasing IS also recommended for denial in Research Natural Areas and the interior portion of the Experimental Forest. Leasing with restrictive COMMENT This Plan should limit geothermal stipulations are used to provide for wildlife habitat conclusions to issue identification and policy areas or areas with sensitive plants. Geothermal declaration. Suggest that an "open unless closed" leasing has already occurred on the Forest in policy for exploration be confirmed througth the accordance with prior environmental analysiss. In Plan and leasing recommendations for all non- many cases leases have been granted within five critical areas. Critical = irreversibleeffects resulting miles of features such as Black Butte Ranch and from exploraton. Mt. Bachelor. These leases contain stipulations which protect recreational and visual values RESPONSE The revised standards/guidelines give direction on leasing. Geothermal exploration Geothermal exploration and development will and development will require additional enviorn- require additional environmental analysis to deal mental analysis to deal with the site specfic with the site specific activities. implications and decisions

COMMENT Comments on leasing in Newberry COMMENT There should be no leasing on the Crater. Lease in Crater: It would be a serious Deschutes. There is already to much leasing error to overlook and prohibit geothermal leasing Leasing should be done to the fullest in the Newberry Crater itself. Deny leasing in Newberry Crater . Geothermal development should not be permitted in the Deschutes National Forest. It is one of the RESPONSE. The recreational, fish and wildlife, finest Forests anyone would want and to develop and geological values found in the interior of the it would not only be a detriment to our Forest but Crater are significant. The Crater is being managed a loss to all which now use it. for both developed and undeveloped recreation There is also a Bald Eagle nesting area which is There is surplus power, geothermal energy is not being protected The unique geologic features needed at this time. Too much land is available are recognized and are being protected. Geother- for geothermal leasing. mal leasing is denied in the interior of the Crater

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to protect these values This does not forclose Special Interest Areas the opportunity to explore and develop the geothermal resources of the Newberry volcano as COMMENT Add a special interest area for the the outside slopes are available for leasing. lava tubes and the caves they create

RESPONSE: There are hundreds of lava tubes on COMMENT. Alternative 'E' --Provide no geothermal the Deschutes National Forest. They are given development within the surface area of newberry special management direction on the Forest crater. The surface interior of Newberry Crater through cave management standarddguidelines provides unique and exceptional geologic re- Several existing special interest areas do contain sources and recreational experiences as well as lava tubes having high scenic values. The chamber supports the preseivation of this area in its present circum- COMMENT. What protection are you giving caves stances. The Newberry Crater area also has great with destructive values? geothermal potential that could provide a long range alternative to nuclear and fossil fuels RESPONSE: All caves on the Forest have applica- electrical gerneration. The chamber feels very ble standards/guidelines pertaining to cave roofs, strongly that this potential must be thoroughly cave entrances, slash disposal, nearby vegetative explored. buffers around entrances, roads and recreation More specific protection is given to caves inhabited RESPONSE Public comment has been running by the Townsend's big-eared bat. continuously and strongly against allowing geother- mal development within Newberry Crater since geothermal leasing on federal land first become COMMENT Add a new SIA or put into undeveloped possible in 1974. In 1975, a local group called recreation a large grove of ancient junipers found Friends of Newberry Crater were successful in in RIOE, T14S, Section 11 SE 1/4 It is presently instigating State of Oregon Resolution HJR-31 in General Forest area. which resolved that Newberry Crater was unsuited for geothermal development because of higher RESPONSE. There are no plans to designate this values such as recreational, scenic, and education- area at this time Also, there are no activities al. The feelings expressed in this resolution seem planned which would disturb this area during this to be broad and deep within the public. planning period Future evaluation of this area for special interest area classification is not foreclosed There is some confusion about the area covered by the name, Newberry Crater. Some people COMMENT Do not allow livestock grazing or have extended the meaning of Newberry Crater ORV's in SIA's. to all land in and around the volcanic caldera (crater) of Newberry Volcano. By this definition, RESPONSE Many SIA's are closed to ORV's and there is now clear or accepted boundary beyound few provide grazing opportunities. Many geologic the crater itself. Following the apparent intent of areas which are predominantly lava flows or Lewis A Mc Arthur in Oregon Geographic Names, obsidian flows naturally exclude ORV's. Few (or 5th edition, Newberry Crater is her defined as the no) active grazing allotments include SIA's. large volcanic caldera (crater) of 17 sq miles at Although this concern does not seem to be a real the top of 500-sq-mile Newberry Volcano. The problem, the SIA prescription was rewritten to exact boundary follows the perimeter of the more clearly state that these uses should occur hydrologic basin formed by the caldera of Newberry only where the use is not incompatible with the Volcano. purposes for which the SIA was established

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COMMENT: Comments favored the existing and RESPONSE We concur on the importance of the proposed SINS and suggestions for adding in Deschutes River. The portion of the river between Castle Rock, Balancing Rock, Head of Jack Creek, Wickiup Reservoir and the Bend Urban Growth Black Crater, Squaw Creek Falls, McArthur Rim, Boundary was designated as a Wild and Scenic Davis Lake, Horn of Metolius. River by the Omnibus Oregon Wild and Scenic River Act in 1988 We are in the process of RESPONSE. These areas were reconsidered and developing a management plan for this section of river. Balancing Rock, Castle Rock, and Davis Lake were added to the SIA list. It was felt that this Recent studies by Forest personnel have deter- existing and proposed list of SIA's adequately mined the headwaters portion of the Deschutes represents the types of features the SIA designa- River from its source at Little Lava Lake to Crane tions were designed to cover. Prairie Reservoir to be eligible as a Wild and Scenic River. The headwaters portion of the river will be protected as a Wild and Scenic River until further Wild and Scenic Rivers suitability studies determine if the river segment should be recommended to Congress for designa- COMMENT It is of utmost importance to now tion as Wild and Scenic. undertake long term planning for the squaw creek corridor and scenic loop, not only because of its COMMENT: Proposals for wild and scenic designa- dramatic beauty and importance to wildlife migra- tion on the Deschutes and Metolius. tion, but also because of its invaluable recreational contributions to local and tourists alike All aspects RESPONSE: New legislation has designated those of the corridor make it an ideal "undeveloped portions of these rivers on the Deschutes National recreation' site and it should be managed as Forest under the Wild and Scenic Act. It is no such in the new forest plan The remaining 9 longer a proposal in the Forest plan. miles of the squaw creek scenic loop should also be visually protected. COMMENT Include the entire Deschutes and RESPONSE. Most of the area mentioned above Metolius Rivers with major tributaries will be managed as a scenic corridor with a management standard of Partial Retention. A RESPONSE Since the DEE was published in large portion of the area is within a Wild and Scenic 1986 all of the Metolius, major portions of the corridor for Squaw Creek and a management Deschutes, and portions of Squaw Creek, Crescent plan is being written. At this time there is no specific Creek, the Little Deschutes River, and Big Marsh plan for the portion of the Squaw Creek scenic Creek have been designated as Wild and Scenic by the Oregon Omnibus Act loop outside of the Wild and Scenic corridor.

COMMENT' Designate the upper and lower COMMENT Alternative 'E' -- Include all of the Metolius River. Deschutes River that flows within the boundaries of the Deschutes National Forest under appropriate, RESPONSE The entire Metolius River was desig- specific designation that include, but are not limited nated as a Wild and Scenic River in the Omnibus to Wildand scenic or recreational classifications. Oregon Wild and Scenic River Act The Forest is The Deschutes River is a vital resource for Central presently developing a management plan for the Oregon. Its waters provide for the bast acreage of river in conjunction with the Confederated Tribes irrigated farm lands and residential yards. It is an of the Warm Springs, Oregon State Parks, Oregon outstanding recreational resource for fishing, State Marine Board, Oregon Department of Fish rafting,canoeing and other water activity. and Wildlife, and Jefferson County.

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COMMENT. Classify the Deschutes, including the COMMENT' Restrict trmber harvest and commercial upper segment. use in the Metolius.

RESPONSE. The portion of the Deschutes River RESPONSE The Metolius has been included in from Wickiup Reselvoir to the Bend Urban Growth the Wild and Scenic allocation. Timber within this Boundary was designated as Wild and Scenic in allocation is not included in the Allowable Sale 1988. Recent determinations have found the portion Quantity Management goals are oriented toward of the river from Little Lava Lake to Crane Prairie protection and enhancing the rivers outstandingly eligible for Wild and Scenic status Further suitability remarkable values. The rivers outstandingly studies and recommendation to congress will be remarkable values are recreation, scenery, fishery completed in the future and geology.

COMMENT. Designate Crescent Creek, Little COMMENT Change 'No commericai rafting on Deschutes, Fall River, Spring River, Tumalo Creek the Metolius (p. 63) to "No rafting ' and Squaw Creek as 'Recreation'. RESPONSE. This suggested change was not RESPONSE: The Omnibus Oregon Wild and Scenic made. There was no compelling argument or data River Act designated 10 miles of Crescent Creek, to suggest this change was needed. The question 12 miles of the Upper Little Deschutes, and 15 will be considered again as we develop a manage- miles of Squaw Creek as Wild and Scenic Rivers ment plan for the river in 1988 Recent Wild and Scenic River eligibility studies completed on the Forest considered Fall River, Spring River, and Tumalo Creek Only Fall COMMENT No road build and limited motorized River was determined to be eligible and will be use below Bridge 99 protected as a Wild and Scenic River until further suitability studies can be conducted to support a recommendation to congress (see Appendix D of RESPONSE No additional road is planned during the EIS) the planning period. Some restrictions are being evaluated in the Metolius Implementation Unit Planning being conducted COMMENT. Classify the Metolius as 'Wild' from Bridge 99 down. COMMENT Metolius Corridor should be used for RESPONSE, With the road as close as it is in intensive recreation places to the Lower Metolius, the segment would not qualify for the 'wild' classification RESPONSE. A variety of indicators suggest the Metolius corridor is near its recreation carrying capacity. Extensive new development is not COMMENT Manage the Metolius and Deschutes planned Rivers for scenic and wildlife values rather than intensive recreation or timber Wilderness RESPONSE The Metolius and Deschutes were designated as Wild and Scenic Rivers by the COMMENT Many comments were opposed to Oregon Omnibus Act in 1988. The Act requires existing or more Wilderness because its a waste that management plans be developed for the of timber, could adversly affect timber related rivers to protect and enhance the rivers outstand- jobs, only a few people use the Wilderness, or ingly remarkable values Management plans for Wilderness excludes some people and activities each of the rivers are in progress and scheduled such as snowmobiles. There were suggestions to be completed in early 1992. that actions be taken in the remaining roadless

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areas so they could not be considered for wildlife habitat improvement, and recreation be Wilderness at some future time. There were also permted in Wilderness afew comments that more Wilderness was needed. RESPONSE Such activites are not permited under RESPONSE: The question of additional Wilderness Wilderness Act or can only be done under very was not addressed in the DEE. The Oregon unusual situations with special authority Wilderness Act of 1984 made provisions that the roadless areas need not be considered for Wilderness in this round of planning but would be COMMENT There was some support expressed considered when the Plan is revised which is for the ban on military exercises and contests in normally at the end of 10 years and not later than Wilderness areas 15 years. No recommendations for additional Wilderness was made, however approximately RESPONSE. The direction baning the use of 80,000 acres are in Management Areas that allow Wilderness for military exercises and contests only minimal development so they could potentialy was retained in the Final Plan. be available for consideration as Wilderness when the Plan is revised. Most of the timber in these areas is lodgepole pine and mountain hemlock COMMENT. Leave existing structures in place with very little of the higher valued ponderosa and let them deleriotate in place rather than pine found in the roadless areas that will remain spending money to remove them This includes undeveloped. Providing for some undeveloped the Muskrat Lake cabin areas outside of Wilderness helps round out the recreation experiences on the Forest. RESPONSE: Structures such as cabins are man made features that are not permitted under the Wilderness Act. Such non-conforming features COMMENT Restrictions on Outfitters and Guides must be removed and direction to do so was in the Wilderness are not reasonable and are retained in the Final Plan. discriminatory.

RESPONSE Some additional flexibility was incor- Research Natural Areas porated into the standards/guidelines for Recre- ation Special Uses. COMMENT The allowance of snow vehicles within RNA's appears to be in direct conflict with the primary purpose of these areas (research and COMMENT Some portions of the Wilderness are education). over used and restrictions should be imposed to Cultail the degradation Commercial groups should RESPONSE: Neither recreation nor range use are not be allowed to use these areas. Such restrictions incompatible with RNA's but they must not threaten would also apply to commercial users the values for which each RNA has been estab- lished. The standards/guidelines for management RESPONSE: The Wilderness Plans provides for of NRA's can be found in Chapter 4 of the Forest restrictions when use begins degrading Wilderness Plan These standarddguidelines are designed to values. Use is currently being distrbuted throught protect the values of the RNA. contacts with the public and advising them on areas to use that are less crowded. Further restrictions may be phased in as needed COMMENT Needed research has not been accomplished and the exclusion of fire in the Metolius RNA has resulted in an impenetrable COMMENT: Some comments recommended that understory, impairing scenic quality, wildlife and management activities such as timber harvesting, the health of the timber stand.

Appendix J - i29 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE. Since the writer did not mention Charlton- The area to remain undeveloped which research has not been conducted this was expand to include more of the roadless comment cannot be responded to The purpose area. The majority of the area is included in of RNA’s is to provide areas that are allowed to Management 12. exist in a natural sltuation where research can be conducted. Beawallows- The majority of this area is available for development. No timber havrest was scheduled in the first decade in the COMMENT The Metolius River, in the Metolius development of the allowable sale quanity Breaks area would be an excellent site for the However due to the mountian pine beetle protection of cell number 8, Ponderosa Pine/Big epidemic or because of the need for Sagebrush/Wheeler’s Bluegrass community in a firewood, some management activities may fourth order stream segment occur. Bend Watershed- The majority of the area RESPONSE The Metolius Breaks area would not remains undeveloped. be a good place for the protection of cell number 8. The community in that area is Ponderosa West-South Bachleor- The major&ty of this Pine/BMerbrush/Needlgrass. Sagebrush is alien area is in Management Area 13 which to the area if present at all. emphasis winter recreation. Timber manage- ment and roading are limited to activities that enhance the winter recreation opportu- Roadless Areas nities

COMMENT Maintain roadless areas in their current Maiden Peak- The majority of this area will condition, i.e., no motorized use, no geothermal remain undeveloped. The boundary of development, no logging were stressed by a large Management Area 12 was moved to the number of respondants. Maiden Peak, North and east in this roadless area because of public South Paulina, Bend Watershed, and the Metolius COMMENT about the area Breaks roadless areas were mentioned most often in this context. Some pointed out that existing North Paulina- That portion of the roadless roadless areas are needed to provide an adequate area inside the Newberry Crater will remain range of recreation opportunlties in the SPNM undeveloped. The portions outside the and PNM ROS classes while others felt that keeping crater will be managed with an emphasis the areas undeveloped would contribute to the on visual quality. economics of recreation and tourism. Presenmg South Paulina- Same as North Paulina the areas for wildlife habitat and old growth were amoung many of the reasons why people wanted Mount Jefferson- Due to the small size and the roadless areas to remain undeveloped. Some fragmentation of these areas, they were comments pointed out the opportunity to use included in Management Area 8 and are some of the roadless areas to expand opporunties available for development. for hiking and cross country skiing. Metolius Break- The majority of this area RESPONSE: Following is a summary of direction will remain undeveloped and is in Manage- for each roadless area. ment Area 12

Waldo- A portion remains undeveloped Three Sisters- Due to the very narrow strip and the area available for development of land involved in this roadless area, it focuses on visual quality, intensive recre- was not pratical to try to manage it as a ation, spotted owl and bald eagle habitat. discrete area With Wilderness on the west

Appendix J - 130 Appendix J Alternatives, Data Analysis, & Planning Process

west side of the area and roads on the COMMENT. Expand dispersed recreation opportu- east, it was more practical to manage it nrties, especially hiking, nordic skiing, wildlife, on consistant with areas that were not in South and West Bachelor Roadless Area. Wilderness. The area is available for develop- ment RESPONSE Management in the WestSouth Bachelor roadless area will emphasize winter recreation with the area open for hiking and other Many of the comments stress that geothermal activities in the summer. leasing should not be permited in the roadless areas. Some of the roadless areas such as WestSouth Bachleor and the North and South Visual Resource ManagemenVScenic Paulinas have a high potential for geothermal Views energy. Portions of these roadless areas will be available for geothermal leasing so the magnitude COMMENT Landscape management techniques of this resource can be determined. If the resource need to be applied more widely, especially relative is there, then it could potentially be developed to to timber harvesting and rehabilitation of past contributed to regional or national future energy timber management activities. needs If a roadless area is in Management Area 12 it is not available for leasing except along the RESPONSE: The Activity Schedule in the Plan perphery with no surface occupancy. If a roadless Appendix provides for the accomplishment of one area is in Management Areas 8 or 13, then they rehabilitation project per district per year These are availble for leasing See the Standards and rehabilitation projects may vary in size and scope, Guidelines in the Forest Plan for more spectic but the majority of them will focus on past timber management activities. Landscape management information on where leasing is permited and how techniques such as visual magnitude studies, restrictive it might be. multiple-entry planning, and computer simulation of proposed treatment activities are now used on With regards to motorized use in the roadless nearly every timber harvesting project within a areas, those areas included in Management Area Scenic Views allocation. 12 are closed to motorized use in the summer but open to over-the-snow vehicles in the winter. The same is true for the Oregon Cascade Recreaton COMMENT Impairment of view from road 12. Area. Those areas in Management Area 8 and 13 Watershed and visual concerns about logging are open to year round motorized use. Further along Abbot Creek. Concerned about clearcutting adjustments may be made in the Off Road Vehicle next to private land. Plan as time passes and new opportunities or conflicts surface. RESPONSE: All planned timber sale activities are open to public comment On timber sale activities adjacent to private lands, the Deschutes National COMMENT Develop roadless areas for multiple Forest usually solicits comment from land owners An environmental assessment of the activity is uses was stressed by a few respondants. published and open for comment RESPONSE: Of the 145,000 acres of roadless areas approximately 62% is available in the long COMMENT. Selective logging in sensitive view- term for some form of development. The portion sheds is preferred over clearcutting, except where that is not was kept undeveloped because of the absolutely necessary, due to insects and diseases. value of providing for undeveloped recreation outside of Wilderness and in recognition of some RESPONSE The standards/guidelines provide for of the features and resources found in them. a full range of timber management prescriptions

Appendix J - 131 Appendix J Alternatives, Data Analysis, & Planning Process

to meet and perpetuate visual quality objectives. RESPONSE Visual quality standards of Retention However, uneven-aged management techniques and Partial Retention are inherent in the Intensive will be preferred whenever conditions permit a Recreation, Wild and Scenic Rivers, Special Interest choice. Clearcutting will be the least preferred Area, Bend Watershed, Dispersed Recreation, treatment method OCRA, as well as Scenic Views allocations The Final Plan allocates a total of 199,981 acres to Scenic Views, plus another 209,726 acres to these COMMENT: Protect scenic values along the other allocations which specify Retention and Metolius, Deschutes, Little Deschutes, Crescent Partial Retention visual quality standards The and Fall Rivers and Big Marsh area. result is a total that exceeds the Draft Plan's provisions for Retention and Partial Retention by 7,893 acres. The net Forest acres allocated to RESPONSE. Scenic values in these areas are managment areas having high visual standards already protected in the Plan. With the exception IS beyond what is similarly designated in the Draft of Big Marsh, which is now mostly within the OCRA Plan. (Oregon Cascades Recreation Area) designation, National Forest lands seen from these water features are allocated to either Developed Recre- COMMENT: Keep ORV's out of visually Sensitive ation, Dispersed Recreation or Scenic Views The areas standards/guidelines require management activr- ties in any of these allocations to be subordinate RESPONSE. ORV use is permitted in Scenic Views to the surrounding landscape or not visually management areas in the Forest Plans Preferred evident. Management activities will be done to Alternative However, when ORV activity begins to maintain healthy vegetation, promote natural impact visual quality in these areas or if they are diversity, and take advantage of enhancement in conflict with other uses, restrictions will be opportunities. imposed on ORV activities. This is covered in the standards/guidelines for Scenic Views

COMMENT Provide strict visual guidelines to protect viewsheds seen from highways COMMENT. Geothermal leasing and development should not be permined in visually sensitive areas RESPONSE. Level 1 viewsheds are allocated in the Preferred Alternative as originally inventoried. RESPONSE. Scenic Views management areas For example, lands within a viewshed that were are within the category of Conditional Use Stipula- inventoried as Retention are now allocated to tion under Energy Resources. The standards/ guidelines for this category permits leasing of Scenicviews with the same Retention management Scenic Views management areas, but may limit objective The standards/guidelines for Retention the use of the surface Depending on the type of areas are adequate to protect scenic values within geothermal proposal, specific locations, and other these viewsheds. An exception to this is in those factors, surface occupancy or development of viewshed areas where the mountain pine beetle geothermal resources may be restricted in order has killed most of the mature lodgepole pine. to protect scenic values Dead trees have already been salvaged to make way for new forests. Inventoried visual quality objectives in these areas cannot be met now, but COMMENT Leave scenic corridors along Pole the objectives will guide long-term management Creek, Squaw Creek, Three Creeks Road, Three of the new forests. Creeks Lake, and Black Butte.

RESPONSE: The Preferred Alternative now includes COMMENT: Expand visual allocation beyond the scenic corridors along Squaw Creek, Three what is designated in current plan. Creeks Road and all but the upper portion of

Appendix J - 132 Appendix J Alternatives, Data Analysis, & Planning Process

Black Butte in the Scenic Views management COMMENT Protect scenic values at the Head of area. The upper portion of Black Butte has been Jack Creek. placed in a Special Interest allocation. Pole Creek was not selected for a scenic corridor, however, RESPONSE: The Head of Jack Creek is allocated the upper portion of the creek that parallels road to Foreground Retention. The Retention visual 1524 falls into a scenic allocation associated with quality objective means that management activities the road and will be managed as such. will not be noticeable to the casual Forest visitor. Next to Preservation, which applies only to wilderness areas, the Retention objective provides COMMENT Continue to provide scenic vistas. for the highest level of protection of scenic values

RESPONSE The Implementation Schedule in the Appendix provides for one Scenic Views enhance- COMMENT The radio tower on Bearwallow Road ment project per year. Scenic vistas are the most is a discordant scenic feature common type of enhancement projects undertaken, but other projects such as planting wildflower RESPONSE Although the Forest has a right of seed mixes, encouraging aspen and larch for fall way for Bealwallows Road across private lands in color in the landscape, and eliminating unattractive the area described, the radio tower is entirely on signs are also planned. private land While we agree that this radio tower is visually discordant, the Forest Service has no authority to prescribe mitigation measures for COMMENT Do not protect scenic quality on forest reduction of visual impacts on privately owned lands adjacent to exclusive homesites. lands

RESPONSE. Exclusive homesites are not included as “significant viewer locations’ in the standards/ COMMENT Timber harvesting in the Prairie Creek guidelines for Scenic Views Management Areas. area has resulted in unacceptable scenic condi- The visual resource inventory does not give special tions emphasis to homesites or subdivisions adjacent to or within National Forest boundaries However, RESPONSE: The timber harvesting in question is some roads leading to homesites and subdivisions along Prairie Farm Creek on the Sisters Ranger are used by National Forest recreationists. These District. Several treatment units resulting from the roads are considered significant viewer locations timber sale are visible to motorists along Rds. and have been considered in the visual resource I150 and 1180. inventory for the Forest Under the current plan, the land management allocation for the Prairie Farm Creek area is COMMENT Timber harvesting units on Black Wood/Forage Generally, the lowest acceptable Crater have reduced scenic quality. visual quality level in this allocation is Maximum Modification. Although the timber sale units in RESPONSE: The regeneration harvest units on question are visually dominant on this landscape, Black Crater are noticeable from several significant they meet the current land management objective viewer locations in the Sisters area. At certain In the new forest plan, this area is allocated to times of the year, color contrasts are extreme and General Forest. The desired visual quality level in these units do not meet the Partial Retention land the General Forest allocation provides for created management objective. Visual Rehabilitation openings to be shaped and blended to the natural projects are planned in the Implementation terrain, to the extent practicable Future timber Schedule in the Appendix Material The harvest halvesting will consider uneven-aged management units on Black Crater will be a high priority for in the Prairie Farm Creek area Where uneven-aged Visual Rehabilitation. management is not silviculturally appropriate,

Appendlx J - 133 Appendix J Alternatives, Data Analysis, & Planning Process

created openings will be designed to blend with Odell Butte and Green Ridge are also allocated to the natural landscape to the extent practicable. Scenic Views with a visual quality objective of Partial Retention.

