Response

United States<br />

Department of<br />

Agriculture<br />

Fest Service<br />

Pacl ,<br />

Northwest<br />

Region<br />

1 9o<br />

r<br />

tcr-<br />

Appendix K<br />

Final Environmental<br />

Impac t Statement<br />

Land and Resource<br />

Management Plan<br />

Winema National Forest<br />

V<br />

I<br />

dI .<br />

t" ~ ~ ~ t<br />

r s<br />

-aei<br />

*i .j<br />

I f ;<br />

I 't A

---

Appendix K<br />

Table of Contents<br />

Page<br />

Introduction 1-i<br />

List of Respondents to the DEIS R-1<br />

Comments and <strong>Response</strong>s<br />

Air Quality K-1<br />

Fire/Prescribed Fire K-7<br />

Firewood K-1 0<br />

Klamath Tribal Lands K-i 1<br />

Lands K-1 8<br />

Minerals K-23<br />

Mountain Pine Beetle K-34<br />

Mule Deer/Big Game K-39<br />

Other Comments K-48<br />

Pelican Butte K-54<br />

Plan and EIS Content K-67<br />

Range K-81<br />

Recreation K-96<br />

Roads and Corridors K-126<br />

Society/Economics/Employment/Budgets K-135<br />

Soils K-1 50<br />

Threatened and Endangered Plants and Animals K-152<br />

Timber Management K-160<br />

Water K-236<br />

Wild and Scenic Rivers K-257<br />

Wildlife Habitat Management K-261<br />

Agency Letters<br />

(From Governmental Agencies, Public Officials, and the Klamath Tribe<br />

1917 City of Klamath Falls, Oregon<br />

0844 Lane Council of Governments<br />

2736 City of Malin<br />

1327 Klamath County Commissioners<br />

3044 Klamath County Planning<br />

0835 Bernie Agrons, Oregon State House of Representatives<br />

1032 Liz VanLeeuwen, Oregon State House of Representatives<br />

1292 Oregon, Dept. of Transportation<br />

5108 Oregon Dept. of Fish and Wildlife<br />

2747 Oregon, Office of the Governor<br />

1536 U.S. Dept. of Energy, Bonneville Power Administration<br />

2743 The Klamath Tribe<br />

0456 U.S. Dept. of the Air Force<br />

2745 U.S. Environmental Protection Agency<br />

0016 USDI, Bureau of Mines<br />

0440 Klamath County-Public Works Dept.<br />

5107 U.S. Department of the Interior<br />

0603 USDI, Crater Lake National Park<br />

5000 USDI, Fish and Wildlife Service

---

This document is printed on recycled paper to confirm our commitment to the wise use of natural<br />

resources.<br />

--Catherine Jean

---

Appendix K<br />

Public Comments and Forest Service <strong>Response</strong>s<br />

Introduction<br />

Purpose<br />

The purpose of this appendix is to display the substantive comments to the draft environmental impact<br />

statement (DEIS) and Draft Forest Plan and to display the Forest Service response to the comments.<br />

Included in this appendix are (1) background information on how comments were obtained, (2) information<br />

about those who commented, (3) a list of those who commented, (4) comments and responses, and<br />

(5) letters from government agencies and elected officials.<br />

Summary of Public Involvement Activities<br />

A Notice of Availability of the Winema Draft Environmental Impact Statement and Proposed Forest Plan<br />

was published in the Federal Register on December 31, 1987. The documents were filed with the<br />

Environmental Protection Agency and mailed to individuals, groups, and organizations on December<br />

24, 1987. Four hundred and fifty copies were mailed. The 120-day comment period ended March 30,<br />

1988. During that time, approximately 100 more sets of documents were given to interested parties<br />

who were not included in the original mailing.<br />

During the early stages of the review period, open houses were held in Klamath Falls, Chiloquin, Chemult,<br />

Lakeview, and Medford. There was light attendance at these meetings. In addition, the Forest Supervisor<br />

and his staff attended a variety of other meetings to speak on the forest planning process. Over 50<br />

meetings were conducted.<br />

After the release of the draft documents, two interest groups issued brochures to stimulate interest in<br />

the planning process and to generate responses that were sympathetic to the concerns of their<br />

organizations. These groups were the Coalition for Wise Forest Use and a coalition of conservation<br />

groups.<br />

Information About Those Who Commented<br />

We received more than 3,100 letters and forms in response to the draft documents. A breakdown of<br />

where respondents resided follows:<br />

Location<br />

Number of <strong>Response</strong>s<br />

Oregon 2,800<br />

Washington 40<br />

California 100<br />

Other states 16<br />

Other nations 2<br />

I- 1

---

Ninety-four percent of the responses came from individuals. The following is a breakdown of the major<br />

categories of response:<br />

Number of<br />

<strong>Response</strong>s<br />

Federal agencies 5<br />

State agencies 3<br />

County agencies 4<br />

City governments 2<br />

Elected officials 2<br />

Organizations 47<br />

Indian tribes 1<br />

Individuals 2,913<br />

A list of those who commented is contained in this appendix. Also, letters from Federal, State, and<br />

local agencies, public officials, and Indian tribal governments are contained at the end of this appendix.<br />

Comments and <strong>Response</strong>s<br />

The Forest Service is directed to respond to public comments in the Council on Environmental Quality<br />

regulations (40 CFR 1503.4). <strong>Response</strong>s may include:<br />

1. Modifying alternatives, including the proposed action.<br />

2. Developing and evaluating alternatives not previously given serious consideration by the agency.<br />

3. Supplementing, improving, or modifying the analysis.<br />

4. Making factual corrections.<br />

5. Explaining why the comments do not warrant further agency response.<br />

The Forest Service has responded to all substantive comments in this appendix. A substantive comment<br />

is defined as: a comment that provides factual information, professional opinion, or informed judgment<br />

germane to the action being proposed.<br />

Comments to the DEIS have been grouped by subject matter. Each public comment is followed by the<br />

Forest Service response. Most comments are a direct quote from a letter. In cases where more than<br />

one comment on the same subject were received, one comment was selected to represent the other<br />

similar comments or the comments were grouped followed by a single response.<br />

I- 2

---

List of Respondents to DEIS

---

Businesses and Organizations<br />

ALLA MAGE SKIERS<br />

AMERICAN RIVERS<br />

ASSOCIATED OREGON LOGGERS, INC.<br />

AUDUBON SOCIETY, BLUE MOUNTAIN<br />

AUDUBON SOCIETY, KLAMATH BASIN<br />

AUDUBON SOCIETY, MT. DIABLO<br />

AUDUBON SOCIETY, ROGUE VALLEY<br />

AUDUBON SOCIETY, UMPQUA VALLEY<br />

BLUE RIBBON COALITION INC.<br />

BOISE CASCADE<br />

BRAKE BONDERS CO.<br />

BRAUNER TRUCKING INC.<br />

BURRILL TIMBER CO.<br />

CALIFORNIA ENERGY COMPANY<br />

CASCADE APT. HOTEL<br />

CASCADE WOOD PRODUCTS<br />

CIRCLE DE LUMBER<br />

CITIZENS FOR RESP. GEOTHERMAL<br />

COALITION FOR WISE FOREST USE<br />

COLDWELL BANKER INC., HOLMAN REALTY<br />

COLUMBIA PLYWOOD CORPORATION<br />

CORAL SALES CO.<br />

CRATER CHAIN SAW CO.<br />

DEL NORTE TAXPAYERS' LEAGUE<br />

DOUGLAS TIMBER OPERATORS INC.<br />

DUGAN CHEVROLET CO.<br />

ELLINGSON LUMBER CO.<br />

ELLIOTT-LEDGERWOOD & COMPANY<br />

FOUR RUNNERS 4-WHEEL DRIVE CLUB<br />

FREMONT MILLWORK CO.<br />

FRIEDMANS'S MICROWAVE OVENS<br />

FRUITDALE GRANGE #379<br />

GARY W. HARGRAVE & ASSOCIATES<br />

GRAPHIC PRESS<br />

GREGORY FOREST PRODUCTS, INC.<br />

HERALD AND NEWS<br />

HIGH DESERT TRAIL RIDERS<br />

HOFER ENGINEERING<br />

INTERMOUNTAIN-ORIENT INC.<br />

IRA SPRING, PHOTOGRAPHER<br />

ISAKSON & CONE<br />

J.E. HIGGINS LUMBER COMPANY<br />

KLAMATH BASIN HOME BUILDERS ASSOC.<br />

KLAMATH BASIN SNOWDRIFTERS,INC.<br />

KLAMATH BOARD OF REALTORS<br />

KLAMATH CATTLEMEN'S ASSOC.<br />

KLAMATH CONSULTING SERVICE INC.<br />

KLAMATH COUNTY ECONOMIC DEVELOPMENT ASSOC.<br />

KLAMATH COUNTY VISITORS BUREAU<br />

KLAMATH MULTIPLE LISTING SERVICE<br />

KLAMATH ORGANIZING COMMITTEE<br />

KLAMATH YACHT CLUB<br />

KOSMATKA, DONNELLY & CO.<br />

MAZAMAS<br />

MERLIN HEALTH RETREAT<br />

MICROAGE COMPUTER STORES<br />

MIDLAND EMPIRE INSURANCE AGENCY<br />

MILLER BROS. INC.<br />

MODOC LUMBER CO.<br />

MOSS ADAMS, CRk'S<br />

NATIONAL WILDLIFE FEDERATION<br />

NATIVE PLANT SOCIETY OF OREGON<br />

NATURE CONSERVANCY, THE<br />

NORTHWEST FORESTRY ASSOC.<br />

NOVAK'S AUTO PARTS<br />

O'HAIRS FUNERAL CHAPEL<br />

OBSIDIANS, INC.<br />

ODESSA MERCANTILE<br />

OLSON'S PIANO SERVICE<br />

OREGON BANKERS ASSOCIATION<br />

OREGON RIVERS COUNCIL, THE<br />

OREGON HUNTER'S ASSOCIATION<br />

OREGON NATURAL HERITAGE DATABASE<br />

OREGON NATURAL RESOURCES COUNCIL<br />

PNW 4-WHEEL DRIVE ASSOCIATION<br />

PACIFIC LUMBER & SHIPPING CO.<br />

PACIFIC POWER AND LIGHT COMPANY<br />

PAPE' BROS. INC.<br />

PELICAN BUTTE PETITION<br />

PELICAN BUTTE PETITION<br />

R2 ANGUS RANCH<br />

ROBERT J. BOGATAY CONSTRUCTION<br />

ROCKY POINT RESORT<br />

ROGERS MACHINERY COMPANY, INC.<br />

ROOKSTOOL & ALTER<br />

S.P. LOGGER'S SUPPLY<br />

SIERRA CASCADE LOGGING CONFERENCE<br />

SIERRA CLUB, KLAMATH GROUP<br />

SIERRA CLUB, OREGON CHAPTER<br />

SOUTH VALLEY STATE BANK<br />

SOUTHERN OREGON TIMBER INDUSTRIES<br />

SPECIAL PRODUCTS OF OREGON<br />

SPRING CREEK RANCH MOTEL<br />

STEATITE OF SOUTHERN OREGON, INC.<br />

13TH MOUNTAIN CORPORATION, THE<br />

THOMAS LUMBER COMPANY<br />

TIMBER AND WOOD PRODUCTS GROUP<br />

TOWN & COUNTRY REALTY<br />

TRENDWEST, INC.<br />

TROUT UNLIMITED OF OREGON<br />

VALLEY BOOT & REPAIR<br />

VIRGINIA FOUR WHEEL DRIVE ASSOC.<br />

VISITOR IND. ASSOC.,KLAMATH RIVERS<br />

WASHINGTON NATIVE PLANT SOCIETY<br />

WEST PACIFIC ELECTRICAL SUPPLIES C<br />

WESTERN FOREST IND. ASSOC.<br />

WESTERN WOOD PRODUCTS ASSOC.<br />

WEYERHAEUSER<br />

WHITE PELICAN INN<br />

WILDERNESS SOCIETY, THE<br />

WIND RIVER MULTIPLE USE ADVOCATES<br />

R - 1

---

Government Agencies and Indian Tribes<br />

CFTY OF KLAMATH FALLS<br />

CITY OF MALIN<br />

KLAMATH COUNTY COMMISSIONERS<br />

KLAMATH COUNTY PLANNING<br />

KLAMATH COUNTY-PUBLIC WORKS DEPT.<br />

LANE COUNCIL OF GOVERNMENTS<br />

OREGON HOUSE OF REPRESENTATIVES<br />

BERNIE AGRONS<br />

LIZ VAN LEEUWEN<br />

OREGON, DEPT. OF TRANSPORTATION<br />

OREGON DEPARTMENT OF FISH AND WILDUFE<br />

OREGON, OFFICE OF THE GOVERNOR<br />

THE KLAMATH TRIBE<br />

U.S. DEPT. OF ENERGY, BPA<br />

U.S. DEPT. OF THE AIR FORCE<br />

U.S. ENVIRONMENTAL PROTECTION AGENCY<br />

U.S. DEPT. OF THE INTERIOR (USDI)<br />

USDI, BUREAU OF MINES<br />

USDI, CRATER LAKE NATIONAL PARK<br />

USDI, FISH AND WILDLIFE SERVICE<br />

Individuals<br />

CONSTANCE L. ABBOTT<br />

KATHLEEN E. ABBOTT<br />

R.L. ABBOTT<br />

JOHN ABELL<br />

TED ABRAM<br />

LLOYD G. ABRAMS<br />

LUPE ACOSTA<br />

FRED ACOSTA<br />

JOHN L ACREY<br />

EVERETT K ADAMS<br />

PAUL ADAMS<br />

BILL ADAMS<br />

DAN ADAMS<br />

LIZ ADAMS<br />

DAVID ADAMS<br />

JOSEPH H. ADAMS<br />

EVERETT K ADAMS JR.<br />

EILEEN ADEE<br />

DAVID & MARIE AIASSA<br />

DAVID ALACIE<br />

J.F. ALBERSON<br />

D. JEAN ALBERSTON<br />

HENRY ALDEN<br />

PATRICIA E. ALDRICH<br />

R.S. ALDSTADT<br />

ROBERT M. ALGER<br />

GORDON ALLARD<br />

LAURA ALLEN<br />

SARAH K. ALLEN<br />

HOWARD C. ALLEN<br />

JAMES E. ALLEN<br />

ED ALLEN<br />

BURL W. ALLEN<br />

DAVID H. ALLEN<br />

DALE R. ALLENSWORTH<br />

KENNETH E. ALVAREZ<br />

CLIFF AMBERS<br />

WILLIAM P. AMBROSE<br />

JOE AMICARELLA<br />

HERBERT D. AMOS<br />

TIM & CECELIA AMUCHASTEGUI<br />

KAREN AMUNDSON<br />

TERRY AMUNDSON<br />

SHERMAN D. ANDERSON<br />

ERLAND ANDERSON<br />

BRUCE H. ANDERSON<br />

ROBERT D. ANDERSON<br />

GORDON S. ANDERSON<br />

SHEL ANDERSON<br />

CHARLES H. ANDERSON<br />

MICHAEL R. ANDERSON<br />

BETTY C. ANDERSON<br />

ERIC T. ANDERSON<br />

HARRY ANDERSON<br />

MICHAEL W. ANDERSON<br />

PATRICIA ANDERSON<br />

LELAND R. ANDERSON<br />

JOHN ANDERSON<br />

RONNIE ANDERSON<br />

ROBERT ANDERSON JR.<br />

DAN A. ANDERSON SR.<br />

DARYL ANDERST<br />

LINDA ANDREWS<br />

JANE V. ANDREWS<br />

JERRY D. ANGLE<br />

MICHAEL G. APICELLO<br />

LINDA APODACA<br />

BONNIE & DAN APPLEBAKER<br />

SUSAN APPLEGATE<br />

GEORGE A. & J. APPLEGATE<br />

SHANNON AQUINAQA<br />

JOHN C. ARCHER<br />

LARRY ARCHER<br />

GILBERT G. ARCHER SR.<br />

GLENN ARCHIBALD, JR.<br />

GWEN ARMSTRONG<br />

DAVID R. ARNOLD<br />

MELVIN D. ARNOLD<br />

FRED ARNOLD<br />

ERNEST ARTHUR<br />

RODNEY T. ARTILLS<br />

ROY ARWOOD<br />

KEITH E. ASHBY<br />

MARYE J. ASHCRAFT<br />

JANET ASHKENAZY<br />

ROBERT & SALLY ASHLEY<br />

KEITH ASHLEY<br />

L C. ASHTON<br />

ELISE J. AUGENSTEIN<br />

LEE AUMET<br />

R - 2

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ROBERT AURNAGUE-DESPAIN<br />

