Dear Mr. Shepherd and others:

I am writing out of conern for the ecological, economic, and gloval negative impacts of the WOPR. All three alternatives are a threat to life here in Oregon. My comments for the BLM are to basically dismiss the entire current plan and to collaboratively work with the public and unbiased scientists and responsible economists on a new plan. The new plan should be grounded in the protection of old-growth, protection of endangered species, sound and responsible economic practices, and protection of our waterways.

Clearcutting old-growth and reducing streamside barriers by 75 % are not sound forest practices. I am concerned about the 2:1 ratio of clearcutting to thinning. The overabundance of evenly aged plantation stands is creating the problem we have in the first place, and it creates a fire hazard.

Regeneration harvesting is poor for the soil, poor for the streams, and poor for the atmosphere. THere should be minute, careful applications of regeneration harvesting, if at all. It should not be a technique used AT ALL in mature stands, but in young, overcrowded stands at risk of insect manifestation. My preference is for modern forest management practices, similar to USFS, to be adapted. Thinning should be the main priority, as there are over 130, 000 acres in Douglas County that need thinning. There should be no reduction in our riparian reserves. The waterways need all the help they can get and are slowly recovering under the current management plan. 

Objective scientific findings, as opposed to politicized science, should be the foundation to the new plan. The old plan failed peer review, Julie MacDonald’s ‘scientific’ findings are currently being audited by the attorney general, and the EPA voiced concerns over how the plan is in violation of the Clean Water ACt. The entire basis used to formulate this plan is flawed and illegal I am disappointed with the BLM as I pay taxes, love this country, and believe in the greatness we could become. I feel you are proposing a plan that endangers myself and my community. Politicians (this is cc’ed to), your silent consent is endangering myself and my community. The Northwest Forest Plan has seen improving waterways and streams. The Northwest Forest  Plan protections should be left intact. 

You should recognize the importance of old-growth trees to wildlife. Spotted owls are being out-competed by the barred owl because of the loss of old-growth. Spotted owls are specialized feeders, relying on a diet of red tree voles and flying squirrels, which are endemic species to old-growth trees. Loss of old-growth trees has led to dwindling food for the spotted owl, leading to an out-competing with the barred owl. I feel the claim that the barred owl is a major threat to the spotted owl is partially false and completely incomplete. The real reason the spotted owl is in jeopardy is because of loss of habitat. I would think the BLM would recognize this. 

In addition to the flawed spotted owl plan, the WOPR fails to recognize global warming, which is currently being recohnized by the BUsh Administration after years of denial. The WOPR fails to address the impacts of logging on fish, wildlife, peak flows, sedimentation, and siltation, even though logging will increase 3 imes. The plan fails to consider Sudden Oak Disease, and increased fire hazards, which is 30-400 % higher.

The economic analysis of the plan is flawed, inaccurate, and ignorant of the importance of an intact ecosystem in both local economies and as a taxable base. 

A 1997 study by Haynes and Horne found that an intact roadless area, 89% of the revenue is connected to tourism and human industry. Only 11% of the revenue is connected to timber harvest. Not only does the BLM WOPR fail to recognize this reality and how it plays out in Oregon economy, the BLM analysis relies on statistics from peak economic times, over-inflated timbetr prices, and a loact of consideration for the economic climate such as the impact of flooding the market with timber, and the effect of logging from WOPR on local businesses., and private timber owners. The fact that the BLM offerws different prices for board feet in two different alternatives shows a distortion of economic facts. Again, the economic analysis part of the plan is flawed.
Oregon is better off with its forest intact, as timber production has been a receding industry for the past 19 years. It seems like the long-term solutions to grow the economic tax base , is by ensuring that the forests are upright and living. What is good for the wildlife, is good for the forests, is good for the economy, is good for families and people in Oregon, when all of the factors are considered. However, the WOPR does not consider all of the factors, and thus, needs to be dismissed as a flawed plan.

Sincerely,

Kerstin Britz	

ps. I would like to be contacted. My no. is 541-954-6745