COMMENT Timber stands need to be managed As ponderosa pine plantations continue to cover to prevent insect infestation and mortality. the scars left by the Peterson Burn and other fires dating back into the 195O's, some distant views RESPONSE Even in extremely sensitive visual along the Three Creeks Road may become zones on the Forest, such as along the Santiam obscured. The Forest Service will continue to Highway. the Forest Service uses the timber sale manage this vegetation through thinning activities. program as a means of achieving a variety of Along the road, vista opportunities will be planned management goals. Sometimes these goals are and managed in strategic locations in order to enhancement of vistas or highlighting interesting perpetuate middle and background views. rock outcrops. In most cases, the objective is to promote the health and vigor of vegetation to Portions of the Metolius-Windigo trail will be promote long term scenic quality. The prevention relocated to more compatible allocations Manage- of insect infestation and mortality is almost always ment activities along this recreation trail will be a benefit whenever trees are thinned to meet done with a greater sensitivity than those of the these visual goals. past, even where the trail is within the General Forest allocation COMMENT Black Butte, Odell Butte and Green Ridge should be allocated to partial retention Black Butte should be classified as Retention COMMENT Avoid planting trees in rows; use Maintain the panoramic view over 'Peterson burn' random placement to avoid 'cornfield" appearance Protect scenic loop along Metolius-Windigo Horse Trail RESPONSE: Within visually sensitive areas adja- cent to roads and recreation sites, the Forest RESPONSE Black Butte was inventoried as Service no longer uses tree planting machinery Retention because it is such a prominent landmark which results in the uniform rows and spacing In on a relatively flat landscape. The Preferred these visually sensitive areas, reforestation is Alternative in the Forest Plan allocates the upper accomplished through natural regeneration or by third of Black Butte as a Special Interest Area, hand-planting. Both of these methods result in a and the remaining lower portion as Scenic Views, random-pattern and avoid the 'cornfield' appear- with a visual quality objective of Partial Retention ance. In other less visually sensitive portions of Given the vegetative types on Black Butte, it would the Forest, tree planting will continue to be be extremely difficult to meet the Retention objective accomplished by planting machinery because it is and still manage vegetation on this sensitive normally the most cost-effective method of reforest- landform. Without active management, the risk for ing larger areas. a catastrophic fire on the Butte would be greatly increased

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this reason, many of the travel routes designated COMMENT As one respondent said, "visual quality as Scenic Views in the Plan are not major highways. is in the eye of the beholder'. Some wrote to say that we should protect all visually sensitive Vegetative management along road corridors and landmarks on the forest and another stated that within other visually sensitive areas is a major we should consider allocating only major highways thrust in our Viewshed Planning program on the to scenic management. One respondent said Deschutes National Forest. Landscapes with little diversity should be improved along roadsides or no variety are often enhanced through vegetative through timber management. management. Landscapes are dynamic, and even those areas of high aesthetic value may require RESPONSE: It is true that visual quality is in the some management to retain desired visual charac- eye of the beholder. However, research has shown teristics. that the majority of recreation-oriented people who visit the National Forests have an image, or mental picture of what they expect to see when COMMENT: The Deschutes and Metolius Rivers they visit the National Forest According to this should not be allocated to Intensive Recreation research, the majority of visitors expect naturally They should be set aside for scenic beauty and protection of their streamside corridors. appearing landscapes, rather than altered land- scapes resulting from management activities For RESPONSE. Protection of visual quality is actually this reason, the Forest Service has developed a provided more adequately under the Intensive Visual Management System to serve as a frame- Recreation allocation than It is in Scenic Views work that establishes objectives for setting allow- because there is no scheduled timber hawest able degrees of alteration to natural landscapes planned for Intensive Recreation. True, more and more people will want to enjoy the scenic and The Visual Management System recognizes recreational attractions these rivers have to offer, variations in the visual strength of different land- and overuse is a definite management concern. scapes Those landscapes with special features However, potential resource damage to streamside normally have the most variety and also have the corridors can be avoided through careful recreation greatest potential for high scenic value. master planning and site design. Changing the allocation for these rivers to Scenic Views, or any Landmarks with distinctive land forms, rock forms, other allocation in an attempt to 'protect' them vegetation, lakes and streams normally are from recreationists would be futile. They are set inventoried as having the highest degree of variety aside for all of us to use and to enjoy. on the Forest. Because of their uniqueness, they are given a high visual quality objective and are therefore 'protectedn from management activities COMMENT: Major roads through the Forest are that could result in obvious alterations to the visual used for destination driving, more than sightseeing. resource. What evidence suggests that visual considerations are more important along these roads than along The Visual Management System identifies degrees other travel routes? of visual sensitivity for all travel routes in the Forest land base. Determinants such as national or local RESPONSE One of the premises upon which the importance, public concern for aesthetics, and Visual Management System was built is that the the long range function for each travel route is number of viewers is critical As a general rule, considered Some relatively small, secondary the visual sensitivity of different parts of the forest roads are considered to be visually sensitive become more important as the number of viewers because they are located within outstanding increases. All areas viewed from primary travel scenery, are traveled by large numbers of people routes, especially roads that have been classified who are vely concerned about visual quality, or by State or other agencies as 'scenic highways', because they lead to major recreation sites. For have relatively large numbers of viewers While a

Appendix J - 135 Appendix J Alternatives, Data Analysis, & Planning Process

large percentage of people on these highways RESPONSE. The National Forest Visual Manage- are involved with daily commuter driving, or hauling ment System inputs the visual resource as an forest products and other commercial uses, there integral component to the land use and multiple are also many motorists who have a major concern use planning processes. The system recognizes for aesthetics For these 'major roads', manage- that landscapes are dynamic and that even those ment activities are normally designed to meet a areas with high aesthetic value may require some visual qualm standard where management activi- management activity to retain the valued character. ties are not noticeable to the Forest visitor. Large In Scenic Views allocations small clearcut units diameter, yellow-barked ponderosa pines are an are used to create vistas or to highlight special important element in these landscapes, especially landscape features But, as a general rule, clearcut- in foreground viewing distance zones. The Forest ting in visually sensitive parts of the Forest is only Service will perpetuate this character on all primary used as a last resort, such as in lodgepole stands corridors. In secondary corridors that receive attacked by mountain pine beetles Uneven-aged substantially less traffic and that are used primarily management strategies are preferred because for forest management activities or for hauling they normally produce and perpetuate the size- forest products, the visual quality objective is class and species diversity that is found in high often different. quality forest landscapes.

COMMENT The Little Deschutes River, Crescent COMMENT It seems irresponsible to assume no Creek, Big Marsh Creek, Squaw Creek, and Brush value to our views of the forests, mountains and Creek should be managed for Retention rivers. Clear cutting practicesthat leave our hillsides checker boarded in an unnatural pattern or allows RESPONSE: The Visual Management System them to erode into our rivers will potentially cost considers two factors in developing the recom- individual landowners through loss of land value mended Visual Quality Standards: Variety Class (physical features of a landscape), and Sensitivity RESPONSE. There is no doubt that a parcel of Level (types and numbers of viewers). Each of land with a view of a naturally-appearing forest these factors is explained in detail in National landscape is worth more than a similar parcel Forest Landscape Management, Chapter One, without a view. The Plan does not 'assume' that The Visual Management System (Agriculture scenic views have no value It merely does not Handbook Number 462). The System does not attempt to place a dollar value on one view 'weigh' the visual strength of one river or creek compared to another. While some research has against another on the same Forest, as was been done to establish the cash value of a suggested in this comment. The rivers and creeks high-quality landscape, no conclusive data has mentioned did in fact rank highly in the Variety been published to date Class portion of the inventory, but most portions of these streams did not rank highly enough in the numbers of recreational viewers to qualify COMMENT It is of utmost importance to now them for the Retention allocation However, most undertake long term planning for the Squaw Creek lands adjacent to these rivers and creeks have a corridor and scenic loop. All aspects of the corridor Partial Retention visual quality standard, which make it an ideal "undeveloped recreation" site and will protect the scenic values of the characteristic it should be managed as such in the Forest Plan. landscape. The remaining 9 miles of the Squaw Creek scenic loop should also be visually protected

COMMENT Clear cutting affects any visual RESPONSE. We agree that this is a significant scenery. In Central Oregon, our scenery is a landscape that should be maintained in a primarily tremendous asset. To destroy this asset is a real natural condition for its recreational values. The crime. Please consider any visual affect as a primary Preferred Alternative now includes a scenic corridor requisite to forest planning. along Squaw Creek, including the scenic loop

AppendDc J - 136 Appendix J Alternatives, Data Analysis, & Planning Process

mentioned in the above. Thevisual quality standard RESPONSE: This is largely the direction of the is Partial Retention. Plan. Lodgepole pine (jack pine), the white fir species and second growth ponderosa pine will receive higher emphasis. COMMENT Certain portions of the Metolius- Windigo National Recreation Trail should be managed visual management. Clearcutting/Uneven-Aged Management

RESPONSE: The Plan now provides a minimum COMMENT Many people objected to clearcutting visual quality standard of Partial Retention for the in ponderosa pine stands Some people also entire trail in Foregrounds. In addition, some objected to clearcutting in mixed conifer stands Middleground areas viewed from the trail have and a few objected to clearcutting in general. The Retention and Partial Retention standards. Howev- overwhelming reason given was that it reduced er, there will be some Middleground and Back- biological diversity. Additional reasons given were ground portions of the Forest viewed from the that clearcutting created a monoculture, reduced trail that will be managed to the Modification wildlife habitat, and created a tree farm appearance standard. Others pointed out that NFMA requires an analysis of other cutting methods before clearcutting can be used Many people wanted some form of selective harvest or uneven-aged management, Timber Management particularly in ponderosa pine stands Afew people commneted that clearcutting should be used only COMMENT. The plan would not generate economic when necessary to control insect and disease development opportunlties. Limiting the allowable problems. harvest of ponderosa pine limits the raw material available to mills in the area. At the level specified RESPONSE Uneven-aged management has been in the plan, the allowable harvest of lodgepole adopted as the preferred method of managing pine would allow the proposed new waferboard ponderosa pine stands in the General Forest and plant to be built, though the company considering Scenic Views management areas Approximately the investment may find Canadian sites more 70 percent of these stands will be managed with attractive and has concerns about a long term uneven-aged management. In all other manage- resource Much of the existing lodgepole pine ment areas, it is given equal consideration with resource is expected to go for firewood. There is other silvicultural systems, but the specific manage- not much the state can do to counter the anticipated ment objectives of these areas (1.e. deer habitat effects of this plan. That is why we advocate that management) will direct the selection of the the forest service develop a new alternative that silvicultural system. (See standards/guidelines for increases the allowable harvest for the reasons Uneven-aged Management.) It is also the preferred enumerated above. method of managing mixed conifer stands, but topography, insects and disease problems will RESPONSE Alternative C maximizes the amount limit use to approximately 48 percent of these of timber that the Forest can offer and still maintain stands. Lodgepole pine are generally not suitable long-term sustained yield. Harvest above this level for uneven-aged management at this time, largely would not be legal or adequately provide for the due to mountain pine beetle problems. utilization of other resources, which the Forest must do. COMMENT Shelterwood harvesting is really a 2-stage clearcut It creates openings too large Departure/Long-Term Sustalned-Yield and has a great visual impact.

COMMENT: Cut less ponderosa pine in general. RESPONSE. Shelterwood harvesting can have a Clean up 'jack' pine and white fir significant visual impact As a result of this concern,

Appendix J - 137 Appendix J Alternatives, Data Analysis, & Planning Process

the Forest Plan prescnbes uneven-aged manage- Forest Inventory ment as the preferred harvest method in most ponderosa pine stands and, where possible, in Utilization Standards muted conifer stands. In existing shelterwood units consideration will be given to retention of COMMENT Many people objected to the harvest some overstory trees to accelerate the eventual of young, rapidly growing trees that were mixed conversion to uneven-aged management. in with other trees.

RESPONSE The direction for uneven-aged COMMENT Do not clearcut along the Metolius- management should deal with this concern (see Windigo horse trail standards/guidelines for Uneven-aged Manage- ment). RESPONSE Most of the Metolius-Windigo horse trail is within the General Forest or Scenic Views management areas. The direction for uneven-aged COMMENT Some people wanted large old-growth management, described above, will apply. ponderosa pine harvested before it rotted RESPONSE. It is recognized that there will be COMMENT Leave snags in ponderosa pine some increased deterioration in stands of old- growth ponderosa pine. In the Forest Plan there clearcuts and designate replacement snags for has been an attempt to balance the needs of the wildlife. timber industryfor this raw material and the desires of people who want to see them left uncut RESPONSE. This is standard practice today and these practices are included in the Plan, Chapter 4 standards/guidelines. COMMENT. Most comments expressed concerns about environmental effects of harvesting such as the need for managing the landscape to prevent COMMENT ClearcuKing has opened up views of unacceptable visual effects, consideration of wildlife the mountains. habitat and recreation needs, and preserving roadless areas from harvesting. RESPONSE. The opportunity to create additional vistas is recognized as important in the Scenic RESPONSE. The effects of timber harvesting can Views management areas and this practice is be seen both negatively and positively. Short-term incorporated in the Forest Plan standards/ effects tend to be more negative than positive in guidelines. the areas of concern such as visual quality. wildlife habitat, and recreation, however, long-term effects in these areas are designed to be positive It is COMMENT There is concern about plans for old the Forest Service’s intent and management growth ponderosa pine management and the direction to manage for the long-term, recognizing long-term economic impact of the proposed policy. that some short-term adverse effects will result. When identifiable. these effects are softened RESPONSE: Several of the alternatives examined through mitigation actions guided by administrative in detail provided for increased harvest levels policies and procedures such as the National Forest timber sale contract, NEPA and NFMA regulations, and locally developed management COMMENT Many people were opposed to Standards and Guidelines On the Deschutes increases in the harvest level. National Forest approximately 50 percent of the forest land area suitable for timber production has RESPONSE: The Final Plan does not call for an been allocated to non-timber uses, such as visual increase in harvest level. quality, wildlife habitat, and recreation. As a result,

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timber harvest projections have been significantly COMMENT Commercial firewood cutting was reduced. However, along with these recognized also an issue with some people. Small commercial values and uses the welfare of the local economy firewood cutters wanted the Forest Service to must be considered. Based upon current informa- charge more for permits to lessen the competition tion and public input, the proposed timber harvest Some were concerned about the amount of level reflects the concensus 'best overall blend' of firewood being sold out of the area. Others wanted land uses. no commercial firewood cutting at all. RESPONSE Commercial woodcutting has a recognized place on the Deschutes National Forest Tlmber Stand Improvement/Lodgepole Pine It provides a means to salvage surplus dead timber in a controlled manner from difficult access areas, COMMENT. The projected accelerated lodgepole more distant areas, and restricted-use areas. harvest increases losses in deer and other wildlife Commercial firewood cutting also provides a habltat. Timber and wildlife habitat can be managed livelihood for a segment of the population and a by using road closures, reduced road designs, service to those who cannot, or do not wish to, public education, etc cut their own firewood. The sale of firewood out of the local area is not something the Forest Service RESPONSE These proposals are all incorporated can control Firewood permit fees have been in the Final Forest Plan. established according to the best estimate of the wood value and Forest Service administrative costs Changing economic factors may cause Firewood future rate changes

COMMENT Need firewood supervised areas. in COMMENT The firewood program is good. It is a Open all bug kill areas. Provide summer youth reasonable way to salvage dead and dying jobs to help clean up the forest. Cut down on lodgepole pine. upper management and payroll throughout the system. Reserve some firewood areas close to RESPONSE The Forest plans to maintain an residential areas for senior citizens' exclusive use. aggressive firewood program. Open more areas for firewood cutting.

RESPONSE Efforts will be made to provide COMMENT Offer more firewood on a non- firewood close to residential areas The entire competitive basis. Forest is open except areas identified on the permits which are closed for Administrative reasons RESPONSE. The personal-use and free-use or prior contract commitments and obligations. firewood programs are non-competitive. Commer- More free-use areas will likely be identified, cial firewood sales must be sold competitively if there is a competitive demand. however.

COMMENT Firewood cutting is part of Central COMMENT The firewood program has related Oregon's recreation. Alternative heating systems problems, such as cutters making little roads are too expensive. All lodgepole pine should be everywhere, fire danger from smoking and power managed for firewood. It is critical to the community saws, increased vandalism, abuse of permit system. RESPONSE. It is the intent of the Forest to manage RESPONSE: There are problems associated wlth lodgepole pine for a continuing firewood supply the firewood program but the Forest will attempt of approximately 30 million board feet or 60,000 to control wlth proper administration of the program. cords annually. Most public input regarding the

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planned 60,000 cords was posltive and suggested RESPONSE Where ecologically feasible and this was an appropriate quantity. It is not feasible consistent with plant community guidelines, to manage all lodgepole pine strictly for firewood ponderosa pine may be used to replace currently consumption when there exists significant market existing lodgepole pine. However, preference demands for lodgepole pine to be used for other given to one species over another must consider product consumption. economics, long-term stand health and vigor and specific management area objectives Strong consideration should be given to the maintenance COMMENT: Lodgepole pine has value beyond of biological diversity. (See Species Preference and Biological Diversity the Timber Management use for firewood. I sell lodgepole 1 X 4 and 1 X in standards/guidelines.) 6s in wlth #2 common ponderosa pine.

RESPONSE: The manufacture and marketability Insect and Disease of lodgepole pine lumber has known values above that of firewood, which identifies it as a commercial COMMENT Control insects and disease by species. Most of the commercial lodgepole pine avoiding monocultures not reserved for firewood will be managed for the commercial market. RESPONSE: This idea has been applied on the Forest for at least 25 years Specifically, what we have called 'host selection' has been practiced to COMMENT' Let the public have access to slash reduce the spread of dwarf mistletoes Dwarf piles. It is a waste to burn them. mistletoes are essentially infectious only to their own specific host species. By maintaining a mix RESPONSE Standards/Guidelines include direc- of species, the spread of any specific dwarf tion for slash piles to be made available to the mistletoe can be greatly reduced The Forest public for at least a year. In the last few years, inherited vast monocultures of lodgepole pine areas made available for this use have increased which were established before the turn of the as has the numbers of free-use permits issued. century. These stands have been largely decimated Best successes in this program have been in by the mountain pine beetle epidemic of the last areas within 20 miles of town and along malor, 10 years. Where appropriate, we have been paved roads. replacing the previous pure lodgepole pine stands with new plantations of mixed ponderosa pine and lodgepole pine, or pure ponderosa pine In Reforestation areas where raising pure stands of lodgepole pine is overridingly sensible, we intend to handle the bark beetle problem through stocking level COMMENT Economics of artificial regeneration control (thinnings) and rotation ages generally not are questionable when you consider the cost of exceeding 80 years. operating a nursery, slte preparation, and general administrative costs. Natural regeneration is the best economically. COMMENT Use an integrated pest management program. RESPONSE As described above, naturalregenera- tion will be the preferred method except where It RESPONSE: During the past decade the Forest's is not reliable. most severe insect and disease problem has been an epidemic infestation of mountain pine beetles. In 1981 the Forest put together a strategy COMMENT: Cut the lodgepole pine on the east to handle the problem (re: 'Environmental Assess- side of the Fort Rock District and reseed with ment - Lodgepole Pine Management', 8/31/87). In ponderosa pine. 1987 the strategy was modified to more adequately

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deal wlth current MPB activity (re: ‘Bark Beetle Recreation) the objectives are to produce and Infestation In Ponderosa Pine and Lodgepole Pine maintain large yellow barked trees This will also Environmental Assessment’, 3/11/87, revised be the case where pine stands are being managed 8/12/87). The programs spelled out in these for nesting habitat for bald eagles. Management documents were Integrated Pest Management Area 15 (old Growth) was established to provide (IPM) programs. additional stands of old growth and includes ponderosa pine. Some large ponderosa pine will also be left in areas where timber production is COMMENT: There are two bat species which being emphasized as a result of uneven-aged need old growth that are the only major nocturnal management. predators of insects in North America. Prey includes adult tussock moths, 3 species of bark beetle, and crane flies. Tree Improvement

RESPONSE: Our old growth areas are intended COMMENT Existing resistance to the mountain to benefit many species of animals - bats included. pine beetle should be propagated.

RESPONSE Forest Research has not shown the Pestlcldes propagation of mountain pine beetle resistant trees to be scientifically proven or operationally COMMENT Use limited or no toxic chemicals. efficient for Forest-wide applications. This process would necessitate applications of artificial regenera- RESPONSE: Chemicals are not used to control tion or planting, which is not cost-effective in unwanted vegetation on the Forest. Pesticides are lodgepole pine. Future developments may surface used only when there is no other reasonable which make this a preferred practice. alternative The use of pesticides for the control of rodents or insects is strictly controlled and monitored, and used only where absolutely Old Growth necessary. COMMENT. We need to preserve old-growth timber in recreational areas. COMMENT Alternatives to pesticides are selective harvesting and manual brush control and manual, RESPONSE. Old growth will be protected in mechanical, or spot application to actively control recreational and other areas that are not part of invasive non-native noxious weeds. the timber base.

RESPONSE. The Forest utilizes all these tech- niques. COMMENT It is very important to keep off-road vehicles out of the designated old-growth area east of Black Butte Ranch in alternatives ‘E” and Ponderosa Pine EGG’.

COMMENT Stands of older ‘yellow belly or red RESPONSE We are implementing restrictions of bark’ ponderosa pine must be maintained through- off-road vehicle use in the area south of Black out the Forest and not just limited to a few token Butte. Off-road vehicle use will be restricted to areas. specific areas when such routes are in compliance with management of Special Interest Areas. RESPONSE Stands of ‘yellow belly or red bark‘ ponderosa pine will be provided for as a result of several things. Where ponderosa exists in Manage- COMMENT The old growth in the Metolius Breaks ment Areas 9 (Scenic Views) and 11 (Intensive area should be preserved.