LEE R. AUSTIN<br />

JOHN D. AUSTIN<br />

ALEC J. AUSTIN<br />

GERALDINE AUSTIN<br />

ELIZABETH H. AUTLE<br />

GLENN A. AVERY<br />

JIM AZELTINE<br />

RON BABB<br />

SUSAN L. BABCOCK<br />

JIM BABIN<br />

R.A. BACCHETTI<br />

DAN & MARCI BACHTELL<br />

RITA BACKA<br />

GLENN A BACKES<br />

SUSAN BADKER<br />

KG. & ELIZABETH BAGHOTT<br />

PETER BAHLS<br />

WADE BAIL<br />

RIC BAILEY<br />

RICHARD T. BAILEY<br />

CHARLOTTE BAILEY<br />

RICHARD BAIN<br />

WILUAM A. BAIRD<br />

BILL BAKER<br />

DALE W. BAKER<br />

JOYCE & ROY BAKER<br />

HENRY C. BAKER<br />

DOUGLAS L BAKER<br />

VIRGINIA BAKER<br />

B. J. BALCOM<br />

LOU BALDOVINO<br />

LARRY BALDRIDGE<br />

JOSE F. BALDUAS<br />

LISLE & MARGARET BALDWIN<br />

C.A. BALDWIN<br />

RODNEY P. BALEY<br />

KEITH E. BALEY<br />

JEFF 0. & JOYCE BALL<br />

NORMA L. BALL<br />

LYLE E. BALL<br />

LOIS BALL<br />

BENJAMIN F. BALME<br />

JAMES E. BALSIGER<br />

SANDRA BALSIGER<br />

LARRY BALZER<br />

JUDY BAMFORTH<br />

ROBERT BANES<br />

GLENN BARBEE<br />

CHARLES W. BARBER<br />

LEELA M. BARE<br />

JESSE G. BARKER<br />

NICHOLAS P. BARNES<br />

CLOYCE E. BARNES<br />

LEONARD BARNES<br />

RICKY J. BARNETT<br />

JOE BARNEtTE<br />

PHILIP M. BARNEY<br />

ROY BARR<br />

GERALD BARRETT<br />

FAYE M. BARROW<br />

JOHN E. BARRY<br />

ROBERT BARTELL<br />

DAN BARTELL<br />

PETER BARTINDALE<br />

CELESTE M. BASSETT<br />

BOB BASSETT<br />

MICHAEL G. BATES<br />

CRAIG R. BATGALE<br />

M.G. BAUER<br />

BRIAN BAXTER<br />

CATHERINE BAXTER<br />

RICHARD D. BAYER<br />

ANDY BAYLISS<br />

BYRON L. BEACH<br />

DAN R. BEACH<br />

ROBERT H. BEACH<br />

MELVIN BEAL<br />

ROXANNE 1. BEAL<br />

CHARLES D BEAN<br />

RALPH F. BEARD<br />

MRON C. BEATY<br />

GARY BEAUCHAMP<br />

FREDERICK D. BECHDOLDT<br />

MARY E. BECHEN<br />

JOHN BECHEN<br />

ERIC R. BECK<br />

S. C. BECKER<br />

MR. & MRS. H.E. BECKLEY<br />

TIM BECKLEY<br />

JOHN G. BECKWITH<br />

STEVE A. & JANNA BEDARD<br />

ROBERT SCOT BEE<br />

ROBERT & KRISTIN M BEE<br />

ROBERT S. BEE<br />

JAMES V. BELL<br />

ROD BELL<br />

DEWARD R BELL<br />

BILL BELLAMY<br />

CHARLES BENCH<br />

REESE E. BENDER<br />

GERALD BENDIX<br />

JUDY BENDIX<br />

GERHART BENDIX<br />

MARTHA BENN<br />

RICHARD L. BENNER<br />

RONALD K BENNET<br />

LINDA BENNETT<br />

DANIEL 0. BENSON<br />

NEIL BENSON<br />

CHARLES E. BENSON<br />

GORDON I BENTSON<br />

DAVID BEOAHOM<br />

PAUL BERG<br />

JEANNE BERGER<br />

RALPH E. BERGERSON<br />

NORMAN H. BERGMAN<br />

PAUL BERNARLL<br />

DON V. BERRY<br />

KIM BERRY<br />

ALVIN L. BERRY<br />

ROGER E. BEST<br />

JUDY K. BIBLE<br />

RAY BIDEGARY<br />

KAY BIDEGARY<br />

STEVE BIEDERMAN<br />

JOHN M. BIEHN<br />

FRED W. BIEKER<br />

R - 3

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ROGER BIELBY<br />

JOANNE BIGMON<br />

RICK BILES<br />

WILLIAM BILLINGS<br />

HENRY L. R. BIRCH<br />

LEO BISHOP<br />

KATHLEEN BISHOP<br />

CHARLES R. BISHOP<br />

JAMES J. BISHOP<br />

KATHLEEN M. BISHOP<br />

C. BJELLAND<br />

GREGORY E. BJELLAND<br />

VERLA BLACK<br />

SONDRA BLACKWELL<br />

BRIAN R. BLACKWELL<br />

DEL BLAIR<br />

BRADFORD L. BLAKELY<br />

CHARLES BLAKESLEE<br />

K. BLANCHARD<br />

HOWARD M. BLOCK<br />

JAN BLOXOM<br />

DAVID M. BLUHM<br />

DONALD L. BLUMERFELD<br />

VIOLA BOARDMAN<br />

LEO & MARGIE BOCCHI<br />

MR. & MRS. STEVEN BOCCHI<br />

W.S. BODDY, JR.<br />

MR. & MRS. A. BODIN<br />

JAMES R. BOEDER<br />

PAUL ROBERT BOEHNER<br />

ARTHUR BOESCHEN<br />

RICH & TONYA BOGATAY<br />

ROBERT BOGATAY<br />

MICHAEL BOHANNON<br />

LEON BOHN<br />

HARRY & ROBERT BOIVIN<br />

JOSEPH E. BOLING<br />

MELVIN R. BONNER<br />

GARY BOOD<br />

ROBERT BOOTAY<br />

ROBERT BORGHORST<br />

MRS. H.C. BORGMAN<br />

MICHAEL BORMUTH<br />

JOHN M BOSSE<br />

DANIEL C. BOTELER<br />

CASSANDRA R. BOTTS<br />

RONALD BOTTS<br />

KATHRYN M. BOULA<br />

JOSEPH A. BOVA<br />

JOHN C. BOWDEN<br />

JOE BOWDEN<br />

LINDA K BOWEN<br />

JOHN E. BOWMAN<br />

RON BOWMAN<br />

PAT BOYER<br />

PATRICIA E. BOYER<br />

ORIEL C. BOYER<br />

MARTIN BOYER<br />

PHIL J. BOYLE<br />

ESTHER BOYLE<br />

BOB BOYNTON<br />

JAMES E. BOYNTON<br />

LARRY BOYUM<br />

THE BRACES<br />

DIANA BRADSHAW<br />

RFE. BRADSHAW<br />

GENE & BARBARA BRADY<br />

A. P. BRAKORA<br />

ROBERT BRAMWELL<br />

DEANE R. BRANDON<br />

PETE BRANDSNESS<br />

RONALD BRANDT<br />

BRICE BRANDT<br />

LOUIE BRANNAN<br />

MARY BRATTEN<br />

PATRICIA J. BRAY<br />

DONNA BRAZIL<br />

ROBERT J. BREAZEALE<br />

MICHAEL A. BREEDEN SR.<br />

DON D. BREHM<br />

PAUL BRErTHAUPT<br />

PATTI BREITMAN<br />

BARRY D. BRENNAN<br />

JAMES D. BRENNAN<br />

BILL BRICKEY<br />

ANN BRIGGS<br />

MICHAEL W. BRINKLEY<br />

MATHEW BRISTOW<br />

RUBY BRIT<br />

JOANNE BRITTON<br />

JIM BRITTON<br />

ROBERT A. BROADHEAD<br />

DONALD W. BRODIE<br />

LAURENCE M. BRODLEY<br />

DALE BRONKEY<br />

ELINOR BROOK<br />

BOB BROOKS<br />

JOHN BROSTERHOUS<br />

JAMES PAUL BROWN<br />

G W BROWN<br />

G.M. BROWN<br />

R. B. BROWN<br />

JACK H. BROWN<br />

THOMAS BROWN<br />

GEORGE. E BROWN<br />

STANLEY BROWN<br />

KATRINA M. BROWN<br />

DAN BROWN<br />

JOHN K. BROWN<br />

RICHARD A. BROWN<br />

DON AND SUE ANN BROWN<br />

W.E. BROWN JR.<br />

LOUIS BROWN JR.<br />

RUSSELL A. BROWNING<br />

KIM BROWNING<br />

W. BRUMBAUGH<br />

DAN BRUMMER<br />

HOWARD BRUNER<br />

ALBERT L. BRUSH<br />

LEE E. BRYANT<br />

MAURICE E. BUCEST<br />

DONALD T. BUCK<br />

MARIAN L. BUCKMASTER<br />

DARELL A. BUELL<br />

MARDELLA BUFFINGTON<br />

DAVID D. BUMHART<br />

JIM BUNKER<br />

GENE BUNNELL<br />

R - 4

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C. M. BURDUCK<br />

SID BURGDORF<br />

KATHERYN BURGER<br />

RANDY BURGER<br />

BRIAN BURGESS<br />

CHIC L. BURGESS<br />

LEO & KAY S. BURGETT<br />

REX BURGETT<br />

DOUGLAS E. & SUSAN BURK<br />

MARK BURKHALTEN<br />

KENNETH A. BURKHOLDER<br />

MICHAEL BURNS<br />

MIKE BURRILL<br />

HERBERT C. BURROW<br />

CAROLYN L. BURUM<br />

ROBERT R. BURWELL JR.<br />

CHARLES D. BURY<br />

DARCY BUSHLEN<br />

JAMES BUSKY<br />

DONALD R. BUTTERFIELD<br />

LEONARD & LEATHA BUTTON<br />

LYALL BYERS<br />

THOMAS CABLE<br />

R. CADA<br />

WILLIAM J. CADMAN<br />

CON CAHILL<br />

EARL H. CAHOON<br />

JAMES R. CALAHAN<br />

ALAN E. CALDWELL<br />

BILL CALDWELL<br />

FRED W. CALEF<br />

BOB CALHOUN<br />

A.G. CAMAILLE<br />

SANDRA E. CAMBRON<br />

STEVE CAMERON<br />

FRANK CAMMACK<br />

PAUL N. CAMPBELL<br />

ROBERT CAMPBELL<br />

LEROY H. CAMPBELL<br />

LAURA CAMPOS<br />

KEN CANEPZ<br />

STEVEN J. CANTANNI<br />

TIM CANTRELL<br />

JOE CARAHER<br />

CONNIE CARDALHO<br />

LEE CARLSON<br />

ALEXANDRA E. CARLSON<br />

C. G. CARLSON<br />

THOMAS A. CARLTON<br />

ALAN CARLTON<br />

M.E. CARMICKLE<br />

ETHEL B. CARMICKLE<br />

SEAN W. CARNAHAN<br />

JERRY R. CARNETT<br />

BLAIR H. CARPENTER<br />

GERALD L. CARPENTER<br />

HAROLD CARR<br />

JEFFREY CARRICO<br />

HEATHER CARROLL<br />

STEVE CARSON<br />

GARLAND & CHERYL CARSON<br />

W.E. CARTER<br />

TRUMAN C. CARTER<br />

STEVE CARTER<br />

MICHAEL E. CARTER<br />

DONALD CARTER<br />

FRANK CARVALHO<br />

ED CASE<br />

DEL CASE<br />

FRANCES G. CASE<br />

DEAN K CASTONWAY<br />

SANDRA CATLETT<br />

MILLIE CHADDERTON<br />

RON CHAMBERLAIN<br />

JUDY CHAMBERS<br />

WILLIAM E. CHAMBERS<br />

JAMES CHAMBERS<br />

RON CHANDLE<br />

LARRY G. CHANDLER<br />

VICTORIA CHANEY<br />

MR. & MRS. E.E. CHAPMAN<br />

DEBRA CHAPMAN<br />

STEVEN L. CHAPMAN<br />

MONTE CHAPMAN<br />

JIM CHAPMAN<br />

MR. & MRS. CHAPMAN<br />

M. EUGENE CHAPPELL<br />

RICHARD J. CHASE<br />

STEVE C CHASE<br />

RANDALL T. CHASTAIN<br />

JOHN CHAVARRIA<br />

JAMES CHENEY<br />

VAN CHESNUT<br />

THOMAS CHESTERMAN<br />

MARTIN D. CHIN<br />

WILLIAM K CHISHOLM<br />

PERRY CHOCKTOOT JR.<br />

EDWARD L. CHRISTENSEN<br />

PAUL W. CHRISTENSEN<br />

R.L. CHRISTIANSEN<br />

ALLEN D. CHRISTIE<br />

ED CHRISTIE<br />

JIM & JUDY CHRISTINA<br />

STEVE J. CHRONISTER<br />

M. ROBBINS CHURCH<br />

GARY L. CHURCH<br />

G. R. CLAFLIN<br />

CLIMPSON B. CLAPP<br />

JEANNE P. CLARK<br />

JIM CLARK<br />

GEORGE CLARK<br />

JOHN & LANETTA CLARK<br />

DONALD H. CLARK<br />

JEFF CLARK<br />

MARLA CLARKE<br />

DEREK CLAWSON<br />

JOE CLAYBORN<br />

LINDA CLIGG<br />

JAMES H. CLINE<br />

ROBERT COATS<br />

DAVID COBB<br />

RANDY R. COCHRAN<br />

GUY R. COCHRANE<br />

GARY COELYN<br />

J.N. COFFMAN<br />

GARLAND COGBURN<br />

JAMES E. COGSWELL<br />

DAVID W. COHL<br />

R - 5

---

JANET R. & TOM COINER<br />

KENT COLAHAN<br />

ELAINE E. COLUER<br />

ARLIE E. COLLIER<br />

WILLIAM & MAXINE COLLIER<br />

BRUCE COLLIER<br />

BARBARA & DOUG COLLIER<br />

ELBERT COLUNS<br />

JERRY L. COLLINS<br />

MARY E. COLLMAN<br />

DAVID P. COLLMAN<br />

RICHARD G. COLPITTS<br />

ARCHIE COLVIN<br />

GARY COLVIN<br />

FRANCES COMER<br />

THOMAS D. COMER<br />

GARY CONE<br />

JOY M. CONLEY<br />

DARRELL CONN<br />

JOHN CONNELLY<br />

R. CONNOR JR<br />

RICHARD A. CONRAD<br />

W.C. CONRAD<br />

WALTER E. CONRADY<br />

PAUL CONTE<br />

PATRICIA B. CONVERSE<br />

CHARLES & DEANNA CONWAY<br />

HARRY L. COOK<br />

KENNETH B. COOK<br />

GUY & CAROLYN COOK<br />

E.V. COOKE<br />

ROBERT COOL<br />

ROBERT S. COOMBES<br />

M COONEY<br />

CLIFF COONROD<br />

DAVID A. COONS<br />

PAUL W. COOPER<br />

ROMAIN COOPER<br />

DAVID COOPMAN<br />

RICHARD CORBAT<br />

CAROLYN & DONALD CORBIN<br />

PEGGY A. CORLEY<br />

R.L. CORNETT<br />

JUAN CORTEZ<br />

JOHN CORWIN<br />

CHARLES W. COSSEY<br />

CAROL A. COSSEY<br />

HENRY E. COTTER<br />

ROY E. COTTON<br />

AUSTIN COUNTS<br />

SUSAN COX<br />

RONELLE D. COX<br />

ALVIN A. COX<br />

HAROLD D./MARILYN COX I FISHER<br />

BOBBY L CRABTREE<br />

LLOYD L. CRAFT JR.<br />

RON CRAIG<br />

LINDA CRAIG<br />

WENDY M. CRAIG<br />

HOWARD M. CRAMBLETT<br />

THERESA & CURTIS CRAMER<br />

LLOYD CRAMER<br />

SUZANNA CRAWFORD<br />

PEGGY J. CRAWFORD<br />

HARRY L. CRAWFORD<br />

R.A. CRAWFORD<br />

MICHAEL CRAWFORD<br />

RICHARD L. CREASEY<br />

KAREN L. CREEL<br />

RAYMOND CREEL<br />

KENNETH R. CREEL<br />

BOB CRESAP<br />

JIM CRISMON<br />

GARY L. CRISP<br />

DAVID J. CRIST<br />

MELANIE CROCKER<br />

DOUG & MARCH CROOKS<br />

HARRY CROSBY<br />

DENNIS L. CROSS<br />

JOHN S. & SUSAN K CROSS<br />

BRUCE A. CROUDER<br />

ROBERT L.& ALISON CROWE<br />

ROBERT CROWE<br />

D.L. CROWL<br />

ROBERT CROWLEY<br />

TRACY J. CROWSON<br />

DEREK CROXFORD<br />

RONALD CROXFORD<br />

JEANNE CRUME<br />

BUTCH CRUME<br />

JANET M. CRUMP<br />

CHARLES H. CRUMP<br />

RANDY CRUTCHFIELD<br />

PEGGY A. CUMMINGS<br />

RICHARD & SHIRLEY CUNNINGHAM<br />

LORI CURLEE<br />

GEORGE N. CURNOW<br />

MICHAEL W. CURRAN<br />

MRS. HUGH B. CURRIN<br />

ALAN CURRISTON<br />

DAVE CURTIS<br />

STEARNS CUSHING<br />

KENNETH J. CUSHMAN<br />

PHYLLIS C. DAHM<br />

JAMES DAHM<br />

J. R. DALTON<br />

W. DAMES<br />

GLEN A. DAMROW<br />

DAVE DANFORTH<br />

ALFRED L. DANIELS<br />

HAROLD DANIELS<br />

CINDY DARNELL<br />

BERTIE L. & F.W, DASSLER<br />

DAVID DAVEY<br />

JAMES C. DAVID<br />

RAY DAVID<br />

E.L. DAVIDSON<br />

ROBERT H. DAVIES<br />

DORIS H. DAVIS<br />

AL DAVIS<br />

JEANNE N. DAVIS<br />

JAMES W. DAVIS<br />

TERESA A. DAVIS<br />

THOMAS F. DAVIS<br />

WILLIAM E. DAVIS<br />

ARNOLD R. DAVIS<br />

RICK DAVIS<br />

DENNIS DAVIS<br />

R - 6

---

ROD DAVIS<br />

WISBY D. DAVIS<br />

JOE DAVISON<br />

LARRY & DIANA DAY<br />

ROGER DAY<br />

RICHARD E. DAY<br />

JOYCE DAY<br />

MARY DE ARMOND<br />

ROBERT J. DE ARMOND<br />

LLOYD & EDNA DE CLERSIN<br />

JAN DE GROOT<br />

PAUL DE HART<br />

GERALD DE JAUVIER<br />

LUCKY DE MARCHI<br />

R.C. DE ROSIER<br />

GEORGE DE SCHWEINITZ<br />

VERA N. DE VOSS<br />

HAROLD W. DEARBORN<br />

GENE 0. DEAVAULT<br />

ROBERT M. DEAVILLA<br />

JOHN DEEGAN<br />

DON & SUZANNA DEFAZIO<br />

PAT DEFFENBAUGH<br />

BEN DEGROOT<br />

TANYA K. DEHART<br />

FRED J. DEL PIZZO<br />

DAVID A. DELANEY SR.<br />

L FAYE DELLER<br />

GEORGE DEMETRAKOS<br />

GEORGE DEMETRAKOS JR.<br />

J.M. DENISON<br />

WILLIAM N. DENNISON<br />

THOMAS DENSON<br />

PHILIP G. DERRE<br />

ELAINE & WILLIAM DEUTSCHMAN<br />

MICHAEL S. DEVLIN<br />

JOE DEVORALL<br />

JOHN W. DEY<br />

ARCH W. DIACK<br />

MRS. L DICKERSON<br />

THOMAS C. DICKERT<br />

EVA M. DICKSON<br />

ERIC DILLENBERGER<br />

PAUL T. DINGMAN<br />

TERRI DIPPEL<br />

DIANE DIRKEN<br />

JANE C. DIRKS-EDMUNDS<br />

ANDREW A. DITCH<br />

DIANA L. DITLEFSEN<br />

CRAIG B. DITMAN<br />

ROD DITRICK<br />

BILL DIVINE<br />

RON DOBROWSKI<br />

RON DOBRY<br />

CRAIG DOBY<br />

MARGARET WASCHU DOCK<br />

DOUGLAS R. DODD<br />

RODNEY & DONNALEA DODGE<br />

KATHLEEN DODGE<br />

KENNETH DOERFLER<br />

JAMES D. DOIG<br />

DOUGLAS DONNAHAO<br />

JAMES R. DONOVAN<br />

RICK DORMAN<br />

GENE DOWNEY<br />

DANIEL DOWNEY<br />

DAVE DOWNEY<br />

REBECCA J. DOWNEY<br />

JAMES R. DRAEGER<br />

JERRY L& PAMELA J DRAKE<br />

GEORGE DRANE<br />

HOLLY & NEIL DREW<br />

EVELYN DREW<br />

SYDNEY DRISCOLL<br />

RAY DRISCOLL SR.<br />

ROY DRISCOLL, JR<br />

THOMAS J. DRYDEN<br />

W.D. DRYDEN<br />

KRIS L. DRYER<br />

CORNELIA K DUBOIS<br />

DAVID DUDDEN<br />

JAMES D. DUEDE<br />

NORMAN J. DUFFY<br />

ROY DUGAN<br />

THOMAS W. DUKE<br />

DENNIS W. DUMONCE<br />

DAVID L. DUNCAN<br />

CHARLES T. DUNCAN<br />

STEPHEN L. DUNCAN<br />

R.WILLARD & GENEVA DUNCAN<br />

MICHAEL DUNCANNON<br />

CHRIS W. DUNFIELD<br />

BRUCE H. DUNN<br />

KW. DUNN<br />

GEORGE C DURAN<br />

BRUCE DURANT<br />

IRA R. DUTCHEN<br />

LOIS DUVALL<br />

GLEN H. DUYSEN<br />

TIM MITCHELL DYER<br />

WILLIAM B. EARLY<br />

WILLIAM & BETTY EASTER<br />

THE EASTLICKS<br />

NEAL & SUSAN EBERLEIN<br />

ALAN EBERLEIN<br />

F.W. EBERLIN<br />

F. EBLING<br />

RUTH C. EDEN<br />

IDELLA M. EDGAR<br />

JOHN L. EDGINGTON<br />

DOROTHEA E. EDGINGTON<br />

NILS A. EDIN<br />

CATHERINE EDWARDS<br />

SCOTT EDWARDS<br />

MARY EDWARDS<br />

LEE EDWARDS<br />

RICHARD M. EDWARDS<br />

LETHA M. EDWARDS<br />

C. A. EDWARDS<br />

DEWEY D. EDWARDS<br />

W. A. EDWARDS<br />

JEROME EGBERT<br />

ROBERT EICHER<br />

B. ELDER<br />

R.P. ELLINGSON<br />

DONALD ELLINGSON<br />

GINGER ELLINGSON<br />

HELEN M. ELLINGSON<br />

R - 7

---

ROBERT P. ELLINGSON JR.<br />

VIOLA ELLIS<br />

JOHN ELLIS<br />

ANNIE ELLISON<br />

HAL ELMER<br />

ROY C. ELMGREN<br />

RUBY P. ELSDON<br />

MARJORIE L. ELSEMORE<br />

ALICE ELSHOFF<br />

PAT ELWOOD<br />

DON M EMARY<br />

DEBBY J. & O.J. ENDICOTT<br />

JACK G. ENDICOTT<br />

FAY S. ENGELAGE<br />

JAY ENGLAND<br />

EUGENE ENGLAND<br />

RICHARD A. ENGSTRAND<br />

JONNA C. ENMAN<br />

JERRY ENMAN<br />

MARK ERICKS<br />

WILLIAM S. ERICKSON<br />

DAVE ERIKSON<br />

LARRY T. ERLEI<br />

LINDA ERNST<br />

ALAN & MYRA ERWIN<br />

NORMA J. ESPERANCE<br />

RAY ESQUEDA<br />

TIMOTHY R. ESTABROOK<br />

SHIRLEY 1. ESTER<br />

DONALD L. R. ESTES<br />

EILEEN E. ESTES<br />

DONALD E. ESTES<br />

W.S. ETTINGER<br />

WALLY EUBANKS<br />

MARVIN L. EVANS<br />

GREG S. EVANS<br />

JAMES M. EVANS<br />

SHEREE EVERETT<br />

FRED W. EVERSON<br />

BRADLEY A. EVERSON<br />

BRIAN EVERSON<br />

BOB EWING<br />

LORRAINE FAGANELLO<br />

BEVERLY FAGEN<br />

WADE P. FAGEN<br />

PATRICK D. FAHEY<br />

CHARLES W. FAIRCHILD<br />

JERRIE FAIRLESS<br />

VIRGINIA L. FALKOWSKI<br />

OTIS FANNING<br />

WILLIAM 0, FARBER<br />

RICHARD A. FARBER<br />

JON D. FARIES<br />

JEANETTE R. FARISS<br />

TIM FARRELL<br />

TERRY FARRELL<br />

EARL W. FEAGAN<br />

PHILIP D. FEDDERLY<br />

ROBERT L. FEDDERSON<br />

ROBERT M. FEHL<br />

SABRINA FEINLUND<br />

DUANE F. FELIX<br />

FRED & IRIS FELTER<br />

MIKEAL FENN<br />

DENZIL FERGUSON<br />

J. FERGUSON<br />

EARL E. FERGUSON<br />

MELVIN FERGUSON<br />

BARBARA J. FERGUSON<br />

DONALD M. FERRELL<br />

R.DAVID FERRIS<br />

DENNIS & BETTY FIEGI<br />

T. FIELDER<br />

BRAD FINCH<br />

STEVEN FINCK<br />

NANCY FIRTH<br />

JOHN A. FISCHER<br />

KEITH A. FISH<br />

DON FISHER<br />

NORMA FITZGERALD<br />

SANDRA FITZJARRALD<br />

MR. & MRS. EDWARD FITZPATRICK JR.<br />

DUANE FITZSIMMONS<br />

CLYDE E. FJORD<br />

TIMOTHY S. FLAGG<br />

GEORGE C. FLANAGAN<br />

MARK FLEMING<br />

JOSEPH & KATHLEEN FLETCHER<br />

EDWARD M. FLETCHER<br />

GEORGIA L. FLEURY<br />

CAROL A. FLIEHR<br />

SHARON L. FLOCCHINI<br />

DEE FLOGERZI<br />

GEORGE FLOREZ<br />

RAYMOND FLOWERS<br />

BRIAN FLYNN<br />

MIKE FLYNN<br />

NORMAN FOELLER<br />

RICHARD FORBES<br />

SHIRLEY JUNE FORD<br />

LARRY FORD<br />

JAN FORD<br />

JUDITH M. FORD<br />

DARRYL L. FORD<br />

WILLIAM C. FORD JR.<br />

DALE FORESEE<br />

CECIL FORNEY<br />

C. B. FORNEY<br />

JOHN FORTUNE<br />

CHARLES FORURIA<br />

NANCY FOSS<br />

JAMES H. FOSSEN<br />

DOUG FOSTER<br />

L. FOSTER<br />

BECKY FOSTER<br />

K FOTHERGILL<br />

JANE FOWLER<br />

WAYNE P. FOWLER<br />

TOM C. FOX, JR.<br />

NARDMAN M. FRAIN<br />

C.E. FRANCIS<br />

GAYLE P. FRANEK<br />

LEONARD E. FRANEK<br />

RUSSEL FRANKEL<br />

TY FRANKLIN<br />

BRENDA FRANSON<br />

PETER FRAZIER<br />

HARRY J. FREDERICKS<br />

R - 8

---

HENRY FREEMAN<br />

OLGA A. FREEMAN<br />

EDNA FREEMANTLE<br />

ROBERT F. FREESE<br />

EDWARD D. FRENCH<br />

GEORGE FRENZLD<br />

JACK FRIBERG<br />

MELVIN G. FRICK<br />

MARK F. FRIED<br />

SID FRIEDMAN<br />

J. ALAN FRIERSON<br />

ARTHUR FRIESEN<br />

ROCKY FRIMBRES<br />

MORRIS L. FRINK<br />

JOHN E. FRiTH<br />

KATHY FROEHUCH<br />

MIKE FRYE<br />

MICHAEL J. FUERSTENBERG<br />

VERNON L. FULTON JR.<br />

ROGER P. FUNK<br />

DANA FURGERSON<br />

CHARLES F. FURREY SR.<br />

JUDITH GAFFERT RICHARDSON<br />

TIM GAINES<br />

PETE GALE<br />

GEORGIA G. GALLAGHER<br />

M.H. GALLAGHER<br />

GERALD L. GALLMEISTER<br />

DANIEL E. GALLOWAY<br />

TINA L. GALLOWAY<br />

DENNIS GALLOWAY<br />

FRANK F. GANONG<br />

FRANK 0. GANONG<br />

JAMES F. GANSBERG<br />

TOM GARBER<br />

JESUS R. GARCIA<br />

HARRIET S. GARDENER<br />

LEONARD B. GARDNER<br />

LESTER GARDNER<br />

WILLIAM GARDNER<br />

DARRELL GARNER<br />

CHARLES GARNER<br />

STUART G. GARRETT<br />

GARY GARRETT<br />

CHARLES T. GARRETT<br />

ROGER C. GARRETT<br />

ROBERT GARRETT<br />

MIKE & JERRIE GARRETT<br />

J. M. GARVEY<br />

KAREN GASAWAY<br />

W. GASKINS<br />

MYRON C. GASTON<br />

MRS.LLOYD GATES<br />

JACK GATES<br />

CUFFORD T. GATES<br />

MICHAEL GAVIN<br />

JIM GEISINGER<br />

ERWIN A. GEISZLER<br />

TIM GENKER<br />

WALT GENTIS<br />

DONALD GENTRY<br />

LAWRENCE L. GEORGE<br />

CAROL B. GERL<br />

GARY E. GERL<br />

BOB & ELLEN GERL<br />

LOIS GERMAN<br />

B.C. GERMOND<br />

JOSEPH W. GERO<br />

HANS GERREMO<br />

GREG D. GESTVANG<br />

E. HOPE GETCHELL<br />

PHYLLIS & CLYDE D. GHAN JR.<br />

LARRY A. & CHERYL GIBBS<br />

WAYNE GIBSON<br />

BENJAMIN H. GILCHRIST<br />

RICHARD & DELORES GILCRIST<br />

EVELYN GILHOOLEY<br />

CATHY M GILL<br />

JAMES H. GILLAM<br />

ROLAND W. GILLER<br />

EDWIN GILMAN<br />

WILLIAM C. GILMORE<br />

JOYCE A. GISZUR<br />

MAI G. GIZER<br />

MARLENE GLASGOW<br />

KENNETH H. GLASGOW<br />

JUDITH GLAZER<br />

ROBERT & JUDY GLOVER<br />

JUDITH K GOAD<br />

HOLLY L GODBEY<br />

ARCHER GODFRY<br />

EVERETT GOETTSCH<br />

RICHARD 0. GOETZ<br />

RICHARD A. GOFF<br />

JAVIER GOINGOLFARRI<br />

ESTHER GOLDBERG<br />

ERIC GOLDBRENER<br />

DEE GOLDEN<br />

JULIE GOLDEN<br />

JENNY GOLDEN<br />

DANETH GOLDEN<br />

DENNIS GOLDEN<br />

MARVIN GOLDEN<br />

DICK GOOD<br />

BETHEL GOODING<br />

DANIEL GOODWIN<br />

MATTHEW GORDON<br />

LAWRENCE W. GORE<br />

JOHN GOTTUEB<br />

DON GOURLEY<br />

VIRGINIA & PHILIP GOVEDARE<br />

ELLEN GOVEDARE-MERRILL<br />

A.E. GRAHAM<br />

JOAN GRAHAM<br />

MILTON R. GRAHAM<br />

L.JOAN GRANT<br />

BOB GRAUL<br />

BILLY GRAVES<br />

PHIL E. GRAVES<br />

R.W. GRAY<br />

WILLIAM GRAY<br />

JOHN & MICHELE GREB<br />

DEAN & PHLEET GREEAR<br />

GERALD & GRACE GREEN<br />

ERIS GREEN<br />

RANDY GREEN<br />

THOMAS L. GREEN<br />

JOE GREEN<br />

R - 9

---

FRED GREEN<br />

JAMES E. GREENHAW<br />

MICHAEL GREENSTREET<br />

TERRY GREGORY<br />

V. GRENSKY<br />

CATHERINE GRIBBLE KELLOGG<br />

STANLEY S. GRIFFIN<br />

DAVID R. GRIFFITH<br />

STEVE GRIGSBY<br />

RONALD W. GRIGSLY<br />

JAMES GRIMES<br />

DONALD E. GRIMES<br />

GARY GRIPP<br />

HARRY L. GROAT<br />

THOMAS GROGAN JR.<br />

DAVID C./CAROLYN E GROSS / WRIGHT<br />

RUSS L GROVE<br />

CHERYL GROVES<br />

MIKE E. GROVES<br />

ANTHONY G. GRUBA<br />

EARL GRUELL<br />

DANIEL GUNKEL<br />

JAMES LEON GUSS<br />

JOYCE GUTHRIE<br />

RODNEY L. HADLEY<br />

CATHY HAGA<br />

STUART M HAGEN<br />

LARRY D. HAGER<br />

CHUCK HAGER<br />

HAGER<br />

ANNETTE HAGUE<br />

DELOIS HAIGWOOD<br />

WILLIAM M. HAL<br />

STEPHEN P. HALL<br />

JEFF HALL<br />

TOM HALL<br />

BONNIE HALL<br />

DAVID E. HALL<br />

LARRY G. HALL<br />

RALPH L. HALL<br />

RICHARD W. HALLEY<br />

THE HALLS<br />

JOHN 0. HALVORSON<br />

CHET HAMAKER<br />

DONALD L. HAMBLIN<br />

RAY W. HAMEL<br />

CAROL HAMLIN<br />

MELVIN L. HAMMACH<br />

WILLIAM R. HAMMER<br />

DALE HAMMERS<br />

ELMER HAMMETT<br />

ALTON W. HAMMILL<br />

JOHN D. HANE<br />

KYLE W. HANKINS<br />

MARK HANNA<br />

GARY HANNSON<br />

D. HANSEN<br />

CRAIG A. HANSEN<br />

ERICA HANSON<br />

DAVID HANSON<br />

SCOTT HARBISON<br />

MICHAEL HARBISON<br />

DAVID E. HARDEN<br />

WILLIAM HARDIN<br />

CAROL & JIM HARDIN<br />

KENNETH A. HARDING<br />

CHRIS HARDT<br />

RICHARD A. HARDY<br />

JEAN HARGROVE<br />

PAUL M. HARLAN<br />

RICHARD HARLAND<br />

ROD HARPER<br />

MERLE HARPER<br />

ROBERTA HARPER<br />

LYNN HARPER<br />

PAUL T. HARPER<br />

R.T. HARPER<br />

ARMAND HARREGUY<br />

DELLA M. HARREGUY<br />

RONALD HARRINGTON<br />

MR. & MRS S.T. HARRIS<br />

JOHN HARRIS<br />

E.M. & PAULINE HARRIS<br />

CHARLES F. HARRIS<br />

CURTIS A. HARRIS<br />

VI HARRIS<br />

KENNETH HARRIS<br />

PAT HARRIS<br />

JIM E. HARRIS<br />

DANIEL W. HARRIS<br />

JOYCE HART<br />

MARY ANN HART<br />

CARLYN HART<br />

MICHAEL HARTFIELD<br />

BRIAN HARTGRAVES<br />

CLYDE R. HARTLEY<br />

PAT HARTNELL<br />

EDDIE L. HARVEY<br />

ROBERT L. HARVEY<br />

LEONARD R. HARVEY<br />

WILLIAM A. HARVEY JR.<br />

AUSTIN A. HASEL<br />

JEWEL HASKINS<br />

DORIS L. HASSMANN<br />

JOHN S. HATCH<br />

GARY HATFIELD<br />

SENATOR MARK HATFIELD<br />

CLAUDE EARL HATHAWAY<br />

ERNEST HATMAKER<br />

JOHN H. HATTON<br />

JEFF HAUN<br />

ROBERT E. HAUSE<br />

MARJ & ROBERT E. HAUSE<br />

JANELL C. & M. HAVIRD<br />

WILMA HAWKINS<br />

ROBIN M. HAWKINS<br />

ROBERT W. HAWKINS<br />

GEORGE W. HAYES<br />

WENDELL L. HAYES<br />

RICHARD HAYES<br />

DAROLD HAYNES<br />

MITCHELL HAYS<br />

DANIEL W. HEAD<br />

WILLIAM H. HEALY<br />

DELMAR L HEALY<br />

A. COREY HEATH<br />

LORETTA HEATH<br />

LARRY C. HEATON<br />

R - 10

---

CHARLES HEATON<br />

JIM HEBERLEIN<br />

JOE HEBERT<br />

KEVIN HEDBERG<br />

ADRIENNE C. HEDGECOCK<br />

SUSAN S. & TOM L. HEDGES<br />

G.S. HEDIN<br />

JOHN & LYNETTE HEDIN<br />

DON & DEBRA HEEL<br />

PHILIP HEID<br />

VERA E. HEIDENREICH<br />

CARL M. HEIDENREICH<br />

RICHARD HEIDT<br />

MICHAEL H. HEINZMAN<br />

RICHARD HELFRICH<br />

ROBERT A. HELLNER<br />

KURT HELMES<br />

WES HEMMERLING<br />

BLAIR M. HENDERSON<br />

TONY HENDERSON<br />

ROBERT A. HENDERSON<br />

GLEN E. HENDERSON<br />

R.W. HENDRICK<br />

F. A. HENDRY<br />

JOSEPH M. HENLIN<br />

LAVERNE HENNING<br />

DANNY R. HENRY<br />

HAROLD HENTON<br />

DAVID HENZEL<br />

DICK HENZEL<br />

RICHARD J. HERBERT<br />

PAUL K. HERIDER<br />

ALFRED A. & VERNA HERMAN<br />

WILLIAM J. HERRON<br />

HARRY H. HERSHEY<br />

WILLIAM B. HERSHMAN<br />

HENRY L. HERYFORD JR.<br />

KURT P. HERZOG<br />

RONALD W HESSER<br />

RICHARD D. HESTER<br />

JUDY R. HEUMANN<br />

STEPHEN P. HEWITT<br />

WALLACE G. HICKS<br />

DOUGLAS S. HICKS<br />

MICHAEL S. HICKS<br />

DONNA HIGGINBOTHAM<br />

ROBERT F. HIGGINS<br />

GARY HIGHLAND<br />

BRIAN HILL<br />

LILLIAN & WILLIAM HILL<br />

B.W. HILL<br />

ARCHIE L. HILL<br />

BILLY HILL<br />

VIDA HILLS RAY<br />

CHRIS HILNER<br />

JEAN HILYARD<br />

CARLA M. HINDS<br />

BILLIE HINTON<br />

ROBERT M. HIRT<br />

COLEEN HISEY<br />

THOMAS G. HOAK<br />

R. C. HOARD .<br />

RAYMOND E. HOBBS<br />

BONITA HOBBS<br />

TAMARA HODGES<br />

TED A. HOFF<br />

JOYCE HOFFMAN<br />

ADAM HOFFMAN<br />

DALE L. HOLBROOK<br />

LESUE H. HOLBROOK<br />

HAROLD L. HOLDER<br />

BRENDA & RONALD HOLEN<br />

DONALD A. HOLLAND<br />

HENRYT. HOLMAN<br />

KERRY HOLMAN<br />

MIRYA HOLMAN<br />

ROBERT HOLMES<br />

WILLIAM & VIRGINIA HOLMES<br />

MIKE HOLMES<br />

DOTTIE HOLTZCLAW<br />

GENE HOLTZCLAW<br />

LOUIS R. HOLZGANG<br />

C.M. HOLZWARTH<br />

BRUCE HONEYMAN<br />

DREW HONZEL<br />

ENID E. & JAMES W. HOPE<br />

MARILYN HOPKINS<br />

DR. & MRS. KH. HORN<br />

LEONA HORN<br />

WILLIAM HORN JR.<br />

CHARLEEN K. HORSTMAN<br />

JOHN F. HORTON<br />

JAMES M. HOSKINS<br />

GREG HOSTITTER<br />

ROBERT N. HOUGH<br />

SHARON HOUNSLY<br />

HARVEY W. HOUSTON<br />

TASKER HOUSTON<br />

JEFFERY C. HOWARD<br />

JOHN HOWARD<br />

GLENN M. HOWARD<br />

RICH HOWARD<br />

V. M. HOWARD<br />

MICHAEL HOWE<br />

DENNIS HOWE<br />

J.L. HOWE<br />

FRED H. HOWELL<br />

GARTH S. HOWELL<br />

KEN HOWELL<br />

CECIL HOWELL<br />

C. T. HOWLAND<br />

EVELYN & FLETCHER HOYT<br />

KYLE & R.L. HUBBARD<br />

RHETT G. HUBBLE<br />

RICK M HUBBLE<br />

WALLACE F. HUBLOU<br />

TERRANCE D. HUFF<br />

HAROLD HUFFMAN<br />

RUTH ANN HUFFMAN<br />

ROBERT M. HUGHES<br />

ADRIAN HUGHES<br />

WAYNE HUGHES<br />

H.R. HULETT<br />

SCOT HULL<br />

STANLEY D. HUMANN<br />

DONALD L HUMMEL<br />

GLEN H. HUMMON<br />

CALVIN L. HUNT<br />

R-11

---

GARY W. HUNT<br />

LOUISE D. HUNT<br />

WAYNE HUNTER<br />

LARRY R. HUNTER<br />

LEROY G. HUNTER<br />

ROBERT A. HUNTER<br />

W.L. HUNTER JR.<br />

ED HUNTLEY<br />

CHARLIE HURST<br />

JAMES R. HURST<br />

ROY/MARGARET HURST/BOYD<br />

HAROLD E. HUSHBECK JR.<br />

GERDA & JOHN H. HYDE<br />

ELINOR HYNER<br />

MIKE IGOU<br />

GARY & GLORIA IKE<br />

H. IMIIL<br />

KENNETH G. IMMKEN<br />

ERNESTO INCLAN<br />

BRENDA INGRAM<br />

GARY L. & MARY A. IRELAND<br />

LOREN IRVING<br />

TERRY ISABELL<br />

DONALD ISENSEE<br />

ALLEN IVERSON<br />

WALLY IVERSON<br />

GERRY IVERSON STRUNK<br />

SANDY IVEY<br />

JAMES R. IVIE<br />

JESS IVIE<br />

DONALD IVIE<br />

RAY JACKMAN<br />

VERLIN JACKSON<br />

FRAN JACKSON<br />

JOYCE W. JACOBS<br />

JAKE JACOBS<br />

LORRAINE E. JACOBS<br />

ROLLAN DALE JACOBS<br />

JERRY A. JACOBSON<br />

LLOYD C. & BETHEL JACOBSON<br />

EMAN T. JAKOBSEN<br />

ALAN & JANA JAMES<br />

JIM JAMES<br />

CHUCK JAMES<br />

PHILIP R. JAMESON<br />

JAMES D. JANSEN<br />

GARY W. JANTZER<br />

JACK JANTZER<br />

MICKEY G. JANTZER<br />

GARY W. JANTZER JR.<br />

MICHAEL JARRETT<br />

RICHARD L. JAUER<br />

VIRGINIA JAYNE<br />

STEPHEN G. JAYNES<br />

CLIFFORD C. JENKINS<br />

RUBY JENKS<br />

KEN JENNINGS<br />

JERILYN G. JENNINGS<br />

BRUCE JENSEN<br />

JUDITH K JENSEN<br />

PHILIP L. & MARIAN JENSEN<br />

DONN JENSEN<br />

CAROL JENSEN<br />

MARVIN JENSON<br />

MICHAEL 0. JESKE<br />

GEORGE JIMEY<br />

RAMON JIMINEZ<br />

PEGGY JIMINEZ<br />

JEFFRY L. JISCHKE<br />

CLINTON & MARGARET JOHN<br />

VERL DWAYNE JOHNS<br />

DON B. JOHNSON<br />

MARK & GEORGEANN JOHNSON<br />

EUGENE JOHNSON<br />

CATHY JOHNSON<br />

C.E. JOHNSON<br />

TERRANCE L. JOHNSON<br />

HOWARD JOHNSON<br />

JAYNA & JOSEPHINE JOHNSON<br />

OBERT JOHNSON<br />

DON W. JOHNSON<br />

ALFRED N. JOHNSON<br />

NICK JOHNSON<br />

DEBBIE JOHNSON<br />

RAYMOND JOHNSON<br />

BRENDA JOHNSON<br />

GARY L. JOHNSON<br />

MARVIN M. JOHNSON<br />

THOMAS E. JOHNSON<br />

DANIEL JOHNSON<br />

RUSSELL JOHNSON<br />

V.T. JOHNSON JR.<br />

DANIEL H. JOHNSTON<br />

BRIAN A. JOKELA<br />

ED JOLLY<br />

CHARLES JONES<br />

RICK JONES<br />

LLOYD JONES<br />

LLOYD JONES<br />

TOM JONES<br />

BRYON D. JONES<br />

ARLIS JONES<br />

ROBIN G. JORDAN<br />

ARNOLD JUSTICE<br />

J. JUSTICE<br />

CHARLES JUSTUS JR.<br />

BRAD KANE<br />

J.W. KANE<br />

JACOB KANN<br />

NORBERT KAPP<br />

NANCY KAPPAS<br />

C.R. KARCIEN<br />

NORMAN L. KARR<br />

ALFRED H. KASMEYER<br />

LARRY KATZ<br />

RICHARD KATZENBACH<br />

KORY KAUFMAN<br />

JAMES R. KAUPPILA<br />

EUGENE M. KEANE<br />

CRESSON KEARNY<br />

DAVID D. KECK<br />

LISA K. KEEMAN<br />

JUDITH D. KEENEY<br />

MARK J. KEISER<br />

DAVID F KEISER<br />

LARRY KEITH<br />

STEPHEN J. KELLER<br />

JOE & ROSIE KELLER<br />

R - 12

---

TOM L. KELLER<br />

DONNA KELLER<br />

RAYMOND L KELLEY<br />

CHUCK KELLEY<br />

GERALD L KELLEY<br />

WALLY KELLISON<br />

GAYLE KELLOGG<br />

DONALD KELLOGG<br />

MAUREEN K KELLY<br />

DARREL KELLY<br />

MICHAEL R. KELLY<br />

DAVID KELLY<br />

KENT S. KELLY<br />

BRUCE E. KELSING<br />

DIANE C. KELSO<br />

DONALD KEMP<br />

ROBERT B. KENNEDY<br />

ALONZA RAY KENNEDY<br />

ERIC & IAN KENT<br />

JIMMIE L. KENT<br />

SHARON K KENT<br />

EARL B. KENT<br />

GLEN KEOWN<br />

AL KEPHART<br />

PHILLIP KEPLINGER<br />

TIM KERNES<br />

TIM KERNS<br />

JAMES KERNS<br />

BERNELL L. KERNS<br />

FRANKLIN N. KERNS<br />

JAMES H. KERR<br />

BILL R. KERWIN<br />

GARY KESTER<br />

TIM KETCHAM<br />

WILLIAM KETTLER<br />

M.L. KEYS<br />

DENNIS V. KEYS<br />

CHESTER KEZER JR<br />

HUGH KIGER<br />

HOLLIS C. KIGER<br />

ALICE G. KILHAM<br />

PHILIP R. KILLIAN<br />

BONNIE KILLIP<br />

DON KIMBALL<br />

A.K. KIMP<br />

C. R. KINCAID<br />

JAMES W. KINGSTIEN<br />

WAYNE KINNAN<br />

RICHARD D. KINNEY<br />

ROBERT KIRBY<br />

GEORGETTE KIRBY<br />

KIM M. KIRBY<br />

BARNEY RAY KIRK<br />

BARNEY 0. KIRK<br />

FRED A. KIRSCH<br />

JOHN H. KISITEST<br />

LESLIE KLEIN<br />

W.E. KLEINER<br />

DONALD KLEM<br />

KLOOS KLEYNE<br />

CLAIR N. KLOCK<br />

KIRK KLUG<br />

ROD KLUS<br />

LLOYD M. KNAPP<br />

DARRELL KNAPP<br />

JOHN P. KNAUSS<br />

LEROY A. KNIGHT<br />

MICHAEL KNOTTS<br />

GEORGE E. KNOWLES<br />

LOWELL E. KOBLER<br />

FRED W. KOEHLER JR.<br />

SUSAN KOFAHL<br />

CHARLES KOLHOW<br />

MARINUS H. KONING<br />

ROBERT H. KONS<br />

A. KONZEL<br />

JAMES 0. KOOPMANN<br />

MARIE L. KOSTENIKO<br />

MARK V. KOUNZ<br />

GREG KOZLEY<br />

KELLY D. KRAHN<br />

LEW KRAUSS<br />

JOHN KRAWEZYK<br />

MARILYN C. KRECHEL<br />

KURT S. KREMERS<br />

MARTIN KRIEGER<br />

JERRY KRUTZ<br />

ARNIE KUBIAK<br />

M.J. 'GUS' KUEHNE<br />

JACK 0. KUHN<br />

PAT KUHNERT<br />

HENRY KUNZ<br />

ISABEL KUNZ<br />

FRANK & NELL KUONEN<br />

EDGAR A. KUPILLAR<br />

STEVEN L. LA VELLE<br />

ALBERT D. LABORDE<br />

ROBIN D. LACY<br />

WAYNE LAHODA<br />

ALAN LAIRD<br />

RAYMOND LAKEY<br />

JIM LAKKE<br />

WINIFRED LAMBIE<br />

RAY LAMOREAUX<br />

MITCHEL LAMPA<br />

JANICE LANCASTER<br />

DONALD W. LAND<br />

BILL LAND<br />

WILLIAM T. LANDER<br />

DENNIS J. LANDWEHR<br />

TOM S. LANDWEHR<br />

JERRY LANE<br />

CLYDE LANG<br />

JONATHAN 1. LANGE<br />

LEWIS & SHIRLEY LANGER<br />

SUSAN LANINI<br />

VIC LANTIS<br />

W.L. LARIMORE<br />

HAL LARSON<br />

RON LARSON<br />

MIKE LARSON<br />

KATHY LARSON<br />

C. L. LARSON<br />

A.C. LARSON JR.<br />

RICHARD F. LAUBENGAYER<br />

EDITH LAVERDIENE<br />

WILBERT J.& AGNES LAWLER<br />

THOMAS A. LAWLER<br />

R - 13

---

H.M. LAWLESS<br />

JIM & MARGE LAWSON<br />

DOROTHY J. LAYMAN<br />

JEANET7E & MIKE LAYNG<br />

FRED LE BLEU<br />

GEOFF LE GAULT<br />

AL LE PAGE<br />

JAMES E. LE ROUX<br />

SHANA LEAGUE<br />

JAMES R. LEARD<br />

RUSSELL W. LEAVITT<br />

MICHAEL LEBERER<br />

JIM LEBO<br />

TOM LEDBETTER<br />

JOHN A. LEE<br />

JOANNA LEE<br />

VICKI LEEPER<br />

DICK LEEVER<br />

ANNE LEISER<br />

JAMES D. LEMERY<br />

VIRGINIA LEMON<br />

PATRICIA J. LENDRES<br />

JOSE R. LEQUINTA<br />

MARILYN LEROY<br />

VERN LESH<br />

DANIEL C. LESLY<br />

HENRY J. LESSARD<br />

CHARLOTTE LEVINSON<br />

ELLEEN LEVY<br />

MACK L. LEWIS<br />

CLARENCE LEWIS<br />

HAZEL LEWIS<br />

MAX E. LEWIS<br />

STEVE LEWIS<br />

MARK E. LEWIS<br />

CATHERINE C. LIGHT<br />

CHRISTINA & S.M. LIUENTHAL<br />

LARRY LIMING<br />

LON LINDROTH<br />

RANDY LINDSEY<br />

JOHN LINEBLY<br />

JASON F. LINES<br />

T.W. LINGENFELDER<br />

MARTIN LINGUS<br />

J.P. LINMAN<br />

HAROLD V. LIPE<br />

CHRISTINE K LIPSCOMB<br />

JIM LISTON<br />

JACK LIU<br />

JENNIFER LIV-COOPER<br />

LESTER D. LIVINGSTON<br />

HAROLD A. LLOYD<br />

LESTER L. LLOYD<br />

R.H. LOCKBAUM<br />

ALAN LOCKLEAR<br />

DONALD E. LODER<br />

ROBERT J. LOEFFLER<br />

BRIAN D. LOGAN<br />

MUREL LONG<br />

BUD & CHERIE LONG<br />

LOMAN LONG<br />

LINDA LONG<br />

VIRGINIA LONGHOFER<br />

D. E. LOOMIS<br />

EVELYN LOOMIS<br />

JEFFERY M. LOOPER<br />

STEVE LOOSLEY<br />

ROBERT LOPER<br />

JOSE J. LOPEZ<br />

FRANK LOSEKOOT<br />

ROBERT LOUCKS<br />

MIKE & WARREN LOUGH<br />

BETH LOVE<br />

WILLIAM R. LOVELACE<br />

PATRICIA LOVELAND<br />

STEVEN D. LOVELAND<br />

KIRK & KYLE LOVENESS<br />

RON & MARY LOU LOVENESS<br />

LOREN LOVENESS<br />

GLENN A. LOWE<br />

STEVE LOWE<br />

BRIAN LOWE<br />

LONZO L. LOWN<br />

GARY 0. LOZIER<br />

JOSEPH LU<br />

MIKE LUCHTUHERD<br />

WAYNE LUDEMAN<br />

KEN LUDERMAN<br />

MICHAEL E. LUFT<br />

STEVEN C. LUKKARI<br />

JEANNETTE F. LUND<br />

JOHN W. LUND<br />

RICHARD LUTE<br />

TERRY A. LUTHER<br />

BLANCHE D. LYMAN<br />

CINDY L. LYMAN<br />

PHILIP LYNCH<br />

DAVID W. LYNCH<br />

TONY LYNCH<br />

TONY LYNDE<br />

MICHAEL J. LYNGHOLM<br />

ROY LYON<br />

FRED P. LYTLE<br />

JEFF B. MACE<br />

RANDAL/SUZETTE MACHADO<br />

BILL MACKENSTADT<br />

FRAN MACKEY<br />

JAMES C. MADDEN<br />

DONALD C. MADDOCK<br />

BARB MAGNUSON<br />

TIPP M. MAHAN<br />

D.L. MAINARD<br />

ERIC & HELEN MAJORS<br />

WALTER MAKAROWSKY<br />

MARK R. MALCO<br />

ANNE C. MALONEY<br />

PAT MALONEY<br />

N. MANDERSON<br />

ERNEST L. MANFULL<br />

GILDA MANLEY<br />

GLADYS MANN<br />

WILLIAM C. MANN<br />

BRENT A. MARCHANT<br />

VIRGINIA MARCHART<br />

STAN MARCHINGTON<br />

LINDA & WILLIAM C. MAREAN<br />

STEVE MARK<br />

SUSAN MARKLEY<br />

R - 14

---

TOM MARKLEY<br />

JOHN D. MARKS<br />

RICHARD H. MARLATT<br />

PAT MARRS<br />

ROBERT R. MARRS<br />

BILL MARSCHALL<br />

HARRY B. MARSHALL<br />

NANCY P. MARTIN<br />

KAREN D. MARTIN<br />

JON MARTIN<br />

JIM MARTIN<br />

JEANNIE MARTIN<br />

SAM MARTIN<br />

SCOTT A. MARTIN<br />

ALBERTO R. MARTINEZ<br />

REX MARTINS<br />

ANDY MARTISAK<br />

MARLA MARVIN<br />

SARAH MASON<br />

LLOYD GEORGE MASTERS<br />

GEORGE A. MATHESON<br />

CLYDE E. MATHIS JR.<br />

CLYDE E. MATHIS SR.<br />

DEAN R. MATLICK<br />

DEBRA G. MATTHEWS<br />

ALLAN MATTHEWS<br />

KETURA R. MATTHIESON<br />

DENNIS MATTIESEN<br />

GEORGE MAUPIN<br />

RANDY L. MAURER<br />

GARY MAXWELL<br />

DAVID A. & CAROL A MAXWELL<br />

RUSSELL M. MAYNARD<br />

DAN E. MAYNARD JR.<br />

KIM MAYO<br />

TERRY MC ALLISTER<br />

KATHY MC ANDREWS<br />

KEVIN J. MC ANDREWS<br />

MICHAEL K MC ANDREWS<br />

QUINTON D. MC BAIN<br />

HARRY D. MC CABE<br />

BERNARD MC CLENDON<br />

EDWARD T. MC CLURE<br />

DENNIS MC CLURE<br />

MARY MC COMBS<br />

DOUG MC CORMACK<br />

A & R MC CORMACK<br />

WAYNE MC COY<br />

KENNETH M. MC CULLEY<br />

PAUL MC CULLEY<br />

KRISTEN MC CULLOUGH<br />

ROBERT S. MC DANIEL<br />

DAN MC DONALD<br />

PAULINE MC DONALD<br />

JUDY MC DOWELL<br />

MARK E. MC GILL<br />

PAT MC GILLIVRAY<br />

M.E. MC GRAW<br />

BRUCE MC GREGOR<br />

TIMOTHY 1. MC GUIRE<br />

GLEN MC GUIRE<br />

KENNETH R. MC GUIRE<br />

DONALD R. MC INTOSH<br />

THE MC KAYS<br />

A.J. & MARGARET L MC KILLOP<br />

ROBERT G. MC LACHLAN<br />

DANIEL R. MC LAREN<br />

KIM MC LAUGHLIN<br />

DAN MC LAUGHLIN<br />

JANE MC LAUGHLIN<br />

JOHN E. MC LEAN<br />

SHERRY E. MC MANUS<br />

R.L MC MILLAN<br />

TOM MC MURRAY<br />

DANNY MC NARY<br />

JAMES D. MC NEIL JR.<br />

ELAINE MC NITT<br />

TED MC PHERSON<br />

MARK S. MC QUEEN<br />

LARRY MC STRAVOG<br />

KAREN MC VAY<br />

PATRICK MCAUUFFE<br />

RICHARD C. MCCORMACK<br />

JAMES E. MCCOY<br />

EDWARD MCCULLOUGH<br />

RUSSELL MCCURDY<br />

FLOYD A. MCCURDY<br />

CRAIG & DEBORAH MCGEARY<br />

MARY A. & DON MCGEE<br />

BONNIE MCGEHEE<br />

LAWRENCE R. MCGRAW<br />

RICHARD L. MCHARGUE<br />

GARY MCLEAN<br />

MICHAEL G. MCMACKIN<br />

STEVEN R. MCMAHAN<br />

DANNY C. MCMILLEN<br />

JERRY MCNICHOLS<br />

EUGENE L. MCPHERSON<br />

ANDY MEAD<br />

JOHN MEADE<br />

EMIL MEADOWS<br />

D. W. MEADOWS JR.<br />

LOREN MECEDE<br />

MARY DIANE MEDILL<br />

WAYNE A. MEEDS<br />

BUD MEEK<br />

DAN & GREGG MEIUCKE<br />

MARK MELAHN<br />

GARVIN MELLENTINE<br />

JERRY D. MELTON<br />

RUSSELL MELTON<br />

WILLIAM MENDT<br />

LEAH C. MENEFEE<br />

MIKE MEREDITH<br />

DAN J. MERINO<br />

TERRY R. MERRILL<br />

ROBERT MESSINGER<br />

M.F. MEYER<br />

BRUNO MEYER<br />

ALAN R. MEZGER<br />

PAT & R.W. MEZGER<br />

D. W. MICHAEL<br />

ROBERT & CAROL MICK<br />

DANIEL Z. MICKEY<br />

V.'PETE' MIHAYL<br />

ELAINE/KENNETH MIKKELSEN/BISHOP<br />

MIKE A. MILANI<br />

MARK D. MILANI<br />

R - 15

---

MILANI & WOOLDRIDGE<br />

RICK R. MILBURN<br />

KENNETH R. MILER<br />

SHARON MILES<br />

CHARLES F. MILLER<br />

MARY MILLER<br />

MICHAEL C. MILLER<br />

LYNN MILLER<br />

JAMES C. MILLER<br />

CALVIN H. MILLER<br />

CARSON MILLER<br />

STEVEN MILLER<br />

LORETTA MILLER<br />

KERRY MILLER<br />

THOMAS L. MILLER<br />

ROLLIN 0. MILLER<br />

ORAN MILLER<br />

EARL F. MILLHOUSE<br />

JACK E. MILNER<br />

MERRflT L. MINNEY<br />

JERRY MINNEY<br />

JOHN MINTER<br />

J. D. MIROEL<br />

BUD MISCO<br />

WILLIAM E. MITCHELL<br />

STEVEN A. MITCHELL<br />

ED MITCHELL<br />

JAMES A. MITCHELL<br />

BOB MITCHELL<br />

HARLEY & JACELYN MITTS<br />

VERNON MITZEL<br />

F. MIZE<br />

DAVID MOCABEE<br />

DONNA & WALT MODEN<br />

ANGELA M. MOHR<br />

JAMES A. MOIR<br />

JERRY MOLATORE<br />

VAN MOLLISON<br />

JOHN D. & LINDA MONFORE<br />

BRANDON MONILL<br />

EDDY MONLANO<br />

CARL MONROE<br />

JAMES MONROY<br />

CHUCK MONSCHERI<br />

TYRUS MONSON<br />

JOE MONTES<br />

C.R. & DOROTHY MONTGOMERY<br />

R.F. MOODY<br />

BLAIR MOODY<br />

KEN L. MOODY<br />

ROBERT MOON<br />

RON MOON<br />

DENNY & R.L. MOON<br />

ROSALIE MOORE<br />

ROBERT C. MOORE<br />

MARTIN MOORE<br />

WARREN MOORE<br />

B. G. MOORE<br />

GREG S. MORALES<br />

KELLY D. MORAN<br />

PAT MORAN<br />

JOHN L. MORAN<br />

PAUL MOREHEAD<br />

MIKE MORENO<br />

JEFF MORESI<br />

SUSAN MORGAN<br />

KELLY MORGAN<br />

REBECCA J. MORGAN<br />

JOHN MORGAN<br />

NICK MORGAN<br />

ROBERT B. MORRIS<br />

STEPHEN D. MORRISON<br />

DAVID C. MORRISON<br />

WILLIAM C. MORROW<br />

JOANNE MORROW<br />

DAVE MORROW<br />

MARIE M. MORSTAD<br />

MICHAEL A. MORSTAD<br />

LEO B. MORSTAD<br />

LARRY J. MORTENSEN<br />

CHERYL LYNN MORTENSEN<br />

ARNOLD MORTON<br />

JOHN C. MORTON<br />

HOMER H. MORTON<br />

JAMES W. MORTON<br />

NAOMI L. MOSHBERGER<br />

BRENT G. MOULTON<br />

DICK MOULTON<br />

MELODY C. MOZINGO<br />

ALICE P. MUELLER<br />

OSGOOD H. MUNGER<br />

SIDNEY MUNJAR<br />

DENNIS C. MURPHY<br />

EVELYN MURPHY<br />

RON AND JOANNE MURPHY<br />

PETER MURRAY<br />

ROD MURRAY<br />

DIANNA MURRAY<br />

GREGORY D. MYERS<br />

RONALD W. MYERS<br />

JAMES MYERS<br />

ROBERT D. MYERS<br />

BARBARA MYERS<br />

ALLEN W. MYERT<br />

C. MYHRE<br />

SUSAN MYRICK<br />

RICHARD NANNEMAN<br />

BOB NARRAMORE<br />

EARL D NASH<br />

ROBERT NASON<br />

VINCENT J. NAUGHTON<br />

EDWARD C. NAVE<br />

PHYLLIS J. NEALY<br />

CHARLIE G. NEALY<br />

GARY E. NEEL<br />

KEN NEIDER<br />

LAWERENCE NEILSEN<br />

DENNIS NEILSON<br />

MICHAEL NEIMOYERS<br />

KAREN G. NELSON<br />

DORIS M. NELSON<br />

WILLIAM 0. NELSON<br />

VIRGIL NELSON<br />

MRS. R. D. NELSON<br />

DOYLE A. NELSON<br />

TIM NELSON<br />

LESTER NELSON<br />

DANIEL NELSON<br />

R - 16

---

E. & W. NEUBERT<br />

BILL NEWELL<br />

JEANNE NEWMAN<br />

BRYAN NEWMAN<br />

STEVEN R. NEWMAN<br />

JANE NEWTON<br />

FRAZIER NICHOL<br />

MARJORIE NICHOLS<br />

GARY W. NICHOLS<br />

ED NICHOLSON<br />

GAYLE R. NICHOLSON<br />

W. R. NICHOLSON JR.<br />

JERRY NIEHUSER<br />

TOM NIEMELA<br />

TOM NIEMELA<br />

BOB NISBET<br />

GEORGE H. NITSCHELM<br />

THOMAS L. NOLAND<br />

NICOLLETTE NORDQUIST<br />

NETA NORK<br />

STEPHEN NORK<br />

BERNARD G. NORK<br />

SHERMAN NORMAN<br />

DAVID G. & NADINE NORTHRUP<br />

MICHAEL NOVOSAD<br />

JOHN NOWASKI<br />

DOUGLAS L. NOYES<br />

DAVID N. NOYES<br />

TERRY NULL<br />

JAMES NUNN<br />

MARK W. NYSTROM<br />

MIKE O'BRIEN<br />

PATTY O'BRIEN<br />

BERTRUM D. O'BRIEN<br />

PATRICK S. O'CONNELL<br />

JAMES O'DONNELL<br />

ROBERT O'NEIL<br />

BRIAN J. O'NEIL<br />

ALAN D. O'NEIL<br />

BILL O'NEIL<br />

FRANK W. OBENCHAIN<br />

W.H. OBERTEUFFER<br />

THERESA OFFICER<br />

DUANE OGREN<br />

LARRY OIRATT<br />

BRUCE M. OLSEN<br />

ROBERT H. OLSON<br />

CHRIS OLUFSEN<br />

TIM OLVERA<br />

TIMOTHY J. OLVERIUS<br />

MICHAEL ORENDORFF<br />

ORFORD'S<br />

LEONARD & BARBARA ORMAN<br />

LORAINE ORR<br />

R. MARRINER ORUM<br />

DAVID OSBORN<br />

DAVE OSBORNE<br />

ROXANNE OSBORNE<br />

GEORGE & RHONDA OSTERTAG<br />

LARRY J. OSTLIE<br />

RUSS OUGARD<br />

W. OVERMAN<br />

ED OWEN<br />

MIKE OWEN<br />

MARIANNE OWEN<br />

MIKE OWEN<br />

JIM OWENS<br />

DARVIN W. PAAPE<br />

CARL E. PACE<br />

SENATOR ROBERT PACKWOOD<br />

HENRY F. PADGEHAM JR.<br />

CHRISTOPHER H. PAGE<br />

FREDERIC A. PAGE<br />

BRIAN F. PAGE<br />

HOWARD A. PAGE JR.<br />

JESSICA PALFREYMAN<br />

MRS.W.A. PALMER<br />

RA. PALMER<br />

MELVIN G. PALMER<br />

LEON A. & SALLY PALMER<br />

ROSS D. PALMER<br />

PATRICIA PALONE<br />

JIM & JINNY PARDEE<br />

FREDERICK PARIANI<br />

DOROTHY H. PARKE<br />

ERNEST PARKER<br />

BILL PARKER<br />

ROBERTA PARKER<br />

DONALD-LINDA-SETH PARKS<br />

HASKELL PARKS<br />