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RESPONSE: Other Forest management areas Area. Retention of old-growth ecosystems IS (visual retention and partial retention, experimental favored in Alternative F. A minimum of 10 percent forests, and undeveloped recreation) will help to of the forested plant communities should be retain old-growth areas that do not fall under an managed as old growth Alternative A adequately old-growth management area. protects old growth Favor 8 percent old-growth ponderosa pine and other species Favor 5 percent old growth outside of Wilderness, Roadless, and COMMENT. Favor locating Some old growth Central Oregon Recreation Areas. Alternative F is accessible to the public supported because of its emphasis on old-growth retention. Alternative C will retain 8 percent old RESPONSE: Because of the flat terrain and growth. This, in combination with old growth in abundance of roads on the Forest, public accessi- wilderness, is adequate. bility to some old growth is assured. RESPONSE The Preferred Alternative (E)will maintain 326,400 acres of the Forest in an COMMENT. Retain the old-growth area on the old-growth condition at the end of the first decade, north slope of Black Butte of this approximately 32,000 acres will be in the old-growth allocation. The additional areas of old RESPONSE The top third of Black Butte will be growth will be in wilderness, undeveloped recre- managed as a Special Interest Management Area, ation, spotted owl habitat areas, management where timber harvest is not scheduled. The requirements for mature and old-growth dependent management goal is to preserve and provide species, research natural areas, Bend's watershed, interpretation of unique geological, biological and winter recreation areas, and the Oregon Cascade cultural areas for education, scientific, and public Recreation Area Also large diameter trees will be enjoyment purposes. available in bald eagle management areas, visual zone and campgrounds The Preferred Alternative indicates that adequate habitat will exist to maintain COMMENT: Favor 8 percent old growth in Wilder- ness, Roadless, and O.C.R.A. viable populations of all vertebrate species that occur on the Forest. RESPONSE: Preferred Alternative will have 223,000 acres of old growth in Wilderness, OCRA and The Preferred Alternative provides more acres of other management areas not specifically managed old growth than Alternative A. only for old growth Additional forested land area will be managed for old growth COMMENT If large trees die in old-growth forest, why not harvest them instead of their being COMMENT. Favor maintaining old-growth pon- 'wasted " derosa pine along Highway 20 north of Sisters. RESPONSE Certain wildlife species depend on RESPONSE: The area along Highway 20 west of the structural conditions found in old-growth forest Sisters is to be managed for scenic views (Retention Standing and down dead trees are an important visual quality objective) This means that large, part of this kind of habbat, thus these dead trees "yellow-bellied' Ponderosa pine will be maintained are not *waste' to dependent animals. over time

COMMENT. Recommend less old growth than COMMENT The following comments related to proposed the same subject represent a variety of viewpoints. We should preserve old growth in Wilderness, RESPONSE The Preferred Alternative has the Roadless and the Central Oregon Recreational optimum level of old growth to provide viable

Appendix J - 142 Appendix J Alternatives, Data Analysis, & Planning Process

populations of old-growth dependent wildlife with COMMENT‘ Do not log along Wickiup Reservoir. the least reduction upon timber yields. RESPONSE. These stands are primarily lodgepole pine which is dying because of mountain pine COMMENT Favor no geothermal development in beetle infestation. The trees will fall over within a old-growth areas. few years after death. The Forest has decided to remove the dead and dying trees and regenerate RESPONSE: Standards/Guidelines developed for a new stand. old-growth areas allows no surface occupancy for geothermal development COMMENT: The Forest should provide a diversity of vegetative communities Do not manage the COMMENT: As the following indicates the com- Forest as a tree farm. ments relating on rather or not to harvest old growth varied from one extreme to the other. No RESPONSE: The Preferred Alternative identified different management intensities in different areas more old growth should be harvested. It is too areas, valuable a part of Oregon’s heritage. Old-growth Some areas (wilderness, spotted owl old-growth areas, Bend watershed, and bald eagle forests should be planned for and eventually areas) will have very few vegetative management harvested. Moratorium on old-growth harvesting activities. Other areas will be managed more old growth. Let natural selection Allow no harvest of intensively (within limits) to encourage tree growth. work within the old-growth stands. Prescribed fire will also be used to maintain vegetative diversity in nonforested areas. It IS not RESPONSE. The Preferred Alternative provides the Forest’s objective to become a tree farm. the best mix of old-growth stands as well as stands managed for timber production Natural Selection will occur within the designated old-growth stands COMMENT Small pockets, as well as large, of as well as in surrounding stands. Genetic diversity old growth should be retained because of their will be maintained over the forest landscape. value. Old-Growth Management Areas will have no scheduled timber harvest or other silvicultural RESPONSE: The Forest is maintaining relatively treatment because the science for achieving large stands of old growth Most are over 100 desiredforest structure and function is in its infancy. acres. The rationale is that larger stands will return Management can be initiated at any later date genetic diversity better than small stands Thus, when knowledge base is good. rather than retain many small, scattered stands of old growth, the Preferred Alternative will retain fewer, but larger, stands of old growth COMMENT Alternatives G and H should be selected because of their emphasis on wildlife habtat and old growth COMMENT Large areas of old growth need to be preserved to retain valuesfor scientific, recreational, RESPONSE. The Preferred Alternative was selected scenic, wildlife habitat, biological purposes, and because it provided the best mix of forest product for a diverse gene pool outputs, wildlife habtat conditions, and old growth. Approximately 326,400 acres of Forest stands will RESPONSE: The Forest recognizes the important be retained as old growth in the Preferred Alterna- of these values and uses. The preferred alternative tive at the end of the 1st decade. These areas in the proposed Forest Plan has identified specific provide habitat for old-growth dependent wildlife old growth areas which will be managed to retain The remaining forest will also provide habitat for old-growth characteristics. Other areas such as other wildlife while providing timber outputs as research natural areas, the Bend municipal well. watershed, spotted owl management areas, and

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some portions of wilderness areas will provide condition at the end of the 1st decade This will forested areas with old growth characteristics. contribute to providing habitat for viable popula- Additional areas with some old-growth characteris- tions of all vertebrate species found on the Forest tics (large ponderosa pine) will also be retained in bald eagle management areas, and scenic view areas. COMMENT. Only 5 percent of each drainage will be maintained as old growth

COMMENT Retain old-growth stands in a well- RESPONSE. The topography of the Forest is not distributed pattern to preselve a diverse genetic characterized by drainages 326,400 acres of base. forest will be in old growth at the end of the 1st decade RESPONSE The Preferred Alternative identified specific management areas where old growth will be retained Other areas, not specifically designat- COMMENT A higher percentage of old-growth ed for old growth, will also provide relatively ponderosa in the allowable cut is favored. unmanaged forest areas which will provide a diverse genetic pool The distribution of these RESPONSE: We believe the Preferred Alternative areas was one of the major considerations in (E) provides the best combination of old growth selecting old-growth stands. and timber commodity outputs.

COMMENT. More old-growth ponderosa pine COMMENT Support of old-growth areas east of needs to be retained and not limited to a few Black Butte Ranch token areas. RESPONSE. The Forest has incorporated this RESPONSE: The Preferred Alternative was selected concern into the preferred alternative because It provided the best combination of old-growth and timber commodity outputs. COMMENT Some areas of old growth would probably be subsidized by taxpayers to harvest COMMENT Desert fringe on the Fort Rock District timber should be managed for deer and old-growth ponderosa. Evaluate need for more guzzlers. RESPONSE Generally, timber sales of old-growth timber make a profit for the Treasury, rather than RESPONSE. The majority of the desert fringe will cost more than stumpage pays be managed to optimize deer habltat. Some old growth stands of Ponderosa will be retained, but deer cover requirements can be met in stands COMMENT' Old growth is a timber 'crop' and it which are not old-growth stands Distribution of should be harvested prior to the loss of this guzzlers is being evaluated according to guidelines resource Old-growth areas should be preserved for habitat requirements. Addition of more guzzlers Old growth is a unique and essential part of the will be evaluated. Forest These areas are an 'economic commodity' from a visual, recreational and wildlife basis.

COMMENT' Maintaining old growth is one of the RESPONSE In old growth areas where the primary prime keys to protecting wildlife Removing old objective is not timber production the Forest growth impoverishes whole ecological systems. management goals include: 1) providing habitat for viable populations of all vertebrate species RESPONSE The Preferred Alternative will maintain currently found on the Forest and to maintain or 326,400 acres of the Forest in an old-growth enhance the overall quality of wildlife habitat, 2)

Appendix J - 144 Appendix J Alternatives, Data Analysis, & Planning Process

to provide quality recreational opportunities in populations threaten the preservation of some undeveloped Forest environments; 3) to provide representation of vegetation for which the natural visitors with visually appealing scenely; 4) to area was originally created provide old-growth tree stands for preservation of natural gene pools and to contribute to the overall forest dnrersity. COMMENT Ensure that the animals have sufficient habitat in wilderness to survive and prosper Protect and conserve the Wilderness and its wildlife for COMMENT. Alternatives A, B, and C also preserve the benefit of its inhabitants not just the recreational insufficient amounts of old growth pursuits of humans or the economic gain its resources bring. RESPONSE: One of the reasons for the Preferred Alternative (E) is it has a good mix of uses and RESPONSE. The plan protects all wilderness still meets the needs of mature and old-growth areas designated in the 1964 and 1984 Wilderness dependent species Acts. Under the Preferred Alternative the Forest provides for the following management areas for wildlife: Bald Eagle, Northern Spotted Owl, and COMMENT It is important to preserve more old Osprey. In addition, the following areas provide growth on the Forest than is identified in the Forest habitat for wildlife that will not be entered for timber Plan. harvest: Research Natural Areas, Wilderness and Old Growth. The Wilderness allocation conserves wilderness. RESPONSE Old growth will be in wilderness, undeveloped recreation, spotted owl habltat areas, management requirements for mature and old- COMMENT Manage for species diversity and growth dependent species, research natural areas, richness. Bend's watershed, winter recreation areas, and the Oregon Cascades Recreation Areas Also RESPONSE The Preferred Alternative was selected large diameter trees will be available in bald eagle because it provided for a mix of uses and still management areas, visual zone and campgrounds. maintained species diversity. There will be a specific species numbers but all endemic species will be represented on the Forest. COMMENT The timber industly should utilize more second growth and we should preserve more old growth. COMMENT Defer logging in the game species allocation surroundrng Black Butte Ranch for RESPONSE The Preferred Alternative (E) would three decades. Recommend no hunting zone reduce the harvest of old-growthhature trees adjacent to the ranch for public safety. and increase the utilization of second growth. RESPONSE The management areas around Black Butte Ranch have changed. In the Preferred Wildlife & Fish Alternative the area east of the ranch is an old-growth area. Areas bordering the ranch on COMMENT Management Area2 (Research Natural the north, west, and south are wood-forage areas Area) - more game grounds, not hunting. which will be logged at some time in the future Deferment of these areas from logging cannot be RESPONSE: The Regional Forester and the assured. However, visual quality of stands sur- Director of the Pacific Northwest Forest and Range rounding the ranch will be considered when these Experiment Station may authorize management stands will be managed. Hunting on the Forest practices to control excessive animal populations. lands will continue unless agreements with ODFW This would only be done in cases where these are developed.

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COMMENT. Special uses which result in constant COMMENT: Deer and elk could be maintained or activity should not be allowed in deer habitat. increased by careful management of logging areas, attention to calving grounds, winter ranges, RESPONSE Project level interdisciplinary teams migration routes, grasslands with respect to wildlife will determine mitigating measures for activities (not domestic livestock) and seasonal restrictions that would reduce habitat effectiveness. of activity in critical areas

RESPONSE: All of these management concepts COMMENT River Study suggests that Deschutes are available for consideration by project interdisci- County should support periodic or seasonal road plinary teams during timber sale planning closures to minimize harassment conflicts on winter range and other sensitive wildlife habitat. COMMENT. Marten populations seem to be in RESPONSE Under the Preferred Alternative local jeopardy. roads may be closed on a seasonal basis and would be coordinated with the ODFW RESPONSE Habitat for the pine marten will be available in management areas emphasizing Old Growth, Wilderness, Undeveloped Recreation, COMMENT. Alternative "E' -- One of the primary Research Natural Areas, Spotted Owls, Bend concerns of ODFW regarding mule deer manage- Municipal Watershed, and the Oregon Cascade ment in Central Oregon is the continuing encroach- Recreation Area. Some Special Interest Areas, ment on deer migration corridors between summer Wildlife Management Requirement areas, and big and winter ranges. Oregon Hunters Association game cover areas located within other management shares this very critical concern and would ask areas will also provide Suitable habitat. The that this question be addressed in their future proposed outputs of pine marten to meet the land adjustment plans. Recent land exchanges desired future condition of the Forest call for more between USFS, Sunriver, and the Inn of The than 1,285 pairs Seventh Mountain have served to encroach on mule deer migration routes We need to encourage all public agencies to preserve those migration COMMENT. More acres should be allocated to corridors owls and ospreys from General Forest

RESPONSE: The Deschutes National Forest RESPONSE Under the Preferred Alternative, intends to study deer migration patterns in order osprey nest sites located outside the Osprey to learn more about specific corridors used Management Area will be maintained Habitat for owls that use cavities will be maintained at 60 percent of maximum population potential Other COMMENT Questions whether annual surveys of nest sites and habitat can be maintained in General osprey nests will occur Forest at the discretion of project interdisciplinary teams. RESPONSE: Monitoring of osprey habitat will seek answers to questions whether desired nesting population levels are being reached and whether COMMENT: (we need more) consideration for reproductive success is adequate to maintain the wildlife population over time. Annual nest occupancy surveys and fledgling success surveys will be RESPONSE The Preferred Alternative provides conducted cooperatively by the Forest Sewice that habitat will be provided for viable populations and ODFW. of all vertebrate species found on the Forest

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COMMENT Manage for 125 pairs of ospreys by COMMENT Prefers Central Oregon Alternative, leaving 10 trees per acre on each current active 'There are enough natural resources being nest site. destroyed now Leave the trees and wildlife alone ''

RESPONSE Under the Preferred Alternative all RESPONSE: The Preferred Alternative provides existing osprey nest sites and associated perch for a system of management that attempts to trees will be protected. Wth many nest sites being maintain habitat for viable populations of all lost to natural causes, an artificial nesting structure vertebrate species found on the Forest program may be required.

COMMENT. The goshawk and great grey owl COMMENT: Provide other wildlife management must receive protection in specific management alternatives besides lust dedicating wildife habitat areas. areas, in order to ensure adequate wildlife popula- tion levels. RESPONSE Under the Preferred Alternative goshawk nesting habitat is available in manage- RESPONSE: The Preferred Alternative provides ment areas emphasizing. Old Growth, Wilderness, that habitatwill be maintainedfor viable populations Undeveloped Recreation, Research Natural Areas, of all vertebrate species found on the Forest. Spotted Owls, Bend Municipal Watershed, Winter Recreation, the Oregon Cascades Recreation Area, and Wildlife Management Requirement areas COMMENT: Natural predators such as the cougar, Suitable goshawk nesting habitat may be available bear, badger, coyote, and others should be in management areas emphasizing osprey In encouraged to return to their niches in the addition, specific standards/guidelines protect ecosystem through identification and protection of nest sites and nesting activities at active nests their habitat Regarding the great grey owl, standards/guidelines have been developed to protect nest sites, activities RESPONSE. Under Preferred Alternative, habitat at active nests, and the forested perimeter around for badgers and coyotes will be provided through- meadows in which nesting owls are suspected to out the Forest. Habitat for cougars will be provided hunt. throughout the Forest where an adequate big game prey base occurs. Habitat for bears will be available in management areas emphasizing Old COMMENT. If old-growth levels continue to diminish Growth, Wilderness, Undeveloped Recreation, to levels below 12 percent, summer roost sites for Research Natural Areas, Spotted Owls, Bend bats may be limited and local populations may be Municipal Watershed, Winter Recreation, and the reduced to dangerous levels. Oregon Cascade Recreation Area, some Special Interest Areas, Wildlife Management Requirement RESPONSE The Preferred Alternative will maintain areas and big game cover areas. adequate Forest land in an old growth condition Also, large individual old growth trees will be available in other allocations such as visual and COMMENT The draft plan's clearcutting use is bald eagle management areas. The National Forest too heavy and works against species diversity Multiple Use Sustained Yield Act mandates the and richness. National Forest system to maintain viable popula- tions of all endemic populations. If research data RESPONSE: The Preferred Alternative provides suggests that present management does not for maintaining habitat for viable populations of all meet the needs of a species, the Forest will take vertebrate species found on the Forest adequate protection measures

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COMMENT: The Plan should be more specific COMMENT: Develop a budget to employ at least with regard to wildllfe and fisheries management. one fish biologist at the Supelvisor's Office and a biologist at each District. RESPONSE: The Preferred Alternative contains specific standards/guidelines for the following RESPONSE: A fish biologist is employed at the Supewisor's Office and Wildlife Biologists are species: northern goshawk, Cooper's hawk, employed at each District. sharp-shinned hawk, mule deer, elk, bald eagle, spotted owl, osprey, great gray owl, pine marten, northern 3-toed woodpecker, wolverine, peregrine Deer Numbers falcon, great blue heron, trout, waterfowl, and Townsend's big-eared bat. In addition S&Gs for COMMENT: Maintain a high level of deer maintenance of snags pertain to species that excavate cavities and species that are secondary RESPONSE The Preferred Alternative meets the users of cavities. Habitat for species associated management objectives agreed to with the Oregon with mature and old-growth tree stands will be Department of Fish and Wildlife. provided for. Habitat for species utilizing dead andlor downed trees will be provided throughout the Forest. COMMENT: The deer population should be at a higher or lower level than in the Preferred Alterna- tive. Tradeoffs between resources need to be recognized. COMMENT: The amount and emphasis on wildlife habtat improvement and maintenance is not RESPONSE The ODFW has developed population enough in the preferred alternative compared to objectives for deer on the Forest. The Forest will other alternatlves. work to meet these objectives through 1) manipula- tion of timber stands for thermal and hiding cover, RESPONSE Wildllfe habitat improvement and 2) use of prescribed fire and mechanical manipula- maintenance is an important part of the Preferred tions of forage to improve forage condition. and Alternative. Habitat is one of the uses within the 3) management of roads to increase habitat multiple-use spectrum. The Preferred Alternatnre effectiveness. The Preferred Alternative provides a of resources and deer populations are an has standards/guidelines to protect habitats. It mix important part of this mixture also has projected accomplishments for deer habtat improvement using prescribed fire and timber haNeSt. COMMENT: Increased harvest (departure) in lodgepole will not lead to increased deer numbers Other factors may also cause a decline in deer Fisheries numbers. Will the deer habitat simulation model adequately address all these factors? COMMENT: Coordinate with other Government agencies in regard to stocking of fish, trapping RESPONSE ODFW has developed population seasons. Coordinate with ELM for winter range for objectives for deer on the Forest. These objectives take into consideration factors which take place mule deer. outside Forest lands. The Forest will work to meet the objectives on the Forest by manipulating RESPONSE The Forest coordinate with ODW habitat. The deer simulation model has the on stocking of fish and has discussed beaver capability to address habitat effectiveness both trapping in areas where beaver numbers are low. on and off Forest lands. However, the model will The Forest and BLM have met together with ODFW be used as one tool of several to assess effects to discuss grazing on winter range. of Forest management on deer habitat If Forest

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projections of regeneration of hiding cover are RESPONSE. The Forest did not select Alternative found to be too optimistic, the outputs projected C. The Preferred Alternative will not develop as in the plan will be reevaluated. many areas with roads.

COMMENT: Reduce highway caused moltality of deer by widening the borrow pits. COMMENT: Hunters are willing to pay to camp in deer hunting areas. RESPONSE: The Forest IS developing a plan to address this problem along Highway 97 south of Bend. The plan considers visual quality, public RESPONSE: At present the Forest is not studying safety, and deer movement across the highway. or considering charging hunters to camp on the Forest except in developed campgrounds where all campers are required to pay a use fee COMMENT High road density and high deer numbers are incompatible, how are they recon- ciled?

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Elk Numbers COMMENT Increase game species management area above a minimum of 212,000 acres. Close COMMENT Under Alternative C the number of one-third of existing roads to improve deer habitat big game would increase (both deer and elk) These increases will bring additional recreational activities such as hunting, and animal watching, RESPONSE, The Preferred Alternative will manage which will bring more economic benefits to the over acres for deer Closure of existing 200,OO area roads will occur in cooperation with ODFW and in coordination with other resource activities and RESPONSE The Preferred Alternative (E) provides objectives. for an optimum mix of commodities and amenities

COMMENT Increase deer numbers by harvesting COMMENT. Wintering elk is limiting to population timber and increase fish numbers by improving size and is not present Elk are present in the water quality and by stocking. These increases winter. We believe Forest will support more elk will benefit bald eagle and osprey by increasing than are currently present and need to protect their prey base winter habitat.