GENE PARRO<br />

BILL PARSONS<br />

ROBERT PARTON<br />

JERRY L. PARTON<br />

RICHARD L. PASTEGA<br />

CRAIG PATTERSON<br />

NILELETTA PATTERSON<br />

WILLIAM H. PATTERSON<br />

ARTHUR H. PATTERSON III<br />

WILLIAM J. PATTISON<br />

DENNIS R. PATTON<br />

JEAN M. PAULK<br />

PATRICIA PAULK<br />

PAUL PAULSEN<br />

MARVIN PAULSON<br />

RUTH E. PAVLAT<br />

EDWARD R. PAXTON<br />

RONALD PAYNE<br />

CAROLYN & LARRY PEACORE<br />

M. A. PEAKE<br />

EARL D. PEARCE<br />

W.G. PEARCY<br />

JUSTIN PEARLSTEIN, JR.<br />

RICK PEARSON<br />

OLIVER P. PEARSON<br />

PHILLIPS & PEARSON<br />

ANITA K PEARSON<br />

DARRELL A. PECKHAM<br />

PARI PEDERSEN<br />

KENT PEDERSON<br />

DAVID E. & MARRITA PELTON<br />

RICHARD PENDLETON<br />

MARK PENDLETON<br />

MIKE & MABEL PENTICOFF<br />

C. SUZANNE PEPIN<br />

TOM C. PERDUE<br />

JAY D. PERKINS<br />

WILLIAM PERNICKY<br />

R - 17

---

NORMAN PERRY<br />

GRANT PERRY<br />

STAN PERRY<br />

DANIEL PETERBOLT<br />

RAY PETERSON<br />

RUBEN & GOLDIE PETERSON<br />

JAMES PETERSON<br />

HOWARD & JEAN PETERSON<br />

RICHARD C. PETERSON<br />

B. LEANNE PETERSON<br />

GARY L. PETERSON<br />

ARLISS C. PETERSON<br />

FREELAND G. PETERSON<br />

FRANKLIN L. PETTGREW<br />

JAMES H. PETTIGREW<br />

DARIN E. PETTY<br />

KENNETH W. PHELPS<br />

BARRY PHELPS<br />

JENNIFER PHILLIPPI<br />

BEN PHILLIPS<br />

WALTER F. PHILLIPS<br />

BRYCE L. PHILLIPS<br />

BOB & SUE PHILLIPS<br />

J. A. PHILLIPS<br />

ROBERT L. PHILLIPS<br />

GILBERT J. PICKENS<br />

WILLIAM P. PICKETT<br />

LEON PICKETT<br />

RAY PIERCE,<br />

JOHN PIERCE<br />

LINDSAY C. PIERCE<br />

IME PIERRON<br />

ROBERT W. PILERME<br />

DAVID PILZ<br />

RICHEL L. PINA<br />

RAY PINARD<br />

DAVID J. & KAREN PINKSTON<br />

JAMES C. & JEAN E. PINNIGER<br />

JANE N. & MARK C. PINNIGER<br />

KENNETH R. PINTOS<br />

CURTIS A PITTMAN<br />

ROGER PITTMAN<br />

DAViD PITTS<br />

BOB PLATZ<br />

J.A. POIRIER<br />

LARRY E. POLING<br />

DON POMEROY<br />

BRET PONT<br />

MARTIN PONT<br />

MABEL POOL<br />

RON POOLE<br />

CARNEY H. & JO ANN POPE<br />

ROBERT PORTER<br />

AMOS W. PORTER<br />

ROBERT D. PORTWOOD<br />

LAWRENCE POST<br />

DONALD LYLE POTTER<br />

LINDA G. POTTS<br />

STEPHEN POTWIN<br />

FRANK POWELL<br />

JOANNE POWELL<br />

WALLY POWELL<br />

BOB POWNE<br />

JAMES S. PRATO<br />

ROBERT B. PRENTICE<br />

JILL PREWITT<br />

DAVID PREWITT<br />

TOM PREWITT<br />

DON PRICE<br />

THOMAS PRICE<br />

JOAN PRINCE<br />

CHARLES E. PRINCE<br />

KEVIN PROCTOR<br />

EARL E. PRYOR<br />

CAROLYN L PUCKET7<br />

J.S. PULLOP<br />

JACK PURINTON<br />

DENNIS L. PUTZMIK<br />

BILL PYLE<br />

BARBARA V. PYNN<br />

H. D. QUIER<br />

EDWIN / AMELIA QUINN I LIPTON<br />

KATHLEEN RACKLEFF<br />

FRANK D. RADFORD<br />

FRANK L. RADFORD<br />

CORRINE RAGO<br />

IRENE RAISEN<br />

S. RAJNUS<br />

D.A. RAJNUS<br />

ARTHUR R. RAMBO<br />

TAMMY RAMIREZ<br />

CHERYL RAMOS<br />

ERIC RAMSEY<br />

JEFFREY N. RAMSEY<br />

WC RANCH<br />

PHILLIP A. RAND<br />

GRETCHEN RANDOLPH<br />

WILLIAM C RANSOM<br />

CAROLYN S. & GARY RARDEN<br />

TIMOTHY J. RASCHKO<br />

DONALD W. RASOR<br />

PHIL RASOR<br />

WILLIS RATCLIFF<br />

RONNIE J. RATHBONE<br />

LOIS & LARRY READ<br />

GERALD D. REAVES<br />

L.E. RECORD<br />

MARY C. REED<br />

LOYD & VIRGINIA REED<br />

WILLIAM G. REED<br />

PATRICK REEDY<br />

CLEO R. REEL<br />

RICHARD T. REEVES<br />

CYNDY REIBER<br />

ROBERT REICH<br />

DWAYNE REICLLIN<br />

TOM REIL<br />

A. TROY REINHART<br />

JACK REMINGTON<br />

CLIFFORD M. REMSTAT<br />

LORRIE RENFRE<br />

ROY E. RENFRO<br />

BUD RENFRO<br />

MAXINE R. RENWICK<br />

GARY W. REPP<br />

FLORENCE RESS<br />

MELVINE REUNICK<br />

MICHAEL J. REVIS<br />

R- 18

---

JOHN R. REYNOLDS<br />

JUDY REYNOLDS<br />

BILL REYNOLDS<br />

PEGGY RICE<br />

MICHAEL L. RICE<br />

DAVID RICE<br />

NICKEY RICH<br />

L. RICHARDSON<br />

DONALD H. & DORIS RICHARDSON<br />

DAN RICHARTZ<br />

CHERYLE A. RICHTER<br />

DAVE RICHTER<br />

WESLEY C. RIDGLEY<br />

LARRY RIEGER<br />

JOSEPH T. RIKER III<br />

ALAN D. RILEY<br />

JAMES S. RILEY<br />

WESLEY S. RILEY<br />

GLENN D. RINGE<br />

LINDA L. RIPPEY<br />

MARTIN S. RITCHEY<br />

WALTER RIVERS<br />

DENNIS ROACH<br />

STEVE ROACH<br />

PATRICIA ROACH<br />

TIMOTHY L. ROBBINS<br />

J. HARRIS ROBBINS<br />

EARL ROBEF<br />

ALLEN ROBERT<br />

CYRUS ROBERTS<br />

DALE J. ROBERTS<br />

RICHARD 0. ROBERTS<br />

WILLIAM E. ROBERTS<br />

JAMES C. ROBERTS<br />

RANDALL P. ROBERTS<br />

MICHAEL ROBERTS<br />

JIM ROBERTSON<br />

DOUGLAS ROBEY<br />

PEGGY ROBINSON<br />

WALTER A. ROBINSON<br />

DIANA ROBINSON<br />

ROBERT H. ROBINSON<br />

BERT ROBINSON<br />

ROBERT D. ROBINSON JR.<br />

THOMAS A. ROBISON<br />

BRUCE ROBY<br />

JOHN H. RODENBERG<br />

DON RODER<br />

VIVIAN W. RODGERS<br />

B.J. RODGERS<br />

TILO RODRIQUES<br />

NANCY R. ROEDER<br />

LANE ROELLE<br />

HOWARD F. ROGERS<br />

MARVIN ROGERS<br />

RONALD L. ROGERS<br />

WARD B. ROGERS<br />

GRANT G. ROGERS<br />

KEN ROLLER<br />

DAVID ROMTVEDT<br />

RICHARD F. RONATO<br />

LES ROOKSTOOL<br />

SONYA ROOKSTOOL<br />

JACK L. ROOKSTOOL<br />

CHRIS ROOKSTOOL<br />

JOHN C. ROOS<br />

JACK ROSE<br />

TRACY S. ROSE<br />

JERRY ROSE<br />

CLYDE ROSE SR.<br />

LARRY ROSEBERG<br />

RICHARD ROSENBERG<br />

EDMUND J. ROSENDAHL<br />

RIVENES/THOMAS/ ROSS<br />

GARY L. ROSS<br />

JEANNE ROSTER<br />

SAMUEL ROWDEN<br />

LEE M. ROWDY<br />

FOREST L ROWELL<br />

ROBERT R. ROWTON<br />

GORDON K ROY<br />

ANN RUDD<br />

FRANCIS V. RUDD<br />

HELEN RUEL<br />

DELAYNE E. RUGG<br />

ORVILLE A. RUMMEL<br />

EARL RUNKLE<br />

BUFF RUNNELS<br />

KENNETH S. RUSSELL<br />

ROBERT K RUSSELL<br />

MARVIN RUSSELL<br />

MARILYN J. RUSSELL<br />

KIM RUSSELL<br />

MILDRED RUSSELL<br />

KELLY RUSSELL<br />

RHONDA RUSSELL<br />

ROBERT S. RUSSELL<br />

R.J. RUST<br />

DAVID RUTHERFORD<br />

KENNETH B. RUTLEDGE<br />

RANDY E. SABO<br />

V. E. SAGERS<br />

BYRON SAGUNSKY<br />

KAREN L. SALLEY<br />

LEROY D. SALSBERRY<br />

DENNIS R. SALYERS<br />

SALVATORE SAMPERI JR.<br />

LESTER E. SAMPO<br />

MIKE SAMPSON<br />

WILLIAM SANDBERG<br />

CAROLYN SANDERBIRD<br />

HUGH R. SANDGATLER JR.<br />

MINDY SANDLER<br />

MUNSON SANDOVAL<br />

GERALD SANTANA<br />

BARBARA SANTOS<br />

GEORGE & MARGARET SAPORA<br />

DALE H. & L. JOAN SARGEANT<br />

EDWARD SARGENT<br />

W.F. SARGENT<br />

JACK SARRETT<br />

ONNIE SARROTT<br />

GLENN SASSER<br />

DICK SAUKKO & CO.<br />

MELVIN SAUL<br />

FRED SAUNDERS<br />

CAROL SAVONEN<br />

LARRY SAXTON<br />

R - 19

---

DAVID L SAY<br />

ROBERT J. SAYLOR<br />

DALE SCENHOWEN<br />

BILL SCHACHT<br />

JERRY L. SCHAEFFER<br />

MRS. LOUIS S. SCHAEFFER<br />

ANN F. SCHAFER<br />

RON SCHARBACK<br />

GARY SCHEFF<br />

THOMAS A. SCHILL<br />

MICHAEL L. SCHLEGEL<br />

LARRY & JUDY SCHLOTMAN<br />

RON SCHLOTrMANN<br />

PETER SCHLYPER<br />

MICHAEL SCHMIDT<br />

ERNEST SCHMIDT<br />

ROBERT P. SCHMFT<br />

J. SCHNEIDER<br />

RICHARD SCHOFFRAN<br />

PAUL SCHRIKZE<br />

WALT SCHROEDER<br />

JOHN D. SCHUH<br />

DONALD SCHULTZ<br />

CHUCK SCHULTZ<br />

MILTON SCHULTZ<br />

FRED SCHUMANN<br />

JOANNA SCHWARZ<br />

DENNIS SCHWEIGERT<br />

WAYNE J. SCHWEIKL<br />

DENNIS F. SCOFIELD<br />

THOMAS M. SCOTT<br />

FRED & GAYLE SCOTT<br />

LIONEL SCOTT<br />

BILL SCOTT<br />

JENNIFER & KARL SCRONCE<br />

KEN SEARS<br />

SCOTT R. SEATON<br />

WILLIAM E. SEFLER<br />

KAREN M. SEIDEL<br />

RANDALL E. SEIDEL<br />

JOEY SELBY<br />

JAMESON D. SELLECK<br />

HENRY B. SELLS<br />

DAVID SELUGA<br />

STEVEN S. SENKOVICH<br />

V. SCOTT SENTER<br />

ERNIE L. SETZER<br />

DAVID SEVERSON<br />

ERIC SEWELL<br />

RICHARD SEXTON<br />

BRADLEY B. SEXTON<br />

WAYNE SHADBURNE<br />

SANDRA G. SHAPIRO<br />

WILLIAM L. SHARK<br />

JANICE SHARP<br />

CHARLES J. SHARP<br />

SKYE SHAW<br />

THOMAS M. SHAW<br />

ROBERT SHAW<br />

ROGER SHAY<br />

H. A. SHEARER JR.<br />

WILLIAM SHEDDEN<br />

LYLE J. SHELDON<br />

ALICE H. SHEPARD<br />

ROBERT SHEPARDSON<br />

JEFFERY G. SHERMAN<br />

IONA MARIE SHERMAN<br />

J.M. SHERMAN<br />

RON SHILL<br />

THOMAS R. SHIOLAS<br />

DOUGLAS & LINDA SHIPMAN<br />

MIKE SHNEENE<br />

ORVILLE SHOCKEY<br />

RONALD C. SHORT<br />

KATHLEEN G. SHORT<br />

JIM & CHERYL SHOTWELL<br />

JERRY L & LICIA SHULTZ<br />

ELDON C. SIBLEY<br />

DUANE & MIKE SICKERT<br />

BOB & DIANE SIEBERT<br />

SAMUEL D. SIEFIELD<br />

FREDICK SIEVERT<br />

JAMES T. SIKES<br />

STEPHEN SILVA<br />

ESPER C. SILVESTER<br />

BOBBIE C. & H.D. SIMMONS<br />

IRENE M.& ORTHA L SIMONS<br />

STEVE SIMPSON<br />

LEE G. SIMPSON<br />

DIANNE SIMS<br />

ELIZABETH SINCLAIRE<br />

WES & KAY SINE<br />

ROBERT B. SINIS<br />

EUGENE A. SINKS<br />

STERN SKEEN<br />

LUCIA N. SKOV<br />

JACK D. SKRIDEN<br />

R. L. SLADE<br />

LAWRENCE & LOIS A. SLAYrER<br />

DALE SLAYTER<br />

LOUIS SLEGEL<br />

IRIS F. & JOHN G. SLEZAK<br />

DEBBIE & MARK SLEZAK<br />

ELLEN & JACK W. SLEZAK<br />

DONALD E. SLUDER<br />

CLIFFORD S. SMELCER<br />

LAWRENCE M. SMITH<br />

C. MARION SMITH<br />

HELEN SMITH<br />

ALICE SMITH<br />

CY & NELL SMITH<br />

NORMA SMITH<br />

JOHN H. SMITH<br />

LYLE V. SMITH<br />

DESI SMITH<br />

DENNIS SMITH<br />

LEONARD SMITH<br />

SHIRLEY SMITH<br />

E.A. SMITH<br />

TYLER SMITH<br />

HERBERT M. SMITH<br />

LARRY R. SMITH<br />

R. SMITH<br />

WAYNE SMITH<br />

JACQUE SMITH<br />

RONALD R. SMITH<br />

H. F. 'BUD' SMITH<br />

JAMES E. SMITH<br />

R - 20

---

RICHARD A. SMITH<br />

CRAIG W. SMITH<br />

WALTER SMITH<br />

JAMES CRAIG SMITH<br />

JACK SMITH<br />

NEAL SMITH<br />

TIM AND JANET SMITH<br />

RON SMITH<br />

LUCRETIA SMITH<br />

CONGRESSMAN ROBERT SMITH<br />

BARBARA A. SNEAD<br />

DON SNEDDEN<br />

MERCY J. SNELL<br />

JIM SNOOK<br />

STANLEY S. SNOOK<br />

ANNETTE & HENRY SNOW<br />

ELVIN D. SNOW<br />

KENT V. SNYDER<br />

RUBY SNYDER<br />

EDWARD L SNYDER<br />

JOELIN SOLOMON<br />

ROBERT M. SORENSEN<br />

EDWIN L. SORENSON<br />

ALLAN R. SORENSON<br />

BRUCE A. SORLIEN'S<br />

HAROLD SOTO<br />

PAUL SOTOS<br />

RANDELL & CAROLYN SOUDERS<br />

RONALD G. & DAVE SOUTHWICK<br />

CURT SPARKS<br />

ALLEN F. SPARKS<br />

LINDA SPEECE<br />

LAWRENCE E. SPENCE<br />

M. SPENCER<br />

ROBERT SPENCER<br />

DONALD G. SPENE<br />

MRS. MORELAND SPEYER<br />

JAMES L. SPICER<br />

RON SPIELBUSH<br />

LEROY D. SPIKEN JR.<br />

HARRIETT SPIRA<br />

CHRISTY SPLIETHOF<br />

FRED W. SPOONER<br />

RICHARD 0. SPRING<br />

KATIE SPRINGER<br />

DONALD SPRINKLE<br />

RICHARD L. SPROUL<br />

BERT E. SQUIRE<br />

FRANK W. ST.CLAIR<br />

MARIE STAFFORD<br />

RODGER W. STAFFORD<br />

WENDELL STALKER<br />

RAYMOND STALNAKER<br />

DEBBIE STANCK<br />

J. E. STANDARD<br />

CARL D. STANDFIELD<br />

ARTHUR STANFILL<br />

STEVEN C. STANFORD<br />

THAD C. STANFORD<br />

V. STAPLEFORD<br />

PHILIP STARLING<br />

DENNY STARR<br />

ROBERT D. STARUS<br />

JOHN STATES<br />

CHRISTY STECK<br />

FRANK M. STEFANEK<br />

B. STEINER<br />

ROBERT STEINER<br />

DAVE STEMPLE<br />

DALE R. STENNOTT<br />

MARGARET & WILLIAM STEPHAN<br />

WARREN W. STEPHENS<br />

PAUL D. STEVENS<br />

PHILLIP C. STEVENS<br />

GARRY STEVENS<br />

JERRY STEWARD<br />

RICHARD STEWART<br />

L. M. STEWART<br />

MICHAEL M. STEWARTT<br />

J.A. STILES<br />

MARK STILWELL<br />

MARTIN L. STOCKDALE<br />

GENEVA STOLLER<br />

WESLEY D. STONE<br />

JOHN M. STONE<br />

DON R. STONEHILL<br />

RICHARD STONEX<br />

E. E. STOREY<br />

JEANINE L. STORK<br />

JOHN 1. STORK<br />

ROBERT M STORM<br />

STEVEN N. STORY<br />

LORRAINE M. STORY<br />

J. D. STRAUGHAN<br />

MR. & MRS. STANLEY STRAUS<br />

T.A. STRAUSBAUGH<br />

D. S. STRAW<br />

CHARLES A. STRENSRUD<br />

C.C. STRINGER<br />

MORRIS STRINGER<br />

DON STRONG<br />

KURT L. STROP<br />

TONY STROP JR.<br />

DONALD A. STROT<br />

WAYNE STRUBLE<br />

BETTY JO STRUBLE<br />

APRIL & BROCK STRUNK<br />

TOM STRUNK<br />

CECIL STRUNK<br />

NINA SULLIVAN<br />

JOHN SULLIVAN<br />

MICHAEL D. SULLIVAN<br />

DOUGLAS T. SULLIVAN<br />

PHIL SUMMERS<br />

JOHN B. SUTHERLAND<br />

HENRY N. & JUDI SUTPHIN JR.<br />

LORA SUTTON<br />

JESSE L. SWAFFORD<br />

EUGENE SWANBERG<br />

JOHN R. SWANSON<br />

STEVEN D. SWANSON<br />

CYNTHIA SWANSON<br />

LEON SWARTZBERG JR.<br />

MARY ELLEN SWEENEY<br />

CHARLES SWITZLER<br />

DENNIS SWOPE<br />

PETER SZEKELY<br />

MICHAEL SZPAK<br />

R - 21

---

JOHN R. TALL<br />

FRANK TALLERICO<br />

JAMES LEE TALLEY<br />

ERNIE TANKIN<br />

HAROLD TANNER<br />

BRENDA & LYLE TARESH<br />

REBA N. TAYLOR<br />

VALERIE L. TAYLOR<br />

FORREST A. TAYLOR<br />

EDWARD J. TAYLOR<br />

LARRY R. TAYLOR<br />

CHARLES E. TAYLOR<br />

DAVID TAYLOR<br />

LARRY B. TAYLOR<br />

WESLEY G. TEMPLIN<br />

A. DOUGLAS TENNANT<br />

GARY TEPFER<br />

DAVID L TERHUNE<br />

MARK THACKER<br />

BARBARA THOM<br />

JACKIE R. THOMAS<br />

M. LYNN THOMAS<br />

MR. & MRS. E.R. THOMPSON<br />

WENDELL THOMPSON<br />

TERRY THOMPSON<br />

MARY & GILBERT THOMPSON<br />

JIM THOMPSON<br />

MEL THOMPSON<br />

NORBERT J. THOMPSON<br />

JIM THOMPSON<br />

STEVE THOMPSON<br />

FREDERICK J. THOMSON<br />

MICHAEL A. THOR<br />

CLIFFORD THORBURN<br />

MARY THORP<br />

JAMES A. THRUBER<br />

R. L. THURBER<br />

HARRY W. TIANIN<br />

DUANNE TICHNOD<br />

LEONARD TIDD<br />

VERN TIDEMAN<br />

HAROLD TIEHN<br />

CAROL L. & SHAWN TIERCE<br />

BRYAN W. TINNIN<br />

JOSEPH LARRY TITUS JR.<br />

ANH VAN TO<br />

PHILIP TOBIAS<br />

DOROTHY L. TODD<br />

JAMES S. TODD<br />

KATHERINE TOFELL<br />

PATRICIA A. TOMEI<br />

MAJOR TONEY JR.<br />

JIM TONOLE<br />

LEO TORBA<br />

ANASTACIO TORRES<br />

SHERYL TORRES<br />

JACK N. TORREY<br />

ROBERT A. TORRIE<br />

LESLIE B. TOTTIN<br />

RANDY TOWNSEND<br />

JOHN J. TOWNSLEY<br />

ALAN H. TRACY<br />

NANCY LOU TRACY<br />

PAULA TRAINA<br />

HUNG CHANH TRAN<br />

MARVIE D. TRAVIS<br />

JIM TREASURE<br />

RONALD TREASURE<br />

BARBARA TREMAINE<br />

MARY TRENT<br />

JOHN & SUZANNE TRITCH<br />

ROBERT L. TROUT<br />

LARRY E. TRUMBULL<br />

WALT TRUMBULL<br />

MIKE TRUMBULL<br />

JIM TUCKER<br />

KENNETH R. TURNBULL<br />

M.R. TURNER<br />

E.C. TURNER<br />

ROBIN TURNER<br />

JODI L. TURNER<br />

PATRICIA M. TUTTLE<br />

TERRENCE J. UDELL<br />

JAMES R. UERLINGS<br />

PAMELA K. UERLINGS<br />

LOIS UGALDE<br />

DOROTHY M. UNDERWOOD<br />

ALVIN R. UNGER<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

UNSIGNED<br />

MARYA URELAND<br />

BARBARA VAIL<br />

PATRICIA A. VALLERONI<br />

KLAAS & CONNY VAN DE POL<br />

DIANNA VAN DELDEN<br />

HUGH VAN DEWALKER<br />

LEO J. VAN DIRK<br />

BOB VAN DUKER<br />

DORIS VAN ESS<br />

WARREN VAN MECHELEN<br />

JUDY VAN TIL<br />

J. GORDON VANCE<br />

BILL VANDERPOL<br />

M. VANDEVENTER<br />

LYNNE M. VANHORN<br />

MR. & MRS. CECIL VANIEL<br />

NELDA M. VARY<br />

KEITH VASILIS<br />

RANDY VASQUEZ<br />

RONALD VASQUEZ<br />

JERRY L. VASSALLO<br />

FRANK VAUGHN<br />

RICK VAUGHN<br />

RICHARD L. VAUGHN<br />

MARTIN J. VE'LEZ<br />

RONALD W. VEACH<br />

KENNETH A. VEAROTTER JR.<br />

ALICE VEITCH<br />

BRAD E. VENSEN<br />

R - 22

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GERALD E. VERMILLION<br />

W. HARRY VETHER<br />

OMAR & KATHRYN VILLA<br />

DONALD & PHYLLIS VINCENT<br />

DAVID T. VINCENT<br />

HON VINZART<br />

HENRY A. VIRGA<br />

GORDON VITCH<br />

EDWARD K. VLIEK<br />

FLOYD C. VOGEL<br />

G. K. VOGET<br />

JIM VOGLER<br />

D. D. VOLLMAR<br />

SHELIA S. VOLLMER<br />

DOAN PHNONG VON<br />

DANIEL WADOSKY<br />

JOHN M. WAGNER<br />

LEE P. WAGNER<br />

JEFF WAGNER<br />

BILL WALDON<br />

LLOYD W. WALDRIP<br />

DIANA WALES<br />

JOHN R. WALKER<br />

STEVE WALKER<br />

DON WALKER<br />

EDWARD WALKER<br />

BRENT C. WALKER<br />

ROGER WALKER<br />

E. RAY WALLACE<br />

TOM WALLACO<br />

MARTHA R. WALLAUER<br />

SIGNE WALLEN<br />

ALFRED H. WALSTON<br />

C.B. WALTERS<br />

RUSSEL WALTERS<br />

MRS. A.L. WALTERSPERGER<br />

JAMES WALTHERS<br />

FRANK WALTKINS<br />

DANNY T. WALTON<br />

E. W. WALTON<br />

RONALD S. WALTZ<br />

JOSEPH WAMPLER<br />

ROBERT P. WAMPLER<br />

WILLIAM C. WAMPLER<br />

SCOTT WAMPLER<br />

ALICE M. WAMPLER<br />

MEREDITH L. WAMPLER<br />

MIKE WAMPLER<br />

ROBERT WAMPLER<br />

RICHARD WARD<br />

JOHN C. WARD<br />

ANITA WARD<br />

PATRICK WARD<br />

RAYMOND WARD<br />

BONNIE RAE WARD<br />

J. WARD<br />

GEORGE D. WARDELL<br />

JULIA B. WARNER<br />

ANTHONY D. WARREN<br />

KEN WARREN<br />

CHARLES & MARIE WARZECHA<br />

GREG WATCH<br />

WILLIAM A. WATERMAN<br />

WALLY W. WATKINS<br />

BOBBY L. WATLEY<br />

GEORGE WATSON<br />

ROBERT P. WATSON<br />

DANA J. WATSON<br />

JAMES S. WATSON<br />

JIM C. WATTS<br />

BRYAN WAYBRANT<br />

LEWIS WAYBURN<br />

JON S. WAYLAND<br />

FREDRICK G. WEARN<br />

J.M. WEATHERFORD<br />

JAMES V. WEATHERS<br />

JOYCE M. WEATHERS<br />

LAVON JANIS WEAVER<br />

JOYCE 1. WEAVER<br />

R. JEFFERY WEAVER<br />

DALE E. WEAVER<br />

MARY ARLENE WEAVER<br />

MRS. FRAN WEAVER<br />

GARY WEAVER<br />

TRACY K. WEBB<br />

KENNETH E. WEBB-BOWEN<br />

KELLIE A. WEBBER<br />

ROBERT WEBBER<br />

JANET WEBER<br />

SANDRA L. WEDDING<br />

RAYMOND Z. WEGNER<br />

KRAIG B. WEIDER<br />

LINDA L. WEIDER<br />

BEVERLE WEIDNER<br />

GEORGE R. WEIN<br />

J.L WELCH<br />

PAUL D. WELCH<br />

BARRY R. WELCH<br />

LU WELLS<br />

DAVID L. WELLS<br />

MIKE WELLS<br />

J.H. WELLS<br />

KEITH A. WELLS<br />

SALLY WELLS<br />

JOHN E. WELLS<br />

CHARLES H. WELLS JR.<br />

JEROME WENCL<br />

DAN WENGER<br />

D.W. WEST<br />

DON WEST<br />

ROGER WEST<br />

GARY L. WEST<br />

ROBERT D. WEST<br />

LAURA L. WEST<br />

CHARLENE WEST<br />

HOWARD WEST<br />

WALLACE B. WEST<br />

DONALD WEST<br />

TOMMY N. WEST<br />

LEOTA & HERMAN WESTLUND<br />

SCOTT WESTON<br />

HARRY WESTROM<br />

LEE K. WETZEL<br />

JEFFREY WHARTON<br />

LARRY 1. WHEAT<br />

JEFF WHEATON<br />

RICHARD G. WHEELER<br />

KEVIN L. WHEELER<br />

R - 23

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DOROTHY WHISENHUNT<br />

DOMINIQUE WHITAKER<br />

BOB WHITE<br />

RICHARD L WHITE<br />

CHARLES WHITE<br />

DELBERT W. WHITEHEAD<br />

PAMELA WHITEHEAD<br />

IRVIN R. WHITING<br />

RICHARD WHITLATCH<br />

JIM WHITLOCK<br />

D.D. WICK<br />

SAM WICKBERG<br />

ARTHUR WIEBE<br />

KEN WIENKE<br />

ERNEST WIENSY<br />

MARK WIGG<br />

BERT G. WILCOX<br />

MIKE WILDE<br />

DAVID WILDE<br />

STEVEN E. WILDE<br />

RUTH T. WILEY<br />

PAT WILEY<br />

ROBERT WILHINSON<br />

ROBERT WILKEN<br />

ROBERT B. WILKERSON<br />

SHELLY WILKESON<br />

PAT WILKESON<br />

MIKE WILKESON<br />

BILLY R. WILLES<br />

EVERETT DALE WILLIAMS<br />

JACK E WILLIAMS<br />

TIMOTHY B. WILLIAMS<br />

ERNIE WILLIAMS<br />

PETER K WILLIAMSEN<br />

DWIGHT WILSON<br />

ALAN L. WILSON<br />

KELLY WILSON<br />

VIRGIL W. WILSON<br />

WILLIAM F. WILSON<br />

DAVID D. WILSON<br />

GLEN WILSON<br />

DEANNA WILSON<br />

LARRY S. WILSON<br />

DICK E. WILSON<br />

CARL E AND RUTH WILSON<br />

LLOYD V. WILSON<br />

RONALD F. WILSON<br />

W. TRAVIS WILSON<br />

WESLEY E. WILSON<br />

DONALD L. WILSON<br />

LARRY WILSON<br />

BARBARA C. & D. WIMAN<br />

LOIS WINCHESTER<br />

RICHARD C. WINFIELD<br />

ROYCE M. WINNER<br />

MR. & MRS. BOB WINSETT<br />

ROY WIRTZ<br />

SANDY WITT<br />

GENE WITT<br />

DONALD G. WITTE<br />

JACKIE WOBBE<br />

CAMERON F. WOGAN<br />

KENNETH M. WOLCOTT<br />

PHIL WOLD<br />

GUS WOLF<br />

J. N. WOMACK<br />

RODNEY WOMACK<br />

HERBERT WOOD<br />

NORMAN D. WOOD<br />

JEFF WOOD<br />

BRIAN WOOD<br />

BILL WOOD<br />

JAMES C. WOOD<br />

TERRY WOODARD<br />

JOHN L WOODLAND<br />

CLAYTON WORDEN<br />

RICHARD C. WORK<br />

VANCE R. WOUSER<br />

D.J. WRAY<br />

VANCE WRIGHT<br />

TERRY WRIGHT<br />

G. WRIGHT<br />

ALLEN & DEBRA L. WRIGHT<br />

WILL C. WRIGHT<br />

FRANK R. WRYN<br />

BOB WRYN<br />

RANDY WUTRON<br />

ELMER WYATT<br />

RICHARD D. WYLIE<br />

HOWARD WYNANT<br />

CLINTON W. WYNN<br />

ROBERT R. WYRICK<br />

ROBERT YAGER<br />

JIM & MADIE YARDLEY<br />

CLAY E. YATES<br />

G. M. YATES<br />

WAIHUN YEE<br />

WAIYEN YOGI' YEE<br />

CATE YOCUM<br />

KENTON EU YODER 11<br />

SCOTT YORK<br />

CAROL LYNN YORK<br />

STEVEN YOST<br />

WALLACE H. YOST<br />

EUGENE M. YOST<br />

WILLIAM R. YOUNG<br />

B YOUNG<br />

GLENN C. YOUNG<br />

LELAND E. YOUNG<br />

SHAWN YOUNG<br />

KATHY L. YOUNG<br />

DOUGLAS A. YOUNG<br />

TED YOUNG<br />

SHARON L. YOUNG<br />

T. JOE ZAROSINSKI<br />

LEONARD ZASTERA<br />

SHIRLEY ZASTERA<br />

A.E. ZENONIAN<br />

STEVEN ZIEGLER<br />

FRED ZIMMERMAN<br />

JO ANN ZIPSE<br />

JOE ZORN<br />

DONOVAN C. ZUPAN<br />

R -24

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Comments and <strong>Response</strong>s

---

Air Quality<br />

Comment<br />

The preferred alternative includes 165,500 cords of fuelwood. There are mitigation measures that the<br />

Winema N.F. could take to reduce emissions from wood stoves. For example, the Winema N.F. could<br />

limit fuelwood collection to spring time and distribute advice on clean wood stove burning methods<br />

with fuelwood permits.<br />

<strong>Response</strong><br />

The Forest is only one of several sources of fuelwood. A limit on the season of gathering would only<br />

be effective if all sources, both public and private, would restrict the gathering period. The Forest currently<br />

encourages reduction of wood smoke emissions by encouraging people to gather their wood early,<br />

and by making pamphlets available with permit issuance that suggest ways to reduce emissions, and<br />

in the firewood handout issued with the permit. All of these supply advise and describe how to reduce<br />

emissions.<br />

Comment<br />

The discussions on wood stove and forestry burning are somewhat inaccurate. Regional haze is seasonal<br />

and has been found to be primarily due to forestry burning or prescribed burning. Wood stove burning<br />

is primarily a localized air shed issue. The Oregon wood stove regulations will slow the growth not<br />

'reduce the long-term problem.,<br />

<strong>Response</strong><br />

See page 111-9 of DEIS. It states "should reduce the long-term problem' rather than say or imply it would<br />

'solve the problem.'<br />

Comment<br />

Smoke Management - (DEIS, page 111-9) The Winema should more clearly emphasize compliance with<br />

the Oregon Smoke Management Plan since the Environmental Protection Agency (EPA) has approved<br />

Oregon's plan as meeting the requirements of the Clean Air Act as amended in 1987. Unplanned ignitions<br />

should be used as prescribed fires only if compliance with the Oregon Smoke Management Plan can<br />

be assured.<br />

<strong>Response</strong><br />

On page IV-53, Forest Management Direction, of the *PROPOSED LANE) AND RESOURCE MANAGEMENT<br />

PLAN' it is stated that the forest will comply with all applicable air quality laws and regulations and<br />

coordinate with appropriate air quality regulating agencies. Currentlyand in the future, all planned<br />

ignitions are, and will be, conducted according to the 'OPERATiONAL GUIDANCE FOR THE OREGON<br />

SMOKE MANAGEMENT PROGRAM' which is administered by the Oregon State Forester.<br />

In addition the Forest will cooperate with local air pollution authorities in monitoring activities that may<br />

result in new or modified sources that may affect Class I airsheds. This is stated in Chapter 3-9, fourth<br />

paragraph.<br />

Comment<br />

Even though wildfires are random events on the forest, this summer's experience in Southwest Oregon,<br />

and especially the Rogue River Valley, indicated the extreme magnitude of the negative effects that<br />

natural fires can have on air quality. The DEIS text makes several references to the contribution of<br />

prescribed fires to airshed degradation. However, it fails to note that the management activity of prescribed<br />

burning reduces the risk of catastrophic natural and man-caused fires which can generate severe and<br />

unplanned reductions in visibility.<br />

<strong>Response</strong><br />

The use of prescribed burning in itself will not necessarily reduce the risk of catastrophic fire. It may,<br />

however, reduce the size of the catastrophic fire because of the change in fuelbed continuity. Quite<br />

K - I

---

often when conditions are optimum for catastrophic fires, previous prescribed burning activities will do<br />

little to determine whether there is a catastrophic fire or not.<br />

Comment<br />

The text states (page IV-7) that, 'The Klamath Basin is not a 'Designated Area' as defined in the Oregon<br />

Smoke Management Plan.' The plan should note the effects of the EPA PM 10 standards adopted on<br />

July 10, 1987, which classified all areas of the state. Klamath Falls was placed in Group I of three groups<br />

based on probability of violating the new standards. Klamath Falls has recently been in violation of this<br />

standard. The effect on compliance with these standards should be included in the evaluation of<br />

prescribed and<br />

uncontrolled fires which might threaten the Klamath Basin with smoke pollution.<br />

<strong>Response</strong><br />

The Klamath Basin is still not a 'Designated Area." We do recognize that it is a smoke sensitive area.<br />

The major concern in regard to PM-1 0 particles is in the City of Klamath Falls and surrounding suburban<br />

areas. The concern for PM-1 0 particles is during the period from November 1 to April 1 when air stagnation<br />

coupled with fuelwood burning causes an unacceptable buildup of PM-1 0 particles. Klamath County<br />

Department of Health Services estimates that 83% of the PM-10 particles are the result of wood burned<br />

in home heating stoves. When there is good air circulation there is no problem. Generally, the Winema<br />

Forest conducts it's prescribed burning program in the fall before November 1 and in the spring after<br />

April 1. Therefore, the Forest generally does not contribute to the City of Klamath Falls winter air quality<br />

problem. It is estimated by Klamath County Department of Health Services that forestry-related burns<br />

from all ownerships are the source of 1% of the pollutants during the period November 1 to April 1.<br />

When the Forest does conduct their prescribed burning program it is done according to the Oregon<br />

Smoke Management Plan and the Oregon Department of Forestry's voluntary smoke management<br />

advisories which minimizes the chance of contributing to the smoke pollution problem in Klamath Falls.<br />

This is covered in the DEIS in chapters 111-9 and IV-7.<br />

Comment<br />

Regarding air quality, the DEQ's main concerns relate to impacts from prescribed burning on the Forest<br />

and from burning of the Forest's fuelwood by the public within urban areas. The Forest should address<br />

EPA's new PM- 0 standard in its discussion of air quality.<br />

<strong>Response</strong><br />

In the discussions on air quality in Klamath County the problem area with PM-10 particles has been<br />

described to be the City of Klamath Falls and the surrounding suburban areas. The problem exists in<br />

the winter when there is poor air circulation. The Forest recognizes there is a air pollution problem in<br />

the City of Klamath Falls and surrounding suburban area. We also recognize that we supply a portion<br />

of the fuelwood that when burned contributes to the problem. We, however, have no control over how<br />

or when the wood is burned.<br />

The Forest's prescribed burn program generally takes place before November 1 and after April 1 which<br />

is outside of the period of concern for Klamath Falls. The areas that are burned are removed from the<br />

City of Klamath Falls. The prescribed burn program is conducted according to the NOPERATIONAL<br />

GUIDANCE FOR THE OREGON SMOKE MANAGEMENT PROGRAM," DIRECTIVE 14-1-601 and<br />

according to the voluntary smoke management advisories issued by the Oregon Department of Forestry.<br />

This burning generally does not contribute to the air pollution problem in the City of Klamath Falls nor<br />

cause adverse air pollution problems in regards to PM-10 particles.<br />

K-2

---

Comment<br />

DEQ has become increasingly concerned about residential woodstove impacts on urban air quality.<br />

The discussion of firewood as an issue devotes little or no analysis to the impact of the Forest's firewood<br />

policy on smoke in Klamath Falls. DEQ data show severe winter air quality problems in Klamath Falls<br />

attributable to woodstove smoke, not only for short time periods as stated on page 111-9 of the DEIS.<br />

Yet, the preferred alternative results in the highest level of total suspended particulates (TSP) from<br />

prescribed burning of any alternative. Why does that occur? What is the impact of the preferred alternative<br />

on wood stove emissions in Klamath Falls?<br />

<strong>Response</strong><br />

The reason the preferred alternative results in the highest level of total suspended particulates (TSP) is<br />

because this alternative has the greatest level of timber harvest. As the level of timber harvest increases<br />

so does the number of acres that require fuel hazard reduction by prescribed burning. As the number<br />

of acres treated by prescribed burning increase there is a corresponding increase in TSP. There are<br />

50 pounds of TSP produced per ton of fuel treated(Reference DEIS, TABLE IV-1, IV-6).<br />

There is no direct correlation between the alternatives and the amount of wood stove emissions in<br />

Klamath Falls. The Forest only supplies a portion of the fuelwood used in Klamath Falls. The Forest<br />

has no control on the type of stove in which the fuelwood is burned nor the air/fuel mixture, nor the<br />

weather conditions that exist when the fuelwood is burned. All of the above listed factors in combination<br />

determine the amount of wood stove emissions.<br />

Comment<br />

You need to develop and analyze particulate levels in Klamath Falls as an indicator of responsive to<br />

the firewood issue. The discussion of air quality impacts in Chapter 4 should address the impact of<br />

each alternative on Klamath Falls air quality. Potential mitigation measures to reduce woodstove smoke<br />

impacts should be addressed. The development of this analysis should be based on the newest<br />

information and monitoring data for Klamath Falls gathered by DEQ. You should not assume, as you<br />

do on page 111-9, that the woodstove certification program will reduce the long-term problem--it will<br />

help, but it will not solve the problem.<br />

<strong>Response</strong><br />

There is no direct correlation between the alternatives and the amournt of wood stove emissions in<br />

Klamath Falls. The Forest is just one source of supply for the fuelwood used in Klamath Falls. The<br />

Forest has no control on the type of in which stove the fuelwood is burned nor the air/fuel mixture, nor<br />

the weather conditions that exist when the fuelwood is burned. All of the above listed factors in combination<br />

determine the amount of wood stove emissions.<br />

There are two mitigation measures which could be implemented to help reduce the emission levels.<br />

The Forest could refrain from selling fuelwood to the people living in Klamath Falls or the Forest could<br />

limit the season of fuelwood gathering. These would be effective if all sources of fuelwood were managed<br />

to implement the same mitigation measures. The Forest is willing to work with Klamath County to implement<br />

mitigation measures if requested by the County Commissioners.<br />

Comment<br />

Regarding air quality, the Department's primary concerns are those of air quality impacts from forest<br />

prescribed burning and the burning of the Forest's fuelwood by the public within urban areas. Because<br />

of the serious nature of the air quality problem in Klamath Falls during the winter months, it is very<br />

important that the Winema National Forest Smoke Management Plan treat the Klamath Basin as a<br />

smoke sensitive area<br />

<strong>Response</strong><br />

The Forest does treat Klamath Falls as a smoke sensitive area. prescribed bum activities are conducted<br />

according to the voluntary smoke management advisory issued by the Oregon Department of Forestry,<br />

Salem office. The advisory is developed with the objective of keeping smoke out of Klamath Falls. In<br />

addition, the smoke from prescribed burns are monitored. If the advisory is wrong and the smoke<br />

appears to be heading for Klamath Falls the burn would be halted. It should, however, be noted that<br />

K-3

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we do not normally conduct prescribed bums during the winter months when air quality is a problem<br />

in Klamath Falls.<br />

Comment<br />

The Forest Plan DEIS Proposed Land and Resource Management Plan (Page 111-9) indicates that<br />

prescribed fire emissions will be decreasing relative to the Forest's baseline emission rate of 131,600<br />

tons per year. This figure is not a particulate emission rate but may be tons of fuel burned. As a result,<br />

it is not clear, how the emission rates proposed under the alternatives compare to the PSD baseline<br />

period. If an alternative is selected which will result in an increase in emissions, a more detailed analysis<br />

of the environmental consequences on air quality standard attainment/maintenance, visibility protection<br />

and PSD provisions of the Clean Air Act will be required.<br />

<strong>Response</strong><br />

The 131,600 tons per year is the Winema National Forest baseline for TSP/year. This figure is the Winema's<br />

portion of the amount shown in the 1984 Final Environmental Impact Statement for the Pacific Northwest<br />

Regional Guides. The emission rates shown for each alternative have been determined by using Regional<br />

Office emission factors, the type of treatment planned in each alternative and the number of acres to<br />

be treated. The projected emissions from all alternatives are significantly below the baseline. Therefore<br />

a more detailed analysis is not needed.<br />

Comment<br />

In addition, the Plan should show that the Forest Service is not subsidizing the public's use of fuelwood.<br />

Both of these issues focus on the Forest's policy of the highest and best practicable use of forest<br />

residues. The Forest Plan should work toward developing better management alternatives that will<br />

minimize prescribed burning smoke while supporting the utilization of woody residues.<br />

<strong>Response</strong><br />

The Forest believes that based on the public's response to the Plan there is a need to continue to<br />

make fuelwood available to the public. This fuelwood will come from two sources, the residue material<br />

remaining after cultural operations such as thinnings, and commercial timber harvest and as available,<br />

from standing dead and down lodgepole pine. The charge for firewood will generally be commensurate<br />

with it's value.<br />

The Forest has in the past and will continue in the future to explore options for increased utilization.<br />

An increase in utilization will only occur when the value of the material removed is close to or exceeds<br />

the cost of removal.<br />

As the result of the Standards and Guidelines in the Forest Plan there will be a need to leave more<br />

material following harvest activities for the benefit of long term site productivity and wildlife. This will<br />

reduce the amount of acres requiring treatment by prescribed burning.<br />

Comment<br />

A basic requirement of all National Forest Plans is presentation of an analysis of planned prescribed<br />

burning in relation to past burning activities. If it can be shown that projected annual and daily air<br />

pollutant emissions do not exceed, or are expected to be less than that which occurred during the<br />

1976-1979 baseline period (using emission estimation methodology for baseline and future years<br />

developed by Sandberg, et al, USDA Forest Service), then issues discussed in Sections 3 and 4 are<br />

satisfied and no additional technical analysis of these issues is required.<br />

<strong>Response</strong><br />

The Forest's analysis shows that emission expected to be less than that which occurred during the<br />

baseline period. Therefore, no additional technical analysis is necessary.<br />

All prescribed burning will be conducted in such a manner as to meet the requirements set forth in the<br />

OPERATIONAL GUIDANCE FOR THE OREGON SMOKE MANAGEMENT PROGRAM.' This will assure<br />

that the emission levels do not exceed acceptable levels.<br />

K - 4

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Comment<br />

Management alternatives should be evaluated with respect to the Clean Air Act and Oregon Clean Air<br />

Implementation Plan requirements. The first issue that must be addressed is that of impacts on air<br />

quality standard attainment and maintenance. Table 1 lists Federal and State of Oregon air quality<br />

standards. Specifically, analysis of the alternatives should demonstrate that the proposed action will<br />

not cause or significantly contribute to air quality standard violations. Air quality impacts within attainment<br />

areas must not exceed Prevention of Significant Deterioration (PSD) increments (Table 2) or cause<br />

violations of air quality standards.<br />

<strong>Response</strong><br />

The Forest's analysis shows that emissions are expected to be less than that which occurred during<br />

the baseline period. Therefore, no additional technical analysis is necessary.<br />

Comment<br />

Part C of the Clean Air Act, requires the Department to insure that pollutant increments in Class I areas<br />

(Table 2) do not exceed specific limits adopted by Congress irrespective of the originating source. To<br />

assure that these increments are not exceeded due to planned increases in prescribed burning emissions,<br />

a technical analysis of the impact of planned burns on nearby Class I wilderness and Class II lands<br />

would be required. As noted above, such an analysis would not be required if it can be shown that<br />

the proposed burning activity would not exceed that which occurred during the 1976-1979 baseline<br />

period. If the analysis indicates significant impacts, specific measures designed to mitigate the impacts<br />

must be described in the Forest Plan.<br />

<strong>Response</strong><br />

The Forest's analysis shows that emissions are expected to be less than that which occurred during<br />

the baseline period. Therefore, no additional technical analysis is necessary.<br />

All prescribed burning will be conducted in such a manner so as to meet the requires set forth in the<br />

"OPERATIONAL GUIDANCE FOR THE OREGON SMOKE MANAGEMENT PROGRAM." This will assure<br />

that the emission levels do not exceed acceptable levels.<br />

Comment<br />

The Oregon Visibility Protection Plan requires the protection of visibility within Class I areas during the<br />

period of the July 4th weekend to. Labor Day, inclusive. During this period, the Winema Smoke<br />

Management Program must be conducted such that smoke is not intentionally transported into Class I<br />

wildernesses. The Final Forest Plan should evaluate the impact of proposed increases in prescribed<br />

burning activities on the Visibility Protection Plan to assure the continued protection of visibility within<br />

Class I areas.<br />

<strong>Response</strong><br />

The Forest's prescribed burn program is conducted in the spring and the fall. Rarely would a prescribed<br />

burn be conducted during the period of the July 4th weekend to Labor Day. Therefore, it is not anticipated<br />

that there is going to be an increased in prescribed burning which would have an impact on visibility<br />

within Class I areas.<br />

Comment<br />

The Department has become increasingly concerned about residential wood smoke impacts on urban<br />

air quality, especially in Klamath Falls. Fuelwood cutting programs managed on the Winema National<br />

Forest is a major and inexpensive source of fuelwood for Southwest Oregon residents. The DEIS does<br />

not discuss the serious environmental consequences of the fuelwood program or it's consistency with<br />

Federal and State environmental policies. Specifically, the DEIS should clearly demonstrate that<br />

woodcutting fees are not subsidizing the public's use of fuelwood. In addition, we would urge the Forest<br />

to distribute at the Supervisor's and District Offices, copies of the Department's public information<br />

brochures on better wood burning practices and to actively promote public education programs intended<br />

to minimize wood smoke problems.<br />

K-5

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The Proposed Land and Resource Management Plan Section on <strong>Response</strong> to Public Issues (page<br />

1-22) notes that with respect to firewood availability and access, that within the past 5 years the supply<br />

of firewood on the Forest has substantially increased. The DEIS does not discuss the serious air quality<br />

and public health consequences of the fuelwood program, nor does it discuss the measures to minimize<br />

emissions from wood burning such as program to assure that only well seasoned wood is harvested<br />

for fuelwood.<br />

<strong>Response</strong><br />

The DEIS, on page 111-9 Affected Environment and IV-6 Environmental Consequences, recognizes-the<br />

problem of fuelwood burning in the City of Klamath Falls and surrounding area. The Forest's fuelwood<br />

program is primarily designed to utilize a forest resource instead of wasting it through slash burning.<br />

The fuelwood meets the public demand for a supply of wood to heat their homes and provides jobs to<br />

a few individuals who cut wood commercially. From a fuel treatment standpoint as well as a utilization<br />

standpoint it is to the Forest's benefit to have the wood removed as fuelwood. A side benefit is a return<br />

of dollars to the federal treasury.<br />

The Forest provides brochures on better wood burning and storage practices. It also encourages people<br />

to cut their wood early in order for it to be properly cured in time for winter.<br />

Comment<br />

Department policy (OAR 340-20-001) requires that highest and best practicable treatment and control<br />

be applied to pollution sources within Oregon. Since prescribed burning smoke is the largest source<br />

of fine particulate emissions within the State, the Draft Forest Plan should include consideration of an<br />

alternative that assures the highest and best practicable treatment of forest residues focusing on intensive<br />

utilization of woody residues for industrial purposes. As noted in the DEIS, it is important that the Forest<br />

Service work toward alternatives that will minimize prescribed burning smoke while continuing to support<br />

utilization of woody residues.<br />

<strong>Response</strong><br />

As part of the Forestwide Standards and Guidelines in the "Proposed Land and Resource Management<br />

Plan,' pages IV-54, 55, there are a number of standards and guidelines that encourage the utilization<br />

of woody residues. In addition, the Area IV forests have had a marketing specialist who is constantly<br />

looking for, and promoting the increased utilization of woody residues. It should be recognized that, in<br />

the end, economics will determine the amount and degree woody residues are utilized.<br />

K - 6

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Fire/Prescribed Fire<br />

Comment<br />

The proposed uneven aged management of 144,000 acres of ponderosa pine forests on former tribal<br />

lands is a good starting point for maintaining vegetation diversity on this portion of the Forest but the<br />

practice needs to be coupled with a prescribed burning program to insure that the stands do not convert<br />

to pine associated or fir dominated forests. Prescribed burning should in fact be instituted across the<br />

Forest to help return the vigor to some of the stands and to assist in the control of forest pests.<br />

Re-introduction of fire into the east Cascades forests will also help return the composition of the forests<br />

to more Ponderosa pine dominated stands, which more closely simulates the natural composition of<br />

the forest and which is the preferred species by timber interests and local economics.<br />

<strong>Response</strong><br />

The 144,000 acres of ponderosa pine forest that is planned for uneven aged management has ponderosa<br />

pine as the climax species. Therefore there is no need to use fire to assure maintenance of ponderosa<br />

pine. It is planned to manage some of the pine associated in uneven aged management favoring<br />

ponderosa pine. This will be accomplished through various silvicultural practices that will favor ponderosa<br />

pine.<br />

Based on some current research there is some question on the desirability of a prescribed burning<br />

program on pumice soils to maintain stocking or reduce natural fuels. There appears to be a reduction<br />

of site productivity as the result of the burning. There is a indication that the greater the intensity of<br />

the burn the greater the loss of site productivity.<br />

Comment<br />

The Department of Forestry supports a policy of applying aggressive suppression action to wildfires<br />

that threaten life, private property, public safety, improvements, or investments. Unplanned ignitions<br />

should be used as prescribed fires only if compliance with the Oregon Smoke Management Plan can<br />

be assured (protection of Class I viewsheds--Wilderness). The Winerna should more clearly emphasize<br />

compliance with this plan since the Environmental Protection Agency (EPA) has approved Oregon's<br />

plan as meeting the requirements of the Clean Air Act as amended in 1987. Coordination of protection<br />

planning and suppression efforts with other protection agencies, including this Department, should be<br />

included as an integral part of these guidelines.<br />

<strong>Response</strong><br />

On page IV-53, Forest Management Direction, of the "PROPOSED LAND AND RESOURCE MANAGEMENT<br />

PLANO it is stated that the Forest will comply with all applicable air quality laws and regulations and<br />

coordinate with appropriate air quality regulating agencies. Currently, and in the future, all planned<br />

ignitions are, and will be, conducted according to the OOPERATIONAIL GUIDANCE FOR THE OREGON<br />

SMOKE MANAGEMENT PROGRAM' which is administered by the Oregon State Forester.<br />

In addition, the Forest has agreed to comply with the the voluntary smoke management advisories<br />

issued by the Salem office of Oregon Department of Forestry.<br />

Since the Forest has no approved prescribed natural fire program all unplanned ignitions will be treated<br />

as a wildfire. Each wildfire will receive an appropriate suppression response. When a prescribed natural<br />

fire program is developed it will allow for participation by the public and other protection agencies.<br />

One of the requirements will be that prescribed natural fires will be in compliance with the Oregon<br />

Smoke Management Plan. It should be noted that only one of the Forest's wildernesses is a Class I<br />

area, that is the Mountain Lakes Wilderness. On page 111-9 states that the Forest operates under the<br />

policy and standards established in Federal and State air quality rules and regulations.<br />

K - 7

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Comment<br />

D-19.<br />

15. These standards and the burn intensity definitions are good. How will the Forest accomplish these<br />

standards? (App. D-19).<br />

<strong>Response</strong><br />

The standards will be accomplished by developing and implementing site specific burn prescriptions/plans<br />

that will assure the end product meets standards. The burn prescriptions/plans define a range of<br />

conditions i.e. temperature, relative humidity, wind, fuel moistures, and lighting sequence which will<br />

result in a burn of a certain intensity and duration. All burns require that a burn prescription/plan be<br />

developed. (Reference DEIS Appendix D, D-28, items 10 and 11.)<br />

Comment<br />

D-99.<br />

Protection No. 3. Underburning tends to diminish forest cover characteristics and browse production.<br />

The Forest has presented no data or direction on its underburning program. This information needs to<br />

be provided in order to determine the consequences of the program on wildlife habitats.<br />

<strong>Response</strong><br />

Impacts that underburning has on forest cover characteristics is a function of the type of vegetation<br />

being underburned and it's response to fire. Some vegetation can be stimulated by fire while other<br />

vegetation may be killed. The forest has no firm information as to the magnitude of the underburning<br />

program during the life of the plan. Currently the Forest is being funded to treat 1000 acres per year. It<br />

is not anticipated that this program will increase significantly over the current level. An environmental<br />

analysis to determine the environmental effects of each proposed underburn project that is undertaken<br />

will be conducted. One of the considerations will be the impact on cover and browse production. If the<br />

analysis shows that the impacts are unacceptable the project will be modified to bring the results into<br />

acceptable limits or if that is not possible the project will not be implemented.<br />

Comment<br />

Fire Suppression Objectives Are Not Clearly Stated. Fire plays an important role in the forest environment.<br />

This role, to ensure positive benefits for the economy of the Klamath Basin, needs a defined script. A<br />

suppression plan that calls for minimum action on certain acreage and types of fires cannot contain<br />

the resources and pre-planning for an aggressive control action on the remaining acreage. I support<br />

prescription burning for wildlife habitat improvement and timber stand improvement. I do not support<br />

anything less than a full control action on any wildfire, regardless of cause.<br />

<strong>Response</strong><br />

As stated on page IV-3 of the Proposed Land and Resource Management Plan the overall goal is to<br />

provide a well planned and executed fire protection and fire use programs that are cost efficient and<br />

responsive to land and resource management goals and objectives. In the final Land and Resource<br />

Management Plan Standards and Guidelines it states that 'All wildfires shall receive an appropriate<br />

suppression response. The response shall be safe, timely, and cost efficient and shall meet management<br />

objectives for the area, including objectives for biological diversity.! It also states that 'Using the lowest<br />

cost suppression option, aggressive suppression action shall be applied to control and extinguish<br />

wildfires that threaten life, private property, public safety, improvements, or investment.' The only time<br />

a wildfire will not be promptly suppressed is if the fire occurs in a wilderness area with an approved<br />

prescribed natural fire plan. If there is an approved prescribed natural fire plan the fire will be evaluated<br />

and a decision will be made on whether to let the fire continue to burn or put it out. A fire allowed to<br />

continue to burn will be evaluated each day to determine if it is still in prescription. Any time the fire<br />

gets out of prescription it will be promptly suppressed. At this time there are no approved prescribed<br />

natural fire plans for the wildernesses on the Winema. However, it is planned to develop and complete<br />

plans following the release of the final forest plan.<br />

K - 8

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Comment<br />

D-19.<br />

15. These standards and the burn intensity definitions are good. How will the Forest accomplish these<br />

standards? (App. D-19).<br />

<strong>Response</strong><br />

The standards will be accomplished by developing and implementing site specific bum prescriptions/plans<br />

that will assure the end product meets standards. The burn prescriptions/plans define a range of<br />

conditions i.e. temperature, relative humidity, wind, fuel moistures, and lighting sequence which will<br />

result in a burn of a certain intensity and duration. All burns require that a burn prescription/plan be<br />

developed.<br />

K.-9

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Firewood<br />

Comment<br />

The demand for dead wood needs to be addressed as a significant interaction for nongame wildlife<br />

habitat. The consequences to wildlife of proposed management strategies for dead wood need to be<br />

discussed in Chapter IV.<br />

<strong>Response</strong><br />

The Wildlife and Fish Forest-wide Standards and Guidelines in the Forest Plan contains the direction<br />

for dead tree habitat. The Plan states that dead tree habitat will be maintained at 40% of the maximum<br />

potential population by a combination of strategies that will leave patches of snags and individual<br />

trees.<br />

The discussion in the DEIS and FEIS, Chapter IV, Effects of the Alternatives on Wildlife Communities,<br />

Woodpecker Groups shows how the alternatives varied in their ability to meet the needs of dead tree<br />

dependent species.<br />

Comment<br />

The gathering of firewood must not decrease habitat conditions for nongame species below the 60<br />

percent level.<br />

<strong>Response</strong><br />

It is Forest Policy to only cut firewood from dead and down trees for all species, except for lodgepole<br />

pine. Both standing dead and dead and down lodgepole pine may be harvested for firewood. This<br />

policy is stated in the Timber Forest-wide Standards and Guidelines of the final plan.<br />

This policy has been effective in maintaining dead wildlife habitat in wood cutting area.<br />

Few people harvest the true firs for firewood in this area. This species group generally meet the needs<br />

for down material in the mixed conifer and pine associated working group areas. Once a dead ponderosa<br />

pine snag falls in the ponderosa pine areas, it also does not make good firewood and generally meets<br />

the dead and down material needs. Down lodgepole pine deteriorates very quickly and is generally<br />

not being used for firewood once it is on the ground. For the above reasons, we believe our firewood<br />

policy will maintain the non-game species population.<br />

Comment<br />

Areas with commercial fuel wood sales must meet a minimum of 60 percent of potential for dead and<br />

down woody habitats.<br />

<strong>Response</strong><br />

As stated in Management of Wildlife and Fish Habitats in Forests of Western Oregon and Washington,<br />

"There are no complete guides to the number of large logs and the amount of coarse debris that should<br />

remain on a site after timber harvest and site preparation. Defining the types and sizes of logs and<br />

other woody debris desired in managed stands is still a major research problem.,<br />

Bill Hopkins, Ecologist, has been studying what the Winema looked like before there was major influence<br />

by mankind. Around the turn of the century, the understory was totally bare of large logs and debris<br />

and early photos show very little. This is very different than what we see today.<br />

Until definitive direction is established, the Forest will generally follow the management considerations<br />

for protecting dead and down woody material stated in Wildlife Habitats in Managed Forests, The Blue<br />

Mountains of Oregon and Washington, and in Management of Wildlife and Fish Habitats in Forests of<br />

Western Oregon and Washington. This direction is included in the Wildlife and Fish Forest-wide Standards<br />

and Guidelines.<br />

K- 10

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Klamath Tribal Lands<br />

Comment<br />

Given the special emphasis on Klamath Tribal Rights and upon the well-being of tribal members, detailed<br />

surveys to determine wants and needs would seem justified. Particularly, since much of the Forest<br />

management direction is targeted towards improving their economic and social condition, surveys<br />

should be planned as a part of the monitoring effort. In the absence of specific, survey type data it will<br />

not be possible to determine whether social goals of the Forest Plan are being met.<br />

<strong>Response</strong><br />

The Forest gives consideration to the social and economic impacts of our activities on all affected<br />

publics, not exclusively the Klamath Tribe. Tribal desires have been expressed during the development<br />

of the forest plan and the Tribe will also be contacted during project level planning. We do not believe<br />

a detailed survey is needed.<br />

Comment<br />

Draft Environmental Impact Statement states in several places that Klamath Tribal members have a<br />

treaty right to hunt. There is no mention of hunting rights in the 1864 Treaty.<br />

<strong>Response</strong><br />

This is true. The treaty only refers specifically to fishing and gathering. However, rulings of the U.S.<br />

District Court of Oregon and the Ninth Circuit Court of Appeals interpreted the treaty to include hunting<br />

[Kimball v. Callahan, 493 F. 2d 564, 566 (9th Cir.1974) cert. denied, 419 U.S. 1019 (1974)]. The Consent<br />

Decree of 1981 spells out responsibilities of the Klamath Tribe, the State of Oregon, and the United<br />

States of America in the management of fish and wildlife resources on former reservation lands.<br />

Comment<br />

Cultural resources needs to be addressed more completely, which includes everything from more<br />

staffing and funding to educational displays that explain the historical and cultural activities that have<br />

and are taking place on the Forest. There are a lot of interesting cultural and historical events about<br />

this area and the Forest really should promote these events so that people can develop a greater<br />

appreciation for Klamath county and the Winema National Forest.<br />

<strong>Response</strong><br />

The Forestwide Standards and Guidelines (see Chapter 4 of the Final Forest Plan) for Cultural Resources<br />

provide extensive direction for management of cultural resources. This direction, which has been revised,<br />

allows for the interpretation of suitable cultural resources for the benefit of the public.<br />

Comment<br />

Food collecting activities of the Klamath Tribe should be clearly limited on RNAs to the non-destructive<br />

collection of seeds and berries. Collection of bulbs and other plant parts that are destructive to the<br />

botanical resources of the RNA should be prohibited to Indians, as well as others.<br />

<strong>Response</strong><br />

Gathering is specifically identified in the October 14, 1864 Treaty (see Appendix D of the Final Forest<br />

Plan) and in the 1986 Restoration Act, 25 USC Section 566 which states: Gathering edible roots, seeds,<br />

and berries within the limits of the Reservation.' Gathering rights apply to all former reservation lands<br />

and cannot be taken away through an administration designation by the Forest Service. The standards<br />

and guidelines state that destructive gathering will not be encouraged. Implementation plans for each<br />

RNA will address site specific coordination needs with the Tribe.<br />

Comment<br />

The Winema National Forest is the product of two additional Major Acts of Congress. This puts the<br />

Winema in the unique position of having the general direction of the 1976 act requiring the preparation<br />

K-11

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of the Forest plan and the compliance with all NEPA requirements. It must consider very special direction<br />

in the Klamath Reservation Termination legislation as amended, and the subsequent appropriation of<br />

funds to purchase those lands available to the government resulting from the termination process.<br />

Further congressional direction, committee intent and debate by our Oregon Senators, Congressman<br />

Wendell Wyatt, Congressman Lloyd Meeds and others when the later acquisition of land from the trust<br />

required additional committee action, including an additional major appropriation, must be considered.<br />

I believe a full review of this originating and supporting legislative action will further strengthen the<br />

uniqueness of the Winema Forest and its plan. A major thrust through the amended termination legislation<br />

and subsequent legislation as cited above strongly supports the management of those lands to provide<br />

and preserve job opportunity and to wisely use the resource.<br />

<strong>Response</strong><br />

The original 1954 Termination Act, 25 USC 564, gave tribal members the option of withdrawing from<br />

the tribe and receiving payment for their share of the tribal estate or remaining in the tribe. By 1955,<br />

when it appeared that over 70 percent of tribal members would elect to withdraw from the tribe, it became<br />

apparent that it would be necessary to sell off most of the former reservation in small economic units<br />

to pay the withdrawing members.<br />

In 1955, the management specialists hired to oversee the termination process concluded that the selling<br />

of the reservation in small units would lead to the timber on those units to be harvested at once, both<br />

ending the sustained yield that the reservation had been successfully managed under for many years,<br />

and glutting the Klamath Basin timber market. That timber glut would cause the market price for timber<br />

to be drastically reduced; thereby reducing the money available to be paid to withdrawing members.<br />

Public and congressional concern about the effects of implementing the original Termination Act on<br />

withdrawing members (reduced payments), on the Klamath Basin economy (creating a boom and bust<br />

timber cycle), and on watershed values (harvest of majority of former reservation lands in a short time<br />

period) led to the recognition of the need to amend the Termination Act.<br />

In 1956 and 1957, Congressional hearings on amending the Termination Act were held in Klamath<br />

Falls and Washington, D.C. Oregon Senator Richard Neuberger chaired the hearings and among the<br />

local people testifying were William Ganong Jr., Eugene Favell (management specialist), and Dan Brown.<br />

The need to continue to manage the former reservation on a sustained yield basis and as a single<br />

unit, was stated over and over at those hearings.<br />

The Termination Act amendment adopted in 1958 gave first choice of purchasing the former reservation<br />

lands to the timber industry, with the contingency that they would be managed on a sustained yield<br />

basis to furnish a continuous supply of timber. The amendment provided the authorization for the<br />

appropriation of funds to purchase the former reservation lands not sold to the industry (and not held<br />

in trust for the remaining tribal members) to become national forest lands.<br />

Two years after this Termination Act amendment, the Multiple-Use Sustained Yield Act of 1960 was<br />

passed declaring that all national forests be managed for multiple use and sustained yield of the several<br />

products and services obtained therefrom. This legislation did not distinguish the Winema National<br />

Forest from other Forests in the system. We believe that sustained yield in the context of this Act<br />

corresponds to the same concept that was discussed in relation to the Termination Act.<br />

Comment<br />

The legal obligations resulting from this relationship are entitled to no less deference than the agency's<br />

governing statutes. Fulfilling this obligation is not a matter of the agency's choice or a planning goal to<br />

be balanced in a trade-off among alternative actions. All Forest Service actions, including development<br />

and implementation of the Forest plan, must be consistent with its trust obligations to the tribe.<br />

<strong>Response</strong><br />

The Forest recognizes the Klamath Tribe's treaty rights. The actions proposed in this Forest Plan and<br />

ongoing coordination with the Tribe at the project level will insure that these obligations are met. See<br />

the forest-wide standards and guidelines in the Forest Plan (Chapter 4) for additional information. These<br />

standards and guidelines have been rewritten to reflect this comment.<br />

K - 12

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Comment<br />

The tribe's relationship with and dependence on Winema National Forest Lands extend beyond the<br />

exercise of hunting and fishing rights. The physical characteristics of the Forest are of great cultural<br />

importance to the tribe and affect the Klamath Tribe's ability to exercise its treaty rights. Specific sites<br />

and their surroundings are one component of the treaty right which is important for religious, cultural<br />

and historic reasons. The abundance and distribution of certain wildlife species are important culturally<br />

as is the diversity of species throughout the Forest.<br />

<strong>Response</strong><br />

I<br />

The physical characteristics of the Forest are of great cultural and spiritual importance to the Klamath<br />

Tribe. This does not directly affect the exercise of treaty rights. Additions have been made to Chapter<br />

1 of the FEIS to reflect this concern.<br />

The Forest has provided strong recognition of the interests of the Tribe, not tied directly to any treaty<br />

requirement, in the designation and protection of Tribal cultural values and historical use areas. During<br />

the development of the Forest Plan, the Forest has worked with the Tribe to address their issues and<br />

concerns relative to the management of resources. Many changes are evident between the Draft and<br />

Final Forest Plan as a result of the continued involvement of the Klarnath Tribe. Beyond the Tribe's<br />

direct involvement in the Forest planning process, coordination with the Tribe on site specific projects<br />

will continue as the Plan is implemented. Please see the forest-wide standards and guidelines concerning<br />

the Tribe for additional information.<br />

The Consent Decree of 1981 between the United States of America, the Klamath Tribe, and the State<br />

of Oregon requires that the Forest cooperate with the Tribe in the exchange of information regarding<br />

habitat management. The parties to this agreement are not required to obtain each other's consent<br />

prior to adopting policies on resource management activities.<br />

Yhe intent of the Forest Plan is to manage habitat to provide for viable populations of all existing wildlife<br />

species distributed across the range of habitats on the Forest. Please see the Forestwide Standards<br />

and Guidelines for Fish, Wildlife, and Sensitive Plants.<br />

Comment<br />

While the extent of the Forest Service's duties as trustee to Indian tribes has not been determined by<br />

any court, it is clear that among its duties it must investigate and disclose impacts unique to the tribe<br />

of its proposed plan.<br />

In Northern Cheyenne Tribe v. Hodel, 12 ILR 3065, Civil No. 82-116-BLG (D. Mont., 1985), the court<br />

held:<br />

(0) Once a trust relationship is established, the Secretary is obligated, at the very least, to<br />

investigate and consider the impacts of his action upon a potentially affected Indian tribe.<br />

<strong>Response</strong><br />

The FEIS and Forest Plan have been expanded concerning the relationship between the management<br />

of the Forest and the Tribe's treaty rights. See Chapter IV of the FEI'S and the forest-wide standards<br />

and guidelines in the Forest Plan.<br />

Comment<br />

For example, no explanation is provided for determining that ODFW population goals are an appropriate<br />

indicator of responsiveness to the tribe's subsistence needs; no analysis is included of the impacts of<br />

the plan on the tribe or the treaty rights area by sedimentation of streams, loss of fish habitat, even-aged<br />

harvest methods, the proposed lodgepole departure, the dramatic change in age and size of trees,<br />

the use of scenic management standards, the use or non-use of dispersion standards, and many other<br />

potential effects. Most anticipated effects are disclosed on a forest-wiide basis averaged over a period<br />

of a decade or more, making it impossible to determine particular effects on the tribe or the treaty<br />

rights area. Those effects purportedly analyzed with respect to former reservation lands were calculated<br />

and estimated based on the Chiloquin Ranger District acreage, rather than the former reservation.<br />

K- 13

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<strong>Response</strong><br />

Chapter 4 of the FEIS has been revised to display the effects of the alternatives on areas of concern<br />

to the Tribe.<br />

Comment<br />

The tribe suggests that the Forest include language in the plan acknowledging its responsibilities under<br />

the consent decree, and in general, as trustee of the tribe's treaty rights.<br />

The proposed plan for the Fremont National Forest includes language acknowledging that the consent<br />

decree: placed responsibility on the Forest Service for providing sufficient habitat to supply populations<br />

of fish and wildlife for the tribe's sustenance needs.<br />

<strong>Response</strong><br />

The discussions about the Forest's responsibilities concerning the Tribe's treaty rights and the Consent<br />

Decree in Chapters III and IV of the FEIS and the standards and guidelines in the Final Forest Plan<br />

have been revised to reflect these concerns.<br />

Comment<br />

The right also includes a continuing opportunity to participate in the acts of hunting, fishing and gathering<br />

on the tribe's aboriginal lands. The visual and other physical characteristics of the Forest determine<br />

the nature and extent of the opportunities available to tribal members to exercise this critical cultural<br />

component of the treaty right.<br />

<strong>Response</strong><br />

Chapter 4 of the FEIS has been revised to display the effects of the alternatives on areas of concern<br />

to the Tribe.<br />

Comment<br />

Part of the failure of the plan and DEIS to adequately analyze the effects of the plan on the tribe and<br />

the treaty rights results from the characterization of the issue: 'How should former Klamath Indian<br />

Reservation lands be managed to address the concerns of the Klamath Tribe?' The tribe suggests that<br />

the following characterization of the planning issue is more appropriate and more helpful in fulfilling<br />

the Forest Service's duty to analyze effects of its actions: 'How must former Klamath Indian Reservation<br />

lands be managed to fulfill the Forest Service's obligation to protect tribal treaty rights and address<br />

concerns of the Klamath Tribe?'<br />

<strong>Response</strong><br />

We have not changed the issue statement as suggested but we have changed the standards and<br />

guidelines in the Final Forest Plan to reflect the Forest's responsibilities concerning the Tribe's treaty<br />

rights.<br />

Comment<br />

Phrased in this manner, additional and alternative indicators of responsiveness will be necessary:<br />

estimated number of catchable trout; estimated number of mule deer; percentage of former reservation<br />

lands retaining their natural scenic qualities; percentage of former reservation lands scheduled for<br />

regeneration harvests by decade; loss of fish and wildlife habitat by stream miles, acreage or decrease<br />

in habitat effectiveness; degree of protection afforded to sites of cultural or religious importance, among<br />

others. Failure to adequately analyze and disclose these effects violates the agency's responsibility to<br />

the tribe.<br />

<strong>Response</strong><br />

The Forest has selected what we believe are adequate indicators of responsiveness to the issue of<br />

management of former reservation lands. The estimated effects of the Forest Plan on the Klamath<br />

Tribe are discussed in Chapter 2 and Chapter 4 of the EIS. The Forest Service is responsible for providing<br />

the quality and quantity of habitat and not actual numbers of fish and animals, however, the number of<br />

K- 14

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trout and deer are estimated in Chapter II of the FEIS. Oregon Department of Fish and Wildlife and the<br />

Klamath Tribe determine levels of animal and fish harvest, which directly relate to population levels.<br />

Comment<br />

Protection of Cultural and Religious Sites and Uses. The DEIS includes a section describing the 'affected<br />

environment' of the proposed plan. Part of that description relates to the Forest's cultural resources.<br />

DEIS 111-93-95. The description is notable for its complete lack of recognition of the tribal interest in<br />

cultural sites and of the tribal role in identification and assessment of sites. The DEIS states: Cultural<br />

resources, in general, are of national interest to both the public and to the scientific community.<br />

The description should include specific reference to the strong tribal interest in these sites, and the<br />

ongoing consultation with the tribe relating to known sites and newly discovered sites.<br />

An additional weakness of this description stems from the definition of cultural resource sites. The<br />

definition omits those sites currently used for cultural and religious purposes. Some currently used<br />

sites also have historic or archaeological value. All sites currently used should be protected. The<br />

management activities allowed near these sites could vary, depending on the particular use and<br />

significance of a site.<br />

The tribe suggests the Forest adopt a 'buffer zone concept for protection of these sites. The necessary<br />

size of the zone will vary depending on the use and significance of the site. For example, if the use of<br />

a site or corridor requires isolation, the buffer may need to be larger than a buffer zone around another<br />

site. Management activities may be allowable seasonably or selectively or prohibited altogether.<br />

It is critical that the Forest continue to work with the tribe to identify these areas, their uses, and the<br />

degree of protection necessary, and incorporate this information in the final plan.<br />

<strong>Response</strong><br />

The sections of the FEIS dealing with the Klamath Tribe and cultural resources have been revised. The<br />

Klamath Tribe's strong interest in cultural resources is recognized and direction is provided, in the<br />

Final Forest Plan standards and guidelines, for coordination with the Tribe in the long term management<br />

and protection of tribal sites.<br />

Comment<br />

The DEIS states that Alternative F is based on information and concerns of the Kiamath Tribe. The<br />

tribe did provide a map of important areas to Forest planning staff in 1985. However, Alternative F<br />

cannot reasonably be considered to reflect tribal concerns. The scenic management designation of<br />

former reservation lands provides no protection except from viewpoints along roads and waterways.<br />

Failure to impose dispersion standards in this area for 20 years renders any scenic management protection<br />

worthless. In addition, all of the acreage designated for uneven-aged management is scheduled for<br />

harvest the first decade. The tribe vehemently opposes both of these concepts. The DEIS states that<br />

the alternative is based on tribal suggestions. This misleading and incorrect assertion must be withdrawn.<br />

<strong>Response</strong><br />

Alternative F was formulated to reflect the proposed management for specific land areas as suggested<br />

by a representative of the Klamath Tribe. The scenic management proposed in Alternative F is not<br />

limited to areas seen from roads or waterways; but, rather includes all lands identified for a scenic<br />

management objective by the Kiamath Tribal Representative. There appears to be a misunderstanding<br />

of the harvest dispersion requirements in Alternative F. The dispersion requirement applied in the Draft<br />

EIS was designed to limit the amount of openings created by harvest treatments. Because in Alternative<br />

F uneven-aged management would be applied to these lands with scheduled timber harvests, no openings<br />

would be created and therefore, no dispersion requirements were necessary. The uneven-aged<br />

management proposed in this alternative is implemented over a 30-year period of time and not all in<br />

the first decade.<br />

Comment<br />

Plan, p. IV-56. The standards and guidelines provide no protection of treaty rights nor any acknowledgement<br />

by the Forest Service of its affirmative obligation to protect the exercise of these rights. How are<br />

K- 15

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these standards to be applied at the project level? What effect,if any, will they have? The final plan<br />

must include clear standards to protect these rights.<br />

<strong>Response</strong><br />

The forestwide standards and guidelines in the Forest Plan have been revised. They outline the Forest's<br />

obligations to the Klamath Tribe's treaty rights. A copy of the treaty with the Klamath Tribe and the<br />

Consent Decree (1981) are found in appendix G of the final EIS and in the Final Forest Plan.<br />

Comment<br />

Plan, p. IV-1 26. The Forest Service is the trustee of the tribe's treaty rights to gather traditional foods.<br />

The statement that such gathering *will not be encouraged is a telling commentary on the agency's<br />

willingness to accept and fulfill its obligations. This language is unacceptable.<br />

<strong>Response</strong><br />

We have altered the standard slightly in the Final Forest Plan. Because the goal of a Research Natural<br />

Area is to preserve a natural ecosystem, we can't encourage any use that would alter the natural<br />

ecosystem. Implementation plans for each RNA will address coordination needs with the Tribe.<br />

Comment<br />

The proposed plan calls for scenic management of 19% of the former Klamath Indian Reservatidri<br />

lands. DEIS Table 11-7 p. 11-142. The tribe is very concerned with the physical characteristics of is former<br />

reservation, including the visual quality of the Forest. However, the assertion that 19% of the former<br />

reservation will retain its scenic qualities is highly misleading. Winema Forest staff has informed the<br />

tribe that acreages in scenic management include acreages in management areas 1, 3, 4, 5d and 7.<br />

These management areas do not necessarily reflect acreage that will actually retain scinshid 4lies.<br />

Acreage designated for management area 3 is subject to timber harvesting, including ciearc;it Dispersion<br />

standards do not apply to MA3 for the first two decades. DEIS Appendix B. As a reSUlt, a lahro percentage<br />

of this management area acreage will be severely altered in the next 20 years. Similrly, Attbrnative I<br />

provides for actual retention of a large area as old growth habitat, yet the plan Shows onl# 23% of<br />

former reservation lands 'managed' for scenic qualities under this Alternative. The plan mUst accurately<br />

disclose the percentage of former reservation lands on which scenic qualities will be mtiftained, not<br />

merely the acreage 'managed' for scenic qualities. Failure to do so violates the duty of the Forest<br />

Service to disclose the impacts of its actions on the tribe.<br />

An additional problem with the scenic management concept is that it relies on the proteoffon of viewsheds<br />

from heavily travelled roadways and rivers. These areas are important to protect primatliy for the general<br />

public but not necessarily for the tribe. The tribe is also concerned about the visual qul ities throughout<br />

the former reservation, and as viewed from sites of cultural importance to the tribe. Ptbtecting highway<br />

viewsheds does not respond to these tribal concerns, and to assert that it adequately Indicates<br />

responsiveness to the tribe is misleading and incorrect.<br />

The table also fails to represent effects on lands actually within the former reservation. Winema Forest<br />

staff estimated the figures shown based on the acreage of the Chiloquin Ranger District. The Forest<br />

must show that this accurately reflects effects on the former reservation lands with respect to age<br />

class, harvest level, working group, acreage, etc., or it must use the actual former reservation boundary.<br />

Estimation based on the Chiloquin District, without showing its accuracy, fails to fulfill the Forest Service's<br />

duty to disclose effects on the tribe.<br />

<strong>Response</strong><br />

It is true that management areas 1, 4, 5, and 7 are not managed to retain scenery as the first priority,<br />

however, it is expected that they will achieve certain scenic quality levels compatible with scenic<br />

allocations. It is true that dispersion constraints were not applied in the first two decades in MA3 in the<br />

DEIS. In the FEIS, the maximum area created opening dispersion constraint is applied in the first two<br />

decades in even-aged management. In uneven-aged management there was no need to apply this<br />

constraint.<br />

Managing scenic quality as viewed from major travel routes, use areas and water bodies is intended to<br />

provide certain levels of scenic quality for the public at large. It is based on the National Visual Management<br />

K- 16

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System applied throughout the Forest Service. P. 1-13 lists 'Scenic management on former Reservation<br />

Lands' as an indicator of the Forest Plan Alternatives by percentage of lands. This does not measure<br />

'adequacy' but rather, attempts to portray an array of options. Apart form scenic allocations, other<br />

management areas will achieve various levels of visual quality, and uneven-aged management techniques<br />

are considered to have less impact than even aged management. The comparison of figures based on<br />

Chiloquin District acreage for nonviewshed areas is a projection of appearance for larger land areas,<br />

not necessarily for former reservation lands.<br />

K- 17

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Lands<br />

Comment<br />

To acquire all inholdings on all Public lands, with no disposal of any public land.<br />

<strong>Response</strong><br />

There is no process in place that allows the Forest Service to acquire all inholdings on all public lands.<br />

Inholdings can be acquired through donation, purchase, or exchange. Donations are fairly rare and<br />

generally occur only when to the advantage of the inholding landowner. Purchases are more common,<br />

but currently are generally limited to specific areas for specific reasons by Acts of Congress. Exchanges<br />

are the most common way that the Forest Service has to acquire inholdings but this method necessitates<br />

the exchange of Federal lands to acquire the inholdings.<br />

Comment<br />

The timber sale areas in green stipple on Alternative E Map could be sold off to the highest bidders so<br />

as to allow the private enterprise, or timber companies to manage harvest areas. Then the Federal<br />

government would no longer be in a business, which can conflict with a capitalist orientation.<br />

<strong>Response</strong><br />

From the passage of the Organic Act (June 4, 1897) to the passage of the Multiple Use-Sustained<br />

Yield Act (June 12, 1960) the mission of the U. S. Forest Service has always been conservation and<br />

management of forested federal lands to ensure a continuous supply of all resources. Selling our Timber<br />

Lands would be a violation of our mission.<br />

Comment<br />

Wilderness and/or National Park Boundaries<br />

There is no cut and dry way of handling the identification of these boundaries mentioned in the plan.<br />

We need to make sure that the establishment of these boundaries and also the maintaining of them is<br />

mentioned in the Plan. Especially since logging, firewood cutting, bug kill, and recreational use<br />

dramatically affect how we manage the resource next to these boundaries.<br />

<strong>Response</strong><br />

A discussion and more information related to the landline program has been added to the FEIS. Also,<br />

refer to the following responses.<br />

Comment<br />

I have a few comments on the Proposed Plan.' While going through it very briefly, I did not see somethings<br />

that should be, in my opinion, mentioned or addressed in some manner. Among these are:<br />

Past, Present and Future Landline Stewardship or Landline Management.<br />

This includes where the landline program has been, where it's going and how we tie the program<br />

to all the other resources. We are under Presidential and Congressional order to establish,<br />

perpetuate and maintain the landlines as part of the on-going land stewardship responsibilities<br />

of the Forest Service. We are also mandated by the State to perpetuate and protect all original<br />

G.L.O. corners. This is required under State license.<br />

<strong>Response</strong><br />

Since initiating the landline location program in the 70's, the Winema completed identification and<br />

marking of approximately 95% of Private/FS property lines. This has been driven mainly by Forest<br />

Resource needs located near these boundaries. The Forest will now be moving into a landline<br />

management/maintenance program to insure the property lines will remain identifiable in the future. A<br />

discussion related to the past and future landline program has be added to Chapter 3 of the FEIS.<br />

Also, changes to the Standards and Guidelines in the Forest Plan have been made in the Land Section.<br />

K- 18

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Comment<br />

Public needs to be aware that the majority of our wilderness areas do not have established boundaries.<br />

Plan needs to address identification of wilderness boundary and how we will monitor and maintain this<br />

boundary.<br />

Consequences are woodcutters and four-wheel drive vehicle owners illegally entering wilderness to cut<br />

firewood. Another is the potential of U.S. Forest Service placing a portion of a timber sale within the<br />

wilderness.<br />

<strong>Response</strong><br />

Forest Service Manual, 7100, Region Supplement No. 67, Dated July, 1988, establishes objectives,<br />

responsibilities, and standards for the performance of congressionally designated area boundary surveys.<br />

A discussion related to the landline program was added to Chapter 3 of the FEIS. Also, changes to<br />

the Standards and Guidelines in the Forest Plan have been made, in the Lands Section.<br />

Comment<br />

What process is there for mcorrecting land allocations if they are determined to be inappropriate?<br />

<strong>Response</strong><br />

Refer to Chapter 5 of the Forest Plan.<br />

Comment<br />

The Division of State Lands suggests the following addition to land ownership standards and guidelines<br />

to facilitate a mutually beneficial exchange program between the Forest Service and the State Land<br />

Board. Group VI:<br />

This group includes Common School lands owned by the State of Oregon and potentially available<br />

for sale or exchange to public and private entities. It includes lands adjacent to special management<br />

areas within the Forest which could be adversely affected by sales to private parties or<br />

state-permitted leasing activities. Adjustments will be made only after careful review and<br />

consultation with the Oregon Division of State Lands, the Oregon Department of Forestry, and<br />

the Oregon Department of Fish and Wildlife.<br />

The State Land Board administers several parcels of land in and around the Winema National Forest.<br />

These lands are blocked together and actively managed and the state is not pursuing their exchange.<br />

We are concerned, though, with the effect that designating one adjacent parcel of Forest land for<br />

old-growth management will have on adjacent state lands. We also recommend that you change your<br />

land ownership standards and guidelines to facilitate potential future exchanges.<br />

<strong>Response</strong><br />

The Forest Plan uses standard language to provide Landownership direction for each management<br />

area The five classification priority groups cover all areas and provides maximum flexibility to accomplish<br />

land adjustment activities pursuant to Forest Service exchange and acquisition authorities. More specific<br />

adjustment plans by area or with specific ownerships may be developed by the Forest as a (supplement)<br />

to the Forest Plan.<br />

State land board lands and adjacent NF lands have been generally classified in Group II, IlIl and IV as<br />

consistent with Regional direction and Winema priority for acquisition or disposal. The Land Exchange<br />

process requires consultation with interested parties. Through this process, we would consult with<br />

State agencies.<br />

The designation of old-growth management areas will not affect management of adjacent ownerships.<br />

K - 19

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Comment<br />

The plan need not be amended to reflect the State proprietary interest in navigable waters. However,<br />

to clarify this issue a section could be added to the Water, Soil and Air Forestwide Standards and<br />

Guidelines" as follows:<br />

Navigable Waters<br />

The State of Oregon holds title to the beds and banks of all navigable waters in the state. The<br />

State Land Board and the Division of State Lands enforce the state's interest in these lands. In<br />

the Winema National Forest, the staff of the Division of State Lands has recommended that the<br />

state claim ownership of Lake of the Woods, all of Crystal Creek and 10 miles of the Sprague<br />

River. The State Land Board has not acted on this recommendation and final ownership<br />

determination is let to the courts and/or legislature.<br />

Parties contacting the Forest regarding development activities in these waters shall be referred<br />

to the Division of State Lands, Salem, Oregon, for information regarding possible lease<br />

requirements. In this context, odevelopment activities' includes but is not limited to marinas,<br />

mineral extraction, hydroelectric power generation, or log raft storage.<br />

<strong>Response</strong><br />

The Forest Service recognizes that the State of Oregon holds Title to the beds and banks of all navigable<br />

waters in the State. The Winema National Forest recognizes this ownership on all waters that have<br />

been adjudicated as navigable within the Forest boundaries. All other lands with such areas will be<br />

managed as National Forest System lands until adjudicated and designated as navigable.<br />

Comment<br />

The administrative problems involving management of commercial timber production, protection of<br />

amenity values and range uses on a scattered land ownership pattern can be serious. The Forestry<br />

Department encourages and supports active efforts for consolidation of these scattered parcels into<br />

major blocks through exchange. Such a program should be discussed in detail in the resource plan.<br />

<strong>Response</strong><br />

The Land Ownership and Adjustments section in Chapter 3 has been expanded. Also, more information<br />

has been added to the Forest Plan, Chapter 4 - Lands Section, and to the Standards and Guidelines.<br />

Comment<br />

It is clear that the Winema National Forest has attempted to produce a forest plan with considerable<br />

interest group and citizen involvement. The same effort, though, does not appear to have been placed<br />

on coordination with state and local planning. For example, the Winema DEIS has nothing comparable<br />

to the Umatilla Forest's depiction of county zoning districts in relation to surrounding and interspersed<br />

federal holdings and findings explaining the overall effect of the alternatives on statewide planning<br />

goals. The alternatives for each national forest should be as compatible as possible with the comprehensive<br />

plans of affected cities and Klamath county and statewide planning goals. See the Department of<br />

Land Conservation and Development suggestions for improving your coordination with local and state<br />

Planning.<br />

DLCD request that the state's response on the Winema ask the Forest to do more to demonstrate that<br />

its management alternatives are compatible with the state land use goals and with the comprehensive<br />

plans of the surrounding communities. Specifically, the Winema should attempt to obtain from local<br />

government planning authorities written indications concerning the relationships of city and county<br />

land use policies, map designations and implementing regulations with the alternatives being proposed<br />

by the Forest.<br />

Our review of the Winema's documents, however, reveals little discussion about coordination with<br />

state and local land use planning efforts except for a statement at IV-35 in the DEIS about the<br />

incompatibility of several alternatives with Klamath County's forest goal. The DEIS also fails to note<br />

that all city and county comprehensive plans affected by the Forest have been acknowledged to comply<br />

with the statewide planning goals by the state Land Conservation and Development Commission.<br />

K-20

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There is nothing in the Winema's DEIS, for example, which is comparable to the Umatilla National Forest's<br />

depiction of county zoning districts in relation to surrounding and interspersed federal holdings.<br />

<strong>Response</strong><br />

The Social Environment section of Chapter 3 and the Effects of the Alternatives on Society section of<br />

Chapter 4 has been revised to include the statewide planning goals and the comprehensive plans of<br />

Klamath County.<br />

Comment<br />

The new boundary (1980) between Crater Lake NP and the Winema National Forest has not been<br />

legally surveyed. Prior to any timber harvest or significant changes in the Winema National Forest<br />

lands, a legal boundary survey should be conducted to ensure that none of the National Park lands<br />

are affected. The Park staff would be willing to assist the Forest in completing a legal boundary survey.<br />

<strong>Response</strong><br />

We agree to the high priority need to complete the survey and posting of the park boundary at Crater<br />

Lake National Park. We have previously submitted a proposal to our Regional Office to conduct a joint<br />

cadastral survey of the Park Boundary, and this proposal has been approved. The approved proposal<br />

would provide a survey of the park boundary by 1991. As has been previously discussed, accomplishment<br />

of this would be a cooperative effort between the Winema, Rogue River, and Umpqua National Forests,<br />

and Crater Lake National Park. The Memorandum of Understanding is currently being prepared. Also,<br />

a portion of the work will be accomplished by the Bureau of Land Management under the existing<br />

FS/BLM 9800 Cooperative Cadastral Survey Program and the Current Memorandum of Agreement<br />

between BLM and the National Park Service. We have submitted our outyear budgets to reflect this<br />

need and funding request.<br />

Comment<br />

The final EIS should provide information on the location of O&C lands on the Winema National Forest,<br />

how they are allocated among the alternatives and their contribution in payments to counties.<br />

Opportunities should be explored to maximize the number of O&C acres retained in the suitable land<br />

base. A separate accounting of projected revenues from these lands was not provided in the DEIS.<br />

<strong>Response</strong><br />

The discussion of the former 0 & C lands has been expanded in Chapter 3 of the FEIS.<br />

Comment<br />

Net Forest Acreage Differences - (DEIS, page 111-105) The explanation of legal acreage and mapping<br />

acreage difference is confusing and does not provide a clear accurate picture of land ownership within<br />

the national forest boundary. The DEIS states that the Forest boundaries contain 1,035,020 acres of<br />

National Forest System land and 60,131 acres of other lands for a total of 1,095,151 acres. When compared<br />

with Table 111-5 (page 111-28) federal lands have 9.6 percent more acres and private lands within the<br />

forest 37.7 percent more. This presents a difference of 22,685 acres of other ownership that is unaccounted<br />

for within the forest boundary. These differences should be better explained in the final EIS to provide<br />

the most accurate picture of federally managed timberlands on the Winema National Forest for public<br />

review.<br />

<strong>Response</strong><br />

This section has been clarified in the FEIS.<br />

K - 21

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Comment<br />

Page IV-34. Wilderness Management Program. The BLM has a 334-acre wilderness study area (WSA)<br />

adjacent to the Mountain Lakes Wilderness. The latest BLM recommendation for this WSA (Supplement<br />

to the Draft Oregon Wilderness EIS, January 1987) is that it be added to the Mountain Lakes Wilderness.<br />

While only Congress can designate the WSA as wilderness, the Winema National Forest Supervisor<br />

indicated in September 1986 that addition of the WSA to the existing wilderness was a viable alternative.<br />