RESPONSE The Forest and ODFW are working RESPONSE The Preferred Alternative (E) supports together to develop objectives for managing an increase in elk approaching 1,500 animals and fisheries The Preferred Alternative addresses new standarddguidelines will protect elk wintering habitat these objectives and projects increases in popula- tion levels of bald eagles Osprey populations are projected to decline due to lack of suitable nesting COMMENT Overpopulation of elk in Big Marsh sites as the number of large trees declines. basin is a concern

RESPONSE: The Preferred Alternative (E) does COMMENT. Alternative G doesn't provide enough not foresee any overpopulations campground development or a high enough deer population COMMENT. Added revenue to local economy as RESPONSE. The Preferred Alternative objectives a result of increased elk herds, huntable without are higher for campground development and damaging population deer populations than in Alternative G RESPONSE The Preferred Alternative E addresses increases in elk numbers which will have revenue benefits to the local economy COMMENT Deer and elk depend on old growth for protection during the winter. Populations will decline without old growth COMMENT. Adopt 0 H A. management practices to protect elk Elk winter on the Deschutes National RESPONSE Cover (hiding and thermal) for big Forest and there is an opponunity to provide for a game is provided not only by old-growth timber herd of 2,500 elk More protection needed than but also in timber stands managed to meet cover planned for in Big Marsh, along the Deschutes requirements Guidelines incorporated in the River and east edge of the Deschutes National Preferred Alternative will ensure that adequate Forest thermal and hiding cover, as well as other habitat quality parameters required for deer and elk, will RESPONSE. The Forest has formulated new elk exist to support the deer and elk populations management standardslguidelines which in many

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cases reflects public comments received on the study these areas in regard to their significance draft plan as deer and elk winter range habitat

COMMENT: There are 500 to 700 elk on the Forest. COMMENT' Road closures are not adequate to Elk herd expanding rapidly as timber harvest prevent disturbance to wintering deer proceeds Elk wintering on west side and some on southeast side. Timber harvest under industries RESPONSE Road closures are one tool that can preferred will increase elk which will probably be used to minimize disturbance to wintering reduce mule deer deer Another tool is an area closure. Enforcement is a cooperative effort with ODFW and OSP and RESPONSE There are approximately 750 to 1,000 the Deschutes National Forest elk on the Forest. No evidence to date supports that expanding elk populations are displacing mule deer populations Wildlife Diversity

COMMENT Need more organic methods in order COMMENT: Create conditons for larger herds of to preserve integrity of ecological cycles deer and elk. RESPONSE. The Forest Plan addresses the use RESPONSE The Preferred Alternative (E) address- es activities which will create habitat conditions of fire as a tool to reduce fuels and as a way to which favor larger herds of deer and elk The minimize natural fire patterns thus providing Forest will cooperate with ODFW to meet the benefits to plants and animals ODFW population Objectives. COMMENT Maintain biological diversity Clearcut- COMMENT. About 35 elk use the Forest to access ting cannot maintain biological diversity Suggest the river adjacent to the Inn of the 7th Mountain alternative logging systems such as selective Concern that further development would deprive cutting elk access to the river. Concerned about narrowing of access as a result of recent expansion by Inn RESPONSE The Preferred Alternative (E) empha- of the 7th Mountain. sizes use of uneven-aged management which when combined with old-growth management RESPONSE: Strategic future planning will account areas and research natural areas will provide for for elk travel corridors to the river. biological diversity

Winter Range COMMENT If old growth remains then perhaps diversity could be maintained COMMENT: River study outlines concerns that O.H.A. expressed on the Deschutes National RESPONSE. Sounds reasonable Forest plan. Study emphasizes need to preserve sensitive deer and elk winter range, and more importantly, deer migration corridors. Adjust land Wildlife Habitat use practices and acquire lands where conflicts exist with migration routes. COMMENT. Maintain Big Marsh as is

RESPONSE As we find sensitive deer and elk RESPONSE The Plan proposes the restoration of winter range, the Forest Plan states that we will the Big Marsh area to its original condition

Appendix J - 151 Appendix J Alternatives, Data Analysis, & Planning Process

COMMENT. Wildlrfe habitat should not be used COMMENT. Manage Big Marsh, Wickiup, Crane as an excuse to harvest timber A balance is needed Prairie and Davis Lake for waterfowl The Deschutes in Forest management. National Forest needs more emphasis on waterfowl management. RESPONSE The goal of Forest management is to provide a variety of recreation, wildlife habitat, RESPONSE Standards/Guidelines will be followed and commodities, one of which is timber. The to manage the riparian zone around the lakes preferred alternative includes habitat quality and reservoirs. A plan for management of Big objectives for game and nongame wildlife. Some Marsh included waterfowl as one of the main of these objectives can be met using timber harvest resources Waterfowl habitat improvement projects as atool However, timber harvest will also continue may be incorporated into the plan. On other lakes in areas where the objectives are to produce and reservoirs, waterfowl habitat improvement wood projects may occur in the future

COMMENT Clearcuning ruins nesting habitat for COMMENT The Deschutes National Forest should birds have less building on forestland so wildlife habitat is maintained. RESPONSE. Uneven-aged management is the RESPONSE: Building on Forestland is done for generally preferred method of timber management several reasons: in most of the Forest in the Preferred Alternative This method will provide vertical and horizontal 1. Campground recreation facilities diversity for many wildlife species In some forest 2. Guard stations to house employees for fire types, even-aged management with clearcuning suppression and other activities as one step in the process, will continue 3 Facilities for interpretation of Forest ecosys- tems and geology 4 Permitted activities such as drilling for oil, COMMENT Cover for elk and deer is inadequate gas, and geothermal resources Some areas should be free of logging activities for deer and elk security. Critical areas must be All of these are part of Forest resource manage- protected Land exchanges must be examined for ment When specrfic projects are proposed, they their impact on deer and elk Migration routes are analyzed for their possible effect on wildlife must be protected Standards/Guidelines for different wildlife species are followed while planning and implementing RESPONSE The Preferred Alternative will provide projects. habitat to meet ODFW population objectives. To accomplish this, the Forest will manipulate forage and cover areas in accordance with standards/ COMMENT Road maintenance and construction guidelines described in the Plan appendix. Road should be planned to minimize effects of roads management is another factor which interacts on wildlife. with hiding cover quality to affect habitat quality Some roads will be closed in cooperation with RESPONSE Standards/Guidelines have been ODFW Seasonal closure of logging activities, developed for road densities and their effect on off-road vehicle travel, and site-specific prescrip- wildlife. tions for sensitive areas will be analyzed as pari of all project analyses. Communication with ODFW is part of the process in analyzing the impacts of COMMENT The Deschutes National Forest needs any proposed activity which may affect deer or to consider the effect of fragmentation on old elk. growth, waterways and meadows

Appendix J - 152 Appendix J Alternatives, Data Analysis, & Planning Process

RESPONSE Research indicatesthat fragmentation Snag-Dependent Wildlife Species of old-growth forests may jeopardize some wildlife species. This issue was not addressed in the COMMENT. Firewood cutting should be prohibited Draft Plan. However, on specific projects, the on areas of the Forest below 60 percent MPP possibility of maintaining corridors is investigated Need management program to recover these and evaluated in the NEPA document. areas. RESPONSE: 40 percent maximum population potential is the minimum guideline on new harvest COMMENT: Cattle grazing should not be allowed activity areas in habitat management areas.

RESPONSE: Cattle grazing will continue as one COMMENT: Plan for 28 to 30 pairs of bald eagles of the multiple uses of the Forest. There are on the Forest. conditions under which grazing can improve forage for wildlife Removal of previous year's growth or RESPONSE The Deschutes National Forest Plan grass improved its palatability for deer and elk. will manage for 35 to 45 pairs on the Forest. Prescribed burning is also a tool presently used to improve forage for deer and elk. The Forest is COMMENT. Snags and nesting areas are important planning to increase its use of fire to manage all year long Eagles do not necessarily leave the vegetation for big game. nesting site. I have seen them stay clear through the fall if feeding in the area is good I see no mention of protection of feeding sites, such as COMMENT: On Davis Lake the Forest should small lakes. I do believe other raptors and owls allow trolling motors only, the grass should be and pine martens deserve specific protection regularly burned, and it should become a bird (rather than general protection of small areas of refuge. habitat) as well as key indicator species

RESPONSE Small motors are allowed on Davis RESPONSE: Standards/Guidlines pertaining to the maintenance of snags and nest sites are Lake. The State Marine Board, ODFW and the applicable year-round The Bald Eagle Manage- Forest cooperate to regulate use of motors on the ment Areas are available year-round Habitat for lake. Grass is presently burned at irregular intervals accipiters, owls and pine martens will be available to maintain its vigor. The Forest has no plans to in management areas emphasizing Old Growth, manage the area as a refuge at this time Wilderness, Undeveloped Recreation, Research Natural Areas, Spotted Owls, Bend Municipal Watershed, Winter Recreation, and the Oregon COMMENT' Osprey, cattle and anglers interact to Cascade Recreation Area, some Special Interest affect fishing opportunity. Areas, Wildlife Management Requirement Habitat for indicator species will be provided in Manage- RESPONSE The Forest resources are managed ment Requirement Areas. to produce a variety of resources, including fisheries, range vegetation, and native wildlife COMMENT Leave all snags in ponderosa pine species. Cattle grazing is managed to minimize for cavity nesters. its effect on fisheries. Habitat for osprey will be maintained to provide for a viable population on RESPONSE Snags in Ponderosa pine are fairly the Forest. Fisheries are managed in cooperation scarce in many places on the Forest because of with ODFW to provide a variety of opportunities past management activities. There has been a for anglers. snag policy in effect for over ten years to protect

Appendix J - 153 Appendix 9 Alternatives, Data Analysis, & Planning Process

existing snags not in just ponderosa pine but all Management Requirements (MRs) tree stands which include lodgepole pine, mixed conifer, and mountain hemlock. This policy includes Spotted Owl Management protecting existing snags if they are not a safety hazard to people and providing for future snags COMMENT The 2,200 acre spotted owl manage- in timber sales by leaving green trees to become ment areas are too large/necessary replacement snags Through time the number of RESPONSE Forest Service Regional policy calls snags in ponderosa pine will increase over what for leaving 1,500 acres of suitable old-growth is currently present The Plan reinforces this snag forest to provide nesting and rearing habitat program plus implements a monitering program to see how effectively it is working T & E Plants and Animals

COMMENT It is the USFS's duty to increase the COMMENT Managing many nongame species' populations of key species (plants and animals) habitat at the 60 percent level is too low, while that are endangered, threatened, sensitive or very meeting the ODFW deer management objectives. important to the ecosystem

RESPONSE. The Preferred Alternative will provide RESPONSE Regarding animals, habitat will be habitat to meet ODFW population oblective for maintained for viable populations of all vertebrate deer Habitat for 100 percent population levels for species found on the Forest. T&E plants have not cavity-dependent and old-growth dependent been found on the Forest Standards/Guidelines are contained in the Forest Plan that would protect species will be maintained in old-growth areas, and manage habitat for the perpetuation of plants management areas for old-growth dependent which are listed as threatened, endangered or species, Bend municipal watershed, research sensitive. natural areas, and forested portions of Wilderness areas Invertebrate Management

COMMENT. Would like to see more emphasis COMMENT The Draft does not allow enough given to invertebrate diversity Need to protect snags and logs to be left Sixty percent is not stagnant pond water and cull logs. Must maintain enough Recommendations were for potential high levels of invertebrate populations to support population levels of 80%, 95%, and 100% the insectivory guilds lnveltebrates are the "cornerstone" of forest management. RESPONSE The 40% of potential population level was retained in the Final This level applies to RESPONSE, The Forest Plan speaks to protecting areas where timber production is a primary invertebrates such as ants which are major objective and falls mid-way between miminum predators on forest insect pests such as western spruce budworm and Douglas-fir tussock moth and maximum levels for cavity nesting species Any colony sites-whether in decaying trees and habitat requirements It provides for adequate logs, or underground and marked by a mounded habitat for cavity nesters while not reducing wood accumulation of fine twigs and other vegetation production outputs significantly Snag levels above debris-will generally be maintained in the forest the 60% level are provided for in other areas such ecosystem as Research Natural Areas, Old Growth stands, undeveloped and winter recreation areas, the Oregon Cascade Recreation Area and to some Comment and Response to the Draft EIS degree in Wilderness Supplement, September, 1988.

Appendix J - 154 Appendix J Alternatives, Data Analysis, & Planning Process

Two administrative appeals of Forest Service states that one integrated plan must be prepared planning procedures resulted in a decision to for each unit of the National Forest System supplement the DEIS. One appeal challenged the assumptions and display of the alternative which RESPONSE The following is added to Appendix continued current Forest management. H The standards and guidelines found at 36 C F R. 219.27 are The m/n/mrumspecific manage- A second appeal objected to the formulation and ment requirements to be met in accomplishing application of measures designed to protect wildlife the goals and objectives for the National Forest "minimum management requirements' in the DEIS, System These requirements guide the develop- currently 'management requirements (MRs): ment, analysis, approval, implementation, monitor- ing and evaluation of forest plans" (Emphasis The most detail comment was submitted by the added ) These management requirements are an Northwest Forest Resource Council Elements of interpretation of the non-impairment standards of this comment are addressed below. the National Forest Management Act (NFMA) Section 6 of NFMA required the Secretaly of Agriculture to promulagate regulations specifying COMMENT The Supplement lacks an evaluation resource protection guidelines to insure species of alternative means to meet Minimum Management diversity, to insure timber is harvested only where Requirements. there will be no irreversible damange to the soil, slope or watershed conditions and only where RESPONSE As explained in Supplement, alterna- protection is provided for streams, lakes or tive means to meet Management Requirements watershed conditions and fish habitat Management were not evaluated if the expected effects on requirements in Forest plans are a detailed and Present Net Value or timber outputs were not specific interpretation of the 219 27 standards significant. In many cases the effects are insignifi- and guidelines They are the smallest set of cant, (less than two percent). The two percent constraints possible and are limited to those figure was chosen because it is very small specified by statue compared to the reliability of the predictive models When the effects of implementing the means or The methods (ways or means) of meeting these ways to meet management requirements were requirements are integrated in each step of the significant, they were examined and displayed in planning process including the analysis which the Supplement indicates the most efficient means of implementa- tion

COMMENT The Supplement does not explain why the term "Management Requirement" rather COMMENT. The MMRs were developed without than "Minimum Management Requirement' is public participation as required by NFMA and used This creates confusion NEPA.

RESPONSE. Appendix H of the FEE was modified RESPONSE As explained in the introduction to to explain the change The change in title is more the Supplement (EIS, Appendix H), one of the in keeping with the language used in the planning purposes of the Supplement was to gain further regulations (36 CFR 219 27). The change was public involvement Management requirements intended to reduce confusion by being more are listed in 36 G F R 219 27 The ways or means consistent with the regulations to implement these Management Requirements are analyzed in the Supplement. The Supplement provides opportunities for the public to comment COMMENT: MMRS have not been developed as on all aspects of the ways or means to implement an integrated part of the other planning steps; Management Requirements Comments from the they were developed using a separate planning public are considered in the development of the process. This violates 16 U S.C. 1604(f)(I) which Final EIS. Prior to the development of the DEIS,

Appendix J - 155 Appendix J Alternatives, Data Analysis, & Planning Process

considerable effort was spent by the Forest and alternative replicates management as it existed others in developing and reviewing the biological pre-NFMA. habitat requirements for wildlife. Consultations were made with agencies or others who had scientific knowledge regarding wildlife manage- COMMENT The Supplement fails to disclose and ment. In addition to that information contained in discuss all major points of view on the impacts of the MR appendix, Draft ElSs included discussions alternatives of Management Requirements in Chapter 2 and Appendrx B. RESPONSE. The appendix was amended to include the following kinds of statements "There are a range of scientific opinions as to what the COMMENT The MMRS should have been adopted habitat requirements - in contrast to desirable through rule-making as were the NFMA planning habitat - are. These differences of opinion are regulations. disclosed. (note this literature search and summary is being worked on by RO Wildlife) RESPONSE As explained in Appendix H, the NFMA Regulations contained the Management Requirements in 36 CFR 21 9 27. The specific COMMENT The Supplement fails to reveal the ways or means of meeting management require- effect of MMRs on employment and county ments can be viewed as the Forest's specific revenues. expression to meet the congressional mandate in section 6 of the NFMA. The MR's and the ways to RESPONSE The intent of the Supplement is not meet them constitute the agency's scientific to be an EIS but rather to evaluate the effects of determination of the minimum resource protection those Management Requirements not already standards necessary to comply with the law examined elsewhere Two key indicators of environmental effects are examined ASQ and PNV. Both are correlated to employment and COMMENT The Forest Service failed to develop county revenues: see Chapter 4 of the FEIS In MMRs using an interdisciplinary process required addition, Appendix B discusses the analysis by 16 USC 1604 (b)(i). including opportunity costs of imposing MR's in the analysis RESPONSE: The Forest ID teams identified the methods and assessed alternatives to represent the Management Requirements, as explained in COMMENT The Supplement does not describe Appendix B. Specialists in the resources involved why a different management requirement is used identified biological requirements and alternative between Forests 'When the conditions are appar- approaches to meet MR's These approaches ently similar on both Forests and the same legal were recommended by the interdisciplinary plan- requirement is being achieved The example cited ning teams and approved by the forest manage- is use of different indicator species on neighboring ment team. Forests

RESPONSE Discussion of why each indicator COMMENT Management Requirements are specie was selected is included in Appendix B imposed in every alternative in violation of NEPA. Generally, the indicator species are consistent from Forest to Forest around the region Where RESPONSE. As stated in Chapter 2, the imposition differences exist, they are a result of different of management requirements in all alternatives habitats or abundances of species. considered in detail is a NFMA Regulation require- ment. One alternative, the No Change Alternative, has been developed which does not include COMMENT The No Change Alternative does not Management Requirements. The No Change represent the historical management practices

Appendix J - 156 Appendix J Alternatives, Data Analysis, & Planning Process

under the Forest's existing legal plans and, an environmental review process before consider- therefore, the effects of implementing the timber ing improvement to a two-lane paved road (see plan are not represented correctly The Rock Creek Accords, Chapter 4, Forest Plan)

RESPONSE: As explained in Chapter 2 of the FEIS, the purpose of representing a No Change COMMENT A request was made for an insect Alternative is not to represent "historical manag- species list, including aquatic insects, for the ment practices. "Instead, it represents the continu- Deschutes N.F Estimate population size for each ing implementation of the existing Timber Manage- species Discuss impacts of managing for MRs on ment plan as amended but not modified by the insect population, including: NFMA regulations. Of course if this alternative were chosen as the selected alternative for the Impacts of pesticide use on the Forest, Forest Plan, either the NFMA regulations would need to be revised or the TM Plan would have to Impacts on aquatic insects from increased include NFMA regulations In that case, this sedimentation; alternative would closely match the No Action alternative in outputs and effects. Impacts on aquatic insects from proposed hydro-electric projects The purpose of the No Action alternative is to represent the integration of all existing plans Also examine population dynamic impacts, espe- including the Timber Management plans together cially between insects and game bird and non- with NFMA regulations. Chapter 2 has been game bird species under each alternative. Discuss reviewed to assure clarity on these points anticipated insect pest cycles.

RESPONSE Although these are valid concerns and the data would be good to have, it is far Comments From individualson the DEE Suppie- beyond the means of the Deschutes NF to gather ment information at this level of detail. The insect fauna of a forest are extremely diverse, and undergo dramatic changes, both temporally and spatially COMMENT. One person would like to see the To describe this insect community adequately area between Century Drive and Waldo Lake would require expertise that is not currently managed as a roadless area. Abandon the road available, and would be prohibitively expensive to connecting Waldo Lake to Century Drive do. Terrestrial ecologists, more likely to be associat- ed with a research facility than with resource RESPONSE: The majority of the Maiden Peak management in the public sector, carry out studies Roadless Area will remain undeveloped. The of this nature, but usually do so on a very limited boundary of Management Area 12 was moved to scale due to the complexity of the task. the east in this roadless area because of public comment about the area. The study and description of aquatic insect communities is better done by a State fisheries Improving the Waldo Road to a two-lane standard agency than by the U. S Forest Service which would provide a shorter route for traffic traveling manages habitat rather than the organisms from the valley (Eugene) to the Cascade lakes themselves. Information has been gathered by Highway (46). It would also provide better access these experts (and others involved in research) for recreationists in the Crane Prairie area to travel for some stream systems, and much is known to Waldo Lake. However as the route became about the relative sensitivites of the different groups known to the public traveling between Eugene of aquatic invertebrates to stream contamination and Bend, it would become a bipass to the Highway by both pesticides and sedimentation. 58 route during the snow-free months. The impacts The information from these studies would be too and benefits of this option will be evaluated through voluminous to include in this €IS, but would be

Appendix J - 157 Appendix J Alternatives, Data Analysis, & Planning Process

heavily referenced in a site-specific environmental COMMENT The 'No Change" alternative was not document for a particular project where the types necessary. Too much emphasis on timber in of potentially detrimental effects are limited and relation to other resources Black Butte should readily identified not be in the timber base

In general, little is known about the population RESPONSE As stated in the Supplement, the No dynamics of insects in the forest. Only the most Change Alternative wa? developed to facilitate prominent forests pests have been studied in comparison of past management, minus NFMA sufficient detail to realistically address the factors requirements for wildlife as displayed in the No that affect each stage of their life cycle. Such Action Alternative, and the other alternatives. The insects would include the Douglas-fir tussock Preferred Alternative allocates the upper third of moth, the western spruce budworm, and the Black Butte as Specialllnterest which does not mountain pine beetle. include any programmbd timber harvest The lower portion is alloca$fd to Scenic Views which The cycles of forest insect pests have been studied does include timber harvest as long as the primary for decades, but there is still disagreement among emphasis (visuals) is maintained Without active the experts as to which factors are most important management, the risk for a catastrophic fire on in regulating these population fluctuations We the Butte would be greatly increased know, for instance, that spruce budworm outbreaks 1 have become increasingly more frequent in recent years and have reached more destructive levels COMMENT The No Change Alternative mandates than they did early in this century. These cycles the destruction of the Deschutes National Forest will vary locally in accordance with an available The Deschutes National Forest should be classified food source, with prevailing weather, and with as a dedicated National Natural Preserve All old other regulating forces. It would be meaningless growth forest should be included in a National to speak of cycles without addressing a particular Old Growth Sanctuary System locality with its own unique set of circumstances that interact to produce the insect populations in RESPONSE The No Change Alternative does not that area. For defoliators and bark beetles alike, provide for the legal requirements of NFMA and we expect there to be problems as long as we would not be Implemented Dedicating the Forest continue to have susceptible stands, and cycles, as a National Natural Preserve would not provide per se, are not meaningful. for 'multiple use' which the Forest is mandated to do. Management of old growth forests is being investigated. COMMENT Alternative E is weak in the following areas, not enough emphasis on preserving old growth stands, beyond saving 'pockets', keep COMMENT Do not wish to see the Forest reduced roadless area development and public access to to a shoft rotationtree farm Emphasize production a minimum; confine geothermal development to of large Ponderosa logs. Clear cut beetle killed nonsensitive areas and carefully examine and lodgepole stands. Alternative G best provides for supervise all permits; keep human interference on multiple use. wildlife populations to a minimum RESPONSE The Plan does not emphasize short RESPONSE: Old growth allocations and areas rotation tree farm management (see Chapter 4, with no harvest provide protection for the desired Timber Management. Standards/guidelines for amounts of old growth for Alternative E There will uneven-age managment, visuals, and eagle areas be no entry for timber harvest in roadless areas will provide for large diameter logs Beetle infected during the first decade of the Final Plan. All stands will be managed by the silviculture prescrip- geothermal development will be Subject to NEPA tion that best meets the needs of the stand procedures. The Plan contains extensive direction to protect wildlife including conflicts with man.

Appendix J - 158 I.

..

Appendix J

Response Letters from Elected Officials, Federal and State Agencies, and Indian Tribal Governments Department of Ffsh and Wildlife OFFICE OF THE DIRECTOR OREGON DEPARTMENT OF FISH AND YILOLIFE COMIENTS ON 506 SW MILL STREET P BOX PORTLAND. OREGON 97207 OESCHUTES NATIONAL FOREST 0 59. DRAFT ENVIRONMENTAL IWACT STATEENT AND PROPOSED PLAN March 31, 1986

April 1, 1986 WJOR ISSUES

Road Management H Mike Miller State ForesteP The conflict between roads and wlldllfe IS one of the major Issues the Department of Forestry Department identified in reviewing the plan documents. The adverse effects of 2600 State Street roads and consequent vehicle use on wildlife has been documented widely Salem. Oregon 97310 throughout the western states. The proposed Deschutes National Forest plan has some discussion of road management but more discussion 1s needed leading Dear 111 ke to a comprehensive road management plan that w~llassure secure habltat for wildlife, and will maintain the quality of hunting experience The Oregon Department of Fish and Wildlife staff has reviewed the Deschutes National Forest plan documents and has attached comments to thls letter The The Deschutes Forest has 4 8 miles of roads for every square mlle of land that comments were prepared according to guidelines approved by the Oregon Flrh IS not wilderness or roadless The lodgepole worklng group recommends that a and Wildlife Comm~rsion road density of 2 5 miles of road per square m?le of land would provide 90% > habitat effectiveness for the road variable wlthin the mule deer model. It 1s 7J There are few fish habitat related problems on the Forest The Forest has 7) apparent that road densities are already high on the Deschutes Forest, that m been responnve to habitat improvement and enhancement needs, and the qual1tY wildlife populations are not able to fully Utilize avallable habitat and that 2 of fish habitat in lakes, streams and reservoirs IS hlgh More could be done, a road management program is needed however, and the plan documents should discuss opportunities for add7tlonal % fish habitat improvement The maintenance and enhancement Of quallty angling Forest roads are necessary for timber management but roads and vehicle trafflc + experience is paramount in the Central Oregon area and we expect contlnued have serious adverse effects on big game range carrying capacity and on A good working relationship with the Deschutes National Forest to provlde high hunting seasons The plan projects maintenance of deer numbers in compliance quality angling experience with ODFW management ObJeCtlVe (W) levels and an increase in the numbers of The concerns are Ronsevelt elk Ifthe road system that will result from lodgepole tmber We have some major concerns for future wildlife resowces harvest allows free and easv vehicle use. then the extensive cutover forage related to the effects of an extensive road system on wlldllfe use of the producing areas cannot be filly utilizeiby b>g game animals that require-a Forest and an hunting reasons, maintenance of old growth ecosystems, rapld more Secure habitat. harvest of lodgepole stands; deer population proJectlons and the potential for funding deer habitat improvements These concerns are discussed at length In 1984, the Department cnnducted a series of elk workshops around the state in the attached comments The Department seeks to have these Concerns addressec The purpose of the workshops was to get elk hunters opinions regarding in the final plan Oregon’s elk hunting The biggest issue identified among 5.000 hunters related to problems caused by too many roads. While we offer extensive comments regarding major concerns wlth w1ldlIfe re- sources, those comments should not overshadow our positive oprmon of the plan Hunting Seasons are affected by the dense road network when it allows high and the efforts of the Deschutes Forest in carefully assembling a comprehensive mobility and a wide distribution of hunters to rapldly find and harvest the plan The alternatives are well thought out and the pveferred alternat3ve PrO- surplus big game. extensive road system allows a hunting season harvest to vides the mort reasonable mix of potentially confllctlng uses We will, howevel An occur In a matter of hours instead of days withhold our endorsement of the plan until such time as our major concerns are addressed There are techniques available to mitigate the adverse effects of roads on wildlife. The recommended techniques include limit vehicle use of wads year around or seasonally, decrease the proportion of main roads and Increase the DroDortion of dead-end low standard roads: obliterate roads after the initial use: leave a vegetative screen alonq kadwavs: institute area John R Donaldron, PhD clor2res, lindrow slash~parallelto roaohayi an0 Dh>slcdlly olock venicle Director access. Tnere may ne Other techniques more appllcaole Io the OescnJtes Forest

odt cne obiective of rod0 mandoebent~~ zhoLlo ~ be to orov~oesecure kilollfe Jds habitat ad spread deer harvesi throughout the seaion. attachment Deer Habltat Rlpdrlan zones are the most Critical w~ldlifehabitat in the forest environ- ment because more species use that habitat type and ~n higher densitles than The Department has Concerns Wlth deer populations predicted In the in any other habitat type. Wildl?fe habitat values should be recogmzed and alternatives, funding for habitat improvements and the effect of rapid ma7ntained in Streamside Management Units lodgepole harvests Page 51 of the standards and guidelines relating to Streamside Management The Department has established a mule deer populatlon management objective Unltr says riparian areas should be managed to maintain upper streambanks in a (M 0.) for the area Of 24,850 deer Alternatlve A, G and H project deer stable condition along at least 80% of the stream's length The entire populations lower than that objective and therefore do not meet our management streaiabank IS important to fish habitat and needs to be maintained. objective Alternatlve C and [I project deer populations significantly higher than our management objective level There IS a major problem in the Deschutes River between Wlckiup Reservoir and Benham Falls, a distance of about 46 miles, where fluctuating flows as a The Department doer not endorse deer populations higher than the M 0 level result of irrigation releases are causing rap'd and severe erosion on the hst mule deer that use sumer ranges on the Derchutes National Forest spend a banks of the Deschutes River Severe flow fluCtUations during summer and portion of the winter months on ranges off the forest winter combined With freezing and thawing Of the loose pumice streambanks causes sloughing. The erosion from fluctuating flows has silted in the gravel The alternatives with highest timber hamest levels also project highest deer spawning bars, and has washed out woody debris, and instream structure. The numbers The deer population projections dve predicated on hab7tat stwm channel has become wider and shallower, resulting ln d loss of winter unprovenient projects to upgrade foiage quality and Interspersion With Cover habitat for fish Habltat lmprOvement does not result dlrectly from timber harvest but 1s The erosion problems that result have made It difficult to maintain a wld dependent upon fundlog of SpeClflC p~ajectsI" future yedrs The Department brown trout flshery. Brown trout habitat losses cannot be mitigated through a believes funding for timber harvest particularly in the lodgepole area should hatchery program because hatchery brown trout cannot in the be contingent upon funding for wildlife habitat protect10n and improvement so survive river Spawning area 1s a Iu"ing factor for wild brown trout and presently they can If timber harvests increase then wildlife habitat projects also increase spawn only in tributaTieS to the Deschutes. The only way to maintain a wlld proportmal ly brown trout fishery xn the Deschutes River IS to restore the habitat and to protect the spawning tTibutdrtes, Fall RIYW and Browns Creek. Throughout the Reviewer's Guide, DElS and Proposed Plan, the present mule deer That nuniber accurate for 1984 but the population 1s listed as 20,300 IS The plan does not provide protection Of lower Streambanks. thewfore allowing populatmn actually fluctuates froni year to year. depending upon weather the to Continue to degrade the quality of the DeSChUteS between severity, hunter success, reproductive and other factors It would be erosion River success Wickiup Reservoir and Bend more accurate to use the five-year average annual deer populatlon as reflected below The Department recognizes the difficulties in achieving streambank stability and rehabilitation but believes the Forest should address protection Of the 1984 - 20,300 Forest-owned land along the Deschutes River 1983 - 20.530 1982 - 23,500 In the Sparks Lake area and tributaries, overgrazing has lowered the carrying 1981 - 26,450 capacity for wild brook tmut production. There are unused allotments On the 1980 - 25.600 forest and the Department suggests movwg cattle from Sparks Lake to One of 5-year anerage = 23,276 the unused allotments On the forest.

Ripanan Habrtat There are isolate0 overgrazing PrOOlemr ~n the upper DescnLtes, .lttle Veschites, ma Crane Prairie areas thdt relate to grazing admloiztratlon. lne The Goal Statement far ripanan areas on Page 50 of the plan needs to olan inoicates tnat rioa?ian zones are qenerally ln qood condltlnn. Tne findl recognize the importance of wildlife habitat in ripanan zones The goal ;Ian, however, should display an Inventory of ripanin habitat on the forest reads "to protect the unique and valuable CharaCter1stlcs,,of riparian areas and list habltat restoration targets and to protect or improve water quality and fish habitat Whlle the goal would meet f?sh habitat needs, wildlife values need to be recognized as well Northern Spotted Owl

Also on Page 50 of the plan, Standards and Guidelines relating to streamside The Deschutes National Forest should manage all spotted owl habitat in a management Units (ShU), we find that SMU'S manage only for Water quality and manner Consistent with the Spotted Owl Management Plan The Forest projects fish habitat protection some timber harvest in spotted owl management areas Thls 1s inconsistent with the spotted owl management plan which precludes salvage of dead and down material within SOWS. Old Growth Adverse effects of longer rotation include Page 113 of the Plan lists the goal for old growth management and the road system must be maintained for repeated entries prescriptions that may be applied. The prescriptlonr refer to meeting objec- down dead lodgepole could hinder terrestrial animal movement tives. 1 e.. ". timber may be harvested to meet old qrowth ObJeCtives." However, th; old growth objectives are not listed. Harvest of lodgepole at current or faster rates could well result in a short-term increase in forage that will boost deer and elk numbers. The The prescription for wildlife says emphasis wll be to provide (1) large long-term effect would be a greater overall loss of habitat quality far trees, (2) standing and downed dead trees, and (3) vertical Structures within outweighing short-term benefit As the lodgepole stands are harvested, there the stands That prescription 1s vague and provider the reader with little wuld be an increase in forage and deer As the harvest areas become information on which to evaluate the merits Of the old growth. wildlife reforested forage IS replaced by Cover Deer need bath forage and cover so If prescn;tion For wildlife habitat valuer In old growth stands. It IS prefer- the lodgepole 1s harves:ed rapidly, ray In 10-15 years, then there would be able to consider old growth as an ecosystem that evolved naturally without extensive stands of cover but no forage in about 25 years. Thore conditions hman intervention OP disturbance The recognition of old growth ecosystems would persist until rotation age, about 80 years. It would be preferable to has been relatively recent There Is much about old growth that 1s not known harvest the lodgepole at & slower, more sustainable, rate throughout the today and )s the subject Of extensive research At this tune we do not know rotation age unless funding for forage improvement can be assured that old growth ecosystems can be "wed at all and still maintain the integrity-of the ecoiyrtems. The management of old growth through timber To meet the big game need for forage and cover, 40% of the forest should be in harvest can at best be regarded as experimental. Since the old growth System cover, well distributed over the summer range This criteria cannot be met in evolved naturallv and we are not certain that timber hawests will maintain or lodgepole stands due to the mountain pine beetle epidemic resulting In massive enhance these &ystemis, it IS best to leave the stands undisturbed until die off of lodgepole The Department understands the concept that the trees more information is gathered. The best available tnformation suggests that to are going to die regardless of management activity and may as well be maTntain old growth ecosystems, from 5 to 15 percent of the forest in each harvested. Lodgepole stands are being harvested in large Units The major plant co!munity be dedicated to old growth ecosyslemr and should be well Department believes mule deer needs in the lodgepole stands will eventually be distributed by slope, aspect and elevation. met as lodgepole stands are managed according to habitat needs. The needs are travel lanes, security from diStu?-bance. fawmng and calving cover and harvest The DeDartment recomnends the Goal for old qrowth be rewritten as folloWs rotations resulting in a mosaic pattern rather than large areas clearcut at "Goal ' To provtde naturally evolved old growth eCDSYSlemS for any one time. Such management schemes would meet deer population needs In (1) preservation of natural genetic pools, (2) habitat for plants and wildlife future lodgepole stands species associated with old growth ecosystems, and (3) contributions to the diversity spectrm. NO new entries should be made adjacent to harvested areas until regrowth in the harvested areas meets hiding cover cnterra. The Ueschutes National Lodgepole Harvest Forest standards and criteria regarding cover needs are adequate

The current direction would harvest all lodgepole affected by the mountain ADDITIONAL COMMENTS AND SUGGESTIONS pine beetle epidemic in 40 years; other alternatives are as follows. Alternatives C and D/lOyears; Alternatives E and FI10-2D years, Alterna- Bald Eagle tive 6/30 years, Alternative H/20-30 years The present population on the forest 1s 20 pair of bald eagle and IS projected For wildlife, the longer time to harvest the lodgepole are preferred for the to increase to 45 pair I" the fifth decade following reasons. Deschutes National Forest plan meets federal guidelines for the management Of allows improved habitat diversity over time and area bald eagle habitat, including habitat monitoring to determine the easier interspersion of cutting units effectiveness of the plan action can better prbtect meadow habiiat in the long-term, will allow a better mosaic of cutting Units Peregrine Falcon can Drovide visual screens alonq roadwavs for hidins cover better hunting experience The Deschutes National Forest has habitat for peregrine falcons, but no bird travel lane corridors can better be maintawed nesting has been documenled recently There was a pair of peregrines near more snag. dead and down habitat Benham Falls in the past and there have been mlscellaneous sightlngs of birds. The monitoring plan for the forest would inventory the presence of populations in the future. 3 All alternatives meet or exceed 60% of the potential for snag dwellTng existing recreational use. The geothermal development such as road species. except for Alternative C which proposes a lower level. Snag construction, powerline rights of way, noise and potential water quality densities meeting or exceeding 601 of the potential can be expected to main- effects could conflict with recreational and wldl7fe use of those areas tain viable populations of snag-dependent wildlife. The Forest has a Development plans for individual projects should be designed to minimize monitoring program that would insure evaluation of effectiveness of snag impacts. retention. The Forest has a program to preserve snags and to protect them from slash burning and Woodcutters, but there IS no inventory to determine the Oreuon Cascade Recreation Area level of success at maintaining Snag trees. The plan needs to display an inventory of existing snag densities on the forest. ODFW is concerned that the prescriptions on Pages 111-112 of the Proposed Plan are not stringent enough to protect wildlife resources. Of particular concern In years past timber management did not routinely provide cavity nesting is the Big Marsh area where the forest acquired private lands for wildlife habitat snags. On forests where timber harvests have occurred, cavity nesting purposes. Further road development motorized recreation and unregulated habitat has been found deficient The Oeschutes National Forest should firewood harvest would jeopardize wildllfe use of the area. There is a need display an estimate of Condition on lands already harvested. The protective to maintain habrtat improvement options. standard to maintam habitat at 60% of potential 1s adequate, assumng that no lands have been harvested. The Standard may be lnadesuate If substantial Roads: Uindigo Pass. Irish-Taylor, Todd Lake-Three Creeks Lake and Waldo Lake harvest has already occurred and snag habitat IS defitlent on those acres harvested. ODFW recomnends the above roads not be developed beyond their current capacity. The roads bisect areas presently unroaded and go through sensitive HardWOOdS and Mlnor Canlfer Species habitats Used by species such as elk and wolverines. Adjacent small lakes are already heamly used in some cases. There are small groves of quaking aspen. deciduous and Other minor species on the forest that should be preserved wherever they occur in order to maintain Aquatic Habitats habitat diversity. Those habitat types are not Specifically addressed in the plan. In general, the stream protect7on on the Oeschutes National Forest IS very good and there are not many fish habitat problems. Soil types and topography Meadows, Freshwater Wetland and Natural Openings mitigate the effects of timber management. Many of the streams are spring fed so water temperatures are easily maintained. The stream channel problems On meadows larger than 30 acres. the Forest proposes to affect no more than caused by fluctuating flows In the Oeschutes River below Wickiup Reservoir one-third of the vegetation surrounding the meadow during harvest operations (documented elsewhere in ODFW comnents) could be reduced by plugglng the leaks The Oepartment believes the standard would not adequately maintain wildlife in Crane Prairie Reservoir. Water saved to augment low flows In the Oeschutes use of meadows. Removal of one-third of the vegetation would expose in many River would result in less streambank exposure and subsequent erosion. cases an entire meadow to view and would preclude wildlife use. Vegetation at least one site distance wide should be maintained around a meadow with no more ODFW recommends leakage from Sparks, Hosmer and Davis lakes also be plugged to than one-th?rd the vegetation outside that distance affected by harvest maintain water level and maintain fish production. operations. Alternative C proposes timber harvest activltles encompas,ing Rosary and There are many meadows smaller than 30 acres on the Deschutes National Forest Maiden lakes. ODFW would prefer a more restrictive designation than of extremely high value for wildlife resources According to Page 166 of the Alternative C. The other Alternatives afford sufficient protection of those EIS, less than 1%of the land base in the Oeschutes National Forest is in two lakes. meadows. many of which are less than 30 acres. Since many of the meadows are small ones and represent a minute portion of the land base, vegetation around There is llttle discussion on flshenes in the planning documents, maybe due all meadows should be protected in the same manner as described above. in part to the forest's history of responslveness to habitat and fishery needs. Work on the Metollus River, replacement of Brown Creek culverts and Geothermal Resources Deschutes Bridge are examples of cooperation. ODFW recomnends that leases for geothermal exploration be limited to the Regarding Scenic, wild or recreational rivers. ODFW suovorts Stream non-sensitive areas on the forest as provided in Alternatives G or H. Sparks de;ignation that allow fish hdb>tat improvements. St&s Such is tne Lake and Newberry Crater are highly important recreational ure areas with DeschLtes system. Retollus and Big Marsh hould be best managed if oeslgnared correspondingly high fish and wildlife values. Geothermal exploration. and 1n Recreational Rivers rather than d more restrictive oeslunation. The Plan particular geothermal resource development. could be incompatible with should emphasize habitat improvements at Big Marsh. DISCUSSION OF WILOLIFEISTANDARDS AND GUIDELINESfPAGE 55-56 IN PROPOSED PLAN Dead and Oohn Woody Material Chapter 4, Standards and Guidelines, Page 56 of the plan discusses species associated with dead and down logs. The standard says "A minimum of two dead and down logs per acre should be left in areas where timber management activitie~will occur". The standard should be strengthened to say that dead and down logs will remain in areas where timber management activities will occur. Pileated Woodpeckers

Protective standards for pileated woodpeckers may need to be revised ~n the Standards and Guidelines. This species IS found only in mixed conifer old growth forest. It has a large territory varying between 100 and 600 acres depending upon the literature reference. The proposed old growth areas may be too small to be suitable for pileated woodpeckers The Plan assumes that reserved old growth will assure viable populations of pileated woodpeckers. The assumption may be flawed. We reconmend further study to determine Ifthe protective criteria need to be different from that for woodpeckers in general. Turkeys

The FEIS should contain a discussion of turkeys and turkey habitat. Birds were introduced ~n 1951 and have increased in number. . Yolverine The standard proposed for wolverine needs to be strengthened to reflect that wolverines are, in fact, present on the forest. Sightings have been recorded for 20 years. not all of which were in wilderness areas. Wolverine need protection from humans and development activity. The standard says "attempt to verify the presence of the species." We reconmend the standard be changed to say "continue to document the presence of the species."

Transportation

The standard for road management does not adequately tell the reader if or how roads will be managed to assure that wildlife will have secure habitat. The standard has ohrases like "...w?ll consider..." "Road closures can be used..." "Closures may be.. 'I. We reconmend the standard be clarified to indicate that road management to protect wildlife values will in fact occur. See also the related comnents on road management.

04-9 Department of Transportation Bob Brow April 22, 1986 PARKS AND RECREATION DIVISION Page 2 525 TRADE STREET SE , SALEM. OREGON 97310 April 22, 1986 We are greatly concerned rrith the economic assumptions made by FCHPLAN. Recreation values were consistently underestimated. We would recomnd that the State Economist be asked to review these assumptions Bob Brown as they apply to the Central OregonIDeschutes National Forest area. If Oregon Department of Forestry recreation values are refigured, a neu away of alternatives might 2600 State Street result which depicr recreation mope faVOPably. salem] OR^ 973iO In addition, we would suggest that the Farest Service Staff contact the Dear Bob: Oeschuter County Planning Department for Current information on the economic value of the Deschutes River and its tributaries. It is our Attached is our staff review of the DEI8 for the DeSChUteS National understanding that this data shows the river Setting and recreation Forest. We have reviewed the draft plan with an Emphasis on its impa opportunity as highly valued resources to residents and nan-residents. to the Division's programs - parks, scenic waterways, trails and to recreation in general. We have relied on the 1983 Statewide Ue are pleased to offer these comnents. Ifyou have any questions Comprehensive Outdoor Recreation Plan (SCOW) endorsed by Governor please contact Don Eixenberger (378-6597) or myself (378-5000). Atiyeh arid the 1983-89 Oregon State Park System Plan adopted by the Oregon Transportation Comission. verv trUlV vows? r

Our review paid special attention to the plan's treatnent of providin for recreational diversity (as Show by the Recreation Opportunity Spectrum) and the protection of scenic qualities required for quality recreation experiences.

The Oerchutes National Forest is the primary provider of outdoor JEL: jn recreation opportunities in the Central OPegOn area. The local econo 97MC is marketing these opportunities as part of its economic developrent plan. The significant population growth in past years has been tied Attachrent the area's attractiveness and recreation opportunity. In order to continue to meet the expectations of the area's residents, visitors a CC: Dave Talbot tourism-related economic interests. the Forest must stabilize its Mike Weland, ODFW recreational offerings and continu; to maintain and improve, where appropriate, its recreation facilities. NO other public agency can effectively move in to fill the future demands.

We are particularly concerned with the erosion of dispersed recreatio especially with regards to primitive and swi-primitive recreation opportunities. We also object to any elements that would reduce or eliminate services at existing developed recreation sites. The division agrees that wild and scenic "recreation" classification for the Oeschotes and Metolius above Bridge 99 is appropriate. However, consideration Of "scenic" Status fop the Metoliur below Bridge 99 to Lake Billy Chinwk may be move appropriate. The current plan gives n consideration to the Fall River though it is considered a candidate for state designation. Ue would support managewent of Fall River that would maintain the future options fov state designation. Fi1 es Ppril 14, 1986 Paqe 2 STATE OF OREGON INTEROFFlCE MEMO Parks md Recreation Division 378- 6597

Counties tn?ou~me par 2000 Tnere IS .m overr.pply of 1.243 Files D~TEApril 14, 1986 campsites, 2.457 p!cnic rites ard 120 Dmt ramps. %uuly of these fdcilitics the, IS amply sufficient W met demnd thhrouqi the par 2000. Don ~ixenberger Research Analyst We have concerns .?bout any reduced service levels for emsting BE campsites md day use areas, be they fee or non-fee areas, Such Review Of Ceschutes National Forest Plan, 1986 reductions vu1 counter to the goal of maintaming hlsh quality recreatim opportmlties