Thus, we suggest that the Plan consider this situation.<br />

<strong>Response</strong><br />

We have revised the Lands section of Chapter 3 in the FEIS to reflect the potential addition to the<br />

Mountain Lakes Wilderness.<br />

K - 22

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Minerals<br />

Comment<br />

A more detailed map may be useful to show lands with locatable and leasable mineral potential and<br />

access restrictions, and to outline areas that are likely to be developed. This map would also be helpful<br />

in showing acres available by mineral potential and by access restrictions, as tabulated in Appendix F,<br />

Table F-3, page F-i1 (and Table 111-3 on page 111-16 of the DEIS).<br />

<strong>Response</strong><br />

The Forest Service has no way to predict areas that are likely to be developed. Industry is generally<br />

the driving force in exploration and development of mineral resources. The lands with the most likely<br />

mineral potential are shown in Figure 3-1 that shows existing mining claim locations, and Figure 3-3<br />

that shows existing geothermal lease locations.<br />

Table 111-3 has been clarified to show which Management Areas are included in each access restriction<br />

category. The Management Areas are shown on the Forest Planning Map.<br />

Comment<br />

In the past, there has been little demand on the Forest for locatable minerals due to the low potential<br />

for economically significant deposits. However, with new technology in extracting precious metals from<br />

low grade deposits, land use planning must anticipate increased minerals activity.<br />

<strong>Response</strong><br />

We anticipate increased minerals activity in the future, however, at this time we cannot forecast the<br />

degree of activity. To our knowledge, the only activity on the mining claims has been assessment work.<br />

Comment<br />

In our opinion, the Winema Draft EIS lacks the specificity in addressing potential adverse impacts of<br />

geothermal development which we have found in other Environmental Impact Statements. In particular,<br />

we feel that the EIS needs to take cognizance of the potential for land subsidence which can occur<br />

with geothermal development. Such subsidence is evident in the local Klamath Falls area. Structural<br />

damage to Ponderosa Junior High School and several residences in the area have a close correlation<br />

with increases in geothermal usage in Klamath Falls. The Winema EIS and plan need to ensure that a<br />

monitoring system for detecting land subsidence is in place, as well as providing for prevention and/or<br />

mitigation of adverse effects associated with geothermal exploitation.<br />

Enclosed are some extracts from the geothermal segment of the EIS prepared in 1976 for the Breitenbush<br />

Hot Springs in the Mt. Hood National Forest, Oregon. CRGD (Citizens for Responsible Geothermal<br />

Development) would suggest that much of the material in this EIS should be incorporated in the Winema<br />

EIS.<br />

As you know, the Winema National Forest is a member organization of the Klamath Geothermal Advisory<br />

Committee. This group is charged with advising state, local and federal agencies on geothermal regulation<br />

and activity in Klamath County. It is highly recommended that the Winiema seek a comprehensive review<br />

of the EIS by the Geothermal Advisory Committee.<br />

<strong>Response</strong><br />

The Winema DEIS is an umbrella document for mineral activities and identifies the areas of the Forest<br />

that are available for mineral activities, and is not intended to be a Site Specific EIS. Site specific<br />

environmental analysis will be made as mineral projects are submitted to the forest. The Breitenbush<br />

Hot Springs EIS is an example of an analysis of a specific project.<br />

It is premature to address subsidence in the DEIS. Land subsidence will be addressed through<br />

environmental analysis on specific proposals and projects as they occur. Even if a geothermal reservoir<br />

is discovered and produced and leads to subsidence, the requirements of Geothermal Resources<br />

Operational (GRO) Order No. 4, dealing with subsidence, would have to be observed. Requirements<br />

include the establishment and monitoring of leveling networks, and monitoring of geothermal production<br />

pressures and quantities.<br />

K - 23

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Comment<br />

Since the State Highway system is crucial to the economy, it must continually be maintained and improved.<br />

There is a continuing need for mineral resources (i.e., rock, gravels, and common fill material) and<br />

waste areas. The west areas are necessary to dispose of material removed from slides, rock falls and<br />

ditches. The material sources are necessary to provide aggregate for construction and maintenance.<br />

Your Proposed Land and Resource Management Plan appears to recognize the importance of mineral<br />

resources. Your Standards and Guidelines (Appendices DEIS) are so restrictive, however, that only<br />

Management Area 12 appears to allow the use outright.<br />

Material sources, when used for highway work, many times need to be opened up and left open for<br />

many years as construction and maintenance materials are produced. This is particularly true of sanding<br />

material sources. Section Xl "Use of Material Sources and Haul Roads,' paragraph B of the Memorandum,<br />

addresses this area.<br />

The Forest Plan should recognize the need for waste areas. If a slide should occur in a snow zone in<br />

winter, for example, maintenance crews are unable to haul the material any appreciable distance from<br />

the highway because of the snow depth.<br />

<strong>Response</strong><br />

1. Standards and Guidelines comment: We have reviewed the standards and guidelines for each<br />

management area and feel that they are appropriate for the objectives and goals of the management<br />

area, and not overly restrictive, for the following reasons.<br />

a. Some of the management areas are small in comparison to the total forest acreage, and the<br />

numbers of acres restricted is minor. See Table IV-13 on Page IV-63 of the Proposed Plan, which shows<br />

the management area acreages<br />

b. All of the management areas have specific management goals and intents and the development<br />

of Materials Sources would not be consistent in some Management Areas. For example, Management<br />

Area 1 is Semi-Primitive Recreation, Management Area No. 2 is within Developed Recreation<br />

Sites(Campgrounds), Management Area No. 4 is Special Interest Areas.<br />

c. In certain management areas, development of Material Sources and Haul Roads is prohibited<br />

or discouraged for example: Management Area No. 6, Wilderness, Management Area No. 4, Special<br />

Interest Areas, and Management Area No. 13, Research Natural Areas.<br />

d. Development of Material Sources in some Management Areas is not prohibited, but certain<br />

restrictions or coordination needs for material source development are required to meet the goal and<br />

intent of the area. Example is Management Areas No. 3, Scenic Management, and Management Area<br />

No. 10, Big Game Winter Range.<br />

e. Management Area 12, which is minimally restricted, consists of a large percentage of the<br />

forest land area.<br />

2. Waste Area Comment: The location of waste areas and agreements on use can be done. Location<br />

and use would have to been in accordance with management area goals and objectives. This topic<br />

will be brought up at the next annual meeting with the State Highway Department.<br />

Comment<br />

The Forest should be withdrawn from appropriation under mining or mineral leasing laws.<br />

<strong>Response</strong><br />

Mineral resources are a major resource and are treated on an equal basis with other resources.<br />

Withdrawals from mineral entry are made only where there are sensitive unique surface resources that<br />

cannot be adequately protected under current public laws and Federal regulations.<br />

Comment<br />

BPA has transmission facilities located in the Winema National Forest. They are identified in the draft<br />

EIS, but not in the Plan. The Plan needs to identify BPA and other utilities existing and planned facilities<br />

and whether they have been designated as utility corridors. Plan must recognize that some areas may<br />

require restricted public access in order to protect the operation of existing utility facilities and/or the<br />

safety of the general public.<br />

K -24

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<strong>Response</strong><br />

The significance and designation of existing transportation corridors, which is presented in Chapter 3<br />

and 4 of the Draft EIS, has been incorporated into the Forest Plan, In Chapter 4 - Forest Management<br />

Direction. The concept of restricted Public Access, would be noted in the Road Management Objectives<br />

for those roads accessing the utilities.<br />

Comment<br />

Transmission corridor must consider factors other than residual capacity. We suggest the standard be<br />

reworded as follows: 'To avoid proliferation of rights-of-way, the use of existing utility corridors must be<br />

considered first in determining the best location for a new utility proposal. A utility application for use<br />

of an existing (designated) corridor will require less time for processing and will be considered for<br />

categorical exclusion from NEPA. New corridors will be subject to Forest NEPA procedures including<br />

preparation of an EA or EIS.'<br />

<strong>Response</strong><br />

The Standard has been revised in accordance with your comment. The intent to utilize residual capacities<br />

and avoid proliferation of separate rights of ways was also discussed in Chapter 3, Page 112, of the<br />

DEIS. The Revised Standard is in accordance with Page 112 and your comment, and is contained in<br />

Chapter 4 of the Forest Plan.<br />

Comment<br />

Page IV-54 - IV-55 - Minerals, Energy, and Geology Forestwide Standards - This section does not address<br />

potential hydro and small hydro sites and the availability of biomass for generation. It is our understanding<br />

that the FS is responsible for issuance of ROW permits for hydro sites. Accordingly, the Plan should<br />

recognize potential sites and identify standards and guidelines for dealing with them.<br />

<strong>Response</strong><br />

There are no inventoried potential hydro or small hydro sites within the Forest. The potential on the<br />

Forest is low with few possible sites, on a limited number of streams.<br />

The FEIS has been be revised to add a discussion of hydro and biomass.<br />

Comment<br />

Page IV-57 (6) - Lands Forestwide Standards and Guidelines - Standard 6 infers that corridors should<br />

be located on private land. It has been BPA and utility practice to locate transmission corridors based<br />

on minimum environmental impact and engineering suitability, irrespective of land ownership. Most<br />

Forests have agreed to this practice. We suggest that this standard be revised.<br />

<strong>Response</strong><br />

This standard applies to all types of special uses. The location of utility corridors would be based upon<br />

an environmental assessment and would consider environmental impacts, engineering suitability,<br />

economics, land ownership, etc.<br />

Comment<br />

Page IV-57 (11) - Lands Forestwide Standards and Guidelines - Crossing transportation corridors at<br />

right angles may not always be the best method of reducing visual impacts. It is recommended that<br />

the February 1970 "Environmental Criteria for Electric Transmission Systems' published by the<br />

Departments of Interior and Agriculture be referenced for other methods that can be used to reduce<br />

visual impacts from transportation corridors as well as other sensitive viewer locations.<br />

<strong>Response</strong><br />

This standard is revised to reflect your comment and is contained in Chapter 4 of the Forest Plan.<br />

K - 25

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Comment<br />

Page IV-60 (22) - Facilities Forestwide Standards and Guidelines - It is not technically or economically<br />

feasible to bury transmission lines of 69-kv or higher voltage. This standard should be revised to include<br />

only distribution lines of 34.5-kv or less.<br />

<strong>Response</strong><br />

The standard is revised to note the technical and economic limitations of burying higher voltage lines.<br />

This was the intent of the wording 'unless special conditions warrant other methods.' The revised standard<br />

is in Chapter 4 of the Forest Plan.<br />

Comment<br />

Page IV-60 (26) - Facilities Forestwide Standards and Guidelines - BPA and other utilities need access<br />

to their facilities at all times for maintenance and emergency repairs. This is essential in maintaining<br />

safe and reliable service to the public.<br />

<strong>Response</strong><br />

This standard, as is noted, deals with existing roads 'not needed for continuous access.' When considering<br />

the need for a road, the road management objectives consider the needs of the public, forest<br />

administration, commercial special use, and the needs of other agencies. Reference Page IV-57 and<br />

58, of the Proposed Forest Plan. Therefore, we feel the standard is correct as written.<br />

Comment<br />

In particular, we found inconsistencies between the use of avoidance and exclusion under the lands<br />

and facilities sections. We also suggest that the Forest consider the establishment of a corridor or<br />

facility management area. Many Forests have established a management area specifically dedicated to<br />

utility facilities, (including corridors) with its own management standards and guidelines. The Gifford<br />

Pinchot National Forest in Washington, has taken this approach. We feel this is appropriate since the<br />

land resources within or immediately adjacent to a corridor should be managed for corridor use.<br />

<strong>Response</strong><br />

1. Comment on Inconsistencies: The phrasing in the Lands Section 'will normally not be allowed'<br />

will be changed to either excluded or avoided, as defined in the DEIS. The definitions will be included<br />

in all Glossaries.<br />

2. Comment on addition of a management area for Utility Corridors: In the process of developing<br />

the proposed forest plan, we originally did have a separate management area for Utility and Transportation<br />

Corridors. For a variety of reasons, such as; mapping difficulties due to width of corridors, the limited<br />

number of existing and proposed corridors on the forest, and the fact that corridors exist within other<br />

management areas, a separate Management Area was not continued. We recognize that these corridors<br />

and facilities are of high importance and significance. The discussion of significance, and corridor<br />

designations presented in Chapter 4 of the DEIS will be incorporated into a separate section on corridors<br />

in the final Forest PLAN. We feel that the standards and guidelines for corridors should continue to be<br />

contained within each of the Management Areas, so that the tie between each management area and<br />

corridor management is visible and specific. For the above reasons, we did not continue with a separate<br />

Management Area for Corridors<br />

Comment<br />

Page IV-70 and 71 - Management Area 2: Developed Recreation - Utility lines are excluded under the<br />

lands section and considered avoidance in the facilities section. Since exclusion areas are lands restricted<br />

to corridor development by legislation, the exclusion requirement described under the lands section<br />

should be revised to an avoidance area requirement.<br />

<strong>Response</strong><br />

1. Comment on Inconsistencies: As noted, this should be an avoidance area. This has been corrected<br />

in the Forest Plan.<br />

K - 26

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Comment<br />

Page IV-1 10 - Management Area 9: Bald Eagle Habitat - The discussion in the facilities section address<br />

distribution lines and not transmission lines. Transmission lines have much greater electrical clearances<br />

and are not normally an electrical hazard for roosting and nesting birds. Nesting platforms can also be<br />

used to mitigate the loss of habitat that may occur with Right-of-way clearing.<br />

<strong>Response</strong><br />

This standard was revised to reflect your comments.<br />

Comment<br />

Right of Facility Access - Utilities must have access to their facilities at all times for maintenance and<br />

emergencies. This should be recognized in the Forest Plan. Please contact BPA's Area Maintenance<br />

Superintendent to discuss actions, such as land transfers, proposed construction of buildings/structures<br />

near BPA facilities that could affect access to or their reliability.<br />

<strong>Response</strong><br />

When considering the need for a road, the road management objectives consider the needs of the<br />

public, forest administration, commercial special use, and the needs of other agencies. These needs<br />

are recognized in the transportation management standards and guidelines in the Proposed Forest<br />

Plan, Page IV-57 and 58. Coordination with others for project development and management is discussed<br />

in many areas of the Forest Plan.<br />

Comment<br />

Page 111-10 to 18 - Minerals and Energy - This section provides good coverage of geothermal, solar,<br />

and wind generation. However, it has failed to address hydro, small hydro, and biomass energy sources<br />

found on the Forest. It is important that the potential of these resources be addressed and the impacts<br />

of Forest Plan alternatives on them identified.<br />

<strong>Response</strong><br />

Chapter 3 and 11 of the FEIS has been revised to include hydro and biomass.<br />

Comment<br />

However, we suggest that a map be added to illustrate the corridors or facilities described on tables<br />

111-38 and 111-39. We have attached a BPA facility map which illustrates the BPA facilities found on the<br />

Forest. It also includes the important physically suitable corridors identified by BPA and the Forest<br />

Service in the 1970 East-West Regional Corridor Study. The Forest should be aware that BPA owns<br />

only the Yamsay (switching station) to Klamath Falls portion of the 230-kv Redmond-Kiamath Falls<br />

transmission line. PP&L owns the southern portion.<br />

<strong>Response</strong><br />

The facilities shown in the tables have been presented in map form in the final Forest Plan, and the<br />

ownerships corrected, as requested.<br />

Comment<br />

Page 111-112 - Utility and Transportation Corridors - The second paragraph mentions providing for new<br />

or expanded facilities within existing rights-of-way to avoid the proliferation of rights-of-way. BPA agrees<br />

with this goal, however, the electrical needs for each project must be evaluated to determine if it is<br />

possible. For example, it may not be possible to rebuild, in place, a transmission line that is the only<br />

source of power to important loads. To do so would require taking the line out of service. In this case,<br />

it may be necessary to build a second line parallel to the first, requiring additional right-of-way.<br />

<strong>Response</strong><br />

We agree the determination of technological and economic feasibilities would be part of the project<br />

environmental analysis.<br />

K -27

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Comment<br />

Page IV-10 - Effects of the Alternatives on other Energy Sources: Solar and Wind Generation - As previously<br />

mentioned, the effects on hydro, small hydro, and biomass should be identified.<br />

<strong>Response</strong><br />

Chapter 4 of the FEIS has been revised to include hydro and biomass.<br />

Comment<br />

Page IV-96 - Effects of the Alternatives on Transportation and Utility Corridors - The first paragraph<br />

should identify which facilities are being considered for designation. It would be extremely helpful to<br />

have them shown on a map as previously requested. We also recommend that additional right-of-way<br />

width (at least double) be included for right-of-way expansion. An additional 125 feet of right-of-way<br />

should be designated for the BPANPP&L Klamath Falls-Redmond 230-kv transmission line. This will<br />

keep facilities in the designated corridor while also allowing for expansion where replacing the existing<br />

power line is not feasible.<br />

<strong>Response</strong><br />

Please refer to the first paragraph, which does identify the designations. They are identified in the FEIS<br />

and Forest Plan. As requested, a map is also included. Additional right of way widths can not be allocated<br />

until a project proposal is received and evaluated.<br />

Comment<br />

Appendix D - Page D-3 (10) - We suggest that the first sentence be reworded as follows: RDesignate<br />

corridors for important transportation and utility corridors allowing for right-of-way expansion where<br />

determined compatible."<br />

<strong>Response</strong><br />

This standard and guideline is from the National Forest Management Act Regulations, 1976, as noted<br />

on Page D-2, 1st Paragraph.<br />

Comment<br />

We suggest that the following sources of information may be useful in the preparation of the Final Plan<br />

and Final Environmental Impact Statement if they have not already been consulted.<br />

The Pacific Northwest Hydropower Data Base and Analysis System: This data base contains<br />

detailed, site-specific information on over 2,000 individual hydro project applications submitted<br />

to the Federal Energy Regulatory Commission. Data include physical location, institutional status,<br />

hydrologic characteristics, cost, and planned power output.<br />

The Pacific Northwest Rivers Study: The Rivers Study, conducted with participation by the Forests<br />

in Regions 1, 4, and 6, resulted in a data base containing an inventory and assessment of the<br />

region's rivers for their resident fish, wildlife, natural and cultural features, and recreation values,<br />

as well as existing institutional constraints.<br />

<strong>Response</strong><br />

These references were consulted.<br />

Comment<br />

If and when geo-thermo is developed near Crater Lake, Oregon, I believe it would be a travesty. Stop<br />

this action now!<br />

<strong>Response</strong><br />

We do not know if a geothermal resource will be developed near Crater Lake, Oregon. To our knowledge,<br />

a developable geothermal resource has not been discovered. Before any geothermal development can<br />

be developed on National Forest System lands, an environmental analysis as required by the National<br />

Environmental Policy Act must be conducted. During this process, the concerns of the public and all<br />

who participate in the process must be considered.<br />

K - 28

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Comment<br />

Save Crater Lake from any more drilling and cap the holes or wells or restore to former conditions Let<br />

us not encourage a few well-drillers under the monetary guise of development destroy our beautiful<br />

landscape.<br />

<strong>Response</strong><br />

The drilling that has been conducted is a valid use of National Forest System Lands. All proposed<br />

drilling activities must have an environmental analysis conducted to determine the effects on the<br />

environment by the specific activity being proposed. Decisions to allow or not to allow geothermal<br />

activities, including effects on Crater Lake, will be based on Site Specific environmental analysis.<br />

Comment<br />

One of the 7 Wonders of the World 'Crater Lake Parks is at present being threatened by drilling<br />

(geothermal) and I feel that presents a hazard to the water quality and natural environment of that<br />

lake. This is a monetary and natural resource that has inestimable value to our State and Nation and<br />

'no way' should this drilling be allowed. There is no sense to it and only shows the greed of the California<br />

enterprise that is promoting this project.<br />

<strong>Response</strong><br />

The drilling that has been conducted was approved after going through an environmental analysis as<br />

required by the National Environmental Policy Act. There has been no evidence that 'Crater Lake Park'<br />

is at present being threatened by drilling. The Geothermal Steam Act of 1970 authorizes the use of<br />

National Forest System lands for this activity.<br />

Comment<br />

The extensive dead lodgepole pine presents another energy opportunity on the Winema. The Winema<br />

has an abundance of beetle-kill pine. This material is available as fuel, fiber or both. This pine and<br />

residues resulting from timber harvesting include biomass energy resources. In response to the need<br />

to reduce slash burning and woodstove use, an environmentally acceptable use of these resources as<br />

fuel (and fiber) should be considered under whichever alternative is adopted.<br />

<strong>Response</strong><br />

The Winema National Forest has an ongoing program to find or develop markets for its beetle killed<br />

pine and residues resulting from timber harvesting. Our contracts for this material do not specify its<br />

end use; however, most of the dead lodgepole is utilized as chips for pulp or firewood for residential<br />

heat. The Winema Forest has increased its sales of this material ten-fold since 1984. Our efforts to<br />

develop markets for logging residues have not been successful. Facilities which could utilize this material<br />

for fuel within the Winema's zone of influence or market area are able to get less expensive fuel. We<br />

continue to receive proposals from the private sector for the utilization of logging residues. However,<br />

so far, none of these proposals have proved to be economically feasible. We are very much interested<br />

in finding alternatives to burning logging residues on site. We will continue to seek these alternatives<br />

as the planning process continues.<br />

Comment<br />

With regard to resource values, some of the estimates seem to be in error. On page 3-16, leasable<br />

geothermal energy is rated as moderate. In light of temperatures and regional geothermal modeling<br />

we believe that a rating of high is more appropriate. In Table F-3 (page -F-1 1) some areas designated<br />

as having low locatable mineral resource potential could be upgraded to moderate where diatomaceous<br />

earth, mercury and gold epithermalization are being actively explored.<br />

<strong>Response</strong><br />

The geothermal moderate rating was made by the U.S. Geological Survey based on classification criteria<br />

contained in Geological Survey Circular 647. The moderate rating willl continue to be used until the<br />

Geological Survey assigns a different rating. Even though higher than ambient temperatures have<br />

been recorded in one of the drill holes, it has not been demonstrated that a geothermal resource exists.<br />

K -29

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While it may be true that some areas of low locatable mineral potential could be upgraded to a higher<br />

rating, we do not have the information to justify more than a low potential rating. To our knowledge the<br />

only locatable mineral activity being performed is the annual assessment work on the mining claims.<br />

We know of no localized study or survey that would give us the information to assign higher ratings.<br />

Comment<br />

We do have concerns regarding access for mineral exploration and development and regarding<br />

assumptions behind estimates of resource values. With regard to access we note that approximately<br />

63% of Winema Forest is closed to locatable mineral entry. We note also on page 3017 that it is stated<br />

that mineral exploration activity can cause major surface disturbance. In judging the relative merits of<br />

various planning options we believe that consideration should be given to the fact that much of the<br />

Forest is already off limits.<br />

<strong>Response</strong><br />

The 63 percent of the Forest that is closed to locatable mineral entry consists of lands withdrawn from<br />

mineral entry, and lands that have acquired land status (former Klamath Indian Reservation lands).<br />

The acquired lands make up about 85 percent of the 63 percent and are available under the mineral<br />

leasing laws.<br />

Comment<br />

Plan provides little analysis of possible impacts of gold mining or geothermal development, both adjacent<br />

to Crater Lake National Park. Adoption of Preferred Alternative would maintain current level of use for<br />

domestic grazing on the Winema.<br />

<strong>Response</strong><br />

The Plan is an umbrella document for mineral activities and identifies the areas of the Forest that are<br />

available for mineral activities, subject to the Standard and Guidelines. The Plan is not intended to<br />

cover specific proposals. Specific proposals will be covered in a site specific environmental analysis.<br />

Comment<br />

The Winema has an abundance of beetle-kill pine. This material is available as fuel, fiber or both. This<br />

pine and residues resulting from timber harvesting include biomass energy resources. The standards<br />

cited in the proposed plan refer to these resources under Minerals, Energy, and Geology Forestwide<br />

Standards and Guidelines Nos. 8 and 9. It is suggested that in response to the need to reduce slash<br />

burning, environmentally acceptable use of these resources as fuel (and fiber) will be considered under<br />

whichever alternative is adopted.<br />

<strong>Response</strong><br />

We are very much interested in reducing the slash burning and finding environmentally acceptable<br />

means of utilizing the material normally burned. This would be pursued in the final selected alternative.<br />

Comment<br />

The impact of the various alternatives on potential production are adequately displayed already in the<br />

analyses of the draft environmental impact statement. This is a constructive step in the direction of<br />

equitable resource judgments and the Forest Service is to be commended for their efforts in this plan<br />

in this area. Primary state interest is on economic impact, however. We would ask that the Forest Service<br />

place more attention on quantitative measures of economic impact, even though displays and tabulations<br />

of impact by area are commendable. The economic efficiency analysis does not factor mineral resource<br />

values into the interpretations. From an economic standpoint this is particularly troublesome, because<br />

the open acre value of land for mining greatly exceeds per acre value for other uses.<br />

<strong>Response</strong><br />

The reason that the economic efficiency analysis does not factor mineral resource values is that we do<br />

not know what mineral values, other than common variety minerals, are located on the Forest. Historically,<br />

K - 30

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other than common variety, there has not been any known removal of mineral resources from the Forest,<br />

and we feel that it would be inappropriate to conduct an economic analysis without sound data.<br />

Comment<br />

The Governor recently asked Interior Secretary Hodel to limit further drilling wareas removed as far as<br />

possible from the Park.' He also urged the Secretary to cease further leasing in the vicinity of the Park.<br />

A copy of the Governor's letter is attached.<br />

Senator Hatfield recently introduced legislation which the Senate Energy Committee has adopted,<br />

designating Crater Lake as having significant thermal features. This underscores the sensitive nature<br />

of this area. Accordingly, the U.S. Forest Service should direct BLM to prohibit further geothermal activity<br />

aimed at establishing an industrial power plant on those lands adjacent to Crater Lake National Park.<br />

<strong>Response</strong><br />

Crater Lake National Park was added to the list of 'significant thermal features within units of the National<br />

Park System' through passage of the Geothermal Stream Act Amendments of 1988. The FEIS will be<br />

revised by adding a discussion relating to the new law.<br />

Comment<br />

Mining has been limited in the past to cinder and gravel removal. Recently, some mining claims have<br />

been filed for pumice on the supposition that they might contain recoverable amounts of gold. Claims<br />

have also been filed for geothermal exploration. More information and analysis should be provided on<br />

the possible impacts of gold mining or geothermal development especially since some of this activity<br />

may take place adjacent to Crater Lake National Park.<br />

<strong>Response</strong><br />

Any mineral activities proposed will be evaluated through an environmental analysis, including possible<br />

impacts to Crater Lake National Park, as the proposals are submitted to the Forest.<br />

Comment<br />

The extensive dead lodgepole pine presents another energy opportunity on the Winema The Winema<br />

has an abundance of beetle-kill pine. This material is available as fuel, fiber or both. This pine and<br />

residues resulting from timber harvesting include biomass energy resources. In response to the need<br />

to reduce slash burning and woodstove use, an environmentally acceptable use of these resources as<br />

fuel (and fiber) should be considered under whichever alternative is adopted.<br />

<strong>Response</strong><br />

The Winema National Forest has an ongoing program to find or develop markets<br />

for its beetle killed pine and residues resulting from timber harvesting. Our<br />

contracts for this material do not specify its end use; however, most of the<br />

dead lodgepole is utilized as chips for pulp or firewood for residential heat.<br />

The Winema Forest has increased its sales of this material ten-fold since 1984.<br />

Our efforts to develop markets for logging residues have not been successful.<br />

Facilities which could utilize this material for fuel within the Winema's zone<br />

of influence or market area are able to get less expensive fuel. We continue to<br />

receive proposals from the private sector for the utilization of logging<br />

residues. However, so far, none of these proposals have proved to be<br />

economically feasible. We are very much interested in finding alternatives to<br />

burning logging residues on site. We will continue to seek these alternatives<br />

as the planning process continues.<br />

Comment<br />

In terms of energy resources, geothermal energy is obviously the most promising on the Forest. DOGAMI<br />

rates the geothermal energy resource value on the Forest as high (see DOGAMI comments at page<br />

2). The main area of interest in leasing on the Forest seems to be adjacent to Crater Lake National<br />

K - 31

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Park. We are concerned about how this leased area is treated in the DEIS and LRMP. There does not<br />

appear to be any variation in the alternatives in the area available for leasable mineral development. I<br />

recently asked Interior Secretary Hodel to limit further drilling to 'areas removed as far as possible<br />

from the Park." I also urged the Secretary to cease further leasing in the vicinity of the Park. A copy of<br />

my letter is attached to the Department of Energy comments.<br />

<strong>Response</strong><br />

Approximately 91 percent of the Forest is identified as being available for geothermal exploration including<br />

the area adjacent to Crater Lake National Park. The recent amendment to the Geothermal Steam Act<br />

of 1970 requires the Secretary of Agriculture to consider the effects on significant thermal features of<br />

Crater Lake National Park in determining whether to consent to leasing. The same amendment requires<br />

the Secretary of the Interior to include stipulations in existing leases to protect the significant thermal<br />

features of the Park. The stipulations can require the lease holder to suspend activity on the lease until<br />

such time a significant adverse effect is eliminated. The stipulation shall provide for the Termination of<br />

the lease by the Secretary of the Interior if the significant adverse effect cannot be eliminated within a<br />

reasonable period of time.<br />

Comment<br />

The Department of Geology and Mineral Industries (DOGAMI) is concerned, however, by the extensive<br />

restrictions on locatable mineral entry. These withdrawals should be reviewed to determine whether<br />

mineral entry truly is incompatible with other uses. If the high percentage of withdrawn lands is attributable<br />

to the former Klamath reservation status, that should be explained.<br />

<strong>Response</strong><br />

The current withdrawals are being reviewed to determine whether the withdrawals should be continued,<br />

modified or revoked. The majority of the acreage withdrawn protects the wilderness areas, and Lake of<br />

the Woods, Fourmile Lake, Miller Lake, and Recreation Creek recreation areas. The withdrawals protecting<br />

these areas will remain. Approximately 85 percent of the area on the Forest closed to locatable mineral<br />

entry is the former Klamath Indian Reservation Land. The former reservation land is not subject to<br />

location and entry under the 1872 Mining Laws, however, the mineral resources are available under<br />

the mineral leasing laws.<br />

Comment<br />

However, the detailed descriptions of how you developed altematives, performed economic analyses,<br />

and set guidelines for the different management areas do not appear to adequately account for geothermal<br />

energy's potential as a forest resource.<br />

<strong>Response</strong><br />

The geothermal energy potential on the Forest was identified by the U.S. Geological Survey. The moderate<br />

rating will be used until such time as the Survey revises the rating. We recognize that the potential for<br />

geothermal resources exists. We feel that the alternatives and management area standards and guidelines<br />

adequately allow for geothermal developments should a resource be discovered.<br />

Comment<br />

Comments on Alternative D. If the goal of this alternative is to provide actual cash returns to the Federal<br />

Treasury, all nonmandated uses which limit geothermal development should be eliminated from<br />

consideration. On page 11-135, the document states that the timber program produces the highest<br />

economic benefit, followed by recreation. We are confident that inclusion of geothermal development<br />

in your economic analysis would reveal that it would produce the highest benefit - and at the lowest<br />

environmental cost. In addition, geothermal development is largely compatible with many other uses,<br />

including but not limited to timber harvest, recreation, and firewood collection.<br />

K - 32

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<strong>Response</strong><br />

The reason for not including geothermal development in the economic analysis is that we do not know<br />

if there is a recoverable geothermal resource. We feel that it would be inappropriate to conduct an<br />

economic analysis without sound data.<br />

Comment<br />

Page B-90 of Appendix B states, 'There are no mineral leases on the forest and no future potential has<br />

been positively identified. Therefore, no value is placed on mineral or energy potential on the forest.'<br />

Clearly, these statements are erroneous and an economic analysis should be included.<br />

<strong>Response</strong><br />

This statement is in error and has been removed.<br />

Comment<br />

Geothermal. Another point of concern is the PLRMP's approach to the geothermal issue as it relates to<br />

Crater Lake NP. Research by Oregon State University scientists, Drs. Dymond, Collier and Lupton<br />

should be referenced. The plan should also include the information that Crater Lake is being considered<br />

for listing as a Significant Thermal Feature, and that such designation would provide additional legislation<br />

to ensure its protection and preservation. Geothermal resources activities are a part of Forest management<br />

and geothermal exploration in the Winema is an extremely controversial issue. Although an environmental<br />

assessment on a geothermal exploration project was prepared by the Bureau of Land Management<br />

(BLM) in 1987, the decision to issue a modified permit is under appeal. The FEIS/PLRMP should discuss<br />

the most current status of geothermal exploration and development in Winema NF.<br />

<strong>Response</strong><br />

The FEIS has been revised to include a discussion of the research of Crater Lake, the Geothermal<br />

Steam Act Amendments of 1988, which designated Crater Lake National Park as a significant thermal<br />

feature, and the most current status of the geothermal activities within the Winema National Forest.<br />

Comment<br />

Page 111-10, Minerals and Energy. The final document should list and address any major mining or<br />

geothermal activities that are proposed or now operating on Forest lands. Information needs to be<br />

updated and reflect plans and consultation with other agencies.<br />

<strong>Response</strong><br />

The major mining or geothermal activities that are proposed or now operating on the Forest has been<br />

discussed in the FEIS.<br />

Comment<br />

Page D-21, number 2. The final document should list and address any major mining or geothermal<br />

activities that are proposed or now operating on Forest Lands.<br />

<strong>Response</strong><br />

Appendix D lists the Standard and Guidelines for each management area and is not the appropriate<br />

place to discuss the minerals activities that are proposed or now operating on Forest lands. These<br />

activities have been discussed in the FEIS.<br />

K - 33

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Mountain Pine Beetle<br />

Comment<br />

With regard to the pine beetle infestation problem, it would appear advisable at least to limit harvest to<br />

trees already dead, and to a narrow buffer zone around infected areas.<br />

<strong>Response</strong><br />

The epidemic levels of mortality in the lodgepole pine are expected to continue until all the larger trees<br />

are dead. Our entomologists expect all the lodgepole pine larger than seven inches DBH to die within<br />

20 years. Many people feel it is very inefficient to harvest a few dead trees this year and then to return<br />

in five years to harvest the next portion of dead trees. Other people are concerned that as the stand<br />

dies little by little, the stand becomes under stocked and no longer grows at its potential until it is<br />

regenerated. These people would rather regenerate the stand at the first entry. The answer to the<br />

problem is a mix of both dead only and regeneration cuttings. The Forest will concentrate on salvage<br />

harvest of the dead lodgepole pine in the first decade and then move more into regeneration cutting<br />

in the second decade. This will optimize the return from the lodgepole pine working group.<br />

Comment<br />

Building roads and intensive logging to counter the Pine Bark Beetle appear self defeating. It looks like<br />

you are actually spreading the insect beyond its normal capabilities. The trees are felled, cut into sections<br />

then transported on open trucks. Bark and wood end up scattered everywhere. Two weeks later the<br />

same truck, perhaps unwashed, goes to a different area altogether. Whatever happened to fire as a<br />

management tool? It is true that Beetles won't infest a clear cut yet, over the long-term they may really<br />

thrive in some the planned even-aged timber stands.<br />

<strong>Response</strong><br />

Mountain pine beetle is a native species which is always present in pine forests. The beetle lives on<br />

trees which are stressed and growing slow. When large areas of pine trees become old or suppressed,<br />

the beetle then has the advantage and an epidemic occurs. Moving beetles around in loaded log trucks<br />

does not spread the insect because it is already in the trees, but at a very low population level. People<br />

can cause ornamental pine tree to be attached and killed by bringing the beetle into town in a load of<br />

wood. Ornamental trees are often under stress and susceptible to attack. The effects of the alternatives<br />

on Forest Pests in the DEIS and FEIS speak to how each alternative will prevent or enhance future<br />

outbreaks.<br />

Comment<br />

The plan states 87,000 acres of Lodgepole pine will be harvested in the first decade. I feel this is misleading.<br />

It indicates that these are pure stands of Lodgepole pine. Current salvage harvesting at Chemult District<br />

has included multiple board feet of Ponderosa pine as well as Lodgepole. I feel the plan should be<br />

clear about all species that are salvaged because of the mountain pine beetle.<br />

I am also confused about the amount of acres that have already been salvage harvested at Chemult.<br />

Are they included in this 87,000 acre figure?<br />

<strong>Response</strong><br />

The plan refers to the acres of the Lodgepole pine working group that will be harvested in the first<br />

decade. The mature, single story Lodgepole pine working group is 17% Ponderosa pine. This Ponderosa<br />

pine is suffering high mortality and is also being harvested along with the Lodgepole pine.<br />

The data base was updated to the end of FY 88. The harvest acres in the plan would be the harvest<br />

from that time.<br />

In 1981, 193,140 acres of mature lodgepole pine was inventoried. By the end of fiscal years 1988, the<br />

number of acres of mature lodgepole pine had dropped to 156,180 acres. The difference of 36,960<br />

acres was harvested during that period of time. Since the data base for the FORPLAN model was<br />

updated in September 1988, the Forest Plan shows the amount to harvest during the plan period.<br />

K - 34

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Comment<br />

Why log economically-losing lodgepole pine just to keep the pine beetle from eating them?<br />

<strong>Response</strong><br />

Two basic reasons are given to justify harvesting the dead lodgepole pine:<br />

1. Future management costs will be lowered by preventing large uncontrollable fires.<br />

2. Many people feel it is morally wrong to waste, a resource. If the trees are harvested green, they<br />

can be milled into lumber and this provides many jobs.<br />

3. At the moment these sales are not losing money.<br />

Comment<br />

My understanding is that the draft proposal would severely restrict the harvest of Ponderosa pine in<br />

the upcoming period because of total proposed cut and the need to deal with the pine beetle infestation<br />

in the lodgepole pine stands.<br />

<strong>Response</strong><br />

The Local Timber Supply and Demand Section of the DEIS and FEIS shows the harvest rate of ponderosa<br />

pine timber during the last ten years. The draft plan would have harvested ponderosa pine at a rate<br />

30% greater than the 10 year average harvest. During the last five years, the harvest of ponderosa<br />

pine has averaged 106 MMBF per year. That is almost 20 percent greater than the harvest planned in<br />

the draft.<br />

The harvest of ponderosa pine was not tied to the harvest of lodgepole pine. The ponderosa pine<br />

harvest was constrained to stay within 20% of the historic 10 year average harvest of ponderosa pine<br />

of 63.5 MMBF.<br />

In the Forest Plan, ponderosa pine harvest was maintained at the highest level possible while meeting<br />

other resource needs and applying uneven-aged management techniques.<br />

Comment<br />

Page 11-102, Table 11-3B. Under outputs/effects on timber resource, it says, 'Forest's response to pine<br />

beetle infestation - future stands not managed to minimize risk of future epidemics." It is difficult to<br />

understand why not! The tremendous problems the Forest faces today in LP management were set up<br />

because managers of the past said the same thing: PI don't want to deal with it.' What is the reasoning?<br />

Why are we so willing to let the problems continue to manage us? Are we allowed to forego our<br />

responsibility as Forest land managers by neglecting our lodgepole Forest, except to react in a beetle<br />

epidemic?<br />

<strong>Response</strong><br />

The lodgepole pine is a small tree that is expensive to log, and in old mills designed to cut mature<br />

ponderosa pine, was very expensive to cut into products. Timber industry simply would not buy large<br />

quantities of small lodgepole pine logs.<br />

During the last ten years, this situation has changed. Mechanized logging and saw mills designed<br />

specifically to mill small logs has made it possible to profitably harvest lodgepole pine. We can now<br />

sell the lodgepole pine, but only at a fraction of the value of large logs. This low value makes it so it<br />

isn't reasonable to make very large investments in lodgepole pine management. But with technology<br />

already available to handle small logs, the harvest of future lodgepole pine stands will be scheduled to<br />

minimize loses. Harvests can start well in advance of the time of expected mortality.<br />

Comment<br />

Harvest the ones that are very badly infested and spray the rest. There is no need to harvest those<br />

that can be 'cured.' If you don't spray now, everything will be infested.<br />

<strong>Response</strong><br />

There is no pesticide with a label for general treatment of the mountain pine beetle. Carbaryl is labeled<br />

for basal treatment of individual trees but it would not be practical for an entire Forest.<br />

The only reasonable treatment for mountain pine beetle is to keep the Forest healthy and growing fast.<br />

K - 35

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Comment<br />

A final comment with regard to the lodgepole pine/bark beetle dilemma is that the Forest Plan is quite<br />

short-sighted in attacking this problem. The preferred alternative does not attempt to control future<br />

outbreaks of the pest through stand improvement techniques that are included in other alternatives. It<br />

would be far better stewardship of the Forest to put more energies into the long term health of lodgepole<br />

pine stands at the slight cost of not being able to harvest all of the present beetle kill while it is still<br />

merchantable.<br />

<strong>Response</strong><br />

The section in Chapter IV of the DEIS and FEIS on Effects of the Alternatives on Forest Pests, Insects,<br />

analyzes how well each alternative prevents future mountain pine mortality in lodgepole pine.<br />

While only 22% of the lodgepole pine working groups receives full stocking level, all but 22% receives<br />

some stocking level control. This level of stocking level control will not prevent all loses to mountain<br />

pine beetle, but under managed conditions where demand exists for this material, we would not expect<br />

the epidemic to be as severe as we now experience. Harvest will start before widespread mortality<br />

exists and that should keep future mountain pine beetle loses proportional to the values at risk.<br />

Comment<br />

Most of the Ponderosa pine is beetle infested now. It should be cut while it is still green.<br />

<strong>Response</strong><br />

The mountain pine beetle is a native insect. It exists in all pine stands at very low population levels as<br />

long as the stand is healthy and vigorous. Most of the ponderosa pine stands on the Winema are<br />

healthy and vigorous so we would not expect an epidemic of mountain pine beetle in the ponderosa<br />

pine stands as now is occurring in the lodgepole pine.<br />

The Winema is experiencing high mortality in ponderosa pine, which is intermingled with large areas of<br />

lodgepole pine. The Forest has been selling the most susceptible stands of ponderosa pine to minimize<br />

loses and that practice will continue as needed.<br />

Comment<br />

I understand you are looking for a way to control the mountain pine bark beetle which presently infests<br />

overcrowded lodgepole stands. I personally have no suggestion. But, I recently met several entomologists<br />

from U.C. Berkeley who specifically study bark beetles. Perhaps if you contacted the University, they<br />

could be of some assistance.<br />

<strong>Response</strong><br />

The Winema works closely with the Forest Service, State and Private Forestry units, which provide<br />

entomologists for our area. They work closely with Forest Service Research entomologists and<br />

entomologists from colleges and universities.<br />

Comment<br />

I would like more informational yignage - to explain the lodgepole pine infestation and consequently<br />

the harvesting and clearing of infected trees. Please coordinate with Deschutes National Forest.<br />

<strong>Response</strong><br />

The Forest has not developed a plan for informational signing for the mountain pine beetle situation.<br />

This will be given additional consideration.<br />

Comment<br />

It would also be well to heed nature's warning - Paul Keen has said that immature Ponderosa pine is<br />

also susceptible to attack by the Mountain Pine Beetle. There is this hazard in pure, even-age Ponderosa<br />

pine management regeneration. In the past, in the selection Ponderosa pine forest, the Western Pine<br />

Beetles and their potential onslaught have formulated silvicultural practices - and, they may continue<br />

to do so!<br />

K - 36

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<strong>Response</strong><br />

Mountain pine beetle kills trees when the stands become overstocked and the growth rate on trees<br />

over seven inches in diameter drops to a level that the tree is no longer healthy enough to fend off the<br />

attack. This is not dependent on the silvicultural system being used but from the lack of stocking level<br />

control in either system. Overstocked and over mature pine stands are very susceptible to insect mortality.<br />

See Chapter IV, DEIS and FEIS, Effects of the Alternatives on Forest Pests for additional information<br />

Comment<br />

Your outbreak of Mountain Pine Beetle is unfortunate, but these things tend to be cyclic, and I hope<br />

that you will not be using any organo-phosphates or chlorinated hydrocarbon insecticide to control<br />

them. Are there any biological controls?<br />

<strong>Response</strong><br />

No insecticides are planned to be used on the mountain pine beetle. The only pesticide available must<br />

be used as a trunk spray and it simply isn't feasible to spray each tree trunk in a forest.<br />