Recreation D1 s persed Recreati an Vast dispersed recreational actlvittes are dependent upon the pnmtive The U.S.F.5 plays a major role in the provision of recreation in the md rem-primitive elements of the Recreatim Opportmmty Spectrum. State of WegM. It 18 m indispenslble element in mamtaininq a These are large1 y provided by the remaining madless areas in the diverse quality of recreational Opportunity whlch will gain wen forest. But as the plan states "Hwwer sore aspects of the greater importance ar the state's populatim grows md as wt-of-state recreation opportunity spectrum, are becommg more dlfflcult to retain tourism plays m evm mPe cruoal role in the state's economy. For exmDle. federallv administered lmds wovide over 30% of the state's For example, as remaining roadless areas are either designated as campiitis ad picnic tables, 50% of its hiking and bridle trails ad wilhrness, or roaded and developed for other uses, there are fewer 60% of its atV areas. Thus. *,le the plan states that the U.S.F.S opportmities for the senn-pr1mtive md pnmtive recreation provides 7.5% of outdoor recreation nationally, ~n Oregon, it is likely experiences outside Of wilderness areas. Related to this IS the idea 3 to 4 times that amomt if not me. that as more md merwdless areas are either dweloped w designated as wilhrness, future qeneratlons will have fewer optlons regarding hw In term of recreation, the Ceschutes is me of the now important to bet manage them to meet changing needs."* forests in Oreqon. Its diversityof OupoPtmitv thrwdart all seasons of the par md its drawtic visial settings mie it a-prime attraction The recreat>on value of these roadless areas IS extremely diverse. not only to (hegmians, but also to Out-of-state visitors. The focus They are importmt settin9 for such activltles as hmtmg md fishinq, of Oremn State Parks then is aided bv two min Concevns the prmitlve camping and hiking, wlnter nordic touring, and wildlife nainteimce of diverse high quilallty reireatianal opportmnlties as observation. Some are appropriate for managemmt as semi-primitive exemplified in the U S.F.S.% Recreational opportunity Spectrum, and roahd activities. Above all, these areas prov7de thme primitive and the protectim of those scenic qualities visitors have cone to expect semi-primitive opportmities to those elemmts of the populatlm unable in thew forests. to Utilize wilderness areas. They also provide in myareas the large scale visual piofile of a mature forest rhich both (hegmians md General Recreational Issues out-of-staters value. Indeed, the quality of both developed and dispersed recreational activltes in the forest would be lessened by Overall the plan adequately describes the general wues in the their diminishment. They are mdlspensible to the expectations Deschutes National Forest. What is lading 1s adequate description md vTsitors have of the character of the faret. alannmo for mec~f~crecreational activities. There~~ ~ little .- ~~~~ ~ .~~ ~ ~ ~ 1s 'informa(im, for example, m *hat future demid there mi#t~befor such Of the 1,640,412 aues of the forest. the plan allocations for things as winter sports, dispersed or developed; or for semi-primitive mdeveloped recreation rmge from 1.4W acres or .01%, to 133,700 acres activities, both roaded md non-rwded, or on hw that demmd is to be or 8%. net. There IS no definitive Informat~on in the plan to determine hw rmch Developed Recreation mdeveloped reweatim lmd will be needed in the future. Ei&t The plan places mpases m the developnent of mre campgrounds, picnic areas md boat ramps. These en$ases my be misplaced. Analyses of 'Draft Envirmmntal Impact Statement OeSchUteS National Forest, the 1983 Statewide Comvehmsive outdoor Recreation Plan indicates m Appendix A, 1%. p. 198 oversupply of these facilities in Deschutes. Jeffersm, md Klamath Files npril 14, 1986 Page 3

percent may likely be insufficient to met demnd. khat is clear is It has bemm a truism that free-flaring r~versmd their surroundings that lmds providing such apportmities cmtinue to diminish md mce are a prim mgnet Of rmch outdoor recreation. This 1s particularlv developd, cannot be replaced. true of the kschutes National Forest. The kschutes Rlver (which has raised mch local cmcern with regard to hydro dwelopmmts), md the In the interest of recreational diversity we urge the retention of the Metolius River. in particular are attractors for both h-egon residents currmt roadless ares to supply the primitive md serm-primtwe md out-of-state tourists, adreceive high recreational use by aspcts of the Recreational opportunity Spectrum. U.S.F.S. measures. The other rivers. Blq hlarsh. Crescent. Little Derchutes md the Fall River, Khile receiving more mderate use, Supply md demmd by activity type are not cmtained in the plan. The currently offer less crwded recreational opportunities. Eut as other Statewide Comprehmsive 01 tdoor Recreation P lan currm tl y anal vzes rivers becom mare crwded, these too my experience wm veater walkinglhiking md bridle trail needs hid?are appropriate to recrea ti onal demnd. mdevelopd recreatlon In the previously mentioned three county area. there will be a need for 65 mre miles of walkinglhiking trails md 44 The value of these stream is supported by the recent Pacific Northwest mre miles of bridle trails by the )ear 2000. That is not to say that immtoryof rivers. The recreational compmmt of this invmtorv was the forest should provide all these additional miles. Glvm their condcted by h-eqon State Parks me hwdred sixty five survevs currmt role of providing 50% of these trails, planned addition Of at evaluating some 300 Dregon stream md rivers were received md lemt 30 miles Of walkinglhIking trails md 20 miles of bridle trails represent a broad diversity of professional recreational mnagers and by the U.5.F.S should be sufficient to met denand experts at all levels of government as well as representative user groups throughout the state. Recreational values m the rivers were Further creatim of nordic ski trails seem warrmted givm the classed 01 a five point scale with the top two ranks classed m (1) continued grwth of that activity. We we also supwrtive Of "ou tstan di n g recreation a1 resources ,I' and (2) "substanti a1 remea tional sem-primitive mtorized areas here feasible. resources." The Oeschutes, Metolius, Little Deschutes, Big Marsh, md the Fall Rivers WePe classed as "outstanding." (The Crescent was not we second OnFWcs mncern about managemnt to mintam ripanan areas surveyed). Current stmdards md guidelines call for managing a%of the stream length in Stable condition. The mtire streanbank 1s imprtant to Tne Desm~tes,Metolws. .~ttlekschutes, Blq marsh mdCrescent *.ere riverine recreatim md needs to be mamtalned iomtified as potential scmlc rivers in d3e 1980 Nariondl& Rivers Immtorv. Tne Derchuter. Metol~~smd Little ksmi.tes hew also Wild and Xenic Rivers idmtif6d by the State of h-egm. In additim, the state also identified the Fall River. The reservation md aotectlon of free-flaring rlvers "7th outstanding scmic md recreation81 values 1s a major goal-of the Statwide The division agrees that wild and scenic "recreation" ClnSSifiCatlOn Comp-ehmswe atdoor Recreation Plan. This issue also 1s reflected in for the Deschutes md Metol1us above Bridge 99 IS appropriate. the Dreom State Parks SKtemPlm (1983-89) reite'atinq the divislm's Hwever, consideration of "scen7C" status for the Metolius belnr Bridge responsibility in the coritinued &vilopnent Of the Dretpn Scenic 99 to L*e Billy Chino& my be mre appropriate. The currmt plan Watknays systw. gives no consideration to the Fall River though it is considered a cmdidate for state designatim. We would support managemmt Of Fall Cur concern in the kschutes National Forest IS impelled by the River that would mlntain the future options for State desiqnatlon. cmtinued demmd for river depmdmt dispersed recreatim thrarghcut the state. mservations of boating activities alone swqest that Ecmomic Cmcerns gmth far exceeds the states PopUialim gmtn. For example. bodtinq on tne Derch~tesbelw Pelton "as been IncreasInq at 5 to IO percent pec year. Wlltwater ooating dithin tne forest nm increased Methodology drmt,cally. loo. Cur expectation IS that as the mre ppldr sbeam oecom mre craded, or restricted in use (s~chm the ROqLe River). Each of the ei@t manaqemnt alternatjves has a calculated Present Net owe' stream. nm D?rhdDI re~ewinqonly nacerate use, will receive Value (PNV) expressed in millions of dollars. This is the difference increased demmd. between the discounted value (bmefits) of a11 outputs to which the Files Files April 14, 1986 April 14, 1986 Page 5 Page 6

mnetary values or established market prices are assimed and the total 1. ~ssrgnmga 0 percent real VK.~trmd for all non-timber dircamted cats of managing the planning area. As such, PNV 1s a resources, including recreatim flies in the face of economic estimte Of the total mnetary benefits gained throuqh the various reality. The demnd for much, ifnot mst, outdoor recreation 1s mixes of resource tradaffs across the alternatives. growing at m accelerated pace.

In formulating these values, a 1 percent per ear real price trend for Simg and river-dependznt recreation are wo prim examples of stumpage was used for Forplan harvest Scheduling analyses. These were this grwth. The supply available for mmyof these activities is applied for the first fifty pars md a 0 percent price trend was used slugglsh or evm static. It is a well established fact that as for the remaining 1M years of the plannmg horizon. A 0 percent real demmd grovs faster than supply, real p1'1ce increases. rice trend far all other resources was used &ring the &velopwnt of kE-5-e en marks md the alternatwes. In other words, their futwe The assumption of a 0 percent real price trend gravely undervalues nominal values will chmge at rates equal to Inflation.* Accordtng to the cmtributim of mtdoor recreatim to the PNV of all the the plm then, recreational resources will not Increase in real value, alternatives. their cantribuhon to PNV in rea1 cbllars remain Static throuqhout the 53 year plann mg period . 2 wjusting recreational activity values 17.5 percent cbwnward 1: clearly errmeous. In addition, the contribution of recreational values to PNV were redced 37.5% for use in ccmparmg resource allocatrm cho~cer. Thls The values for mny of theze actlv?tier were generated using Forest was based tn pmt on dissatisfaction with travel cost methods of Service sites md !hen Forest Service cmtrlbutions to the overall determining recreational activity values. To arrive at th~s37 5% supply were present. It is errmeous to assum that the Forest reduction, the following method was used Servlce lmd 1s an additim to qumtity !hidl lavers these values when that land was ZTiT65-a part of the total quant7ty when the First it wm estimated that nationally. a 5 percent Increase in price values were estimted. would result in a 1 percent decrease in quantity of outdoor recreation demmded for a price elastictty of .2 3. A nahonwide &wnd elasticity IS likely misrepresentat7ve of the demmd elartiaty for Specific recreatim activities md my not be p.~. =quantity &mod relevmt 'to Wegan ad the Deschutes National Forest price demmded 4 It is faulty to assum? that because nationally the Forest Service It was also estimated that in 1982, the Forest Servrce provided 7.5%of ~ovides7.5% Of all outdoor recreation. the Sam holds true for all mtdoor recreatim md that as a consequence, there will be a 5 the Deschutes Forest. Also mmy Of the opportmities offered by percent &crease In price for each percent of the 7 5 percent Forest the forest have no reasonable substitutes libuntain clinbing, Market %are or a total &crease of 37.5 percent for clearing the wilderness travel, alpine *ling are examples of this market * In other words, the increase in supply created by the Forest Service creates a 37.5% &crease in the price of mtdoor recreatim. 5 There is no reasm to believe that Travel Cast nrathocblow For example, the initial value of $24 for a day of resident trout Consistently over EtlmteF trip length, md therefore no reasm to fishing was redced to $15. adjust thme values hwnward as a result of this contention.*

Discuss ion These nethods, the 0 percent real grarth rate assumptim md the further 37.5 percent devaluation of recreation activity values, are The nethoblogy used to estinste the arrent and future value errmeous. recreational resourc~merits careful consideratim if responsible planning of our shrinking resource base 1s to occur. *Corroboration of these pints are provided in the accompanyng cements by Rebecca L. Johnsm, Assistmt Professor, Resource *OEIS Oachutes National Forest, 1986, Appendix 6, p 181. Economist, Department Of Resource Recreation Mpnagemnt, Wegon State University, Corvallis (Edibit A). *ibid p. 193 to 194. Files Exhibit A April 14, 1986 Page 7 COWD(TS ON THE RECREATION VALUES FCR THE DESCHJTES NATIONAL FOREST PLAN

Their net effect is to seriously confound and unc'erestlnute the value of rem-tional resources ad thew cmtributim to Present Net Value Cmsideration of ~esource allocations in the kschutes Forest will be In sumnarizing the reationale for adjusting the mltial values Of the dlstated unless apwopriate recreation value Etimtes are reflgured Resource Evaluation Group, the plan states that TO values need ta be thrw@out the alternatives. adjusted to be canparable with marginal values of other forest wtplts (p. 193). The nationwide c'emnd elasticity of 2 is used to shav that If the Forest Service increases qumtity Of mtdoor recreatim in the nation by 7 5% (their current share of quantity), price should &crease DE jn by 37.5%. There are several problems with this logic 9750C 41 10186 -- The prices rhich are being adjusted mwnward were estimted when the F.S. lmd wx a part Of the total qumtity. In fact, mmyof cc: A1 Cook the smdier rhxh were used to generate the recreation values were John Lilly done for F.S. sites. Studies that were dme on "on-F S. sites would frequently have had F S. sites as substitutes. and regional mdels would have included these F.S. substitutes dwectly in the D estimtion. It is erroleous to assum? that the F.S land is m -0 additim to qumtity mich will lower these values rh7ch were % erUrnated at a tim? when F.S. land was already a part Of the total 3 q "in tl ty . s -- A nationwide dennnd elasticity for outdoor recreation my be a wor represmtatlm of the elxt~c~tyfor speofic vecreatm A+ activities. Similarly, the wrcentag of the total quantity of 0 wtdoor recreatim in the U.S. that the F.S. lmd represmts my be a por representation of the wrcentag that 1s relevmt in the Deschutes National Forest. If adjlstmmts are to be dme, m attempt should be mc'e to use reglonal or Forest-related factors for adjustment rhenever possible

Other reasons stated for adjusting the values mbwnward were related to problem with the TCM. including a, assertim that TCM studies typically are &ne for hi@er quality sites, substitutes are not accomted for, md trip length 1s not accurately measured. mile my of these my be true for a particular study. several points should be m de -- Values for som? activities we~ebased on CYM studies instead of Tm studies. Adjusting these values dowward for problems with the TCM IS clearly ewoleous.

-- Not all Of the studies used single-site Tan models. and therefore m adjustment for substitutes my or my not be necessary. There IS clearly no smgle factor to adjust all of the values by to accomt for excluslm of Substitutes - it would vary by site. -- Aside from the argurmnt of whether or not TCM studies accurately measure trip length, there 15 no reasm to believe that trip length is consistently Over-estimted, and therefore no reasm to adjust these values domiid x a result of this cmtmtim Ifthe planners for the Deschutes National Forest are not satisf?ed ~7ththe activity values est7mted by the Resource Evaluation GrOup, they should make an attempt to find recreation valuation StUdieS hich have been dwe in the Pacific Northwest regiw for spdflc activit~er mich are provided on their Forest It appears that planners want recreation values to be ccmparable to other forest resource values, md therefore the sane effect shwld be mde to find value5 vhxh reflect x accurately x possible the colditions that exist w the Deschutes National Forest

DE:jn 9750C 4/14/06 Department of Geology and Mineral Industries OREGON INTERGOVERNUENTAL PROJECT REVlEU ADMINISTRATIVE OFFICE -"Wr*_u_ 910STATEOFFlCEBLDG. 1400SW5thAVE PORTLAND, OR97201-5528 PHONEW state Clearlnghouse Intergovernmental Relations D1v151on 155 Cattaae Street N E

April 4, 1986

STATE AGENCY REVIEU WAR 07 t986 ProJect Number OR 860137-065-h,=~peturnDate Mr. €I.Mike Miller Dept. of Forestry ENVIRONUENTAL IMPACT REVIEU PROCEDURES 2600 State St. biiim, OR 97310 If you cannot respond by the above return date, please call to arranl an extcn~lonat least one week prlor to the return date Dear Mike. The Oregon Department of Geology and Mineral Industries has prepared the following coments on the Deschutes ENVIRONMENTAL IMPACT REVIEU National Forest Proposed Land and Resource Management Plan. DRAFT STATEUENT They refer only to portions of the Plan and Draft Effects. although measurable, would be acceptable Environmental Impact Statement dealing with mlnerals and o( mineral fuels. Thls PrOJect has no slpnfflcant envlronnental Impact. Reviewers in the Department include Dennis Olmstead The envlronmental Impact 15 adequately deECrlbed (ail and gas), George Priest (geothermal), and Jerry Gray (minerals). Total effort involved approximately 50 hours. Uc suggest Ahat the.folloulng palnt5 be Considered In the aside from a general coordination meeting involving the preparation Of a ~1na1Environmental Impact statement U.S.F.S. and State agencies, we had no direct contact with U.S.F.S. staff on this review. submittal of more detailed I No comment constructive susgestlons and advice or assistance would require more staff availability than is currently at our ...... disposal. RemarEs Sincerely,

-ZL..- Donald a. null State Geologist DAH:ak attachment 1 2

Review cam" tor Deschutes National Forest Plan any area, particularly roaded. non-wilderness areas ADKi1 4. 1986 such a6 Newberry Crater. If the potential resource is deemed less valuable than the potential impact on the (Oregon Department of oeology scenic value of a particular area, then specify that and Mineral Industries) the area by No Surface OCcuoanCY, but still allow leasing. This would allow companies who wish to try to directionally drill into sensitive areas to do so into General: In terms of mineral potential and energy potential leases which they m. It would also Open up the thenis lacking meaningful inventory data for minerals possibility of drilling sme mini"-disturbance and oil and gas. It is vague and inaccurate in its temperature gradient holes in roaded sensitive area6 to treatment of geothermal potential. Without inventory data test for targets which might be reachable by specific to the area the Plan is misdirected__.... - -..in -*ts __ directional drilling. aSSUmPtions of potential,-impacts of develoment. and t If there is a concern that withdrawal of fluids will not emerce in a meaninaful wav in the mrtrrval of the somehow degrade the scenic or recreational value, then the above suggestion will not be feasible. experience ~ ~~ ~~~~~:inent references that should be-consulted is provided.- in other volcanic geothermal fields indicates that there is likely to he little or no impact at the Enerm Minerals surface. The rigid volcanic and crystalline rocks Geothermal: underlyrng the entire forest are unlikely to subside The rarity of high-quality geothermal sites, those very much as a result of fluid withdrawal. The hot associated with young silicic (rhyolite, rhycdacite) springs in the Newberry area are the result of heating volcanism, needs to be factored into the management of relatively shallw ground water by various volcanic Process. The two sites in Deschutes Forest which are gases. This is unlikely to be very strongly affected accessrble by road and which fell into this category by tapping into the hydrothermal system. In any case, are the Devils Lake-Sparks Lake area and Newberrv the Newberry hot springs are not a major part of the Crater. There are oniy a few of these areas in-che scenic or recreatronal resource. United States and an even smaller number of them are accessible by road. The high resource potential and In sunrmary, the USFS should place reasonable rarity of these sites seems inadequately addressed in restrictions on surface uses, hut disallowing use of

the plan. The recreational opportunities offered at subsurface~~ ~ ~ should be based on a Proven potential impact each site are orders of magnitude less rare than the on the surface. No such mpact has been shown for the unique geothermal resource characteristics. The case of drilling directional geothermal production impression one receives from the plan is that holes under enviromntally sensitive areas in volcanic recreation, scenlc views, and possible natural study terrane. There is therefore no reason to disallow as areas are, in every case, more unique and more valuable~~ competitive leasing on anv area as long surface use than the large potential geothermai resources. This restrictions are clearly spelled out. The restrictions overall philosophy needs to be reexamined in the will affect the monetaw value of the leases; some context of the national rarity and economic value of areas will probably reciive no bids based on current the geothermal resources. drilling technology. These areas may get bids in the future as the technolow improves, but the USFS is In the Management Plan, alternatives do provide for hardly qualified to jdge which areas are geothermal leasing. but geothermal development does not technologically feasible for drilling. The market have its own "management area" so must be considered as should decide this. an additional use in other management areas. For example, "undevelowd recreational" areas~~~~. around In reference to the Reviewer's Guide, p. 73, there is Newberry Crater would also be available for geothermal no accurate estimate on the life of a geothermal field

leasing and development. under 8" of the in-. relationshiD.._~~ to the recharae of both heat and alternatives. fluids. Some ireas with very-active magmatic and hydrologic recharge could provide hydrothermal fluid6

In the Reviewer's guide (p. 40. 40. 57). the Management for-~~ essentiallv~~~ an infinite weriod in term of historic Plan (p. 18. 64. 661, and insert IMPS, there is no time, depending on the rate of discharge and obvious reason for not permitting geothermal leasing in reinjection. The resource could be considered renewable in this case. There is at present no data 3 4

for the resources in the mschutes Forest which would Forest, the "Bureau of Land Management Mining Claims either prove or disprove this hyporhesia. Recordation" should be cited and claims should be shown on Classification of the resource as "irretrievable" is an insert map. This reference is available on microfilm premature for this area. from the state BLM office in Portland. The Management Plan does not clearly spell out whether The DEIS, like the Management Plan dismisses metallic a geothermal plant will be all& in various minerals by saying "there is relatively low potential for management areas which are not wilderness or otherwise metallic (locatable) minerals" lp. 179). while this mybe exempted from leasing. For instance, Management Area true, the chance of both metallic and industrial minerals 2-H and 11 cover the accessible part of the Devils exists and exploration, with restrictions if necessary, Lake-Sparks Lake geothermal resource area, but there should be provided for in most Management Areas. In are no clear guidelines about what sort of geothermal Appendix E, Rivers, again no minerals are indicated. Until plant design would be appropriate for these areas. Is exploration has been done, the area should not be ruled out a steam plume a major impact on the visual resource? in terms of potential. would a low-profile, low-noise geothermal plan screened by trees from roads and trails be an appropriate design for these areas? A clear statement on this issue needs to be made for each land classification.

... . ~ 'eas, with the proper controls and resthtions. Metallic and Industrial Minerals: or metallic and industrial minerals a map prtrayal of ADDITIONAL REFERENCES existing quam and aggregate sites is provided. .&ere is no portrayal, however. of claims, mineral leases, resouroe causey, J.D., 1982, Mineral TeSOUTCeG of the Mount data, geophysical data, cr geochercLca1 data. A general Washington Wilderness, Deschutes, Lane, and Linn mineral inventory perfomed by UXWI for the U.S. Forest Counties, Oregon, U.S. Bureau of nines Open-File Report Service in 1977 was not utilized for basic mineral MLA 38-82 occurrence data. Causey, J.D., and Willett, S.L., 1981, Mmeral Resources of All alternatives need a statement about metallic and the Three sisters Wilderness, Deschutes, Lane, and industrial mineral assessment and exploration. The Linn counties, Oregon, U.S. Bureau of Mines Open-File alternatives have largely ignored non-energy minerals. Report MLA 22-82 Provision should be made for exploration under several of the Management Areas, Management Area 8 Iforest use), for Macleod. N.S., Taylor, E.M., Sherrod. D.R., Walker, G.W., example. Causey, J.D., and Willett, S.L.. 1983, Mineral resource potential map of the Three Sisters Wilderness, In the Plan, page 67, the idea is presented that "the Deschutes, Lane, end Linn Counties, Oregon, U.S.G.S. Forest should intensify exploration to deteyine if new open-File Report 83-659 'proven' mineral reserves can be identified. Thus, the Plan elaborates on each Management Area, but only two, Areas U.S. Bureau of Land Management, 1986. BLM Mining Claims 2 and 6, contain a discussion of minerals. It is clear that Recordation, microfilm metallic and industrial minerals have been largely overlooked in the preparation of the Plan. There are many U.S. Geologlcal Survey, 1984, wilderness Mineral Potential, silicic volcanic features in the National Forest. and while U.5 G.S. Professional Paper 1300, vol. 2 most have not been studied. these types of features frequently have epithermal qold resources. One such area, in section 9, T. 23 5.. R. 15 E., is an opal mins site. TO determine the level of interemt in mtallic minerals in the Division of State Lands 3. Natural Heritage Issues 1445 STATE STREET. SALEM OREGON 97310 PHONE 378-3805 The draft €IS identifies a variety of rare and endangered species and proposed Research Natural Areas in the Deschutes National Forest. The Division of State March 51, 1986 Lands noold like to see the inventories of rare and endannered soecies locations and evaluations. as well as inventory and evaluation of Research Natural.Areas, be coordinated with the Natural Heritage Advisory Council. Dave Stere, Director The orooosal for establishment of Research Natural Areas Forest Resources Planninz and broktion of rare and endangered species should be Forestry Department coordinated with Oregon's Natural Heritage Plan. 2600 State Street Salem. OR 97310 4 Stream Alterations Re National Forest Planning Response Coordrnation One issue not discussed in the draft EIS IS the De5chutes National Forest streambank erosion problem between Wickiup Reservoir and Benham Falls. This erosion problem results in loss of bar Dave fish habltat and degradation of water quality possibly due to irrigation withdrawls for the North Unit Staff of the Division of State Lands have reviewed the Irrigation District water supplres A permanent Proposed Land and Resource Management Plan for the solutzon to fishery habitat losses and streanbank Deschutes National Forest, and have identified the erosion should be coordinated with the Division of State following issues that should be addressed in formulating Lands and subject to the Removal-Fill Law permit the coordinated state response requirements 1. State-Owned Uplands A second concern of the Dzvision of State Lands is loss of instream habitat from stream alteration along the The Division of State Lands holds the title to 5even Deschutes River between Pringle Falls and Sunriver. parcels surrounded by and adjacent to U.S. Forest Only a minor number of these alterations, if any, occur Service Land. Two parcels are completely surrounded by on U.S. Forest Service Lands. Any land exchanges that Forest Service Land and five parcels are immediately would result in recreational development of these lands adjacent to U.S. Forest Service Land. It may be should be closely coordinated to insure that bank appropriate to consider expressing interest in alteration complies with state Removal-Fill Law exchanging title of these lands far the purpose of requirements. Recreational users of U.S. Forest Service blocking ownership. lands along these properties should also be informed of the Removal-Fill Law requirements. 2 Submerged and Submersible Land Ownership The Land and Resource Management Plan does not have a The Division of State Lands has a potential claim on the fishery habitat plan that Identifies the potential for submerged and submersible land under Blue Lake, Suttle instrean habitat improvement projects. Identification Lake, Cultus Lake, Little Cultus Lake. Davis Lake, of the management program for these resources and Paulina Lake and East Lake all within the Deschutes coordination of these projects through the Fish Habitat National Forest. Permanent uses and facilities in these Enhancement waiver rules of the Division OP State Lands lakes, including marinas, may require leases from the could be an important aspect of resource management of Division of State Lands. the Deschutes National Forest We appreciate this opportunity to comment. and will be prepared to discuss our remarks I" more detail at the next meeting In the meantime, if you have questions or If I may be of further assistance, please let me know. Very truly yours,

-7lbtMD&~.~Martha 0. Pagel -

Deputy Director MOPIdr 0739f cc Ron Geitgey Geology and Mineral Industries John Jackson Dept. of Environmental Quality Jake Szranek Water Resources Jim Knight DLCD Mike Byers Energy Delores streeter Intergovernmental Relations Bob Brown Forestry an carlson Fish and Wildlife John LillY Transportation Parks and Recreatron George Stubbert Agriculture Dave Fiskun Economic Development Ann Nolan Hanus State Economist Intergovernmental Relations Division - 1\45 npril 8, 1986 Page Tw

Pages 214-219, Geothermal TO Intergovernmental Relations Oivision - A-95 DATE April 8, 1986 The section on geothermal resources Should be expanded to include the state's goetherma1 rules OAR Chapter 690, oivlslm FROM a 65 in any leasing application agreement (copy enclosed). MCLlLam H. Ywng, Oirector, Water Resources Department RoPOSed Land and Resource Management plan Page 61, Special use5 - NM Recreational Permits UZ Comnts - Deschutes National Forest Plan The section m nm-recreational permits Should De mdlfied to reflect state policy on hydroelectric projects listed m ORs 543.165. This law will have major effect M any application for a license in the Upper Deschutes man. me Water Resoumef Department has reviewed the Proposed Land and Res"? Wnagewnt Plan for the Oescwtes National Forest. Page 77, Water cur "rents The text mentions that the us. Farest Service (WS) will work fOllO*. Closely with the watermaster dunno mv oerlod of drouoht to General CMments make sure reservoirs are filled. We &g&t that this &tion The alternative managerent Plans all appear to Provide forest be expanded to include the cooperation with any state task force managgnent oractices consistent with sound water resources estahlishea to reSpOnd to drought conditions. managemt. The Upper Deschutes Rlver Basin has been withdram frm further water awroprlatlon. Each of the management plans appear to Appendices take this limitation into cmsiceration with respect to future Awendix G In addition to the WS and me 8ureau of Land Management developnent. special conditions and stlDdationS for oeothermal develooment. specific "rent5 applicants will also be required to imply iith the -stat; OEIS standards for geothermal wells listed in OAR Chapter 690, Pages 177-178 Division 65, State of Oregon. we suggest that the section on water IeXIILlces be expanded to 1lKOrPorate the &chutes Basin Rogram for the Upper Deschutes 33530 River (enclosed). This Pmgrm refers to potential water management policy directives for streams (p. 177). lakes (p.

177) and water wes (0. 178). As a Oart of farrest olarminor~. .~~~ ~ ~~~.. Process, these pr~grm'statenentsneed to be addressed becaus; water use is restricted in the upper basin both by policy and actual supplies and potential Projects would require alternative rater swrces. Page 178, Colum 2, 1st Paragraph me text mentions the withdrawal of the upper basin as "1969". m15 statement should be "1913". Page 178 me text motions many Streams are being evaluated for low head hydro and a list appears in Appendix G, page 529, Table 10. ne suggest this list be modiPied to reflect current hydro policy in the Deschutes as listed in ORs 543.165 (copy enclosed) and Other state requirements such as water rights, the upper basin withdrawal order and hydro rules OAR 690, Division 50. We encourage mtinued cooperation between the US. Forest Service and the state to as5we cowtibility hetween revisions in the forest plan or changes in state water iesources policy. 4. Aqmntatia of the water resources can be achieved thmugh storage of wmlus winter and spring mff; reduction of storage, chamel, and transmission losses: am mre efficient use of Dresentlv appropriated water.

5. mere are physically feasiDle storage sites in the ba51n. 6. Vlappropriated raters of the Descktes River and its tributaries above Bend, Tunalo Creek abve Coldla-Southern Canal, mmked River, Ochoco creek am mite River and its trimries have ken witherawn for special uses. 7. me establlskd llmitea purpses of existing storage develwnts restrict rmltiple beneficial use of the water reswrces. 8. me existeme of gmwd water has been established in certain sectiw of the basin, but wantities have mt been detennfned. 9. Carestic, livestock. am mielpal uses of rater, while Wrtant, represent minor quantities in existing ard contenplated future water Use. la. rrciwtim is and will ccntlnn to be the m@r comwtiue rater use in the basin. ll. Mequarely lrripated agricultural lards represent only a mall portion of the total irrigated area. 12. The existing lrrrsated acreage CWld b IMR than dcdlled pmvldm an awtesqly of rater rere available. u. me basin has substantial potential for power developmnt. 14. me basin has potential for Mustrial developnent.

16. The use of water for minim puwposes 1s slight and is not expected to increase mterially in the foreseeable future. 3. Upultaneors (M of a mdor portion of exist- nnswtive rwts fhs at or mar the am level sme stream @rhth? rude in on ReCIeadM a USe Of and tfW mth% 17. iS malar later an important factor 1" - ec"y of the basin. la. mere is an abumance or reservoirs, lakes am stream available for water-based recreation in the western portion of me Msin. 19. There 1s putential for mre extensive use of existing waters for recreation purposes. 35. Criteria for detednatinn of desirable base Plows c-surate with all beneficial uses have cot keen developed. Flow levels for recreational use may be Substantially greater than rlas recormendm for the Swrt of aquatic life. 36. It is inperative that single-purpose develomnt of available sites does not preclude optir" utilization of the rewrce. 31. Certain major rivers, or river SeCUMS, wd nmrouf lakes, mimr Streams, and CIWS are by nature of their physiography, katiM, land ownership. or ecoKmic wtential available only ror limited resme uses. 38. Physical features, degree of ecmc aevelomnt, and rater use requirements vary from subbasin to Subbasin. -ORE BE I7 REsayEo that for reasa of variance in physical features, mee of ecomnic develomnt, and water use requirmts fm subbasin to SLkbasin, the Board aaopts the following findings and isms pmgram statmnts for each of the subbasins of the Oesbyltes River Basin.

lppER OE-S RIwl WKRUIS the State Water Reswrces bard under the autmrity of WS 536.Mo has eltaken a stm or the Upper Desctwtes River Basin as delineated on State water RCSOUIC~S Board WP,~ile 5.m~; WEWAS in this study consiaeratim was given to means and mews of augnenting, conserving and classifying such nter reSOUITe6, existing am contemplated reeds and uses of water for dcmestic, mumcipai, irrigation, power developnent, insustrial, mini*, recreatxn, wildlire and fish life uses, ana for pollution abatgnent as well as other related subjects including drainage, reclamation, and flood control; am 30. ~Lm6..drowpa no s- emim are mt major pwleaa. WKREPS as a result of said stay the following findmngs have been remDy this Board: 1. me total quantity of rater is sufhclent on an average-year basis to satisfy all existing ana contemplated needs and uses or nter with the exception of utilization or water to minimize pollution. 2. mere is not emugh water legally available on a critical-year basis to meet existins aM contenplated cmswtive needs within tnis basin. 3. mldistrihtion exists wth regard to physical lccation and with respect'to availabllity a"g time of need.

4. Han streams dn mt pmvide e- flow for present mmqtive pubLC uses in periods or relatively low as weu as critical rim.

-4- 24. Utilization of flows to lninrmlze pollution should not he pemritted if scch use interferes with the nultlple-purpose concept. 25. Certain lakes are, by nature of their physiography, location, lard mrship, or ecWc potential available Only for limited resoMe use.

26. The l~ximmmficial use of the raters of the upper Dexhltes ~iver msin will be for carestic, livestock, Mnicipal, irrigation, pmr develqment, imustrial, mining, recreation, wildlife and fish life uses.

MW WCRE BE IT REYLVED that this Enam hereby adopts the f0llWL-g pmgram in accordarce with the provisions of CRS 536.x10(2) pertaining to the M. ma?s is mad to lnapo water for -tic. livestock, wd Mlicipal rater reswrces of the upper kwhutes River Basin: .hlcn, .Nlo Wll, are Qf baefit ta va *taw. - a. The naxlnun econanic aevelomt of this state, the attairnent or the highest ard best use of the waters of the Upper kxhltes River Basin, and Me attaimnt of an integrated and coordinated pmgm for the benefit of the state as a mole will be furthered throypl utillratim of the aforemntioned waters only for daestic, livestock, Mnicipal, irrigation, power developmt, icestrial mi-, recreation, wildlife and fish life uses and the raters of r& UFper Deschutes River Basin are hereby $0 classified with the roll" exception: me ecmc develqnent of this state, the attaiment or the highest and best use of the waters of the natural lakes 01 the upper Deschutes River Basin. except for Crescent Lake, anc the attainrent of an integrated and coordinated prwam for the benefit of the state as a whale will be furthered thrqh 16. mS basin has Potatfal for mtimu5~ of water. me mallakes uld m" mtitute valusble recreation assets. utilization of the aforgnentimd waters only for carestic, livestock, irrigation of lam or nlwrmrcial garden mt to 17. mtu -tim by wildlife represent a sipliricant exceed m-half acre in area, power develqnent mt to exceed dDEi mt 7 1/2 theoretical horse-r, recreation. wildlife aM fish ClPntltY. ufe uses anc the waters of the natural lakes, upper ksdutes le. Rrm ara m VPmpM ria in the Dam. M msim fish River !&sin, except for Crescent Lake, are hereby so classified. couutute M ir"t asset state. of thn 8. TO support aquatic Ufe and minimize pollution, in accordarre with Section 3, chapter 796, Laws, M 19. ll" la potential for dcMqat of a"e fish, M this meson 1983, awmpriation of water CmOT tm .eNcrcd dVlaX Va lrpmVenan of fish pasupe am shall be made or granted by any state agency or pmlic corporation of la-fla 0ndtia-a. the state for waters of the Upper DexhlteS River aM tribUtarieS *hen flows are below the levels specified in Table 1. This lfmttation shall mt awly to. 20. Mfllcts axist btm fish life am irriwtim uses of rater. 21. Fnllutlm of na grand water is rot a sipnificant pmblm. 1. HUMn ahd livestock cmsvnption. surf- 2. Water legally released fm storage. 22. ORlnSpe ana rrcLnsrion of dnM 1- are mt sipnirlcant factors In praenr nd smtaplsted 4ter "sa. Attaimnt of the Specified flow levels during SOW POFdMS Of the year will require developnent of rater stora~or iwlementation of 23. FlompmblsaOrS.imr. other measures to aument flows.

-s- C. riplicatims for tM use of the waters of the Upper oeschtes River Basin shall not be accepted by any state agency for any other use am the granting of applications for such other uses is declared to be prejudicial to me publlc interest and the grantins oP applications for Swh other uses iwld De cmtrary to the integrated and cmdhted program for the Use aM CWtml Of the Water reSWrces Of the state. 0. Rights to use of rater for iwstrial or mlnLng purposes granted by any state agency shall be issued only on the mndition that any effluents or retum Plows fmsmh uses shall not interfere with other beneficial we* Of rater. E. Structures or w*$ for the utilization of the raters in am with the aforementioned classificatlons are also dfflared to be prejudicial to the public interest mless plaamed. constructed and operated in cmPonRity with applicable pmvisions of OAS 536.310 and any such stnrtures or xol*s are further declared to be prejudicial tO the public interest which do not give proper cognizance to the rmltiple-se concept.

UXLE MSWTES RIYER WREAS the State Water ResmCeS Board under the authority of WS 536.3W has drtaken a study of the Hiddle Deschutes Wver Basin as delineated on state WatfX RewLCeS Bo& Hap, File 5.7014. w- w- in this study mnsideration was given to mans aM mtMs of awting, cwerving, and classifying suCn water resources, existing am cmtqlated needs aM uses of water far danestic, Mnicipal, irrigation. pewr develop" industrial, mining, recrsatim, wildlife and fish life use5 uses, and for pollution abatement as well as other related subjects irrlwhg drainage, reclamation, and flmd contml; and WHEREPS as a result OP said 5tudy the lollowing rimins5 have been read by this Board: 1. The total quantity of water is sufficient on an average-year basis to satlsfy all existing and cmtwlated meds and uses of ater in this basin dm the exception of utilization of rater to "ire pollution. 2. HBldlstriDUtion exists with regard to physical location and dm respect to ayailability &ing tim of neea. 3. Unultanews use of a major cartion of existing commtive rights results in flows at or near the zero level on many stmans dDing the smrmths. 21. Base flows recmnded by riskdes agemies are substantially 4. ma ev.isrars of gmua rater has ken established in certain nigher sectims of vle but ~uantitieshpve teen deternirrd. in nany locations than flow levels that can be obtained during basin, rot average water years mer current stream regimen and existiw water rights priorities. 5. mrs are lcplrlatin restdctioro m the uy of waters of TW and mxk. 22. Pollution of surface and grmwater is not a siwiricant prmlem. nscd to water for donatic, liww 6. man is lnsrpo am wntitative mes of water rill be for irrigation, YIOI bhM, nile mu, 8re Of tamfit to 23. Major foreseeable the state. pnrer, recreation and fish life. 7. lrx*tlal ia am will mntina to bo th am* cm8uQun Uz4 Of 24. Utilization of flows to minimize pollution should mt be permitted if ntes. such use limits or conflicts with the multiple-purpose corrept. 8. 25. Haintemrre of "m peremial streamflows muld generally bmeflt recreation, wildlife and fish lire. 9. 26. criteria ror detennhtion of desirable base fhs camensmate with all beneficial uses of water have Mt been developed. lo. 27. Certain river Sectlm, lntmr streams, Reeks and lakes are by mtm of their physiopraphy, lccatim. lard ownership, or ec&c potential available mly for llmited resome me.

mars M @&ally feasible stomp sites. 28. me maxi" benericial use of che waters of the Mlddle 0eScM.s mer .%sin rffl ae ror mestit, livestock, mnicipal, irristim, pnrer developnent, industrial, dnlng, recreation, wildlife and fish life mes. MW -CRE E IT RES(LVED that this Bard hereby adopts the rouwing program in accordarre with the provi~ionsof ms 536.300(2) pertaining to the ater re%xrcesof the Middle OesChUtes River Basin a. me rexi" ecacdevelopment of this state, the attaimt of the Nghest and test use of the raters or the Middle Cesbwtes River Basin, and the att-t of an intwated and Cwrdinated pmgram ror the benefit of the state as a mole will be rurthered tNough utilization of the aforementioned waters only ror thmstic, livestoclr, mmicipal, lrrigatim, pwer developnent, industrial, mining, recreatim, wildlife and rish lire uses and the waters of tk Hiddle oesdytes uver !&sin are hereby so classified with the fallowing exceptions: 1. me state water Resource4 Board urogram. Lwer win Stem Oesbwtes River, aacpted ~1113, 1964, as mzdified by the Water Policy Review Board.

2. me m'i$rm ec~~rmcdevelopment of this state, the attairment st and best me or the waters of the nain sten, $toEmMZr. ahve river mile 13.0, aM the attaimnt of an inrematea and CmrdlMted pmgram ror the benefit or the state

-9- -1% u J We dll bs npthucd avDuoll utilization of the wrated in cwronnity with tbe awlicaDle provisions of ms 536.310 aformntimd w8ters only for d-tic, livestock, Irri.ptim and any such structures or wrks are further declarw ta br of lam or mrrolgrcial pvancarden mt to exceed m-hllf acre in PreJudicial to the public interest rnich do rot give prop: -. pasr dsvslopar, -rim, vildlife and flsh life uses cogrdrance to the rmltiple-pwse cwept. ond the nms of the min stm. mtollur River. pmvc rive- L" EHIlESRIYER IiliXaS the State water Res-s Boarct uder the authority or (As 536.m studied the Lower oeschutes River Basin as dellneared on State Water Re-- eaa.d w, File 5.7014; WGTAS the mater Policy Review Board Vmer the authority of ms 536.303 am 536.340 has uldertaken a restudy of the Lower oesdutes easi"; WmmS in this study mnsideration was given to mans and news of augnentinp, "sew- and classifying Wm water resouces, misting and emtenplated needs and uses of rater for danestic, municipal, irr-uon, pwer developrent, inoustrial, mining, recreatim, wildlife and fish life uses, am for pollutim abatemnt as we11 as other related subjsts inclrdinp arm, reclamtion an0 f1-j cmtrol; and WEEPS a6 a result of said study the following findings have been rea- by tNs Board for the tributaries or the OescMes River within the ~acr ce%iutes River Basin: 1. The total quantity of water is Sufficient on an average-year basis to satisfy existing reeds and Uses of water with the exception of utilization of rater to minimize pollutiw. 2. NaldistrrhRion exists with regard to dIysfcal lDcation and with respect to availability dur- time of need.

3. Many stream dD mt provide emugh flow for ~nnnslnptiveplbb uses at present in periods of relatively low as well as critical flw. 4. sirmlt-us use of a major pmtion of existing cmsvrptive ri$ts results in flms at or near the zem level on mny st- dur- the s-r months. for ach otho m uuld bs omtrary io the- in&&ea and 5. Flows, unless awnred by storaae. wld rot be surricient on most emrmratsa pm(pr for the we a-d CDntml Of the water rrSOUrrer Of streams during the 5urmer mths to srpply future CDNUrOtive am M state. rrrrwwtive aemands.

0. +ta to IM of vatex for lndatrial or ai- msgranted by 6. The exist- of gmm rater ha5 been established in certain any state .gacy sIml1 bs issued only m ccaEtion that my effluents sectim of the basin, kt wtities have rnt keen determined. or reUnn ?On Im such uses shall mt interfere with other baafiCi.1 \DO. Of water. 7. W unappmpriated waters of white River aM trhtaries have been nit~nwnby the State mpineer for 5-1 uses. E. stncunaa or wska for the utilization of the raters in PCCO- r1th the .forramiud classiflcatlms ue al*o Ccclared to be prejuud to the palic interest UllCIs PlaN€d. nnrmrted, and

-u- 42- 26. IUinteMnce of mininun peremial streanrlas would be in the pmlic interert.

27. Certain lakes are by nature of their physiography, location, lam arnership, or e"ic patenrial available only for limited rescue Use.

28. CTiteIla for detenniMtiM Of desirable base f1wS CrPllMUIPte with all Lweficial uses of rater have mt Men developd, 11- infomation is available M flow reqdmts for awtic life. 29. The mi" benefical use of the waters of the tributaries of the Deyhrtes Uver within the Lmer Desdwtes &sin will be for annestic, llvestmk. nunicipal, irrigation. mer devel-t, irmstrial, mining, recreation, rilalife sm fish life uses.

m -(RE BE IT ESXVED Chat this Boud hereby aacpts the roilam pmprn in acmmnce dm the pmvisions of L+(s 536.Mo(Z) PertainIq to the water re-cs of the Laer Desblltes River &sin:

A. The mpxiMn eccnn!ic aevelwnt of this state, the attainrrnt of the himt am best use of Vr waters of the Lmr 0e.iCMes River win, am the attaiment of an intqratea am cmmimted program for the &fit of the state a* a .hole rill be fmtherea thm@ utilization of the sforamtiad raters only for mmstic. livestcck, dcippl, irrigation, -1 devclqment, imntrial, wining. recreation, wildlife am fish life uses am the vatem of the Laer Dewhit- River &sin are McDv so classified rim the rollowins exceptim: 1. The State Mater Resmes e" prcgrm. Lowr Main Stm Desdwtcs River, awtea April 3, 1964. as mdifiea by the Mater Policy Review soam. 2. The waters of Boulder Lake in How River am nay0 CMtics are Classiflea only for dneStlc am livestock uses; per develmt mt to exceed 7-112 theoretical her-r; P. mt factors recreation, wildlife ax fish life -9; am irrietion mt to exceed io0 acre-feet a-uy fmwater stored in tk i&. 3. The "ec&C de"e1-t Of this state, the attairamt of the Nshest ax best us? of the waters of the other (Utmal lakes of the Lwer Desdutcs River &sin, and the DaEfit of the state as a *hole rill Dc furthered maqh utilization or the aforementioned waters mly for Camstic. livest&, irrigrtim of lam OT mncmrrial .p&n mt to exceea onc-half acre in area, pner acvslccmnt mt to cxceec 7-112 Uroretid hm-, recreation. rilalife. am fish life ulies am the waters of vr Mtm.1 lakes of Vr Lower Oerchutes River earin are hereby so clasiifiea.

-u- -14- 8.