There are no biological controls available, but silvicultural practices that keep the Forest vigorous are<br />

very effective preventing mortality from mountain pine beetle. See Chapter IV, DEIS and FEIS, Effects<br />

of the Alternatives on Forest Pests for additional information.<br />

Comment<br />

The problem comes when we see that this good site being nonproductive. Let's put this area and<br />

others like it back into production - the sooner the better. We realize that some of this area is being<br />

brought back into production but let's finish the job once and for all. In its present state, the only value<br />

here is for wildlife habitat. Yet, in a few years, this habitat will begin to deteriorate when the snags<br />

begin to fall to the ground. Not only will the wildlife habitat be lost but a new crop of trees won't be<br />

established and a high fire hazard will be created. Heaven forbid, but if a fire should ever get into a<br />

dense area of dead material like that at Sellers Marsh, it would burn so hot and move so fast through<br />

the area that it would more than likely destroy the already managed smaller areas as well as get into<br />

the higher value ponderosa pine stand types - and then where will we be?<br />

<strong>Response</strong><br />

It is important to keep the Forest productive for timber, but it is also important to maintain the Forest's<br />

productivity for other resources. The Forest Plan is to harvest the dead and dying lodgepole pine as<br />

quickly as possible, while maintaining wildlife habitat at an acceptable level. There is definitely a trade-off<br />

of some timber production potential to maintain an acceptable level of wildlife habitat, but on the other<br />

hand the wildlife habitat is also not being managed at an optimum level. The Forest Plan is designed<br />

to be an acceptable compromise between the two competing resources.<br />

A large fire is a definite possibility. The Forest Plan has been designed to salvage as much of the dead<br />

lodgepole pine as possible in the plan period to minimize this risk and to salvage as much of the value<br />

as possible.<br />

Comment<br />

The prescription would include leaving 2 dead snags per acre, removing the rest of the dead material<br />

and site preparation for artificial regeneration of genetically superior lodgepole pine. The advantages<br />

to our prescription are: (1) puts high site areas back into production quickly; (2) enhances wildlife<br />

habitat in the long term; (3) alleviates a very high fire hazard; and (4) most cost effective.<br />

<strong>Response</strong><br />

We agree with your concept of regenerating the dead lodgepole pine as quickly as possible and enhancing<br />

long term wildlife habitat while being cost effective.<br />

Comment<br />

The DEIS states that Alternative E is the only alternative that harvests sufficient lodgepole pine in the<br />

first decade to minimize the risk of timber losses to the mountain pine beetle, however it also states<br />

K -37

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that .'..Alternatives B and C are the only alternatives with sufficient stocking level control in lodgepole<br />

pine to prevent future timber losses from mountain pine beetle mortality." (page IV-37). More detail<br />

should be provided on how the current mountain pine beetle epidemic will be addressed by the different<br />

alternatives and how the different management applications will prevent or promote future outbreaks of<br />

this insect, as well as other insects, diseases and parasitic plants associated with the forest.<br />

<strong>Response</strong><br />

This section on Effects of the Alternatives on Forest Pests was rewritten as you suggested.<br />

Comment<br />

The Winema should provide additional information in the final EIS to demonstrate that the timber yield<br />

tables utilized in FORPLAN have adequately addressed the effect of both current and potential future<br />

insect damage on timber inventory, growth, and mortality throughout the planning horizon.<br />

<strong>Response</strong><br />

Adjustments to the yield tables are presented in Yield Table Adjustment for FORPLAN in Managed<br />

Yield Tables for Land and Resource Management Planning on the Winema National Forest, Volume 1,<br />

pages 8 and 9, and in Uneven-aged Managed Yield Tables for Land and Resource Management Planning<br />

on the Winema National Forest, pages 4 through 8. The entire Yield Table process is described in<br />

Timber Yield Tables, in Appendix B.<br />

The timber inventory process and empirical yield table generator measures the current growth and<br />

mortality and then projects the current standing inventory into future. This process adjusts future yields<br />

of existing stands for insects, disease, and operational fall downs. The lodgepole pine mortality was<br />

redetermined in 1988, and the lodgepole pine empirical yields were revised based on the actual measured<br />

mortality.<br />

The uneven-aged management yield tables were originally stand table projections. These yield tables<br />

were recalculated during 1988, using the Southern Oregon Northern California version of the PROGNOSIS<br />

model. This model was calibrated to the Winema National Forest using forest inventory data and local<br />

research data.<br />

K - 38

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Mule Deer/Big Game<br />

Comment<br />

Adequate protection of deer and elk habitat must be assured. Wildlife biologists, including Forest Service<br />

Staff biologists, estimate that this would require preservation of 40% of these animal's ranges, as well<br />

as reducing the road density in their ranges. The current road densities are already too high at 3-->4<br />

miles per square mile vs. the 1.5->2 mile figure given by wildlife biologists as required.<br />

<strong>Response</strong><br />

The standards and guidelines in Chapter 4 of the Forest Plan are designed to maintain habitat<br />

effectiveness for deer summer range and improve habitat on deer winter range.<br />

Comment<br />

Is it really true that there are more deer than ever before in the history in Winema Forest?<br />

<strong>Response</strong><br />

To answer this question, one must qualify what period or how far back in history you are referencing.<br />

Early historical accounts of explorers and settlers in the early 19th century indicate low populations<br />

throughout the West, with increases and drops documented through the 1930's. In the mid-1 950's to<br />

early 1960's populations throughout the West were phenomenally high including the area encompassing<br />

the Winema. Those levels were too high for ranges to sustain and much key range was damaged and<br />

populations crashed. Most populations have returned to levels the present habitat can support.<br />

The Oregon Department of Fish and Wildlife (ODFW) has set Management Objectives (MO) for numbers<br />

of deer on various ranges. Statistics from the ODFW indicate that populations on game management<br />

units of which the Winema N.F is part ranges from 36 to 104 percent of MO. The ODFW management<br />

objectives for game management units of which the Forest is part are summarized in Chapter 3 of the<br />

FEIS.<br />

Comment<br />

I feel that if deer habitat is the most important consideration on former reservation lands, that the National<br />

Forest should enter into cooperative land management plans with adjacent landowners, especially<br />

where winter range is the primary limiting factor. These plans should be designed to promote and<br />

establish quality deer winter range. Furthermore, I feel the National Forest should conduct track counts<br />

with the Klamath Tribe and ODFW to establish its own base for deer population status and trends, and<br />

design management plans to reverse the present downward trend. This is not discussed in the plan.<br />

<strong>Response</strong><br />

Guidelines specific for the deer winter range are designed to improve winter habitat. Mule deer habitat,<br />

population, and habitat relationships are addressed as monitoring needs. The Forest proposes to be a<br />

cooperator in studies that will clearly define the causes for mule deer decline in this area.<br />

Comment<br />

I feel that the Forest should put pressure on the State Fish and Game to restrict hunts in the Klamath<br />

and Sprague Units, and help establish quality hunting instead of the present volume hunting that is<br />

taking place. Also, I feel that the Forest should put pressure on the Klamath Tribe to enforce its game<br />

laws and to restrict the number of deer it allows its members to harvest.<br />

<strong>Response</strong><br />

The Winema N.F. provides input to the ODFW process to determine deer harvest. The deer harvest is<br />

set by the Oregon Game Commission using recommendations of ODFW biologists and the input provided<br />

by other agencies and private individuals. The Klamath Tribe also coordinates deer harvest with ODFW<br />

and ODFW hunting is designed with tribal needs in mind.<br />

K - 39

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Comment<br />

Also, I feel that along with this a more active and visible law enforcement program between the Forest<br />

and the other concerned agencies should be taken. This issue is addressed but no action plan is<br />

made part of the forest plan that I can see. The apparent attitude is it's someone else's problem let<br />

them deal with it, I $on't feel that this attitude should be allowed to continue, and the Forest should<br />

take some steps that say I do care and I am going to do something about it. The present rate of harvesting<br />

of deer, timber, lack of law enforcement, and the removal of quality deer winter range is going to eliminate<br />

a viable deer population, and more fingers are going to be pointed at the Forest Service because of<br />

its lack of management, and potential legal actions will become even more of a reality.<br />

<strong>Response</strong><br />

Game violations are the jurisdiction of the ODFW and Oregon State Police. The Forest cooperates with<br />

the state by reporting any violations. The deer harvest is the jurisdiction of ODFW. The Forest has no<br />

jurisdiction over land uses on winter range outside the Forest boundary.<br />

Comment<br />

I feel that the Forest needs to beef up its staffing in the Wildlife, and this should include people with a<br />

range background that understand the importance of the forage component and the necessary<br />

management to keep the forage component in a state that provides quality forage for deer, elk, and<br />

antelope. Effective control on existing hunting pressure would eliminate the need to maintain expansive<br />

cover components and would eliminate the need to mitigate other agencies lack of enforcement of<br />

their game laws and regulations.<br />

<strong>Response</strong><br />

The Forest currently has seven Wildlife Biologists on staff at the Districts and Supervisor's Office. Some<br />

of these biologists are responsible for the range program on the Districts and the Forest and do understand<br />

the importance of the forage component.<br />

Comment<br />

The plan fails to consider necessary cover/forage ratio for mule deer or elk and dispersion standards<br />

in scheduling timber harvests in the first decade. These standards must be considered and the harvest<br />

rescheduled in the final plan. This is a particular concern on former reservation lands, but it appears to<br />

be a failing of the plan forestwide.<br />

<strong>Response</strong><br />

Forest-wide standards and guidelines for deer and elk habitat provide for a minimum of 30 percent of<br />

its area in cover distributed throughout its area. The standard and guideline for big game winter range<br />

requires a minimum of 30 percent cover with an objective of 50 percent cover. These requirements do<br />

not appear to constrain timber harvest in any decade.<br />

Comment<br />

The plan and DEIS project no variation in mule deer population among the alternatives, nor any change<br />

in population over time within any alternative. The explanation given for this assertion is that the population<br />

is dependent on off-forest winter range unaffected by forest management. The Tribe strongly questions<br />

the validity of this explanation. Even if the dependence on winter range were correct, the alternatives<br />

vary as to the amount of land managed as winter range. According to the Forest Service theory this<br />

should result in population changes, but none is shown.<br />

The Tribe asserts that other factors are at least as important as winter range in determining herd<br />

populations: quality and quantity of forage on summer ranges; fawning habitat; disturbance on migration<br />

routes; and the loss of winter range. The Forest must manage its lands for each of these factors. The<br />

forest plan should also provide protection for transition ranges, used instead of true winter range areas<br />

in mild winters.<br />

K - 40

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<strong>Response</strong><br />

We agree that other factors than just forage or just winter range have effects on mule deer population.<br />

We have recalculated populations based on the concepts of the Mule Deer Model. The Forest-wide<br />

standards and guidelines indicate that the Forest will manage its lands for forage quantity and quality<br />

to maintain at least the current number of deer on summer range. Migration routes have not been<br />

identified for which disturbance can be mitigated. The Forest will manage overall habitat capability<br />

including open roads density which contributes to disturbance to maintain at least current populations<br />

on summer range, and to improve on winter range. No losses of winter range acres are projected to<br />

occur on the Forest. Forest standards and guidelines require an increase of habitat capability on identified<br />

winter ranges. The Forest is managing for summer range and winter range conditions, not specifically<br />

for transition range.<br />

Comment<br />

Deer populations and habitat are issues of vital importance to the Tribe. Too many timber sales have<br />

been appealed in large part because of inadequate consideration of deer and tribal rights. The Forest<br />

Service must begin to recognize the gravity of the situation and the serious nature of the Tribes concern<br />

and its own responsibility to the Tribe.<br />

<strong>Response</strong><br />

The Forest recognizes its mandated responsibility per the Consent Decree with the Klamath Tribe to<br />

provide for subsistence hunting opportunity for deer.<br />

Comment<br />

The planned departure in the lodgepole working group on the Chiloquin district could have devastating<br />

effects on deer habitat. The discussion in the plan fails to acknowledge the need to protect fawning<br />

habitat, and to apply forage/cover ratios, and dispersion standards. It appears that the planned harvest<br />

volume far exceeds that which can physically be harvested if these resource needs and management<br />

standards are applied and natural regeneration of the stands is planned. These conflicts must be disclosed<br />

throughout the plan and planned harvests reduced to account for application of the standards and<br />

guidelines.<br />

<strong>Response</strong><br />

Management Area 8: Riparian Areas has been increased to include all riparian areas. Standards and<br />

guidelines for this management area have been modified to protect deer fawning habitat. Outside<br />

riparian areas, the emphasis in lodgepole pine will be to harvest the dead as quickly as possible while<br />

leaving green trees to provide some measure of cover. Forest-wide standards and guidelines allow<br />

short-term reductions of cover to 15 percent of an area if reductions below the 30 percent standard<br />

will provide long-term benefits for deer. This standard does not appear to constrain harvest projections<br />

in lodgepole pine.<br />

Comment<br />

The plan fails to disclose whether or not the Forest Service intends to manage for elk habitat. Past<br />

management activities, by design or default, have created elk forage at the expense of deer forage. If<br />

the Forest intends to manage for elk, it should develop standards and guidelines which adequately<br />

address the relationship between the deer and elk and disclose the effects on deer of managing for<br />

elk. Even if the Forest intends not to manage for elk, it must address their presence on the forest and<br />

their effect on deer populations and habitat. Abdication of responsibility by failing to address the issue<br />

is unacceptable.<br />

<strong>Response</strong><br />

The FEIS and Forest Plan have been altered to state that the Forest will not specifically manage for elk<br />

habitat except for currently identified calving areas (on the Klamath District) or calving areas as they<br />

are identified. Elk are recognized to occur on the Forest. Their effect on deer populations is not known.<br />

K - 41

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Comment<br />

The habitat management standards and guidelines should be related to and consistent with herd<br />

management objectives, while accounting for existing conditions. For example, if optimum cover/forage<br />

ratios are obtained and sustained in mule deer summer range, the Forest will need to provide additional<br />

winter ranges to support the level of deer that optimum summer range habitat can support. The road<br />

density standard equates with 90% habitat effectiveness, but the forage/cover ratio equates with 100%<br />

habitat effectiveness, if achieved. The plan needs to declare the Forest Service's intention to manage<br />

for a specific goal and use a consistent approach to reach it.<br />

<strong>Response</strong><br />

The Forest has identified the objective to maintain deer habitat in at least current condition on the<br />

summer range, and to improve deer habitat on the winter range. All factors such as cover/forage<br />

conditions, open roads, water distribution, etc. will be considered in evaluation of management activities.<br />

Comment<br />

The table on page 11-145 of the DEIS shows 0 acres managed for fawning habitat in the no change<br />

and no action alternatives. The Forest previously has agreed to the application of lodgepole standards<br />

and guidelines which provide for management for 5% of cover as fawning cover. This agreement should<br />

be reflected in this table.<br />

<strong>Response</strong><br />

This section of the EIS has been rewritten.<br />

Comment<br />

The plan fails to refer to the Interagency Technical Advisory Committee mule deer model. The model<br />

should be cited and used in the Forest's monitoring plan to determine the effects of the plan's<br />

implementation on mule deer populations and habitat. The plan should specify which model and version<br />

it cites.<br />

<strong>Response</strong><br />

The concepts and factors identified in the Interagency Technical Advisory Committee mule deer model<br />

are now identified as factors to be considered. The Forest will monitor the factors identified in the model<br />

to determine habitat condition for mule deer. The Forest does not agree that the TAC model provides<br />

an adequate projection of the interactions between habitat conditions and mule deer populations.<br />

Comment<br />

We are extremely concerned about your management objectives for mule deer. The Forest projects a<br />

mule deer output which is nearly 30 percent below the ODFW planning benchmark for the Forest; the<br />

same output (11,000 mule deer) is projected across all alternatives through all decades. This does not<br />

produce a sufficient range of alternatives, nor does it meet ODFW management goals. You should<br />

either document more completely why changes in habitat under the different alternatives have little or<br />

no impact on mule deer numbers or provide information on the benefits and costs of more nearly achieving<br />

the ODFW management goal for mule deer.<br />

<strong>Response</strong><br />

Estimates of deer populations have been redeveloped using the concepts of the TAC model. They<br />

now vary across the alternatives.<br />

Comment<br />

ODFW does not agree with your assumption that deer numbers are directly related to available forage<br />

production. The impacts of management activities such as timber, roads, and grazing should be part<br />

of the evaluation of impacts on mule deer populations. The forest should provide a measurable index<br />

of change expected in mule deer numbers, productivity, and survival. This index needs to reflect changes<br />

in habitat effectiveness that would result with the implementation of each alternative.<br />

K -42

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<strong>Response</strong><br />

The Forest recognizes that other factors such as cover, open roads, water distribution, livestock<br />

competition, cover and forage distribution and juxtaposition, predation, disease, tribal and sport hunting,<br />

poaching, winter range encroachment on private lands, and weather severity all influence deer<br />

populations. We have redeveloped our estimates of deer population using the concepts of the TAC<br />

model.<br />

Comment<br />

The evaluation of habitat effectiveness for deer and elk needs to be applied to an area smaller than<br />

the entire Forest, such as specific geographic subdivisions of the Forest that ODFW describes as<br />

permanent monitoring units.' According to ODFW, the Forest's monitoring effort, using a combination<br />

of analysis zones, analysis areas, TRI compartments, and management areas may meet this objective,<br />

but this needs to be demonstrated more completely.<br />

<strong>Response</strong><br />

Monitoring is described in Chapter 5 of the Forest Plan. Habitat effectiveness will be monitored on<br />

smaller areas.<br />

Comment<br />

ODFW is extremely concerned with the lack of acknowledgement to mule deer management objectives<br />

and elk benchmarks that were provided to the Forest in 1980 (see DEIS, Chapter 3 comments). The<br />

Forest projects a mule deer output which is nearly 30 percent below ODFW planning benchmark for<br />

the Forest; the same output (11,000 mule deer) is projected across all alternatives through all decades.<br />

The Forest's assumption that deer numbers are directly related to available forage production is not<br />

valid. The impacts of management activities such as timber, roads, and grazing needs to be part of<br />

the evaluation of consequences to mule deer populations. The Forest needs to provide a measurable<br />

index of change expected in mule deer numbers, productivity, and survival. This index needs to reflect<br />

changes in habitat effectiveness that would result with the implementation of each alternative.<br />

<strong>Response</strong><br />

We have rewritten much of the EIS and Forest Plan in consideration of your comments.<br />

Comment<br />

Elk are present on the Forest. Although no formal objectives are established, management direction is<br />

in place under ODFW regulations. Elk need to be included as a management indicator species. The<br />

elk habitat effectiveness model, which has greater sensitivity to cover and open-road density, must be<br />

used to evaluate elk habitat conditions. ODFW will provide the Forest with a map of areas recommended<br />

for elk/deer management emphasis.<br />

<strong>Response</strong><br />

Since this response, ODFW and the Forest Service are cooperating in an Elk Study in south-central<br />

Oregon to determine the population dynamics and distribution of elk in the area. Until the results of<br />

this study are evaluated the Forest will manage to protect elk calving areas currently identified and<br />

that may be identified through project area analysis.<br />

Comment<br />

The Forest's delineation of winter range agrees with that of ODFWs. The Forest needs to delineate the<br />

important transition range bordering the upper limits of winter range. Transition range in the fall has a<br />

significant bearing on big game body condition for winter survival. Management direction for transition<br />

range needs to support a diverse and thrifty shrub component intermixed with areas of cover.<br />

<strong>Response</strong><br />

The Forest decision has been to not delineate transition range.<br />

K -43

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Comment<br />

The conversion of 74.2 percent of mature lodgepole pine stands in two decades will have significant<br />

long term impacts on cover-forage ratios for big game, and habitat diversity for wildlife in general. The<br />

Management Standards for lodgepole pine.., September 1986' provides a basis to minimize impacts<br />

on wildlife. Dead lodgepole stands provide big game cover, although It is not of optimum quality, and<br />

provide feeding and nesting habitat for no-game wildlife. Proposed rapid liquidation of timber stands<br />

would have a significant effect on diversity of plant and animal species.<br />

<strong>Response</strong><br />

The Forest will harvest dead lodgepole as quickly as possible often leaving the green component for<br />

some level of cover. Minimum standards for cover to 15% of an area may be justified to provide long-term<br />

benefits for deer. Snags will be managed at the 40% potential population level for cavity nesters. Riparian<br />

areas in lodgepole pine will be managed to provide for fawning habitat. These standards are felt adequate<br />

to maintain deer use of the areas.<br />

Comment<br />

Well-distributed cover in management area (MA) 12 is essential to assure maintenance of hunting<br />

recreation visitor days (RVD) and to meeting ODFW management unit buck ratio objectives. Stable<br />

cover conditions in the timber management areas is desired and can be accomplished by using<br />

appropriate harvest dispersion rates. Assuming regeneration is successful, cover would be dominant<br />

on timber management lands. Silvicultural treatments that eliminate cover should be limited to those<br />

areas with an excess of 40 percent well-distributed cover.<br />

<strong>Response</strong><br />

Forest-wide standards and guidelines have been developed to maintain a minimum of 30% of the Forest<br />

area in cover for deer. An exception of short-term decrease in cover to 15% if justified to provide long-term<br />

benefits for deer is provided. These standards apply to all vegetation manipulation activities including<br />

silvicultural treatments.<br />

Comment<br />

The evaluation of habitat effectiveness for deer and elk needs to be applied to an area of less than<br />

10,000 acres. This area needs to be a permanent 'monitoring unit for evaluating the effects of roading<br />

and harvest dispersion on big game over time. ODFW will refer to 'monitoring units' a number of times<br />

in this document. The Forest's monitoring effort, using a combination of analysis zones, analysis areas,<br />

TRI compartments, and management areas may meet Our objective of less than 10,000 acres; but this<br />

needs to be demonstrated.<br />

The monitoring units should govern the blending of harvest prescriptions and open road density. The<br />

bounds of monitoring units should not extend more than one-quarter mile onto adjacent unavailable or<br />

unsuitable lands providing a cover or forage credit.<br />

<strong>Response</strong><br />

For mule deer habitat monitoring the Forest proposes the use of implementation areas which range<br />

from 8,000 acres to 50,000 acres. Management areas will overlap the implementation areas in most<br />

cases.<br />

Comment<br />

P.111-57. Mule Deer (Add: and Elk)<br />

Elk need to be included as an indicator species along with mule deer. The 1987 population estimate<br />

for elk was 1550 animals. The ODFW management strategy for elk on the Forest is slow population<br />

growth in areas with little or no conflict potential on private lands.<br />

<strong>Response</strong><br />

Species are chosen as management indicators to represent featured species or ecological indicators.<br />

Elk, a hunted animal, could possibly be a featured species. However, its significance as a hunted animal<br />

is low compared to mule deer. On the Winema N.F. elk would not be a good ecological indicator. Ecological

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indicators are selected because their population changes are believed to indicate the effects of<br />

management on other species. Elk are believed to be expanding range and population in this area<br />

and would indicate little change due to management activities. Several agencies are cooperating in an<br />

elk study in this area to determine their distribution and population dynamics.<br />

Comment<br />

P.111-57. Mule Deer (Add: and Elk)<br />

The Forest has incorrectly acknowledge ODFW planning data that was provided in 1980. In 1981, the<br />

Oregon Fish and Wildlife Commission adopted winter deer populations and buck ratio management<br />

objectives (MO). The Forest's portion of the MOs are referred to as benchmarks. The Forest needs to<br />

include the following information in the discussion on big game.<br />

Mule Deer Management Objectives<br />

(Winter)<br />

Unit Total Door Forest Allocation<br />

Sprague<br />

Klamath falls<br />

2,200<br />

6,200<br />

1,000<br />

400<br />

Keno 1,900<br />

TOTAL 10,300 1,400<br />

On-Forest Summer Benchmarks<br />

Unit Total Door Forest Allocation<br />

Fort Rock<br />

Silver Lake<br />

500 3,600<br />

2,000<br />

Klamath Falls 1,900<br />

Sprague 60 5,800<br />

Keno 250 2,000<br />

TOTAL 810 15,300<br />

The Forest's estimate of deer is 12,800 adults, ODFW benchmark for the Forest is 15,300 adults, and<br />

the Forest's projected output is 11,000 deer.<br />

Deer transition range should be addressed in this section.<br />

<strong>Response</strong><br />

Then 1988 ODFW Management Objectives for game management units are summarized in Chapter 3.<br />

Management objectives for elk have not been developed for this area.<br />

Comment<br />

PP IV-28. Wildlife and Fish Program<br />

(Bottom of Page). The herd management objectives should be stated here.<br />

<strong>Response</strong><br />

Herd management objectives are displayed in Chapter 3 as part of the description of the existing condition.<br />

K - 45

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Comment<br />

PP IV40.<br />

8. Disturbance of elk calving areas should be avoided from May 1 to July 15.<br />

<strong>Response</strong><br />

A Forest-wide standard and guideline states that road access will be restricted and human activities<br />

discouraged between May 1 and June 30 in areas identified as traditional elk calving.<br />

Comment<br />

P.IV.44. Mule Deer<br />

Mule Deer. The Forest's ability to support 11,000 mule deer is based on forage production. The use of<br />

forage as an indices for deer production is misleading. The Forest must also consider the impacts<br />

from a loss of cover and the impacts of open roads on mule deer populations and habitat effectiveness.<br />

<strong>Response</strong><br />

We have done this.<br />

Comment<br />

P.IV-45.<br />

(Top of Page). The nutrient value of forage is important to a healthy deer population. The true value of<br />

quality forage needs to be assessed using all of the components of habitat effectiveness (i.e., cover,<br />

roading, spacing).<br />

<strong>Response</strong><br />

We have done this.<br />

Comment<br />

P.IV-45.<br />

Paragraph 1. The last two sentences are incorrect. It should be stated that a majority of the present<br />

deer herd uses winter range off the Forest. Should other winter ranges be destroyed or further reduced,<br />

deer will not move to different winter ranges. The winter range on the Forest is viable and needs to be<br />

maintained or improved with the goal of increasing wintering deer to management objectives.<br />

<strong>Response</strong><br />

We plan to manage nearly all winter range to contribute to our share of the ODFW Management Objectives.<br />

Comment<br />

P.IV-45.<br />

(Paragraph 2). Intensive timber management on even-aged regeneration can also reduce forage<br />

availability. Harvest activities and site preparation can eliminate much of the bitterbrush component of<br />

a site, and recovery of the bitterbrush is extremely slow.<br />

<strong>Response</strong><br />

We agree.<br />

Comment<br />

D-9.<br />

7.b. Seventy percent cover is a good standard. The cover needs to be well distributed.<br />

<strong>Response</strong><br />

On-the-ground surveys during 1989 by Forest personnel indicate that 70% cover is unattainable in<br />

ponderosa pine stands. The Prognosis model also indicates that 70% cover is not achievable in ponderosa<br />

pine stands.<br />

K -46

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Comment<br />

D-10.<br />

1.a. Deer winter and transition ranges need to be considered when deciding an appropriate season of<br />

use.<br />

<strong>Response</strong><br />

See previous responses regarding transition range and the delineation of deer winter range.<br />

Comment<br />

D-10.<br />

6. The Forest's definition of 'created opening does not specify a standard for when the opening is no<br />

longer a created opening. The standard should be for big game cover characteristics. For elk/deer<br />

areas the standard needs to be 10 feet tall. In deer-only areas the standard needs to be 5 feet tall.<br />

<strong>Response</strong><br />

A harvest area shall no longer be considered a created opening for silvcultural purposes when stocking<br />

surveys carried out in accordance with Regional instruction indicate prescribed crop tree stocking at<br />

or above 4.5 feet in height and ree to grow. Where other resource management considerations are<br />

limiting, such as wildlife habitat and scenic requirements, a created opening shall no longer be considered<br />

an opening when the vegetation in it meets the management area presciption objectives.<br />

Comment<br />

D-92.<br />

Objectives No. 1. Add well distributed' to this standard.<br />

<strong>Response</strong><br />

These objectives have been rewritten.<br />

Comment<br />

D-93.<br />

Standards and Guidelines need to address transition range.<br />

<strong>Response</strong><br />

See previous comments regarding transition range.<br />

Comment<br />

Your assessment of deer outputs is below acceptable levels. You should meet long term ODFW MOs.<br />

In order to do that you will have to develop more sophisticated tools for assessing habitat. You address<br />

big game habitat in terms of cover and forage. In fact, much of what you have identified as one or the<br />

other component fails to really meet the definition of either. Forage needs to be addressed in terms of<br />

a nutritional quality index. Bare ground would meet your definition of forage. Likewise, an area with<br />

trees isn't necessarily meeting cover requirements. We ask that you assess the quality of both of these<br />

components of habitat and rewrite this section of the plan in terms of current quality of habitat and<br />

projected quality and quantity of habitat by alternative.<br />

<strong>Response</strong><br />

We have redeveloped our population estimates based upon the concepts of the TAC model.<br />

K - 47

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Other Comments<br />

Comment<br />

I am in favor of full ElSs done on all Forest projects.<br />

<strong>Response</strong><br />

FSM 1950 contains the national direction which describes the type of environmental analysis which is<br />

necessary for Forest Service proposed actions. Briefly summarized, this direction indicates that<br />

Environmental Impact Statements (EIS's) will be prepared to document the results of analysis of major<br />

Federal actions that will significantly affect the human environment (40 CFR 1502.3). Most Forest projects<br />

are not classified as major Federal actions and the analysis is documented in an Environmental<br />

Assessment or categorically excluded from documentation. Copies of the direction are available at any<br />

Forest Office. Copies of Environmental Assessments are available for review at the office of the<br />

Responsible Official for the analysis. Direction regarding environmental analysis is also contained in<br />

the Forest Plan, Chapter V, Page 2. Also, refer to the discussion on project level planning in the DEIS,<br />

Chapter I, Pages 1-3 through 1-5. This discusses the concept of 'tiering" of project level planning and<br />

environmental analysis with the approved Environmental Impact Statement and Approved Forest Plan.<br />

Comment<br />

Are aesthetics ever a primary concern in Forestry Decisions?<br />

<strong>Response</strong><br />

Yes. Concern for and consideration of aesthetics is required and discussed in many sections of the<br />

Environmental Impact Statement and Forest Plan. The National Forest Management Act Regulations,<br />

which apply to all management practices, requires that practices be evaluated and monitored to protect<br />

aesthetic values. In reviewing the Forest Management Goals, Desired Future Condition, and Standards<br />

and Guidelines in Appendix D, and in Chapter IV of the Forest Plan, you will find numerous examples<br />

of management direction and requirements which directly relate to protection and enhancement of<br />

aesthetic values. Aesthetic concerns and values have been and will continue to be evaluated in project<br />

level environmental analysis. There have been numerous examples of project design and mitigation<br />

measures used specifically for the purpose of protecting or enhancement of aesthetic values.<br />

Comment<br />

As shown on the attached map, the Winema National Forest is subject to military overflights in the<br />

form of low-level training missions. Inasmuch as low-level overflights do have the potential to disrupt<br />

the solitude and naturalness of areas directly under their flight paths, we recommend you include<br />

consideration of such activities in your discussion and decision-making process. Within that context,<br />

we further recommend you consider location, altitude, and frequency of flights.<br />

Areas which are appropriate for military overflights and low altitude training routes are becoming<br />

increasingly rare. In selecting overflight training routes, the Air Force must consider mission requirements<br />

and fuel costs as well as environmental constraints. Ideally, training routes are located within areas<br />

which: are relatively isolated, have diverse topography and minimal commercial activity, maintain sparse<br />

human populations, and contain lands under federal jurisdiction. It is obvious that these characteristics<br />

are also desirable to a large degree with National Forests and potential wilderness areas. Therefore,<br />

even though the Winema National Forest is subject to air training activities, the Air Force generally<br />

supports your Land and Resource Management Plan provided such a proposal, and subsequent<br />

management thereof, does not restrict use of the airspace for military overflights.<br />

<strong>Response</strong><br />

The Forest Service Manual, Part 2326.03 (3) states as policy,nDiscourage flights over wilderness with<br />

2,000 feet of the ground surface, except in emergencies or for essential military missions. (The Federal<br />

Aviation Administration (FAA) has agreed to and the National Oceanic and Atmospheric Administration<br />

(NOAA) has posted, for the FAA, a 2,000 foot over terrain flight advisory on appropriate aeronautical<br />

charts. Specific legislative provisions regarding overflight pertain to certain wildernesses.) Cooperate<br />

K-48

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with the Federal Aviation Administration, the National Oceanic and Atmospheric Administration, military<br />

authorities, and with local pilots to promote compliance with the 2,000 foot limit, to keep aeronautical<br />

charts current, and to reduce low level flight.' These are the only restrictions on overflights over National<br />

Forest Administered Lands.<br />

Comment<br />

Why not send literature out to people showing both sides equally (not one-sided).<br />

<strong>Response</strong><br />

The Draft Environmental Analysis and Proposed Forest Plan was sent to the Public for Review and<br />

Comments. It displays 10 alternatives, reflecting a full range of resource uses and values, which were<br />

evaluated in detail. These documents display the comparisons and environmental effects and<br />

consequences of each alternative. Refer also to Environmental Impact Statement, Chapter 11, Pages<br />

11-3 and 11-4, which discusses the alternative development process.<br />

Comment<br />

I feel that the Forest Supervisor must take personal responsibility for management taken on the Winema.<br />

In the final, I want to see the Supervisor's personal professional commitment to management action he<br />

recommends in the preferred alternative as it will be finally implemented.<br />

<strong>Response</strong><br />

The Record Of Decision for the Final Environmental Impact Statement documents the Regional Foresters'<br />

decision regarding management of the Winema to meet our agency's multiple use mission. It is the<br />

Regional Forester's responsibility to see that the Forest Supervisor carries out that decision.<br />

Comment<br />

We recommend that the dispersion constraint operate against both the suitable and non-suitable land<br />

use.<br />

<strong>Response</strong><br />

The dispersion constraint was applied only to suitable lands and was found not to affect anything.<br />

Adding unsuitable lands wouldn't change the situation at all.<br />

Comment<br />

The Cannon Well and Cherry Creek Basin proposed RNAs are both fully deserving and appropriate<br />

candidates for designation.<br />

<strong>Response</strong><br />

The plan designates Cannon Well, 853 acres and Cherry Creek, 1065 acres, as RNAs.<br />

Comment<br />

It seems highly likely that additional RNA community cells or other sites appropriate for inclusion in the<br />

RNA system can be located on the Winema National Forest. We urge you to identify this necessary<br />

ongoing inventory in your Information Needs section in the final LRMP.<br />

<strong>Response</strong><br />

Potential research natural areas on the Winema National Forest were identified in the publication Guide<br />

to Research Natural Area Needs for Planning area 40(USDA Forest Service 1980). The FEIS and Final<br />

Forest Plan reflects the designation or expansion of these identified needs.<br />

Comment<br />

The WNF is clearly a Forest that should actively research and consider designation of geological RNAs,<br />

due to the variety and complexity of the geology of the mountains of south-central Oregon region.<br />

K - 49

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<strong>Response</strong><br />

Research Natural Areas are part of a national network of reserved areas that include an array of North<br />

American ecosystems. Unusual geological features can be managed under special interest area<br />

designation. Geological features on the Winema National Forest are not uncommon to the eastern<br />

Cascade Mountains of Oregon. Potential research natural areas on the Winema National Forest were<br />

identified in the publication 'Guide to Research Natural Area Needs for Planning area 42(USDA Forest<br />

Service 1980). The FEIS and Final Forest Plan reflects the designation or expansion of these identified<br />

needs.<br />

Comment<br />

We recommend a specific set of guidelines for restricting recreational and commercial exploitation of<br />

RNAs. In general, recreational activities that cause any amount of resource degradation are not<br />

appropriate in RNAs. Camping and open fires should be specifically prohibited to prevent vegetative<br />

destruction. The collection of native plants and their seeds and parts without a scientifically based<br />

collection permit should be specifically prohibited. Construction of additional permanent trails in RNAs<br />

should be prohibited. We especially recommend specific S&Gs prohibiting ORVs and snowmobiles<br />

and the closing of the RNAs to firewood cutting.<br />

<strong>Response</strong><br />

Management direction for Research Natural Areas is established in Management Area 13: Research<br />

Natural Areass of the Forest Plan. Although some activities are allowed, generally, nothing is permitted<br />

that would significantly reduce the research or educational values for which the area is designated.<br />

The Standards and Guidelines for Research Natural Areas, contained in the Draft Forest Plan, Pages<br />

IV-125 through IV-127 contain your recommended set of standards and guidelines.<br />

Comment<br />

Provide a discussion of the effects of noxious weed introductions on native plants, including the role of<br />

domestic livestock, ORVs, and other recreational activities in such introductions. We could find no<br />

mention of this important effect in the DEIS.<br />

<strong>Response</strong><br />

The discussion has been expanded. Please refer to Chapter III of the FEIS, in the Section on Forest<br />

Pests-Noxious Weeds and Competing Vegetation and also refer to the effects discussed in Chapter IV<br />

of the FEIS, in the Section on Effects of the Alternatives on Vegetation.<br />

Comment<br />

We would also like to point out that none of these roadless areas, or any of the others on the Forest,<br />

appear to have been adequately censured for the presence of Sensitive Plant species. This should be<br />

remedied.<br />

<strong>Response</strong><br />

Table 111-4 of the DEIS presents the Pacific Northwest Region's October 1986 revised list of plants<br />

considered sensitive and that have been documented as or are suspected of appearing on the Forest.<br />

These plants are also listed in 'Rare, Threatened and Endangered Plants and Animals of Oregonw(Nature<br />

Conservancy 1985). Also, inventory and consideration of sensitive species is part of any site specific<br />

projects conducted on the Forest.<br />

Comment<br />

The Plan should also provide standards for wastewater systems. We request that the following language<br />

be added to the forest-wide standards section beginning on page IV-36 of the proposed Plan: OSewage<br />

treatment and disposal facilities shall be approved by the Department of Environmental Quality or its<br />

contract agents and shall be in compliance with rules of the Environmental Quality Commission.*<br />

K- 50

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<strong>Response</strong><br />

A standard similar to the your proposed standard for wastewater systems has been added to the FEIS<br />

and Forest Plan. Please refer to Chapter 4- Forest Management Direction- Forestwide Standards and<br />

Guidelines and to Appendix D of the FEIS.<br />

Comment<br />

Throughout the DEIS and LRMP, you refer to proposed actions that may or may not occur depending<br />

on budget constraints. While the general discussion of budget constraints is useful, OSDF and the<br />

State Economist wish you would address more specifically the likelihood of funding availability for the<br />

proposed actions and the impact on Forest resources i expected funding does not materialize.<br />

<strong>Response</strong><br />

The alternatives have been developed to be realistic in their capability of being funded. Also, the annual<br />

and out-year planning and budgeting process sets priorities should full funding not be available. However,<br />

we cannot predict the likelihood of the funding levels that will be available. These budget levels are set<br />

by Congress and the final budget levels depend on many factors. Also, an individual forests capital<br />

investment projects compete Nationally for funding. The effects of reduced funding levels would be<br />

monitored and evaluated in accordance with Chapter V of the Forest Plan, The implementation and<br />

monitoring section, Chapter V of the Forest Plan, has been revised to add clarity and detail to the<br />

budget discussion.<br />

Most of the information you list in the planning records in one form or another. We have mapped riparian<br />

areas and will be refining that data as the Forest Plan is implemented. The Standards and Guidelines<br />

in the Forest Plan (Chapter 4) include provisions which address the riparian allotment area, Forest<br />

access, wildlife and many other concerns. We are currently developing an old growth inventory and<br />

will use that information to specifically locate Management Area 7 during plan implementation.<br />

Comment<br />

The following information is essential for a more thorough and site-specific evaluation of alternatives<br />

and needs to be provided:<br />

1. A map of riparian zones and their condition; rated according to 'Managing Riparian Ecosystems<br />

for Fish and Wildlife in Eastern Oregon and Eastern Washington," (1979);<br />

2. An overlay map showing the location of grazing allotments on the riparian zone map, with summary<br />

information by allotment on: management strategy, range condition and trend, overuse problems<br />

to resolve, existing and planned grazing season, livestock numbers and permitted AUM's,<br />

improvements planned, and schedule for implementation;<br />

3. Explicit information on methods to be used to effectively implement Forest access and travel<br />

management to protect natural resources and meet hunter/recreationist demands;<br />

4. A map delineating big game transition ranges with special management direction for these ranges;<br />

5. A map delineating elk habitat management areas with specific management direction for these<br />

areas; and<br />

6. A map of forest ecoclass and seral stage distribution showing old-growth habitat (by R-6 refined<br />

definitions) as an independent component of mature forests.<br />

<strong>Response</strong><br />

Much of this information is available in process records and other plans such as permittee allotment<br />

plans at the Forest Supervisor's Office.<br />

Comment<br />

P.111-43. Significant Interactions.<br />

The discussion does not provide much information to the reader about the Forest. How have these<br />

interactions affected the various resources on the Forest? (DEIS 111-43).<br />

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<strong>Response</strong><br />

The discussions in chapter III of the DEIS that are titled 'Significant Interactions' were meant to indicate<br />

potential relationships between different components of the environment. The environmental effect are<br />

displayed and discussed in Chapters 11 and IV of the DEIS and in the FEIS.<br />

Comment<br />

P.111-67.<br />

(Entire Page). See comment for 11-43. P.111-43. Significant Interactions. The discussion does not provide<br />

much information to the reader about the Forest. How have these interactions affected the various<br />

resources on the Forest? (DEIS 111-43).<br />

<strong>Response</strong><br />

The discussions in chapter III of the DEIS that are titled Significant Interactions were meant to indicate<br />

potential relationships between different components of the environment. The environmental effects<br />

are displayed and discussed in Chapters 11 and IV of the DEIS and FEIS.<br />

Comment<br />

PP IV-12.<br />

Did the Forest use the refined definitions of old growth found in the Regional Guide? (PP IV-12).<br />

<strong>Response</strong><br />

Yes, the refined definitions were used.<br />

Comment<br />

The LRMP and DEIS discuss to some extent the rationale for eliminating an alternative that uses primarily<br />

uneven-aged management for all of the ponderosa pine working groups on the forest. An alternative<br />

similar to the preferred one, except for a non-declining flow of ponderosa pine, is also discussed but<br />

has been eliminated.<br />

Further discussion concerning the decision to not use an alternative that results in a non-declining<br />

flow over the long term of ponderosa pine should be included in the analysis.<br />

<strong>Response</strong><br />

The Final Plan, Alternative J, uses uneven-aged management throughout the Ponderosa Pine working<br />

group. We found that we could sustain a fairly high level of board foot production for 30 years with a<br />

decline thereafter as a result of conversion to uneven-aged stand structure. This is discussed in the<br />

FEIS and Record of Decision.<br />

Comment<br />

It appears that the Winema, unlike some other forests, still has the potential to mold an alternative that<br />

fully satisfies the Forest Program for Oregon objectives of, which the timber harvest targets are but<br />

one measure. The Forest is encouraged to construct such an alternative, incorporating the other<br />

recommendations in this review, and to provide an opportunity for public review.<br />

<strong>Response</strong><br />

We have discussed the relationship of the Final Plan to the Forestry Program for Oregon in the FEIS<br />

and have worked closely with the State in developing the Forest Plan.<br />

Comment<br />

The lack of economic parameters for monitoring the social and economic resources separately is a<br />

primary concern. It is also unacceptable that the decision to amend or revise the plan be based solely<br />

on a subjective judgement by the Forest Supervisor. Instead, all monitoring questions should be assigned<br />

specific variability standards.<br />

For example, if the appropriated budget for the forest prevents the Winema from providing at least 90<br />

percent of the allowable sale quantity (ASQ) proposed by the plan, some degree of plan amendment<br />

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or revision should be considered. We suggest that monitoring questions which directly affect community<br />

stability, such as the species composition of the ASO, should be held to within a + or - 10 percent<br />

standard.<br />

In addition, several important economic criteria are missing entirely from the monitoring program. Changes<br />

in job numbers, personal income, returns to counties and the ASQ species composition should be<br />

monitored with a variability standard of 10 percent.<br />

<strong>Response</strong><br />

The Monitoring Plan (Chapter 5 of the Forest Plan) has been redeveloped with your comments in mind.<br />

We have included specific socioeconomic indicators and the thresholds of concern for each monitoring<br />

elements.<br />

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Pelican Butte<br />

Comment<br />

The plan should identify an acceptable access road corridor between bald eagle habitat areas on the<br />

east side of the butte.<br />

<strong>Response</strong><br />

Site specific road locations or road corridors are outside the scope of the overall Forest planning process.<br />

Road locations and road corridors will be evaluated during project specific environmental analysis.<br />

Comment<br />

We would hope changes to the proposed Forest plan would include increased land for skiing, i.e.,<br />

downhill and cross-country.<br />

<strong>Response</strong><br />

The Forest Plan maintains the option to develop a winter sports area on Pelican Butte. The current<br />

City of Klamath Falls development proposal includes facilities for both downhill and cross-country skiing.<br />

Additional cross- country trails and supporting sno-parks are scheduled for construction in the Activity<br />

Schedule Appendix in the Forest Plan.<br />

Comment<br />

I feel the boundary of the proposed winter recreational area on Pelican Butte within the Forest plan<br />

should be large enough to accommodate the growth potential that exists with Pelican Butte. Therefore,<br />

4,000 acres would be a minimum rather than the current proposal of 2,500 acres of land.<br />

<strong>Response</strong><br />

The area available for winter sports development and future expansion will be determined in a separate<br />

site-specific EIS. No limit is set in the Forest Plan.<br />

Comment<br />

I believe that the proposed area should be expanded somewhat to include the northern and northeastern<br />

slopes so that the Pelican Butte ski area could accommodate cross-country as well as downhill skiing<br />

and would make the development more attractive.<br />

<strong>Response</strong><br />

This proposal is included in the current City of Klamath Falls development proposal being analyzed in<br />

a separate EIS.<br />

Comment<br />

The plan should also identify an acceptable access road corridor between the bald eagle habitat areas<br />

on the eastern side of the butte and scenic management standards within and around the ski area<br />

should allow for the visual alteration that will accompany the development of a ski area.<br />

<strong>Response</strong><br />

See the response to the first comment in this section.<br />

Comment<br />

However, in the event that the Forest decided to keep open the ski development option, the Sky Lakes-B<br />

roadless area should be classified, on an interim basis, as a Special Management Area to: (a) provide<br />

old growth habitat, primitive recreation opportunities and a natural appearing Forest environment; and,<br />

(b) to keep open the option of developing a downhill ski area on the mountain. This classification would<br />

allow for more flexibility and management options once a decision is reached whether a downhill ski<br />

area will be built. A better allocation of timber, wildlife and recreation resources will be possible at that<br />

time, and the plan indicates that such decision would probably be reached in the near future.<br />

K - 54

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<strong>Response</strong><br />

A separate Management Area Intensity has been described for the Pelican Butte Area, including the<br />

Skylakes-B roadless area (see Forest Plan Chapter 4). This area will be managed for semiprimitive<br />

recreation while preserving the option for future recreation development, including a winter sports<br />

area. Undeveloped portions will continue to be managed for semiprimitive recreation and other compatible<br />

uses which preserve the roadless character of the area.<br />

Comment<br />

The development of Pelican Butte will fulfill the growing local and regional needs for winter recreation<br />

facilities and achieve badly needed diversification and expansion of the local economy, including<br />

significant new jobs and purchased goods and services.<br />

<strong>Response</strong><br />

Agreed.<br />

Comment<br />

If the ski area goes in near the Tule Marsh, please prohibit the use of motor boats there.<br />

<strong>Response</strong><br />

Currently the use of motorboats is not permitted outside the channels of Crystal and Recreation Creeks<br />

in the marsh area. Any proposal to change this would be subject to site specific environmental assessment<br />

and the concurrence of the Fish and Wildlife Service which manages a large portion of this area as a<br />

Wildlife Refuge.<br />

Comment<br />

As a taxpayer and a WNF user, I urge you to support the city's project and to work with them in making<br />

what changes are necessary in your plan to allow the Pelican Butte winter recreation area to be completed.<br />

<strong>Response</strong><br />

The Forest Plan preserves the option for future recreation development on Pelican Butte, including the<br />

current City proposal being analyzed in a separate EIS.<br />

Comment<br />

From a technical standpoint, the Butte can clearly provide a superior alpine and nordic skiing experience<br />

if properly developed. Snow conditions were excellent from the summit consistently throughout lower<br />

elevations to well below the 6,000 foot level. I was particularly impressed by the many possibilities for<br />

both advanced skiers and beginners and specially the unique form of the bowl.<br />

As I also learned during this visit that you are adopting a new Forest Plan for the area, I wanted to<br />

take this opportunity to urge you to designate the northern half of Pelican for winter sports development.<br />

As a professional ski area operator with 18 years of experience, and have evaluated more than 10 ski<br />

areas in the last 10 years, it is clear that Pelican Butte has the snowpack, vertical fall, and diversity of<br />

terrain that can make up an exciting and competitive facility in today's winter recreation industry.<br />

<strong>Response</strong><br />

The suitability of this area for winter sports development was the major factor for preserving the option<br />

for development in the Forest Plan.<br />

Comment<br />

I feel that turning the butte into a ski resort would lead to the banning of snowmobilers to just the trails<br />

skirting Pelican Butte to a complete ban.<br />

<strong>Response</strong><br />

Pelican Butte will be managed to continue present uses, including snowmobiling until a decision on<br />

development is made. The current development proposed by the City of Klamath Falls includes areas<br />

specifically designated for snowmobiling.<br />

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Comment<br />

Outside of the three designated wilderness areas, only three percent of the Forest is in a roadless<br />

condition. This three percent should remain roadless including Pelican Butte with the proposed ski<br />

area. We feel as an organization that subscribes to ski activities, that there are presently ski areas<br />

available for the people of Klamath Falls.<br />

<strong>Response</strong><br />

The Sky Lakes-B roadless area on Pelican Butte will continue to be managed in its current roadless<br />

condition until a decision on development is made. If development is permitted, the undeveloped portions<br />

will continue to managed for semiprimitive recreation.<br />

Comment<br />

While it would be nice to have a ski area close to Klamath Falls, I wonder how profitable it would be.<br />

The expense is great and there are only so many skiers to keep it going.<br />

<strong>Response</strong><br />

The economics of any development proposal will be analyzed in a site-specific EIS.<br />

Comment<br />

I urge you to strongly support the proposed Pelican Butte winter recreation area for a multiple-purpose<br />

facility that includes:<br />

Downhill skiing on 2,500 vertical feet of terrain using 2-3 lifts to accommodate up to 2,000 skiers<br />

initially, with the ability to double the area's capacity using additional lifts.<br />

Continue snowmobiling using existing and new trails.<br />

Snowboarding and speed skiing on special downhill slopes.<br />

Cross-country skiing on lower slopes.<br />

Access to backcountry wilderness skiing.<br />

<strong>Response</strong><br />

All of the listed activities would be permitted and encouraged in a winter sports development proposal<br />

for Pelican Butte. The current City of Klamath Falls proposal includes these elements.<br />

Comment<br />

Pelican Butte development as a destination resort and convention facility could enhance the area and<br />

be enjoyed by many tens of thousands annually. Development should include complete facilities for<br />

500 or so conventioneers, including state of the art sewer disposal. Housing would be clustered, similar<br />

to Inn of the Seventh Mountain and sold as condos or time share.<br />

Activities should include year round family oriented facilities. Winter would include complete skiing,<br />

advanced to beginners, tubing and toboganning, snowmobiling, ice skating, horse-drawn sleigh rides<br />

and hay rides and wildlife watching (no hunting allowed within the area).<br />

Summer enjoyment would have equestrian breakfast rides into the wilderness area, guided and including<br />

llamas as pack animals. Use of the chair lift to the top of Pelican Butte, swimming, tennis, crafts, canoeing<br />

through the refuge area, fishing, water skiing, backpacking, carriage rides and hay rides and an 18-hole<br />

golf course in the vicinity, are other amenities that should be included.<br />

Spring and fall activities would be weather dependent but could include any of the summer or winter<br />

activities, and should include headquarters for hunters and fisherman, fall foliage viewing and wildlife<br />

nesting and migration.<br />

<strong>Response</strong><br />

An integrated winter and summer development would be encouraged in any proposal for Pelican Butte.<br />

The type and extent of development permitted would be determined in a site-specific EIS.<br />

Comment<br />

I do wonder if it is wise at this time to make a firm decision on whether 2,000 acres or 4,000 acres is<br />

the correct amount of land to set aside. Would it not be beneficial to set 2,000 acres aside immediately<br />

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with the understanding that after a predetermined period of time the development of Pelican Butte<br />

would be reviewed and additional acreage be set aside as seems appropriate at the time?<br />

Such an understanding would need to be well documented so that the delayed decision would not<br />

simply set off another round of political hassles and possible lawsuits. The standards for the decisions<br />

would have to be spelled out for the immediate acreage set aside in such a way that they could be<br />

used again for the later decision. A conservative approach limiting the set aside to 2,000 acres for now<br />

and forever may or may not give the best, long term results. On the other hand, setting aside 4,000<br />

acres might be unnecessary and extravagant. Why not wait to get the best information?<br />

<strong>Response</strong><br />

To give a potential developer maximum flexibility in planning and siting facilities, no specific acreage is<br />

allocated for development in the Forest Plan. All suitable area developable for winter and summer<br />

recreation may be considered. The actual area to be developed will be determined by a site-specific<br />

EIS. In the interim the entire area will be managed in its current roadless condition for semiprimitive<br />

recreation.<br />

Comment<br />

We believe the Pelican Butte area designated in the 1979 McLoughlin-Klamath Planning Unit Land<br />

Management Plan for winter sports management should retain that designation. This will preserve the<br />

option for such development at least until the current feasibility studies are completed and private<br />

developers make specific proposals. The feasibility studies should include a comprehensive market<br />

analysis. We are unsure from the DEIS why there is a difference in acreage needed for Pelican Butte<br />

in the NC Alternative and Alternative E. In addition, under the Preferred Alternative some land within<br />

the winter recreation area would be managed as old growth and lands needed for access would be<br />

managed as bald eagle habitat. We believe the plan should be designed to preserve the option of<br />

winter recreation development.<br />

<strong>Response</strong><br />

The option for development is maintained in the Forest Plan. The acreage differences between alternatives<br />

reflect acreage needs for various developments proposed in the past. No maximum acreage is specified<br />

in the Plan as pointed out above. Effects on old growth and bald eagle will be analyzed in a separate<br />

EIS.<br />

Comment<br />

The feasibility of a ski area at Pelican Butte has not been established. The plan states a capacity of<br />

60,000 skiing RVDs a year for the facility and then estimates future economic benefits based on the<br />

facility drawing that much use. This may well create unrealistic expectations. Pelican Butte faces<br />

considerable competition from other facilities in the region such as Ashland, Shasta and Bachelor<br />

Butte. Nearby Ashland, for example, drew 78,000 skiing visits in 1984-85. Transposing this into 12-hour<br />

skiing RVDs gives less than 40,000 RVDs. Yet Ashland draws from a considerably larger population<br />

base than Pelican Butte would.<br />

We suggest use and economic benefit projections for Pelican Butte not be made until more comprehensive<br />

market analysis is conducted.<br />

<strong>Response</strong><br />

Since feasibility of Pelican Butte development will be analyzed in a separate EIS, estimates of use and<br />

economic benefits are not included in the FEIS.<br />

Comment<br />

Specifically we are concerned about access to the North and Northwest slopes (of Pelican Butte) where<br />

the best snow exists. This part of the mountain also is ideal for telemarking which has been the hot<br />

new trend in X-C skiing the last few years and this fast growing sport deserves to be given due<br />

consideration in the plan.<br />

K -57

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<strong>Response</strong><br />

The current winter sports development proposal include areas for nordic skiing and snowmobiling on<br />

the north and northwest slopes. Until a decision is made on development, the area will be managed to<br />

continue existing uses, including telemarking.<br />

Comment<br />

Perhaps my memory has forsaken me, but as I recall input from biologists etc., indicated several<br />

endangered, rare plant species in the area of proposed ski area, as well as very numerous nesting<br />

areas of our beloved" bald eagle and osprey! Pelican Butte was to be set aside as roadless and forever<br />

protected from development. No roads could be engineered without infringing on eagle or osprey<br />

trees! I have to ask if all that has changed in a mere ten to fifteen years, or are we now willing to sacrifice<br />

our wonderful plants and birds for an ugly scar of a ski resort, used by few, viewed by many.<br />

<strong>Response</strong><br />

A portion of Pelican Butte was allocated for winter sports site development in the McLoughlin-Klamath<br />

Unit Plan implemented in July, 1979. The development option is maintained in the Forest Plan. Specific<br />

environmental effects (including effects on wildlife, plants and scenery) will be addressed in a separate<br />

EIS.<br />

Comment<br />

For many years I have dreamed of having a ski area closer to home. Fighting the battles of Rare I and<br />

11, why must we once again redefine this area?<br />

<strong>Response</strong><br />

RARE I and 11 were endeavors to determine the eligibility of National Forest roadless areas for wilderness<br />

designation. The Sky Lakes B roadless area (Pelican Butte) was not recommended for wilderness and<br />

in 1979 the McLoughlin-Klamath Unit Plan allocated a portion of the area for potential winter sports<br />

development. Congress has directed the Forest Service to examine land allocations and management<br />

direction of National Forest lands on a periodic basis (every 10-15 years). This has been done in this<br />

current planning process which maintains the option for winter sports development.<br />

Comment<br />

As currently written, the LRMP and DEIS do not appear to recognize this long-standing history, nor to<br />

take full advantage of the extensive background information on Pelican Butte that has been developed<br />

since the 1960's. An historical chronology of these efforts is given in Appendix B, and a bibliography<br />

of relevant documents in Appendix C.<br />

The City encourages the Forest Service to review this material and incorporate it as appropriate in the<br />

final LRMP and EIS, so as to properly reflect the large amount of community and agency effort already<br />

expended towards a winter sports area on Pelican Butte.<br />

<strong>Response</strong><br />

Additional documents relating to Pelican Butte have been added to The Winema Forest Plan planning<br />

records. These are listed in the references section of the FEIS. These documents will be utilized during<br />

preparation of the separate EIS which will address Pelican Butte development.<br />

Comment<br />

The City is aware that some members of the public still believe the area should be managed in a roadless<br />

or quasi-wilderness manner. Given the lengthy and exhaustive evaluation that occurred during 1973-84,<br />

which resulted in a multiple-use management determination for the Sky Lakes-B area, the City believes<br />

further roadless debate is redundant and technically insupportable. Most important, it is inconsistent<br />

with Congressional intent expressed in the 1984 Oregon Wilderness Act.<br />

<strong>Response</strong><br />

Although not included in the Oregon Wilderness Act, most of the Sky Lakes-B area is currently in a<br />

roadless condition providing a semiprimitive recreation environment for activities such as snowmobiling<br />

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and cross-country skiing. The Forest Plan allocates this area to semiprimitive recreation while maintaining<br />

the option to develop a portion of the area for recreation in the future. This allocation will result in the<br />

area being managed in its current roadless condition until development is permitted. Undeveloped<br />

areas on the Butte will continue to provide a semiprimitive experience outside of wilderness.<br />

Comment<br />

Because these land allocations are being made at the Forest planning stage, the final LRMP and EIS<br />

should discuss the feasibility of ski area development at other sites on the Winema, and explain why<br />

Pelican Butte is the only reasonable site on the Forest for supplying winter recreation opportunities of<br />

this nature and magnitude.<br />

<strong>Response</strong><br />

During the scoping effort for the Forest Plan and its DEIS, interest in ski area development was only<br />

received for the Pelican Butte area. Previous studies by the Forest Service and others have identified<br />

Pelican Butte as the only viable area on the Winema National Forest for ski area development. Alternate<br />

development locations on adjacent Forests will be addressed in a separate EIS analyzing development<br />

alternatives.<br />

Comment<br />

As currently drafted, the LRMP and DEIS use a "Developed Recreation' designation on a Forestwide<br />

basis for all types of developed recreation activities. Given the uniqueness of winter sports generally,<br />

and Pelican Butte in particular on the Winema National Forest, the City believes that the 1979<br />

McLoughlin-Klamath Unit Plan's 'Winter Sports Area' designation should be retained and applied in<br />

the final LRMP.<br />

Such a designation is not only a more accurate description of the area's management requirements,<br />

but is also consistent with designations of similar areas on other National Forest Service levels.<br />

<strong>Response</strong><br />

Agreed. A new management area designation as been developed to more accurately reflect the<br />

uniqueness of the Pelican Butte area The Pelican Butte Management Area 1 C is described in Chapter<br />

4 of the Forest Plan.<br />

Comment<br />

The LRMP and DEIS Alternative E propose to reduce the Butte's 1979 Winter Sports' land allocation<br />

from 3,100 acres to approximately 2,000 acres. According to Winema staff, and as stated in the DEIS<br />

Appendices, the location and size of the smaller proposed allocation was based on recollections of<br />

previous ski area studies.<br />

Given the necessity of locating Phase 1 cross-country ski trails on the lower northern and western<br />

slopes, along with the proposed expansion of snowmobile trails in the same vicinity, and the likelihood<br />

of downhill run expansion over 10-15 years, it seems logical to delineate the winter sports area's boundary<br />

coterminous with the terrain zones shown in Figure 1.3. This modified area includes 5,400 acres, but<br />

only a small fraction of it would be physically altered for runs, trails, and associated facilities.<br />

<strong>Response</strong><br />

The 2,000 acre area proposed in the DEIS eliminated some lower elevation area on the east flank of<br />

Pelican Butte which has not been included in recent development proposals. The current City of Klamath<br />

Falls proposal includes additional area on the north and west slopes. Since this proposal will be analyzed<br />

in a separate EIS, no limit on the acres available for development is set in the Forest Plan.<br />

Comment<br />

The LRMP creates three management intensities that may be applied in a Developed Recreation area,<br />

which would presumably also apply to a Winter Sports designation. However, the LRMP does not<br />

designate a management intensity for any particular Developed Recreation area, including Pelican<br />

Butte.<br />

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Because the only reason given in the LRMP and DEIS for the designation of Developed Recreation on<br />

Pelican Butte is to provide for a ski area with up to 60,000 RVD's annually, the city urges the Forest<br />

Service to explicitly state in the final LRMP and EIS that management intensity '2C' will be applied to<br />

the winter sports area on the Butte. Also, expected facility development should be identified as level 4<br />

or 5.<br />

<strong>Response</strong><br />

New management area intensities have been developed to more accurately reflect the allocation for<br />

Pelican Butte and to provide more specific standards and guidelines. Management Area 1C in Chapter<br />

4 of the Forest Plan describes the interim management for the area. Any facilities permitted after completion<br />

of the EIS addressing development, will be managed as a special-use permit recreation area (Management<br />

Area 2D or a similar separate designation). This EIS will provide specific standards and guidelines for<br />

managing the area.<br />

Comment<br />

The LRMP states that the visual quality objective applicable to all management intensities of Developed<br />

Recreation is 'retention.' 'Retention' is defined as a level of visual quality in which management activities<br />

are not visually evident to the casual Forest visitor. Additionally, the 'desired future condition' for even<br />

the high level (2C) development intensity is stated as occurring 'in a natural-appearing environment.'<br />

The LRMP goes on to define *natural-appearing' environment as one in which 'no more than 5 percent<br />

of the total area is visually altered, similar to visual quality objective preservation and retention standards.'<br />

These visual quality objectives seem inconsistent with the development of a winter sports area. Ski<br />

runs, chair lifts, base area facilities, and access roads can be constructed to repeat the color, shape<br />

and form of the surrounding landscape to a certain extent, but they will still introduce obvious visual<br />

changes regardless of design, and at a level that is likely to exceed 5 percent of the area.<br />

A more compatible set of visual quality objectives for a winter sports area is 'partial retention* for mountain<br />

facilities, and 'modification' for base area facilities. These are apparently the most common visual quality<br />

objectives applied to ski areas on other national forests, and the city urges the Forest Service to modify<br />

the objectives for the winter sports area on Pelican Butte accordingly.<br />

<strong>Response</strong><br />

A developed recreation site may have a retention visual quality objective which means that the environment<br />

shall be natural appearing. It is a commonly understood inconsistency that the recreation facility will<br />

often only achieve the partial retention or modification VQL within the natural appearing setting. The<br />

facilities are the points from which the settings are usually viewed and appreciated. Structures are<br />

designed to fit the setting so they achieve as close as possible to a natural appearance in form, line,<br />

color and texture. Structures are not likely to exceed 5 percent of the area.<br />

Comment<br />

The LRMP states that these old growth areas represent a 'minimum management requirement ... for<br />

northern three-toed woodpecker and pine marten habitat.' The proposed standards and guidelines for<br />

old growth areas further state that 'developed recreation is not compatible with the goals of this<br />

management areas." However, neither the LRMP nor draft EIS explain how the proposed old growth<br />

areas on Pelican Butte are expected to co-exist with a winter sports area if they are incompatible.<br />

The city urges the Forest Service to not designate old growth areas inside the proposed winter sports<br />

area and to address the issue of other surrounding old-growth areas' compatibility with the winter<br />

sports area in the final LRMP and EIS. Guidance is needed as to how these different designations can<br />

be implemented in a complementary fashion, including possible mitigation measures.<br />

Additionally, the old-growth management guidelines for each indicator bird species states that 'disturbing<br />

human activities' will be discouraged or minimized within 1/4 mile of active nest sites. Presumably, this<br />

would apply if an active nest is identified at the perimeter of an old growth management area, such<br />

that the 1/4 mile protection zone would extend a 1/4 mile outside the old-growth management area.<br />

However, it is not stated whether the relevant old-growth areas on Pelican Butte contain active nest<br />

sites, so it is unclear how this management prescription might affect winter sports area development<br />

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or other surrounding management designations. Nor is it clear what type of activities are considered<br />

'disturbing,' or whether an access road could be placed through an old growth area The city urges<br />

the Forest Service to clarify these issues in the final LRMP and EIS.<br />

The city's proposed expansion of the winter sports area allocation would include a small portion of an<br />

Alternative E Minimum Management area on the Butte's western slope (see Figure 2.2). Exactly why<br />

that area was deemed most suitable for Minimum Management is unclear. The goal of Minimum<br />

Management areas, as stated in the LRMP, is to 'keep the Forest in public ownership and a part of the<br />

national Forest system with a minimum of administrative cost.' The desired future condition for these<br />

lands is to Oremain in their present condition;' and applicable standards and guidelines include the<br />

statement that 'recreation developed sites, and recreation special uses and sites will be closed down<br />

(including ... ski areas).<br />

Because this portion of Pelican Butte is considered necessary by the city for the development of an<br />

economically viable winter sports area, it is suggested that the public interest and economic return to<br />

the Forest Service would be better served by redesignating this small section of land for winter sports.<br />

This would also prevent the inconsistencies in desired future condition and management standards<br />

cited above.<br />

<strong>Response</strong><br />

In the FEIS preferred alternative all the area in question has been allocated to a management area<br />

which retains the option for development as a recreation area. Effects of development including the<br />

effects on old growth will be analyzed in a separate EIS.<br />

Comment<br />

Finally, the city is concerned that the LRMP presently provides no detailed guidelines for management<br />

of visual resources in bald eagle habitat areas. It is stated that 'visual quality levels will be subordinate'<br />

to eagle habitat, but nevertheless the issue of which visual quality objectives would apply to an access<br />

road should be clarified. The city recommends 'partial retention' and 'foreground retention' in such<br />

cases.<br />

<strong>Response</strong><br />

If an access road lies within a bald eagle (BE) habitat designation, then BE management has priority<br />

and scenic quality would be secondary. There would be an effort given to achieve the visual quality<br />

level associated with the road, but not to the detriment of the bald eagles. If an access road lies outside<br />

a BE habitat area, the resource values would dictate its designation. If a scenic allocation occurs, then<br />

foreground retention and middleground partial retention would be the probable designation.<br />

Comment<br />

As shown in Figure 2.2, the city's recommended access road route also passes through a Scenic<br />

Management area The LRMP contains standards and guidelines that can be interpreted as precluding<br />

the construction and use of roads through these areas but discussions with Winema staff indicate that<br />

this interpretation is not intended. This should be clarified in the final LRMP and EIS.<br />

<strong>Response</strong><br />

Visual quality objectives do not preclude project activity, but rather, provide the framework in which it<br />

is conducted. A facility may or may not be appropriate in a scenic allocation depending on the<br />

environmental analysis and the line officer decision.<br />

Comment<br />

The statement that scenic views from the Westside Road, Upper Klamath Lake, Highway 140, and<br />

Highway 97 'would' (emphasis added) be affected by development of a winter sports area cannot be<br />

factually supported until a specific development plan is offered and visual resource modeling is<br />

accomplished as part of a project EIS. The statement should be rephrased to reflect potentialities rather<br />

than certainties.<br />

K - 61

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<strong>Response</strong><br />

True. Effects will be determined in a separate EIS, so this reference was deleted.<br />

Comment<br />

The statement that multiple cultural resource "sites, (emphasis added) are known to exist on Pelican<br />

Butte is not supported by an inventory conducted in 1987 by the city. As reported to the Klamath Ranger<br />

District in March 1988, this inventory resulted in identification of only a single resource site which is<br />

located outside of the proposed winter sports area boundary.<br />

<strong>Response</strong><br />

Identification of cultural resource sites will be part of the site-specific analysis of the current proposal.<br />

Comment<br />

The DEIS contained a limited discussion of winter sports area impacts on cultural and visual resources,<br />

community services, and local socioeconomics. At a minimum, the final EIS should also address potential<br />

generalized impacts on soils, vegetation, wildlife, water resources, noise, and fire hazards.<br />

<strong>Response</strong><br />

Impacts of development alternatives will be addressed in a separate site-specific EIS and are not included<br />

in the FEIS for the Forest Plan.<br />

Comment<br />

Using the winter sports area design studies and environmental investigations that it has completed<br />

thus far, and the foregoing analysis of the LRMP and DEIS, the City has prepared a modified Alternative<br />

E land allocation plan for Pelican Butte as shown in Figure 3.1 (superimposed over the City's concept<br />

plan).<br />

This modified set of land allocations is intended to address the major concerns outlined in this document<br />

in a way that will allow for optimum winter sports area development without jeopardizing the Butte's<br />

important environmental qualities. The City stands ready to work with the Forest Service in refining this<br />

recommendation during completion of the final LRMP and EIS.<br />

<strong>Response</strong><br />

The Forest Plan maintains the option to develop all the area recommended subject to the findings of a<br />

separate EIS addressing development alternatives.<br />

Comment<br />

Page 111-4, 3rd paragraph. The derivation of 700 jobs generated by development of a Pelican Butte<br />

winter sports area should be clarified. The City's preliminary estimates of local economic benefits from<br />

such development are given in Table 4.1.<br />

<strong>Response</strong><br />

Economic benefits of developing Pelican Butte will be addressed in a separate EIS, so are not included<br />

in the FEIS for the Forest Plan.<br />

Comment<br />

The description of Pelican Butte as a roadless area is misleading. Only 38% of the Pelican Butte geographic<br />

area is contained within the Sky Lakes-B roadless area.<br />

<strong>Response</strong><br />

The Sky Lakes-B roadless area is located on the upper slopes and northwest flank of Pelican Butte.<br />

The roadless area has 9,863 acres and includes nearly all the area which has been identified as suitable<br />

for winter sports development.<br />

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Comment<br />

The advocacy of a winter sports area is not limited to the City of Kiamath Falls and Kiamath County<br />

Chamber of Commerce. This discussion should reflect the broad-based organizational support evidenced<br />

by LRMP/DEIS public comments received by the Winema National Forest. Furthermore, this advocacy<br />

is not limited to downhill skiing, but rather encompasses a full spectrum of winter sports, including<br />

snowboarding, snowmobiling, cross-country and back-country skiing, and snowplay activities.<br />

<strong>Response</strong><br />

In Chapter 1 of the FEIS the revised description of the Pelican Butte public issue reflects the range of<br />

public support indicated in comments on the draft EIS for the development a winter sports area on<br />

Pelican Butte.<br />

Comment<br />

It is misleading to suggest that only 'local downhill skiers' have advocated Pelican Butte development.<br />

As stated above, the public comment record will show that a wide variety of interest groups, local<br />

governments, and other community organizations desire a multiactivity winter sports area on the Butte.<br />

<strong>Response</strong><br />

See previous response.<br />

Comment<br />

Under Alternative E, it is misleading to suggest that winter sports area development would result in 0%<br />

of Pelican Butte being left unroaded. Even with the City's recommendation to increase winter sports<br />

area acreage to 5,400, much of the Butte's higher elevations would remain unroaded.<br />

<strong>Response</strong><br />

A new management area has been created which recognizes that much of Pelican Butte will remain<br />

unroaded even if winter sports development occurs. Undeveloped areas would be managed for<br />

semiprimitive recreation activities, such as snowmobiling and cross-country skiing, which would be<br />

compatible with and complement developed site operations.<br />

Comment<br />

Additionally, the statement that the 1979 McLoughlin-Klamath plan designated the Butte for winter<br />

sports 'in response to the City of lKamath Falls' expressed interest' is incorrect. The City did not initiate<br />

its Pelican Butte studies until 1984. The 1979 McLoughlin-Klamath Plan decision was the result of<br />

participation by many citizens and organizations throughout southern Oregon.<br />

<strong>Response</strong><br />

We agree. The reference is not correct and it has been removed.<br />

Comment<br />

The City is concerned by the following statement:<br />

'It would be inappropriate to issue a permit for development of a ski area on Pelican Butte (if<br />

requested) until or unless the provision of such development is made in the final environmental<br />

impact statement and record of decision for the approved Forest Plan. The feasibility studies<br />

and site-specific environmental analysis may continue, with the stipulation that permit issuance<br />

could occur only if permitted under the land management direction in the approved Forest Plan."<br />

The City has had recent discussions on this particular question with the Forest Service's regional and<br />

national offices. In both cases, the Forest Service staff at these levels have disagreed with the foregoing<br />

statement. They cited no such requirement in applicable Forest Service regulations or NEPA, and instead<br />

indicated that a project EIS could be completed and a permit issued under the 1979 plan.<br />

The City is concerned about this difference in interpretations, particularly in light of possible legal<br />

challenges that will delay final LRMP adoption. The City therefore urges the Winema to reconcile its<br />

position with the regional and national interpretations.<br />

K - 63

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<strong>Response</strong><br />

Scoping for the Forest Plan effort revealed that the land allocation to winter sports in the Mcloughlin-<br />

Klamath Unit Plan was an issue. This required a re-examination of the land allocation during the Forest<br />

Plan development. Since there was the possibility of a change in land allocation, it was inappropriate<br />

to issue a permit until the completion of Forest Land Management Planning process. Feasibility studies<br />

and site-specific analysis of the City's proposal have been initiated.<br />

Comment<br />

The City's market research to date indicates that Pelican Butte visitation can reach 80,000 RVDs annually<br />

by the year 2005. The physical capacity of suitable terrain on the Butte could exceed 100,000 RVD's<br />

per year (see Appendix D).<br />

<strong>Response</strong><br />

The use figures presented in the DEIS were estimated based on a number of assumptions on the type<br />

and extent of development. Since specific development alternatives will be addressed in a separate<br />

EIS, use projections are not included in the FEIS for the Forest Plan.<br />

Comment<br />

Alternatives: The basis for estimating the amount of Pelican Butte to be developed, and the resulting<br />

roadless character of the area, should be explained in detail given the significance of this issue. The<br />

origin and derivation of the cited land area percentages, i.e., 69-75%, should be clarified.<br />

<strong>Response</strong><br />

A new management area has been developed to more specifically describe the allocation for Pelican<br />

Butte. Appropriate sections of the FEIS have been revised to reflect this change. The percent of the<br />

Sky Lakes B roadless area remaining roadless is displayed by alternative in Chapter 2.<br />

Comment<br />

The statement that development of Pelican Butte as a ski area Ncould t (emphasis added) have an economic<br />

effect on Klamath Falls is inconsistent with several statements elsewhere in the DEIS which project<br />

definite economic impacts. Given the large body of literature documenting positive economic impacts<br />

from winter sports areas on surrounding community economies throughout the United States, this<br />

statement should be rephrased to reflect that certainty.<br />

<strong>Response</strong><br />

This statement has been revised.<br />

Comment<br />

This discussion of Pelican Butte should expand the listing of proponents beyond simply the City and<br />

Klamath County. Also, the phrasing should be changed to correctly portray the Sky Lakes-B roadless<br />

area as being located on a portion of Pelican Butte, rather than vice-versa as is presently stated.<br />

<strong>Response</strong><br />

This section has been revised to clarify both points.<br />

Comment<br />

The statement that Orecreation and tourism have not played a dominant role in the development of the<br />

local economy is inconsistent with local economic data and analyses. It is widely recognized and<br />

documented that recreation and tourism is the 'third legm of the local economy after agriculture and<br />

wood products industries.<br />

<strong>Response</strong><br />

While we agree recreation and tourism is an important component of the local economy, we don't feel<br />

it is a dominant factor when compared to the agriculture and wood products industries.<br />

K - 64

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Comment<br />

The statement that 'development of the ski area is not planned below 6,000 feet' is inconsistent with<br />

the concept of a multiactivity winter sports area that includes nordic ski trails situated between 5,000<br />

and 6,000 feet in elevation, and new snowmobile trails which would reach as low as 4,500 feet.<br />

<strong>Response</strong><br />

The statement refers to the developed ski area, rather than the associated winter trail systems that will<br />

not require major construction work.<br />

Comment<br />

Also, the loss of a potential winter sports area at Pelican Butte would conflict not only with City plans,<br />

but also with policies in Klamath County's Comprehensive Land-Use Plan, and Klamath County's Overall<br />

Economic Development Plan.<br />

<strong>Response</strong><br />

Only the City has a documented development proposal.<br />

Comment<br />

The statement that 'lodging, resort homes, and condominiums would (emphasis added) occur on<br />

nearby private land' is inconsistent with the City's concept of developing a day-use facility, and cannot<br />

be factually supported with currently available information. Given the relatively small amount of private<br />

land in the vicinity, and the day-use scope of winter sports area plans, this statement should be modified<br />

to reflect potentialities rather than certainties.<br />

<strong>Response</strong><br />

Based upon experience with establishment and operation of other ski areas, this type of development<br />

is probably a certainty.<br />

Comment<br />

Despite the prominence of Pelican Butte as one of the Winema's major public issues, there is only a<br />

single Pelican Butte reference document cited in the DEIS. The City urges the Forest Service to incorporate<br />

relevant literature listed in Appendix C of this comment document.<br />

<strong>Response</strong><br />

Documents used in the development of the Forest Plan or referenced in planning documents have<br />

been incorporated and will be used to develop the site-specific EIS for the proposal.<br />

Comment<br />

Outputs used in the input-output analysis for recreation include downhill skiing and snowplay, but<br />

should also include snowboarding, cross-country skiing, and snowmobiling.<br />

<strong>Response</strong><br />

Outputs from the proposed development of Pelican Butte were not included in the FEIS analysis.<br />

Comment<br />

We would suggest in the final plan a section on how new winter sports sites are permitted on USFS<br />

land. Recently, in discussions in Washington D.C. with the National Recreation Staff for Recreation,<br />

their illustrations of the California System, Colorado System and others was most informative. With<br />

Pelican Butte being in the other category, a discussion of the permitting history of the Sandy Butte<br />

Winter Sports Site at Early Winter, Washington, on the Okanogan National Forest plus the issues causing<br />

the legal appeals should be part of the discussion of Pelican Butte.<br />

<strong>Response</strong><br />

The process for permitting ski areas is included in Chapter I of the FEIS. A separate EIS will address<br />

regional ski area issues.<br />

K - 65

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Comment<br />

The main points we wish to comment in detail about is Pelican Butte. The draft plan was very short on<br />

the history of the local community's 30 years effort to work with the Winema Forest Service toward a<br />

Winter Sport Site. The EIS was very lacking in direct site specific points about Pelican Butte. The city<br />

of Kiamath Falls has done an excellent job of documenting the history and we are enclosing a copy of<br />

their work with our letter, as we believe it to be very factual and correct. Members of our company<br />

have been part of or helped with most all studies, reports, and field trips during these three decades.<br />

<strong>Response</strong><br />

Site specific details and the history of public interest in the development of winter sports area on Pelican<br />

Butte will be addressed in a separate EIS.<br />

Comment<br />

In the final plan a section on competitions for Forest 'Products should state just as the Winema cannot<br />

control the fact that 40% of its timber sold is processed in the Rogue River Valley could it control or<br />

believe it is of concern that many skiers from the Rogue River Valley would not ski at Mt. Ashland but<br />

at Pelican Butte. We understand that the National Office of the USFS is quite adamant on this point.<br />

<strong>Response</strong><br />

Additional discussion concerning currently developed and proposed winter sports areas in the region<br />

will be included in the Pelican Butte Recreation Area EIS.<br />

K - 66

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Plan and EIS Content<br />

Comment<br />

What are you doing for monitoring? What are you using for checking Districts' modifications to plan<br />

volumes? You should do an EA or EIS on grazing and allotments. Your plan should pinpoint where<br />

EAs or further assessments are needed - recreation planning, special uses, etc.<br />

<strong>Response</strong><br />

Chapter 5 of the Forest Plan contains a monitoring plan which states the outputs and effects that will<br />

be monitored. It also includes a decision tree which describes appropriate actions that will be taken if<br />

monitoring indicates that desired outputs and effects are not being achieved.<br />

FSM 1950 contains the National direction which describes the type of environmental analysis which is<br />

necessary for Forest Service proposed actions. This direction changes occasionally in response to<br />

national issues and therefore was not included in the Forest Plan. Copies of the direction are available<br />

at any Forest Office.<br />

Comment<br />

There should have been an expanded and more complete Glossary. For instance are there too many<br />

Big Game Species to list? Would one average number suffice for a general Board Foot/Cubic Foot<br />

Ratio? What are current Carrying Capacities? Are the 10 Condition Classes too lengthy to include?<br />

What are the Seral Stages?<br />

<strong>Response</strong><br />

Typical big game species are included in the definition contained in the glossary.<br />

Due to the variability in tree size mix between species and species harvest composition among alternatives,<br />

it is a good idea to vary the board-foot/cubic-foot ratio to more accurately portray the board foot volume.<br />

Divide the ASQ in board feet by the ASQ in cubic feet for each alternative to get an average ratio to<br />

see how it varies.<br />

Carrying capacities are discussed in several places in the EIS in relation to the resource to which they<br />

apply. The Winema National Forest condition classes are listed in the glossary. nSeral is defined in the<br />

glossary.<br />

Comment<br />

We are especially concerned that the timber harvest level proposed in the draft plan was apparently<br />

not a result of any planning decision, but rather the residual left over from the FORPLAN analysis after<br />

providing for all other non-timber resources. The basic premise underlying the Forest's analysis appears<br />

to have been that irreconcilable differences exist between timber production and other forest management<br />

objectives. We are concerned that the planning team did not attempt to harmonize the various multiple<br />

uses of the forest. Timber production appears to have been treated as a secondary output rather than<br />

a harmonious one that the Forest seeks to harmonize with other uses. This 'trickle down' analysis<br />

approach fails to comply with the requirements of the Organic Act of 1897, the Multiple-Use Sustained<br />

Yield Act, the Forest and Rangeland Renewable Resource Planning Act and NFMA.<br />

<strong>Response</strong><br />

The timber harvest levels in the alternatives are not the result of a single decision, but rather represent<br />

a blending of many decisions. Many non-timber uses of the Forest are compatible with timber production<br />

(visual resource management, wildlife habitat management, dispersed recreation etc.) The FORPLAN<br />

model was used to estimate the effects of alternative ways to harmonize the various uses of the Forest.<br />

The various alternatives do represent tradeoffs between competing interests simply because every<br />

individual's needs can not be satisfied on every acre of land simultaneously. Our efforts have been<br />

aimed toward developing a plan that maximizes the net public benefits (which include both monetary<br />

and non-monetary considerations) of managing this Forest.<br />

K - 67

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Comment<br />

The DEIS does not adequately identify the sources of the data used in the Forest's analysis. Nor does<br />

it clearly discuss the reliability of the data and the scientific uncertainty involved in many elements of<br />

the analysis. As a result, important policy decisions are effectively hidden behind a facade of numbers<br />

that appear "scientific" to the public but may be no more than best guesses in reality. The FEIS should<br />

provide a full and frank discussion of the Forest's modeling assumptions and their limitations.<br />

<strong>Response</strong><br />

Sources of data are discussed in Chapter 2 and Appendix B. Concerns about the reliability of data are<br />

highlighted in Chapter 4. Details on model assumptions are presented in Appendix B with many references<br />

to the Planning records.<br />

Comment<br />

The non-public process by which minimum management requirements were developed significantly<br />

constrains the potential of the suitable timber land to produce forest resources in every alternative and<br />

makes the Winema National Forest Plan and draft EIS legally indefensible.<br />

<strong>Response</strong><br />

Appendix J of this FEIS summarizes the effects of the management requirements. Appendix J of the<br />

Draft EIS (which is now part of the planning records) provides more details. The essential conclusion<br />

is that no management requirement reduced the allowable sale quantity or the present net value by<br />

more than 2 percent and thus the effects of implementing those requirements on this Forest are not<br />

considered to be significant in any alternative.<br />

Comment<br />

The MMR's developed by the Winema violate the public participation, interdisciplinary analysis, and<br />

integrated planning mandates of the National Forest Management Act. Additionally, the MMR's were<br />

developed with complete disregard for the requirements of the National Environmental Policy act to<br />

examine a range of alternatives for major federal actions affecting the environment. Furthermore, the<br />

MMR's violate the Multiple Use Sustained Yield Act because they prevent a high level output of other<br />

resources.<br />

<strong>Response</strong><br />

The effects of implementing the management requirements were found to be insignificant on this Forest.<br />

Comment<br />

Because the minimum management requirements as developed by the Winema National Forest become<br />

an inflexible standard incorporated into all alternatives in the planning process, they violate the mandates<br />

of the National Forest Management Act and Multiple Use Sustained Yield Act, which require that one<br />

resource is not to override the attainment of other resources. In addition, the implementation of MMR's<br />

on the national forests is an action which significantly affects the quality of the environment and therefore<br />

must comply with NEPA, including the evaluation of a range of alternatives.<br />

<strong>Response</strong><br />

The effects of implementing the management requirements were found to be insignificant on this Forest.<br />

Comment<br />

However, rather than incorporating the Clean Water Act, approved Oregon standards, the Winema has<br />

bypassed the public process that must be followed to change water quality laws and has independently<br />

and without public review developed its own forest practices act. MMR's are supposed to reflect the<br />

legal requirements established by statute and regulation, not the requirements imposed by hydrologists<br />

and fisheries biologists. The Implementation Plan for Water Quality Planning on National Forest Lands<br />

in the Pacific Northwest, December 1978, notes: The Forest Service problem solving efforts in #208<br />

Water Quality Planning is based on tbest management practices" (BMP's) which are defined by regulation<br />

as la practice or combination of practices, that is determined after problem assessment, examination<br />

K - 68

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of alternative practices, and appropriate public participation to be the most effective, practicable (including<br />

technological, economic, and institutional considerations) means of preventing or reducing the amount<br />

of pollution generated by non-point sources to a level compatible with water quality goals.<br />

(Emphasis added.) The riparian area MMR developed by the Winema does not comply with this<br />

implementation plan. There is no evidence that the Winema considered alternative practices to the<br />

harvest rate constraints that it claims are the necessary MMR's. Furthermore, the public was not allowed<br />

to participate in the development of these MMR's.<br />

<strong>Response</strong><br />

The effects of implementing the management requirements were found to be insignificant on this Forest.<br />

In some alternatives additional emphasis was given to resources such as those in riparian areas. In<br />

alternative J, for example, additional considerations in riparian areas were added after consultation<br />

with the State of Oregon.<br />

Comment<br />

Forest plans that contain MMR's for riparian protection in excess of BMP's are not minimum management<br />

requirements. Furthermore, the Forest Service has signed a memorandum of understanding regarding<br />

water quality protection with the Oregon Department of Environmental Quality. This memorandum<br />

provides, The USFS is required by many federal laws, federal regulations, and internal agency<br />

requirements, to involve the public in agency decisions. It will utilize these measures...to bring public<br />

involvement into water quality decision-making processes.' The development of the riparian area<br />

management strategy for the Winema National Forest violates this agreement. The riparian area MMR's<br />

were developed in secret solely by Winema National Forest personnel. The public had no input into<br />

their development, and therefore the Winema cannot claim that the MMR's were developed pursuant<br />

to the Forest Service agreement.<br />

<strong>Response</strong><br />

The effects of implementing the management requirements were found to be insignificant on this Forest.<br />

Riparian area management guidance was developed and refined using public comments and other<br />

agency input.<br />

Comment<br />

Table 11-7: are these projections still valid? Estimates made in 1979 may be outdated/superseded.<br />

<strong>Response</strong><br />

Most of the estimates presented in the Draft EIS were developed in 1985 and 1986 using the best<br />

available data. If better data was available, these numbers were updated in the Final EIS.<br />

Comment<br />

MRVD is not defined in the glossary.<br />

<strong>Response</strong><br />

MRVD refers to thousands of recreation visitor days. 'Recreation visitor day' is defined in the glossary.<br />

Comment<br />

Wildlife MMR's. Wildlife MMR's establish 'indicator species' that will be emphasized in the forest plan.<br />

The Winema, however, did not involve the public in either the selection of the MMR indicator species<br />

or the definition and location of indicator species habitat.<br />

<strong>Response</strong><br />

The effects of implementing the management requirements were found to be insignificant on this Forest.<br />

See Appendix B and Appendix J of this Final EIS and Appendix J of the Draft EIS for more information.<br />

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Comment<br />

The Winema did not perform a comparable analysis with the no-change alternative as was performed<br />

with all other alternatives examined in the draft EIS. Thus, it is impossible to compare the current<br />

management direction on the Forest with the direction that would be imposed by adoption of one of<br />

the alternatives considered in the draft EIS.<br />

<strong>Response</strong><br />

The 'No Change' alternative does not depict current management direction on the Forest because<br />

certain legislative actions have required changes (particularly NFMA). These changes are reflected in<br />

Alternative A, the NNo action' alternative, which is intended to describe the way the Forest is actually<br />

being managed. The 'No Change' alternative would be comparable to historic conditions if those<br />

conditions are assumed to be static. Conditions of Forest management have continually changed in<br />

the past and continue to do so. That evolution is expressed in the 'No Action' alternative in an effort to<br />

estimate the future amounts of goods and services that continuation of current management direction<br />

(not simply current management) will bring. The 'No Change' alternative is described, to the extent<br />

possible, along with the other alternatives so that can be used as a baseline reference.<br />