IS 21. ynall reservoirs on mimr triwtaries could rea flash flccds and atreamam emsm ana provide late-seasan irrigation rater.

z!. UtliZatiM Of flW5 to miWZe POllUtlM ShWld Mt Qe pennltted if such use Mts or CMflictS with the nultiple-purpose ConCept. 23. Criteria for determination of oeslrable base flaws cm"rate with all Derrficial YYS of water have not been developed. 24. The maxinun beneficial use of the maters of the Upper Crwed River &sin vi11 be for dmstic livestock, mnicipal, irrigation, poxer develwnt, industrial, &, recreation, wildlife aM fish life -5. Nln TKREFORE BE IT RES~VED that this ham hereby adopts the lollaim pmpram in accordance with me pIOViSiM5 of OR5 536.303(2) pertainh4 to the water "rces of the msdutes - upper Crmked River Basin:

~~~~ ~ ~ ~~~~ ~ ~ -em ror'the~benerit of tw state as a whole will be rUrtherpO thrmph utilization of the aforementicred waters only for darrstic, livestock, Mnicipal, irrigation, power evelopnent, Wtrial, -, recreatirn, wildlife and fish life uses ana the ratexs of UU Desblltes - upper cmoked River Basin are hereby so classified. 8. npplicatlw for the use of the waters of the mschrtes - Wr Qwkd River Basin shall mt be accepted by any state agency for any other use ana the granting of applications for such other uses is declared to be prejudicial to tin? puelic interest and the wantirq of appllcatlms for wh other uses rruld be contrary to me integrated and emminated program for the use aM control of the water re-ces of the state. C. Rimts to use of rater for industrial or mining purposes granted by any state ag-y shall be issued only m condition that any effluents or ret- ?lows frm such uses shall mt interfere dm Other beneficial uses of water. -.n. -<+".-+"res ____ or_. mrks... .. for.. the. . utilization. . Of the rater5 in acto- with the aforementioned classiflcaths are also declared to be prejuaiclal to the puQlic interest unless plamed, cwtwted, aM operated in mfomlty with tM applicable PmViSiOnS Of CRS 5336.310 a~ am su% stmtures oz m*s are further declared to be

-17- 13. ~eservolrswill provide a mor Dortion or mter-bared recreation. 14. The waters of the Crooked River, including Opal Springs, fron river mile 6.5 to rwer mile 18.0, are a valuable smce of mniczpal, irrigation, am iraustrial rater. 15. Little patential for erharcenent or ?ish Me exists and is depement rp~nsRvring adequate streamflow. 16. I-ases of pDpulation and the need to serve presmtly -wered arras rill require municipal =rape ror~sto be e-. 17. Limited flmd problems exist. M. a coordinated plan of operation of ochon, and Prineville ~eservoirs rill materially alleviate flood damages in the Prinevllle Valley. l9. Them are physically feasible storage sites rithln the basin. 20. %all reservoirs on mimr tritutaries could redre flash rlmds and rwermm am provide late-season irrigation rater. 3. lpsthl and with 21. Utilization of flows to "ire pollution mamt be pennitred if Use UfSOr CMmCtS With the mUltfp1-W -t. 22. Certain river seftiMS, mimr streams ard creeks are by nature or theheir physicgapny, location, land o*nerShlp, or eCOKmic potentia1 available only ror limited reSDuLcc use.

23. Criteria for Ottern&ru1iCn Of ocslrablc base tlorr cDnnelluvate "itn all Deneflcial uses of *ate= MYe mt ken develwed. 24. me mexh beneficial use of the waters of the Oesztwtes - ~ower Crwed River easin will be for aarestlc, livestock, mcipal. irrigation, power develownt, imtrial, mining, recreatim, rilalife ma rish lire uses.

A. me nexi" emnaic developRnt OP this state, the attairuent Of the himt am best use or the waters of the Deschutes - L- wed River 0-in and the attaument of an integrated and cwminated prcq" ,ror'the benefit or the state as a *hole win be furthered tkc&i qkllization of the afoorenentioned waters only for donestlc, livcseock, mnicipal, irrigation, power devel-t, imustrial, mining, -ation. wildllfe and fish life uses and Lhe waters of Me Ceschutes - Lwer Crookd River Basin are hereby so classifid with Me following exceptions:

49- HYDHOELECTHIC POWER PROJECTS 543 165 1. Th? State water ResourCes Board program, Lower Main Stem Deschrtes River. ampted mril 3. 1962, as madiried by the water policy Review Board. 2. No further awmpriatirm of ater except for dmstic or livestock used shall be made or granted by any state agemy for the lilters of ochoco Creek ard its trlbytaries. 0. applicatims for the use of the waters of the Deschrtes - Lower CmCKed River Basin shall mt be accepted by any state agerry for any otter use am the granting of applications ror swh uses is declared to De prelu3lcial to the public interest and the granting or appllcatims for such other uses mld be cwtrary to the integrated ard c"ted program for the use and control of the water remsof the state.

C. Riphts to use nter for imtrial or mi- woses granted by any state agsry shall be issued only on -airion that my errl-ts mtm fhs fm such utes sMIl mt interrere with other beneficial usof nter. 0. Struturn or works for the utiliatim of the vats in acco~d- with the aforarnriDxd clarsificatims are also declared to be pn1udicW to the F&UCinterest des5 plam, comtmted am mtedin cmfornity with the applicable provisions of ORs 536.310 am3 my wr(, stmtms or wrks are further declared to be prejudicial to Va Wlic interest rhich do Mt give pmper CopliMCc tn the nultiplhplrpose cmept.

Dated Novmaer 29,1984 wnm WCY FEVIEW BOW

APPROPRIATION OF WATER FOR mwm. APPLICATION OF LAW 643.110 Apprapruliam ad "e of r-lsr for power I. governed by tbi.

-21- OREGON ADMINISTRATIVE RULES CHAPTER 690, DIVISION 65 -WATER RESOURCES DEPARTMENT

STANDARDS AND PROCEDURES FOR LOW TEMPERATURE GEOTHERMAL WELLS AND EFFLUENT DISPOSAL SYSTEMS

65405 POLICY AN0 PURPOSE: (1) All Low Temperature Geothermal Fluids are palt of the ground water remu~ce~Of the State of Oregon and shall be admmlatered by the Water Resources Dtre.eCLm (Director) undar the provlelons of ORS 537.010 to 537.795. The Director recognizes that these fluids are developed prlmarlly because Of them thermal CharactenstIC9 and that ~pecial PEELlMNAF3' PERMITS:LICENSES management Is necessary. Reservoir assessment Of LOWTemperature Geothermal Fluids shall be conducted by the Director sn the -me manner as ground Water investlqations Outlined In ORS 537.665 and ORS 537.685.

(2) ThW purpose Of the folloWlNJ rules 19 to pmwde EtBndsids and procedures for the development. use and management of Low Temperature Geothermal Fluids, while insurtng P~DPB~management of all ground water relources 60 maximum beneficial use of the reD0ume will be most effectively attamed.

(3) These wles supplement OAR 690-10-005 to 690-10-oy5, 690-60-005to 690-63a5. and 690-64-000 to 6904610. Rule 690-60-050. paragraph 47 and 690-61-181 are hereby rescmded.

DELETE: [690-60-050 (47) "Thermal Ground Water''. means ground water having a temperaturn greater than 90 degrees Fahrenhert or 32 degrees Celsius, (The statutes Of Oregon delegate to the Department Of Water Resources the epproprtation and ouPervlslon of thermal ground water having a temperstwe of less than 250 degrees Fahrenheit or 121 degrees Celaus, and accurrmg w8thm 2,000 feet of the land *"rfaCe.)I

[690-61-181 CONSTRUCTION OF THERMAL OR HOT WATER WELLS. All thermal 01 hot water wells havmg B maximum wstw tempemtue of less than 250 degrees Fahrenheit (121 degrees Celsus) and ConstPucted La depths Of le- than 2,000 feet shall be EonstwCted In conformance wlth rule$ 690-61-006 through 690-61-176. The bottom-hole temperature shall be measured and recorded an the water well report.1 (b) The effluent contams contammants, other than hest. that have heen added to the Low Temperature Geothermal Fluid.

(C) The effluent 19 reinpcted to B ground water reservoir that IS not consiaered

suttabie by the Ohrector. Factors Which may render a ground water leSelYDll msuitsble rwlude. but BR not Irmrted to. chemrcal or phyaxal incompatibility of the fluid* involved or adverse hydrsUllC CharaCtePistlCS of the recslvlnl re8erYOIr. (d) Them are existlrq or potential problems or special conditions as determined by the Director. PrDblems or special condltlona resulting fmm the effluent dimosal system which may warrent a nonstandard designation miude, but are not limited to, lnstabtllty at near-~urfaceearth m8tmmis. undue slterstlOn Of them" CharBCterietICe, unreasonable haad ehangsa or downrbps subsurface leakage of effluent.

(7) Secondary Unrr Comumption of LOWTemperature Geothermal Effluent for beneflctai use including, but cot limited to. domestic, irrigation. stock watering, commslciel and induetriel uses.

(8) Standard Low Temperatum Geothermal Effluent Di4)osai System: Any LOW Temperature Geotnsrmai Effluent Disposal System 8n whih om of the f~ilowing cOnditiOn?lare msc

(a) No contaminants except heat have been sddsd to the Low Tempereture OLlDthsrmsl Fluid and the effluent is put to B Secondety Use. (b) No contsmmsnb except heat have been sddsd to the Low Temparetum Geothermal Fluid and the effluent 1s returned to the pmducing or other witable ground water ree.llrv011 end them are no other existing OP potentisl problems or -cmI cmdititm 8s determined by the DmCtoI Including, but not limited to. those factom, problems and conditions listed 8n 65410 definition 6, paragraph* f and d. SUBOIVISON I '%ELLrONSTRIJCTION STANDARDS 65-035 WELL-HEAD PROTECTION EQUIPMENT Adequate well-head equipment to mswe phbC aefety and the protection of the qrouna water resoume shall be Immediately 65-015 LOW TEMPERATURE GEOTHERMAL WELL AN0 REINJECTION WELL lnrtelled an any LOW Temperature Geothermal Wpll or Low Temperature Geothermal CONSTRUCTION. LOW Temperature Geothemel Well$ and Relniection Wells shell he Relnlectton Well when fluid tempePstuleS Of 65' C (15O'F) Or qreater am encountered cmstructed in confoimsnce with applicable des (OAR 690-10-005 to 690-10-040 and dunnq dnlllng. Low Temperature Geothermal Fhdr produced during drlllmq or testmq of 690-60-001 to 690-63495) with specific sdditlM8 and modiftCatlolU a* dsserlbed In OAR such a well shall be dwased of m such a manner 88 to minimize health hazards. A 690-65-001 to 690-65-070. vmance from the requirement for well-head pmcectlon equipment may be gamed If a written request demanstcaka that Ihe equipment ts not ne~es~eryto aafely complete the 65-020 LOW TEMPERATURE GEOTKRMAL REINJECTION WELL LOCATION For welL appiopilatmns not exceeding 15,000 gallons per day no Low Temperature Geothermal Reinlectmn *Id ahall be located wlthin 75 feet of any exlattng Low Temperature 65-000 PUMP TESTING OF LOW TEMPERATURE GEOTHERMAL REINJECTION Geothermal 'Ne11 utlllztnq the =me gmund water resowyotr WlthoUt Buthorl~atlOnfrom the WELLS; All Low Temperature Geothermai Rempctmn Well, hall be pump tested for a pertod of at least One hoUn results must be recorded On the wate? well report. This Director. Unless both the wltkdrawsl and remjectron wells are on the lame PelEd Of land minimum test shall be Conducted as follow= and are used by tho same gMdWater appmpmator. A varian~efmm the 75-foot *tback r0qUIrement may be 8-d by the Director, follawlng B WIIttBII reque(Lt for 5pBClSl (1) standards (desmbed by 690-60-000) by the water well ConsVUctOr OP Isndownsr. who under Pmor to tetinq, the StatlC Water Level tn the well shall be measured and recorded. the pmYllions of 537.753. 18 conrlructing the well, If hydrologic and thermal Conditions permit closer )pacing. (U Water shall bs pumped mta or fmm the w01l at B mesnmd end steady rate the rate shall BPPmXm" the maximum BnllElpated unptlon rate of the aperstrng For aPplDPristiwu exceeding 15,000 gsll- per day, the BpPrOpmtor shall submit plans for well. review to the Oireeror or hi8 authorized rep-ntatwO. indleatlng parat ti on dlstancer (3) For tBIa that withdrew water. only banltng 01 pumping the well ID acceptable. between PrOdUEtlm end remlectlon wslli on the pame1 of land an whlch the pwductmn well (4) The Water level In the well ahell he meesured and =corded both at the end of pumping end after one hour of recovery. 18 located. on the parcel of land on wlch the reinjection well la located, and an sll adjoming parcels of land. In dltion, the plem shall indicate the anticipated hourly (5) For pmPossd dlsppollsl exceeding 15.000 qallom per day the DIRC~OImay Pmductlon and remnjscfmn rates, ths maximum entimpated dally pmduetion, and any pisaribe B more detalled teat that Could amludq but 111 mt llmlted to. planned fafogusmi* against undue thermal and hydrologic lntarfsntms with exmtmng rqhts tncreased frequency Of Water level mwure~~nt.mereatad t& duration end to appropnste ground water and surface water. mnltomng of Obsarvatmn wells. Such modifications will be required when POMlble ImPaCtS reaultlng fmm the development mclude. but are not llmted to. 65425 DESCRIPTION OF FROPOSED uy: For any Low Tempereturn Geothermal thermal or hy&log#c interference waul exfsttng water ng,ts, water guslnty degradation OP Of Cmttwctmn. Well or Low Temperature Goothermal Rsinlectlon Wall, the report required under OR5 failure well 537.762 prior tm co~sncirqcmLNctim .hs(l identify the intended "sa of the well. the BPPrOPIIat0r"r name and the Bppmpnstoth maolinq address

65-010 lOENTlFlCATlON OF INTENDEd WELL USE: Any Low Temperature Geothermal Well or LOWTempmatm Geothemd Rslnjsctlm Well shall be ClesrlY Identified a$ such on the water well report filed with the Water Resources Dspartment.

-5- SUBDIVISION 2 65-L145 dATER TEMPERATURE MEASUREMENT: For any Low Temperature LOW TEMPERATURE GEOTHERMAL EFFLUENT DISPOSAL Geothermal 'ne11 that withdrawn qmund waler. the Water well report mut include the maximum temperature measured in thwboreholt) and its corresponding depth. and the 65-055 EFFLUENT DISPOSAL BY REINJECTION / FLUID QUALITY ASSESSMENT lemperature of the fluid m meamred at lhs dmharqs point at the beqlnninq and CO~C~UI~O~ Prior to remnieclmn, usm required to file for wter nghts shall supply the Dmctor flwd of a timed Produflion test (la. pump or bailer teat - 811 lest unacceptable). The maximum quslity mformatmn concerning the Low Temperature Geothermal Flurd, the Low lsmpsraturo measured nn the borehale end ita EOIre.pondlnq depth I* required on tho water Temperature Geothsrmsl Effiusnl. and the gmund water 8n the recsivlng zone of any Low well rem for B Low Tarnperaturn Csothsrmd Wall that do- not withdraw ground water. Tempmaturn Geothermal Rsin)sotlon Well for system that withdraw and reinject ground waler In order that the Low Temperature Geothermal Effluent Dlnpossl System bs 65-050 ADDITIONAL STANDARDS FOR LOW TEMPERATURE GEOTHERMAL clawifled 88 Standard or Nonstandard. The required lnfonstion shall include e certlflad REINJECTION WELLS: ROcedum rsquhed to miniset eftlusnt into e Low Temperature chemical snslysls for the following pnrm"erb Temperature, pH, Suspended Solids, Gaotha~lRslnjactim Well mum mt E~Mfallura of casing and mal material or other Specific Conductance, Total Dissalved Solids, Tots1 Coliform Baclerra, Aisenx!, Boron, cmv"tt of the well cmmctim Calcium. Carbonate or Bmarbonste, Chioiide, Imn, Magnesium. Mangsnsss. Potasalum. -Slllc~odlum-and-5ul(ste. If-poor-water-quality or wate? qualify l~~mp~tlbl~-w~lh.th~-- - reln]ectlon zone fluid8 Is suspected, the Director may raquire additional specific date. The Director may wdve the requirement for .pecIIIc porti~nsor all of the chemrcsl malysm tf the fluid quality la known to be svltebls for the Intended dthdrewel end rslnjsctlm,

-7- -6- SUaOIV1s10N 3 WATER RIGHTS PROCEDURE

65-060 PROCESSING OF APRICATIONB The appmprlatOI shall make BppltCallDn for a water rlqht to Bppmpnste LOWTemperalum Geothermal Flutd wlers 80 exemptmo ~5 Plovidsd for under ORs 517.545.

65-065 EXEMPTION FROM WATER RIGHT PERMIT APRlCATlON I USE OF LOW TEMPERATURE GEOTKRMAL FLUlh Low Temperature Geothermal Fluid appmprmtion for single ~nduslrral or commlllclal use mluding. but not limited to. electncsl. BgrlcuItwaI, aqwdtural. heating and/or coolmg m an amount not exceeding 5,000 gallons per day shall be exempt fmm spplicsttm for a water nmt as pmvided for under ORS 517.Y5. This exemption eppliet to the uw of gmdWeter fop any wch PU~OBBto the extent that ut 18 bsnsflcial and constitutes a rlmt to appropriate ground water equal Lo that eatsbllshhed by s gmdwater right ee*lflcate.

65-070 WATER RIGHT LMITATION FOR NONSTANDARD EFFLUENT DISPOSAL SYSTEMS If the Low Tempemure Geothermal Effluent ID disposed of by way Of a Nomtsndsrd Low Tempratme Geothermal Effluent Disposal System. the nmt to appmpnate the Lou Tempmat- Geothermal Fluid shall be Inferior to all oubsquent nmta for beneficial ronwnptlra and/or to the nmtts of thaw eppmp~iatorsWho make uw of B Standard LOWTanmat- GeoUnrmsl Efflusnt Dtsposel System. If a

Nonstandard Low Tempmtm Cdothermsi Effluent Diq)-1 System IS upgraded to e Standard Law Temperature Geothmsl Efflusnt Dlqaaal System the -elated water nmt retalns the prionty date sotoblihad wm inltlsl flllng.

16998 1 Norm Arseneault March 21, 1990 Forestry Depaiiment Page 2 OFFICE OF STATE FORESTER C. Recommendmg that habitat should be managed based upon sound research data and the recognition that mF1 ZWSTATESTREET. SALEM.OREGON 97310 PHONE37525MI forests are dynamic and most forest uses are compatible over time; and d. Cooperatively establishmg forest management standards and regulations for the protection of necessary habitat that are based upon the best knowledge available and that are consistent with March 21, 1990 responsible forest management; 2. Promote the maximum level of sustainable timber srowth and harvest on all forest lands available for rimbe; Norm Araeneault production, Consistent with applrcable laws and regulations Deschutes National Forest and taking Into consrderation landowner obiectives by: 1645 Wiuhwav 20E Bend, oi-egon 97701 a. Promoting timber growth and harvest on public lands m a manner Consistent with the governlng Statutory Dear Mr. Ars’eneault: direotion while seeking to meet Oregon‘s timber needs through the application of enlightened land and As you know, the Deschutes National Forest Draft Environmental resource management. Impact Statement assessed the compatiblllty of the selected alternatives with the plans of others, including the “Forestry b. Supporting the use Of Intensive timber management Program for Oregon“ developed by the Oregon Department of practices where those practices are professionally, Forestry. On January 3, 1990 the Oregon Board of Forestry environmentally, and economically sound. adopted a new “Forestry Program for Oregon” (FPFO). C. Supporting federal policies and initiatives that The new FPFO 1s srgnrfuzantly dxfferent than the FPFO analysed in provide sufficient funding for forest management and the DEIS. The FPFO (1982) assessed in the DEIS included timber timber sale programs on federal lands. outputs assigned to the varmus forest landowners, including federal, reqired to accomplish the coordinated programs 3. Encourage appropriate opportunities for other forest contained In the FPFO. The volume figures previously given to uses, such as fish and wildlife habitat, grazing, recrea- the national forests, including the Deschutes National Forest, tion and scenic values on all forest lands, Consistent wlth are no longer part of the FPFO. landowner objectives by; The new FPFO focuses on Intent, rather than on specific numbers, a. Encouraging a full range of recreational and reflects a broader interest in all forest uses, rather than opportunities on both public and private lands focusing nn timber production. The obiectives of the new FPFO consistent with landowner Obiectives. relevant to the Deschutes Forest Plan and FETS are: b. Promoting adequate funding far the full 1. Preserve the forest land base of Oregon and assure Implementation, operation and maintenance of forest practical forest practxces that conserve and protect 501.1 recreation facilities, includlnu trails, campgrounds, productivity, and air and water quality by: etc., on public forest lands aliocated for fbrest recreation. a. Developing land use recommendations that recognize that forests are dynamic and most forest uses are 4. Devise and use environmentally Sound and economically compatible and that emphasize the integration Of forest effioient strategies to protect Oregonos forests from land uses: wildfire, insects, disease, and other damaging agents by: b. Encouraging federal agencles to maintain as large and as stable a commercial forest land base as possible and to minimize future withdrawals from thzs land base, Norm Arseneault narch 21, 1990 Page 3 Department of Fisb and Wildlife a. Encouracl~nclcost-effective federal fire manaclement policies t6at-emphasize planned ignition fires over OFFICE OF THE DIRECTOR natural ignitron fues and that consider impacts to the 506 SW MILL STREET. P 0 BOX 59. PORTLAND. OREGON 97207 PHONE 1503)229-5406 State of Oregon's forest fire protection program: h. Encouraging that federal plans which develop and implement fire suppression policies at both the State and national levels be coordinated with the state; and

C. Promoting the effective use of integrated pest management as a coordrnated approach to the selection, integration and implementation of pest control actions. August 14. 1987 Information m the FEIS on the consistency of the selected alternatives with the plans and policies of state agencies IS important public Information. Since the new FPFO 1s different from the previous FPFO In both tone and scope, It 1s very likely Nom Johnson that an asseswent of the compatibility of the new FPFO with the Executive Department selected alternatives would result in much different conclusions 155 Cottage St , N.E. than those presented m the DEIS. Certainly the number of the Salem, OR 97310 issues reviewed far Compatihllity would be much greater. Dear nom As a public document, I believe it is important that the information included in the FEIS be as correct and up-to-date as UY staff has reviewed the public comnts to the Vallowa- possible. Therefore, If possible, the Deschlttes National Forest Whitman. Ochoco and -National Forests Our add,- FEIS should reflect the significant policy changes recently made tional cments to the Ochoco and Deschute~National Forests to the "Forestry Program for Oregon" by the Oregon Board of are Forestry. 1 The Department supports the use of unevenaged timber I appreciate the consideration you have given to the Input management provided by the Department of Forestry during the development of the Forest Plan and FEIS. Dave Stere (378-5387) of my staff 1s 2. I ask that each Forest work wrth Department biologists available to assist you with regard to the new "Forestry Program to develop area specific standards for open road dennty, for Oregon". (i e winter ranges or important sumr rarges). The Department comnents to the Wallowa-Whitman National Forest are mare detailed and are attached Sincerely, mel,y,

James E. Brown State Forester

rro JEB'tll attachment V:\document\newfpfo cc: Norm Johnson US ENVIRONMENTAL PROTEOTlrJl46E&C-\ REGION 10 1200 SIXTH AVENUB -2- SEATTLE WASHINGTONW the DNF from Your staff. This infonnstion should be included in the Final EIS and Plan. This Information provides a good historical description of water quality nmnitoring. In addition the Final EIS and Plan should include the mnltoring plan itself and hon it will be used to make forest managmnt decisions.

The Intent of our comnents Is to be constmctfve. We are confident that, by addressing our concerns and comnts. the DNF can present a Final Lee F. Coonce EXS and Plan which clearly shows that important resOUKeS nil1 be adequately Deputy Forest Supervisor protected. while providing DNF personnel with the necessary flexibility to DeschUteS National Forest manage day to day activities on the ground. 1645 Highway 20 East Bend, Oregon 97701 Thank YOU for the opportunity to review this DEIS and Plan. If you have any questlons about our review, please contact Wayne Elson of our EXS near Mr. Coonce. and Energy Review Section at IFTSI 399-1463.

In accordance with our responsibilities under Section 309 Of the Clean Sincerely. Air Act and the National Environmental Policy Act we have reviewed the Draft Enviramntal lmpact Statement and Proposed Land and Resource Management

.,"..I~i=nInFlS and Plan1 for the Deschutes..-.~~~~ National Forest IDNF). The DNF is located in central Oregon and includes i;6 miilion acres. The preferred alternative upon which the Plan is based provides for intensive timber management and personal use firewood cutting for parts of the forest. Oevelo ed and dispersed recreation would be emphasized. Geothermal leasing Enclosures would !e permitted. CC: USFS. R-1 Based on our review we have rated the DEIS Et-2 (Enviromental USFS. R-4 Concerns - Insufficient Information). The basis for our rating is USFS, R-6 sumarized below with details included in the enclosed revien report. DUr Fred Hansen. Oregon OEq report is divided into two sections providing general and specific comnts Mike Miller, Oregon Forestry Dept. on each document. Also enclosed is an explanation of our rating system. Patrick Wright, USFWS ..-.. Slerra Club Our concerns are that the Plan be consistent with Oregon's adopted Statewide Water Quality Management Plan for Forest Practices required by the Clean Water Act. The Plan and DEIS should reference Oregon's Forest 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 DNF and Oregon's nepartuent of Environmental Quality and Forestry and that water quality standards are met. The water quality management discussions in both the DElS and Plan are insufficient to evaluate potential impacts. There are several statmnts in both documents that indicate riparian areas and water quality are in good condition. However. there is no specific information or data suwaries to support the general statements about riparian areas and water quality. The Final E1S and Plan should include this information. Several of the items identified in this review were discussed in the meeting we had with your staff in Bend on Decernber 2, 1985. The meeting was useful in becoming familiar with issues on the DNF. Subsequent to the meeting we received supplemental water qualiw monitoring infomtion for