Comment<br />

The CEQ regulations require that an agency include within an EIS reasonable alternatives not within<br />

the jurisdiction of the lead agency. 40 CFR 1502.14(c).<br />

The Ninth Circuit Court of Appeals recently addressed this issue and commented: An EIS is rendered<br />

inadequate by the existence of a viable but un-examined alternative (cite omitted). Furthermore, even if<br />

an alternative requires legislative action,' this fact 'does not automatically justify excluding it from an<br />

EIS.'<br />

(city omitted.) Methow Valley Citizens Council v. Regional Forester, Case No. 86-4108 (9th Cir. 1987).<br />

The no-change alternative is a reasonable alternative which must be fully evaluated by the Winema<br />

planning staff. The failure to objectively evaluate the current management direction on the Forest is a<br />

violation of 36 CFR 219.12(f)(v) and (vii) and 40 CFR 1502.14(c) and (d).<br />

<strong>Response</strong><br />

The no change alternative is not the current management direction of the Forest. Alternative A<br />

approximates the current management direction and it is fully evaluated.<br />

Comment<br />

The minimum management requirement for silvicultural practices states: 'Timber harvest and other<br />

silvicultural treatments shall be used to prevent potentially damaging population increases of forest<br />

pest organisms.' 36 CFR 219.27(c):(7). Furthermore the NFMA evidences significant congressional<br />

concern regarding waste of timber resources by allowing salvage harvest of insect infested timber. 16<br />

USC 1611 (b). All of the alternatives, except the preferred alternative, flout congressional concern over<br />

this issue and exalt waste. Given this congressional expression of concern over waste of our timber<br />

resources and the fact that protection against insect depredation is a specific requirement of the planning<br />

regulations, more alternatives should have been developed which specifically address the mountain<br />

pine beetle infestation on the Winema National Forest.<br />

<strong>Response</strong><br />

Additional emphasis in this area is included in Alternative J.<br />

Comment<br />

Compared to current trends in the forest industry in Oregon, the economic analysis performed by the<br />

Winema understates the cost of implementing the preferred alternative.<br />

The Winema, at the very least, should have recognized that the use of 1977 as the baseline period for<br />

determining the effects of the preferred alternative on jobs and income in the affected area makes it<br />

appear as i implementation of the preferred alternative would result in a great increase in jobs and<br />

income to the residents of the affected area. At the very least, the Winema should have pointed out<br />

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that current levels of timber volume, jobs, and income are considerably higher than the levels from<br />

1977 used as the basis of comparison. For example, in 1984 and 1985, an average of approximately<br />

185 million board feet was cut on the Winema National Forest (table 111-8, p. 111-34), and in the last two<br />

years, the harvest level in the Winema has been even higher. People are being employed commensurate<br />

with this level of harvest. The Winema should have looked at recent trends in timber harvests in the<br />

area in order to determine a more realistic baseline date from which to conduct this economic and<br />

social analysis.<br />

<strong>Response</strong><br />

The basis of comparison in the Final EIS is an estimate of jobs and income associated with the average<br />

levels of Forest activities from 1980 through 1989. In addition the estimates are based upon the structure<br />

of the economy in 1982 rather than 1977 as was used in the Draft EIS. This is the most up-to-date<br />

information on the structure of the economy that is available. We have pointed out, in the discussion<br />

on the economy in Chapter 4, that there are many factors that could affect these estimates. The estimates<br />

are comparable between alternatives and provide the necessary information for the decision at hand.<br />

Comment<br />

The Winema should have used the no-change alternative as a baseline to compare total jobs produced<br />

by the alternative management plans. The presentation of table IV-33 on p. IV-1 03 of the DEIS is inaccurate,<br />

misleading and should be withdrawn. The comparison of alternatives to an economy that existed 11<br />

years ago misleads the public with regard to the effect of implementation of any of the alternatives on<br />

the Winema National Forest.<br />

<strong>Response</strong><br />

The comparison in the Draft EIS was based on the structure of the economy in 1977, not to levels of<br />

employment at that time. Economic structures shift over time and it is a complicated process to track<br />

and update the description of those structures that are used in our input/output model (see Appendix<br />

B for more discussion of the process used in estimating jobs and income effects). The basis of comparison<br />

used in the Final EIS involved the structure of the economy in 1982 (most recent data available) and<br />

the average level of Forest activities from 1980 through 1989. It has been argued that 1982 was a poor<br />

year for lumber production and that this might cause employment impacts to be underestimated. There<br />

are indications that the opposite may be true simply because efficiencies of scale are lost when production<br />

levels fall and higher levels of employment are associated with each board foot produced.<br />

Comment<br />

The draft EIS contains an inadequate discussion of one of the most important environmental issues --<br />

that is, the environmental impact of not actively managing the Forest. The Winema must consider the<br />

environmental consequences of not harvesting timber from areas that are not scheduled for active<br />

forest management and particularly must address the consequences of delaying salvage of the mountain<br />

pine beetle infested timber stands.<br />

<strong>Response</strong><br />

The alternatives display a whole range of timber management levels. The comparison of the alternatives<br />

provides full consideration of these impacts.<br />

Comment<br />

The forest management plan for the Winema National Forest necessarily affects activities on private<br />

and other public lands, and these effects must be considered when analyzing the environmental impact<br />

of the alternatives.<br />

<strong>Response</strong><br />

These effects are discussed in Chapter 4 of the Final EIS.<br />

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Comment<br />

Webster's Third New International Dictionary defines criteria as 'a standard on which a decision or<br />

judgment may be based." Throughout the entire draft environmental impact statement the Winema<br />

National Forest never presents criteria or a standard by which the different alternatives can be evaluated.<br />

The entire draft environmental impact statement consists of comparisons among and between the<br />

alternatives until it is impossible to determine the underlying rationale of the comparisons.<br />

<strong>Response</strong><br />

The EIS has been rewritten so that it is more clear. The Record of Decision highlights key considerations<br />

in the decision.<br />

Comment<br />

The Winema National Forest draft EIS fails to explain why the preferred alternative was selected. This<br />

frustrates informed public participation in the decision making process. The discussion of the preferred<br />

alternative must be such as to allow meaningful analysis of this alternative compared to the other<br />

alternatives considered. 40 CFR 1502.9(a). Furthermore, the draft EIS must fulfill and satisfy the<br />

requirements established for final environmental impact statements by NEPA.<br />

<strong>Response</strong><br />

Chapter I now includes a complete discussion of each issue, the public input related to the issue and<br />

how the issue would be resolved under the preferred Forest Plan.<br />

Comment<br />

The Winema fails to address the effect that the timber supply from the Winema National Forest, considered<br />

in light of reductions in the timber supply projected from other national forests in the region, will have<br />

on the economic and social structure of the affected area The cumulative effect of region-wide reductions<br />

in the timber supply will be significantly greater than the effect of reductions from any single forest.<br />

<strong>Response</strong><br />

We have discussed what we know and do not know about this concern in Chapters 3 and 4 of the<br />

Final EIS.<br />

Comment<br />

The Winema National Forest uses sophisticated computer models to shield the decision making process<br />

from public scrutiny. Numerous models are used in the planning process, for example, DFSIM,<br />

PROGNOSIS, IMPLAN and, most importantly, FORPLAN. None of these models is adequately documented.<br />

The Winema must state the assumptions underlying each of these models and make the models<br />

available for public scrutiny.<br />

<strong>Response</strong><br />

The models are used to develop estimates of outputs and effects of various management alternatives<br />

so that reasonable decisions can be made. The DFSIM, PROGNOSIS, FORPLAN and IMPLAN models<br />

all have user manuals that are available for public review from several sources (the Supervisor's Office,<br />

the Regional Office, Forest Service Experiment station). The assumptions used in applying these models<br />

are documented in the Forest Planning process records in the Supervisor's Office. Appendix B of the<br />

EIS contains a general description of the analysis process used in the development of the Forest Plan.<br />

These models have also been scrutinized repeatedly by the public. For example a symposium was<br />

held in 1986 (FORPLAN: An Evaluation of A Forest Planning Tool) where representatives of the Forest<br />

Service, academia, Oak Ridge National Laboratory, Boise Cascade Corporation, British Columbia and<br />

others discussed the adequacy of FORPLAN.<br />

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Comment<br />

The Winema's analysis is therefore deficient in two respects; the public has no confidence in the data<br />

which goes into the FORPLAN model, and the Winema fails to discuss the consequences of the outputs<br />

of the model. Only by scrutinizing the inputs to the model, and the model itself, can the public or a<br />

reviewing court place faith in the model's output.<br />

<strong>Response</strong><br />

The data that we used is the best currently available. The consequences of the outputs are discussed<br />

in detail in Chapters 2 and 4 of the EIS. Chapter 4 also discusses reliability of the data and the estimates<br />

developed from it. The Planning Records contain voluminous data and support information, much of<br />

which is referenced in the EIS.<br />

Comment<br />

This chapter indicates that much of the information regarding the environmental consequences of the<br />

alternatives was already presented in Chapter II of the EIS. The description of the alternatives contained<br />

in Chapter II is an inappropriate location to place material regarding the environmental consequences<br />

of the alternatives. Furthermore, Chapter II of the draft EIS is composed primarily of exceedingly complex<br />

tables that convey little information to the reader regarding the environmental effects that implementation<br />

of any of the alternatives would have. Chapter II of the DEIS should be limited to a description of the<br />

alternatives themselves and Chapter IV should be rewritten to plainly and thoroughly describe the<br />

effects that implementation of the alternatives would have on the affected environment, not merely the<br />

results from the FORPLAN runs for each alternative.<br />

<strong>Response</strong><br />

The chapters have been rewritten for the Final EIS.<br />

Comment<br />

Is the land to be put to productive use for the benefit of the majority of people, or is it to be locked<br />

away in overly restrictive and unnecessary MMR's, visual management areas, and de facto wilderness?<br />

Because this is a principal issue in the forest planning process, the draft EIS must spend considerable<br />

effort addressing the issue.<br />

<strong>Response</strong><br />

The entire purpose of the EIS is to address these questions in an open forum with an opportunity for<br />

the public to comment and express their preference. Chapter 1 summarizes the broad range of public<br />

opinions on these issues and our <strong>Response</strong> to them.<br />

Comment<br />

Be more specific; does this call for an EA?<br />

What does 'normallym mean? Too subjective and vague for a standard.<br />

<strong>Response</strong><br />

Reference is to: Page IV-41, Draft Forest Plan, item 11 c.<br />

We agree, the standard is vague. The standard has been rewritten in the Final Forest Plan. Environmental<br />

analysis is conducted on all project level work. The analysis may be documented in an Environmental<br />

Impact Statement if the project would have a significant impact on the human environment. If no significant<br />

impact is found, the analysis is documented in an Environmental Assessment or categorically excluded<br />

from documentation.<br />

Comment<br />

Federal regulations for the implementation of the National Environmental Policy Act (40 CFR 1502.22)<br />

state that federal agencies in their preparation of- EIS documents 'shall include a worst case analysis<br />

and an indication of the probability or improbability of its occurrence' in cases of incomplete, uncertain<br />

or unavailable information concerning the environmental impacts of a proposed action. The WNF admits<br />

a clear lack of information on a variety of resource issues that would be affected by the PA, yet no<br />

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worst case analyses are presented. Worst case analyses need to be prepared for the following resource<br />

areas:<br />

1. Effects on the range and distribution of the full diversity of native plant communities on the WNF.<br />

Many areas remain incompletely known.<br />

2. Effects on the distribution and status of listed species of native plants and wildlife. Census data is<br />

incomplete or lacking for many areas and cumulative effects on rare species are poorly known.<br />

3. Effects on the structure and composition of naturally evolved old growth communities of a reduction<br />

far below existing levels.<br />

4. Effects of biocides on native plant, vertebrate, and invertebrate species.<br />

5. Effects of the proposed action on water quality and fisheries resources.<br />

6. Effects of destruction of dispersal corridors for old growth dependent species of low dispersal capacities.<br />

7. Effects of snag depletion on nesting wildlife.<br />

8. Effects of livestock and ORV-introduced noxious weed species on the structure, composition and<br />

diversity of native plant communities and listed plant species. This is barely addressed in the DEIS.<br />

<strong>Response</strong><br />

The regulations you reference have been changed. Such an analysis is not required. We have identified<br />

areas where information is incomplete or unavailable, but in no case do we consider any such information<br />

to be essential to a reasoned choice among alternatives.<br />

Comment<br />

A definition of standards is unfortunately missing from your documents, but the definition from the<br />

Wallowa-Whitman N.F. DEIS should be generally acceptable - la principle requiring a specific level of<br />

attainment, a rule against which to measure.' Frequently, the standards offered in the Plan are so vague<br />

and unquantified that they would be better described as goal statements, not standards. Reference to<br />

yet-to-be-developed plans or future project-level analysis is inappropriate. Standards and guidelines<br />

need to be more precisely defined, and their effectiveness as mitigation measures needs to discussed<br />

and documented. A similar lack of precision in the monitoring plan only compounds these problems.<br />

<strong>Response</strong><br />

We have rewritten the plan with your comments in mind.<br />

Comment<br />

The Tribe urges the Forest Service to continue conferring with tribal staff and ODFW staff to properly<br />

identify mule deer winter range and the appropriate amount of winter range to manage.<br />

<strong>Response</strong><br />

Our delineation of mule deer winter range was developed in concert with ODF&W.<br />

Comment<br />

NEPA requires that EIS's include mitigation. Without a detailed monitoring plan, it will be difficult for<br />

the Forest to comply with the Council on Environmental Quality's NEPA regulations which require that<br />

an EIS shall contain: 'means to mitigate adverse environmental impacts (40 CFR 1502.16(h)).' When<br />

adverse effects on water quality and fisheries are potentially significant, they must be mitigated. A<br />

detailed monitoring plan needs to accompany any proposed mitigation activity in order to measure its<br />

effectiveness and ensure that necessary corrections are implemented.<br />

<strong>Response</strong><br />

Chapter 4 has been rewritten to highlight mitigation. The Forest Plan contains a detailed monitoring<br />

plan (Chapter 5).<br />

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Comment<br />

Upgrading of BMPs or prescriptions to correct inaccurate predictions.<br />

<strong>Response</strong><br />

The BMP's have been rewritten and are included in Appendix H of the Final EIS and Appendix C of<br />

the Forest Plan.<br />

Comment<br />

Selection of BMPs for specific activities and how uncertainty is factored into selection.<br />

<strong>Response</strong><br />

See Appendix H of the Final EIS or Appendix C of the Forest Plan.<br />

Comment<br />

Best Management Practices (BMPs) and prescription development.<br />

<strong>Response</strong><br />

See Appendix H of the Final EIS or Appendix C of the Forest Plan.<br />

Comment<br />

On-site inspection and administration during an activity, verifying that a particular activity is occurring<br />

as prescribed in contracts, leases, or permits.<br />

<strong>Response</strong><br />

The Monitoring Plan (Chapter 5 of the Forest plan) addresses these concerns.<br />

Comment<br />

Detailed environmental monitoring (especially for water quality and fisheries) before, during, and after<br />

the completion of an activity to determine whether impacts were accurately predicted.<br />

<strong>Response</strong><br />

The Monitoring Plan (Chapter 5 of the Forest plan) addresses these concerns.<br />

Comment<br />

Built-in feedback mechanisms so that forest activities causing a problem can be corrected before they<br />

are allowed to continue.<br />

<strong>Response</strong><br />

The Monitoring Plan (Chapter 5 of the Forest plan) addresses these concerns.<br />

Comment<br />

A description of the data base for existing conditions from which technical experts and the public can<br />

judge the expected effects and level of uncertainty of the predictions.<br />

<strong>Response</strong><br />

The data describing the existing conditions is included in Chapter 3 of the Final EIS. The use of that<br />

data is discussed in Appendix B. The raw data itself is among the planning records.<br />

Comment<br />

The regulatory requirements in NEPA and the National Forest Management Act (NFMA) support the<br />

development of a detailed monitoring plan and feedback mechanism.<br />

<strong>Response</strong><br />

The Monitoring Plan (Chapter 5 of the Forest plan) addresses these concerns.<br />

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Comment<br />

IV-14 Para. 3. (and all other references). The term wild should replace native which would not include<br />

wild populations of brown and brook trout.<br />

<strong>Response</strong><br />

We will attempt to clarify this wherever it occurs.<br />

Comment<br />

It is not clear nor reasonable that the outputs and effects can be the same in all alternatives for recreation<br />

and visual resources (11-86 to 89), wildlife and fisheries resources (11-91 to 94), and soils, water and air<br />

resources (11-92) while at the same time the outputs are variable for timber resources (11-79 to 86), grazing<br />

(11-94), and transportation system (11-95 to 97).<br />

<strong>Response</strong><br />

Let's look at some of these areas. Developed Recreation use varies by alternative, but by the emphasis<br />

applied to developed recreation rather than by the emphasis applied to timber. This type of recreation<br />

can be supplied on small areas without interacting with timber outputs much. Likewise, downhill skiing<br />

relates to alternative approaches to the Pelican Butte Area (note that any proposals for Pelican Butte<br />

will be evaluated after the Forest plan is completed).<br />

In the case of dispersed recreation, we find that generally the capacity of the Forest to supply this<br />

type of recreation exceeds the anticipated demand for it. This anticipated demand level is a constant<br />

and it's basis is described in Chapter 3. Whenever capacity exceeds demand levels, the demand level<br />

is said to be equal to the use level which is reported in the tables. Thus any alternative where capacity<br />

exceeds projected demand has the same estimated use level. In the case of Wilderness, the acreage<br />

is constant across the alternatives so the estimated use levels are also constant.<br />

The visual quality objectives. do vary by alternative depending upon the emphasis given to that resource.<br />

Timber harvest levels generally decline as more emphasis is given to visual quality.<br />

Wildlife and fish use are estimated to be constant across alternatives. In the case of hunting, the use<br />

levels are lower than demand primarily due to projected static deer population levels and the potential<br />

for permit-only hunting in future decades.<br />

We have updated many of these estimates based upon the latest information on user demand as<br />

described in Chapter 3. We've also rewritten Chapter 2 to explain more about the basis of the displayed<br />

numbers.<br />

Comment<br />

We believe that the standards and guidelines for implementing a Forest Plan should provide detailed<br />

guidance on how all practices will be carried out in achieving the objectives of the Plan. Toward this<br />

end, your standards and guidelines appear strong in some places and weak in others. The Department<br />

of Agriculture found an excellent discussion on forest-wide standards and guidelines for range<br />

management, although they still have some suggestions for improvement. The Water Resources<br />

Department and ODFW, on the other hand, found significant weakness in the statement of quantifiable<br />

standards for measuring performance in statement about fish, wildlife, water, soil and air. The qualifiers<br />

that occur throughout these sections, such as Osome,O Osufficient,' and 'where neededo are subjective<br />

and do not allow for comparison.<br />

<strong>Response</strong><br />

The standards and guidelines in Chapter 4 of the Forest plan have been extensively rewritten with<br />

your comments in mind.<br />

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Comment<br />

We believe the purpose of a monitoring plan should be to establish methods and threshold levels for<br />

evaluating the direction, standards, and outputs of the Forest Plan. The State recommends that the<br />

Winema consider adopting the monitoring format just recently developed by the Regional Office.<br />

Because so much is unknown about the effects of management activities on different forest resources,<br />

we must rely on monitoring to provide early warning signals about activities having effects beyond<br />

acceptable limits. Therefore, we recommend that the budget for this monitoring be considered an<br />

integral part of the provision of outputs from the Forest.<br />

<strong>Response</strong><br />

We have revised the monitoring plan (Chapter 5 or the Forest Plan) to better deal with these issues.<br />

Budget estimates are provided for each item and are included in the overall budget estimate in the<br />

Forest Plan.<br />

Comment<br />

On 15 November 1984, the Regional Office briefed ODFW on Forest Planning. At this briefing, a document<br />

titled 'Forest Plan Contents (1983, USDA Forest Service)' was explained to ODFW. A reference from<br />

page 10 of the above document states:<br />

'Standards and guidelines state the bounds or constraints within which all practices will be<br />

carried out in achieving the planned objectives. Therefore, standards and guidelines should be<br />

measurable to be meaningful. There is little purpose in defining standards and guidelines for<br />

which no methods of measuring the degree of compliance or attainment exist.'<br />

ODFW is pleased to see that the Forest makes reference to the above paragraph. However, the standards<br />

and guidelines are too general to be meaningful. Although some protection is provided in Forest-wide<br />

water, soil, and air standards and guidelines, specific criteria should be formulated. ODFW is especially<br />

concerned with programming of timber harvest in riparian areas. There is inadequate concern for fish<br />

and wildlife and other riparian-dependent resources in the Range standard and guidelines. The degree<br />

of forage utilization is not stratified by vegetation type or by riparian condition. The 1979 interagency<br />

paper 'Managing Riparian Ecosystems (zones) in Eastern Oregon and Eastern Washington' is referred<br />

to as a standard in the Forest-wide standards and guidelines for fish and wildlife. Rather than referring<br />

to the publication, the Forest should mention specific criteria from it. The Forest should state specific<br />

time frames for achieving improved habitat conditions (see recommendations for Aquatic/Riparian<br />

Habitats).<br />

<strong>Response</strong><br />

We have rewritten many of the standards and guidelines to better address your concerns.<br />

Comment<br />

ODFW, therefore, recommends a strong set of specific standards be developed for the plan. By definition,<br />

a standard is a point to measure against or a basis for comparison. The qualifiers used (such as some,<br />

sufficient, where needed, significant, should, etc.) are subjective and do not allow for comparison. The<br />

Forest must develop clear and objective standards which would provide guidance for implementing<br />

the final plan.<br />

<strong>Response</strong><br />

See Chapter 4 of the Final Forest plan.<br />

Comment<br />

When terms are used that identify a type of direction or degree of restriction, the terms need to be<br />

defined. ODFW recommends that the Forest use the definitions (below) developed by the Siskiyou<br />

National Forest for four of the most often used terms. The Forest would need to define other terms<br />

used in the standards and guidelines that can be subjective in nature. (See letter for terms).<br />

<strong>Response</strong><br />

We have added additional definitions.<br />

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Comment<br />

The proposed monitoring plan is too general to be useful because it is based on standards and guidelines<br />

that are themselves general. Specific criteria must be selected and a threshold for changes that trigger<br />

action must be identified.<br />

ODFW recommends the Forest develop a monitoring plan that establishes specific methods, frequence,<br />

and threshold levels.<br />

<strong>Response</strong><br />

We have redeveloped the monitoring plan. See Chapter 5 of the Forest Plan.<br />

Comment<br />

The 'No Change' Alternative appears to be a compromise approach that could present a true, unaltered<br />

historical reference for public review in the DEIS. However, the Winema has rendered this reference<br />

point meaningless by providing limited output information for this alternative. For example, Tables S2<br />

and I11-A showing resource outputs and environmental effects by alternative has repeated omissions<br />

where data was not provided. The DEIS states that '...outputs and effects of this alternative are derived<br />

in a variety of ways. If an estimate was supplied in the [1 978] Timber Resource Plan then this figure is<br />

used. Other outputs and effects are estimated based on similarities between the 'No Change' Alternative<br />

and Alternative A the 'No Action' Alternative. In some cases no estimates are provided if there is no<br />

information on which to base an estimate...'<br />

Even though the information may be outdated or of unknown precision, it should have been included.<br />

The purpose of the alternative is to allow the public to directly compare management under the existing<br />

plan with management under the proposed alternatives as required by NEPA. By not providing this<br />

data, the Winema has failed to present a true 'No-Action' Alternative for public review.<br />

We have included information about Alternative NC where it exists or where it could be reasonably<br />

estimated on some basis. Estimates without a basis are useless in comparison of alternatives so rather<br />

than be misleading in the comparisons we chose simply to state that the item was 'not estimated.'<br />

<strong>Response</strong><br />

We have included information about Alternative NC where it exists or where it could be reasonably<br />

estimated on some basis. Estimates without a basis are useless in comparison of alternatives so rather<br />

than be misleading in the comparisons we chose simply to sate that the item was 'not estimated.'<br />

Comment<br />

How much does this minimum management emphasis duplicate similar management provided by<br />

other management areas such as Scenic Management (Area 3), Special Interest Areas (Area 4) Wildlife<br />

Habitats (Area 7, 8, 9, and 10) or Research Natural Areas (Area 13)? Additional information on the<br />

types and acreages to be protected by retaining these lands in their present condition and the purpose<br />

for this minimum management emphasis needs to be explained and made available for public review.<br />

Analysis should also present acreages and values withdrawn from productive range and timber lands<br />

in order to provide this protection.<br />

<strong>Response</strong><br />

The minimum level management area (Management Area 14) duplicates none of the other areas. It's<br />

main purpose is to provide the minimum levels of stewardship necessary to avoid damage to the inherent<br />

resource (e.g. soil productivity). It is generally used for lands which are not suitable for furthering the<br />

intent of the alternative. In Alternative J, for example, these are generally small segments of the general<br />

Forest area, outside of important visual zones, that are unsuitable for timber production. No other<br />

management area would be appropriate for these types of lands.<br />

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Comment<br />

Management Area 14 (DEIS, page 11-72,11-75; App., D-104) Little discussion is provided as to criteria or<br />

forest conditions that would necessitate placing an area in this management category. Management<br />

Area 14 is described as a minimum management area that may be applied to any area of the forest or<br />

to the entire forest however the conditions that are being protected are not clear and seem to be inclusive<br />

of other management areas. Table 11-2 shows 8.6 percent of the total forest proposed forthis management<br />

emphasis under the preferred Alternative E. The map for this alternative indicates an additional 1.25<br />

percent in special management areas totaling nearly 10 percent in these categories.<br />

Explanation is not provided as to the qualities that are being protected by each of these withdrawals.<br />

<strong>Response</strong><br />

Management Area 14 can apply to any part of the Forest where the management is intended only to<br />

protect inherent resources and not to manage them in a proactive sense. In alternatives with a significant<br />

level of management, including alternatives E and J, these are generally lands that are in the general<br />

Forest area, but are unsuitable for timber production. Since they are not particularly suited to recreation<br />

or wildlife use and they are not in critical visual zones, they are simply set aside and protected from<br />

damage. An example would be unvegetated rocky areas, each only a few acres in size.<br />

Comment<br />

There is little or no reason why most acres of National Forest land cannot produce timber products,<br />

clean water, wildlife, forage and quality recreation if the forest management professional does the job<br />

we have all been trained to do. Allocation of areas to principal uses is a cop out; it eliminates first the<br />

hard decisions that we can make.<br />

<strong>Response</strong><br />

A review of the standards and guidelines associated with each management area (Chapter 4 of the<br />

Forest Plan) reveals that various mixes of these resources come from most of them. In some cases<br />

certain uses are excluded because of critical conflicts with other uses or because the types of land do<br />

not lend themselves to one use or another.<br />

Comment<br />

A general deficiency we have observed in many draft plans has been the implicit assumption that all<br />

adverse environmental impacts result from timber harvest, grazing or other human activities on the<br />

land. Almost universally, the Forests have ignored the fact that natural events, such as catastrophic<br />

fires and floods, can have far greater impact on environmental values than a well-designed and<br />

implemented timber management program. Invariably, the 'environmentally preferable' alternative has<br />

been the one that has the largest roadless management acreage and lowest timber harvest level. Both<br />

the public and Forest Service decision makers need to know: (1) that the environmental effects of<br />

non-management can be as bad as, or even worse than, the effects of planned management activities;<br />

and (2) that an active timber management program can significantly reduce the risk of catastrophic<br />

natural events.<br />

<strong>Response</strong><br />

The variations in effects of the different alternatives on fire, insect and disease are discussed in Chapter<br />

4 of the FEIS. The general relationships between fire, insects and disease and aspects of Forest<br />

management are discussed in Chapter 3. Catastrophic events such as major floods or volcanic events<br />

are equally likely to occur under any alternative and speculation about them would not help in the<br />

selection of one alternative over another.<br />

Comment<br />

Monitoring-The proposed monitoring program may be ineffective because of its immediate reliance on<br />

Plan amendments and revisions in case Plan objectives are not attained. Amendments and revisions<br />

require a full EIS process, are outside the supervisor's authority, and higher Forest Service officials<br />

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may be reluctant to authorize them. The monitoring program should specify which actions will be taken<br />

in case of problems with Plan implementation.<br />

<strong>Response</strong><br />

The monitoring plan (Chapter 5 of the Forest Plan) has been rewritten. Implementation of other Forest<br />

Plans has revealed that amendments and revisions are commonly approved.<br />

Comment<br />

Page 111-18, para. 3. The final document should list the acreages associated with each of the Forest's<br />

10 major plan communities. Acreages for the six successional states should also be provided in order<br />

to assess impacts of the alternatives on the existing environment.<br />

<strong>Response</strong><br />

Acreage percents of the various plan communities and successional stages are displayed in Chapter<br />

3 of the FEIS.<br />

Comment<br />

The Park should be included in the affected environment section since the Park and the Forest have<br />

over 32 miles of common boundary. It is important that Crater Lake NP be included as part of the<br />

affected environment and impacts of each alternative described. In light of the 1916 Organic Act, Public<br />

Law 97-250 and the 1978 Redwood Act, it is felt that both the PLRMP and the DEIS inadequately address<br />

protection and preservation of NPS resources.<br />

<strong>Response</strong><br />

We have rewritten Chapters 3 and 4 of the EIS. The relationship of various resources to Crater Lake<br />

National Park are included in the discussions.<br />

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Range<br />

Comment<br />

I cannot find figures for Range use receipts and direct costs. Table IV-2 shows average costs for first<br />

decade of $4,700. What was the actual costs for 1985. Require range users to fence off riparian and<br />

seeded or planted areas.<br />

<strong>Response</strong><br />

Range use receipts and direct cost are not included. Implementation decade costs have been revised.<br />

Range users are not required to build fence though they have a part in maintenance. Costs of resource<br />

protection are born by the resource in question. Standards and guidelines have been revised to emphasize<br />

riparian area protection.<br />

Comment<br />

I advocate that better domestic grazing management be adopted by the plan including:<br />

1. prescribed seasons of use<br />

2. grazing systems fitted to the allotments<br />

3. exclusion of livestock from areas already in poor condition<br />

We want to see more done to prevent damage from overgrazing, like prescribed seasons of use and<br />

exclusion of livestock from riparian areas in poor condition from grazing. Winema Forest has many<br />

fishing streams in substandard shape that could produce far more fish if managed well.<br />

The plan should a) prescribe seasons of use, grazing systems, and improvements by individual allotments<br />

and b) SHOULD EXCLUDE LIVESTOCK FROM RIPARIAN AREAS THAT ARE IN POOR CONDITION.<br />

<strong>Response</strong><br />

The Forest Planning process does not prescribe this level of detail. This is done in the Allotment<br />

Management Plans. The allotment management plans currently in place on the Winema have prescribed<br />

seasons of use, grazing systems and allow for the exclusion of livestock or resting a portion of the<br />

allotment to improve conditions. A current range analysis needs to be conducted on all our allotments<br />

and range management plans updated at which time trends in range condition will be reviewed, seasons<br />

of use changed if needed, grazing systems changed or modified if warranted and prescriptions for<br />

management of riparian areas within allotments developed that may exclude livestock partially or totally<br />

until such time as the riparian areas are in a condition such that they can be managed with livestock.<br />

Comment<br />

I am also concerned with the current and proposed levels of grazing on the forest particularly in the<br />

riparian areas. Many of these areas are severely over-grazed. Many studies have been done showing<br />

the importance of NOT GRAZING the riparian areas at all. These same studies show that cattle will<br />

utilize the rest of the allotment more efficiently, and at the same time stream flows, clarity, and water<br />

temperature will improve dramatically. The benefits to fish, wildlife, and the watershed are tremendous.<br />

The AUMs on the Winema need to be drastically reduced, with an elimination of riparian grazing.<br />

<strong>Response</strong><br />

The allotment management plans currently in place on the Winema have prescribed seasons of use,<br />

grazing systems and allow for the exclusion of livestock or resting a portion of the allotment to improve<br />

conditions. A current range analysis may need to be conducted on all our allotments and range<br />

management plans updated at which time trends in range condition will be reviewed, seasons of use<br />

changed if needed, grazing systems changed or modified if warranted and prescriptions for management<br />

of riparian areas within allotments developed that may exclude livestock partially or totally until such<br />

time as the riparian areas are in a condition such that they can be managed with livestock. This has<br />

been identified as an information need in the Final Forest Plan.<br />

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Comment<br />

A complete assessment of environmental impacts of grazing should be done by the Forest Service,<br />

and no grazing should be allowed in riparian areas in poor condition.<br />

<strong>Response</strong><br />

Whenever a range allotment management plan is re-written or updated, an environmental analysis is<br />

the first step in the process and management of riparian areas will receive top priority consideration.<br />

Comment<br />

Overgrazing is still a problem on national forest lands particularly in riparian zones. Fencing and elimination<br />

of grazing from certain allotments has helped restore some areas. However, I believe we should establish<br />

and rigidly enforce procedures to control grazing on each allotment to preclude overgrazing, improve<br />

overgrazed allotments and exclude livestock from riparian areas which are in poor condition from<br />

overgrazing.<br />

<strong>Response</strong><br />

The allotment management plans establish forage use levels that should prevent overgrazing any portion<br />

of an allotment. Through the administration of the Grazing Permit and the Allotment Plan, livestock are<br />

managed to insure appropriate grazing objectives.<br />

Comment<br />

Overgrazing of livestock on our public lands should cease.<br />

<strong>Response</strong><br />

In all alternatives of the DEIS, forage allocations are such that a percentage of the total available forage<br />

is allocated for wildlife, a percentage for livestock, both permitted, and recreation use and a percentage<br />

of the welfare of the forage plant. None of the alternatives allocate all the forage to either wildlife or<br />

livestock. With proper administration of grazing permits and well prepared management plans, overgrazing<br />

on the Winema should not be a problem.<br />

Comment<br />

There should be a full assessment made of the environmental impacts of grazing. The plan should<br />

prescribe seasons of use, grazing systems, and improvements by individual allotment.<br />

<strong>Response</strong><br />

Whenever a range allotment management plan is re-written or updated, an environmental analysis is<br />

the first step in the process and management of riparian areas will receive top priority consideration.<br />

Comment<br />

While on this subject of overuse, I think cattle grazing should be phased out. The damage to riparian<br />

areas is extensive.<br />

<strong>Response</strong><br />

Grazing has been an accepted and encouraged use of National Forest land since the inception of the<br />

Forest Service in 1897. The science of range management has continually improved since that time,<br />

too. For many years, the Winema range conservationist, in cooperation with ranching permittees, have<br />

built water developments away from the riparian environments and have fenced out cattle from riparian<br />

zones.<br />

Comment<br />

I propose that the Forest Service do a full assessment of the environmental impact of grazing. Grazing<br />

in riparian areas in poor condition should be prohibited.<br />

<strong>Response</strong><br />

Whenever a range allotment management plan is re-written or updated, an environmental assessment<br />

is the first step in the process and management of riparian areas will receive top priority consideration.<br />

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Comment<br />

How can Management Area 11 be properly considered if it is used to provide high levels of forage<br />

under only one alternative; and that is not the Preferred Alternative. How many of the 335,000 acres of<br />

suitable range lands are allocated in each alternative? How do we know where the acres for the 13,055<br />

AUM's are?<br />

<strong>Response</strong><br />

The theme of Alternative C was to provide high levels of timber and forage production. The assumption<br />

behind the other alternatives was that demand for forage could easily be met so no emphasis was<br />

placed on its production.<br />

No alternative assumed using the full 330,000 acres of suitable range land.<br />

The 13,055 AUM's are produced on the 22 active allotments on the Forest which are identified in Chapter<br />

3.<br />

Comment<br />

*The Forest has the capabilities to produce several times the demand for livestock forage for the planning<br />

horizon," (11-71). What is the total production of forage on the Forest? What is the average per acre per<br />

year production of forage on the suitable and available acres? How many AUM's have been allocated<br />

to big game? How may AUM's, if any, are allocated to other wildlife for any type of habitat?<br />

<strong>Response</strong><br />

Total forage production on the Forest is about 67,500 tons. Part of this production is on low production<br />

areas that may not be cost effective to use. Average production per acre varies widely from less than<br />

100 pounds per acre to more than 1000 pounds per acre. Of the total forage production 60% has<br />

been allocated to forage plant maintenance 20% to big game and other wildlife and 20% to livestock<br />

when there are no conflicts with wildlife.<br />

Comment<br />

The DEIS-LRMP seems to have taken a 'doomsday' approach to livestock grazing. 'The livestock grazing<br />

program on the Winema National Forest will, in all probability, continue its present decline due to poor<br />

economic conditions of the livestock industry,' (IV-27). The industry must be assured, by the Forest,<br />

that the AUM's will be available for an increase, when the market changes direction.<br />

With America's increasing population the Forest is making no effort to help provide for an increased<br />

production of red meat. Why this lack of concern?<br />

<strong>Response</strong><br />

Most of the livestock grazing on the Forest is associated with riparian areas. In the future the livestock<br />

industry will have to compete more with other uses of these areas. Livestock grazing will be balanced<br />

with other resource values.<br />

Comment<br />

Grazing? Why should grazing of domestic animals on public land be allowed as all? Let's put grazing<br />

on moratorium for 10 years!! The grazing laws are archaic. This is 1988, not 1938. Our public areas<br />

are going to have pressures of all kinds this next few decades. There is no money in it for the State or<br />

the Government. If we the had to pay for damage grazing has done. It would far outweigh the revenue<br />

from it.<br />

Historically, grazing has been the rights of a very few that didn't really infringe on the rights of many.<br />

That's not true anymore. Some unbiased studies should be done this next decade. For example, eliminate<br />

grazing in one area, allowing it in another -- let's not just think and argue -- let's know!! In ten years<br />

we could really know -- Maybe. Let's keep grazing out of any forest that has a pumice floor. Livestock<br />

congregate - always - and when they do they overgraze. Let's let wildlife graze it, then the nation benefits.<br />

Livestock grazing tends to be alien to the natural diversity. Livestock grazing is not cost efficient to the<br />

government and also tends to be a subsidy to a privileged few. Considering the damage from grazing<br />

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the the soils, riparian zones, and the competition to wildlife - grazing should be reduced and eventually<br />

eliminated. There also needs to be special efforts to reduce the impact of cattle on the riparian zones.<br />

<strong>Response</strong><br />

Grazing has been an accepted and encouraged use of National Forest land since the inception of the<br />

Forest Service in 1897. The science of range management has continually improved since that time,<br />

too.<br />

For many years, Winema range conservationists, in cooperation with ranching permittees, have built<br />

water developments away from the riparian environments and have fenced out cattle from riparian<br />

zones.<br />

In all alternatives of the DEIS, forage allocations were such that a percentage of the total available<br />

forage was allocated for wildlife and a percentage for livestock. None of the alternatives allocated all<br />

the forage to either wildlife or livestock. With proper administration of grazing permits and well prepared<br />

management plans, overgrazing on the Winema should not be a problem.<br />

The allotment management plans currently in place on the Winema have prescribed seasons of use,<br />

grazing systems and allow for the exclusion of livestock or resting a portion of the allotment to improve<br />

conditions. A current range analysis may need to be conducted on all our allotments and range<br />

management plans updated at which time trends in range condition will be reviewed, seasons of use<br />

changed if needed, grazing systems changed or modified if warranted and prescriptions for management<br />

of riparian areas within allotments developed that may exclude livestock partially or totally until such<br />

time as the riparian areas are in a condition such that they can be managed with livestock. There are<br />

also equally as many studies that show the riparian areas can be managed with livestock and will<br />

flourish. Stream flows can be increased, water quality improved and fish and wildlife benefit from proper<br />

livestock management.<br />

There are currently more livestock AUMs permitted on the Winema N.F. than are being utilized. This<br />

trend has been true for the past several years. Many livestock operators have been grazing much less<br />

than the permitted numbers. In some allotments, no livestock grazing has occurred for several years.<br />

Grazing laws and grazing fees are outside the jurisdiction of the Winema National Forest.<br />

Comment<br />

In reviewing the proposed Land and Resources Management Plan, I see that most of the land in the<br />

Dam's Meadow and Switchback allotments that is open enough for good grazing is classified as either<br />

Area 3, Scenic Management or Area 14, Minimum Management. I thought that the scenic management<br />

could be a problem, but was not concerned about the minimum management until I read the Draft<br />

Environmental Impact Statement. It said grazing was usually not compatible with this area, then I saw<br />

in the Appendices that grazing would be discontinued in Area 14, although it was admitted that grazing<br />

was not doing any damage. If this is implemented, in my opinion, the main result to the Forest would<br />

be a greater fire danger. It would be impractical to fence each area, so it seems to me the only alternatives<br />

other than complete removal of cattle, are to stop grazing about half of each allotment, which would<br />

require a lot of expensive fencing, or continue using them in more or less the same way as is presently<br />

being done.<br />

In the interest of highway safety, a goal should be added to state: Grazing cattle should be separated<br />

from major transportation corridors wherever possible for public safety.<br />

<strong>Response</strong><br />

A scenic management classification in the Dam's Meadow and Switchback allotments should only<br />

affect grazing to the extent that structural improvements blend into the environment, (see page D-44 in<br />

the Appendix of the DEIS under Range). This would typically be a concern in the foreground areas<br />

only along the Switchback Road and State Highway 140.<br />

Final Forest Plan recognizes livestock grazing as a legitimate use of the Forest. The Forest plan will<br />

generally not eliminate livestock grazing where there are no conflicts. Utilization standards and season<br />

of use may be more restrictive for livestock grazing, but each area will have to be evaluated on a case<br />

by case basis. This will be done as allotment management plans are updated and revised.<br />

The Forest Plan sets standards and guidelines, the individual allotment management plan sets specific<br />

goals and objectives for each allotment. As individual allotment plans are updated and revised, if there<br />

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are major highway corridors, and livestock are presenting a health and safety problems, fencing highway<br />

right-of-ways, and other control measures will be considered to eliminate the above problems.<br />

Comment<br />

We want you to do a full E.I.S. on the impacts of grazing. We also want a total halt to grazing in riparian<br />

areas.<br />

<strong>Response</strong><br />

Livestock grazing and other Forest Management Activities are being covered under this Environmental<br />

Impact Statement. Forest Standards and Guidelines set the direction for livestock grazing on the Forest.<br />

Allotment Management Plans set specific direction for individual allotments. Livestock are a management<br />

tool that can be used to maintain the desired vegetative condition for plant communities. Livestock if<br />

presenting a problem will be excluded, and/or restricted on the amount of forage they are allowed to<br />

use, and the time that they can graze the above areas.<br />

The Environmental Impact Statement on the Forest Plan is considered to be an umbrella document<br />

which guides project level planning (see the plan implementation section of the Forest Plan for additional<br />

information. An Environmental Assessment will be prepared for each allotment plan which is updated<br />

or revised. One of the purposes for preparing an Environmental Assessment is to determine the need<br />

for a full EIS. If the finding in the EA is that there will be no significant impact on the human environment,<br />

an EIS is not prepared. Generally this is the case with allotment plans.<br />

Comment<br />

We are also aware of the damage that can and has Forest Service to include specific prescriptions for<br />

grazing that will be mutually beneficial to wildlife and livestock in the final LRMP. We further ask that<br />

the prescriptions afford particular attention to current and potential damage in riparian ares and winter<br />

range. We will comment further under Riparian Areas.<br />

<strong>Response</strong><br />

Allotment Management plans, as they are updated and revised to conform to Standards and guidelines<br />

in the Forest Plan, will prescribe the amount of forage that can be harvested from riparian areas by<br />

livestock. The condition of the riparian plant community in the individual allotment will determine the<br />

degree of utilization allowed, Utilization levels may range from total exclusion of livestock to 40% of the<br />

current year's growth. Annual grazing plans will prescribe interim direction until the allotment management<br />

plan is updated, and provide yearly direction to the revised allotment management plans as these<br />

plans are completed. Forest standards and guidelines for forage allocation and livestock use in riparian<br />

zones will be established based on a blending of total resources in the Final Forest Plan.<br />

Comment<br />

We ask the final LRMP address grazing management plans with priorities toward reducing conflicts<br />

detrimental to wildlife and recreational activities.<br />

We generally support the management proposals in the draft plan. Wre do believe that careful selective<br />

logging in riparian areas can be accomplished and cannot only assist in correct riparian management<br />

but also can prevent waste of timber output on these very productive sites. Studies in Arizona and<br />

Central Oregon indicate that modern grazing management systems can improve quality and increase<br />

vegetation production better than elimination of grazing. We urge that such techniques be reviewed<br />

and installed.<br />

<strong>Response</strong><br />

Allotment Management Plans as they are revised and updated according to the<br />

Final Forest Plan will prescribe livestock grazing to minimize conflicts with other resource users and<br />

activities, and blend total resource uses and resources to compliment each other.<br />

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Comment<br />

Studies in Arizona and Central Oregon indicate that modern grazing management systems can improve<br />

quality and increase vegetation production better than elimination of grazing. We urge that such<br />

techniques be reviewed and installed.<br />

<strong>Response</strong><br />

Yes we are aware of these studies and will consider the results during the allotment planning process.<br />

Comment<br />

I feel that the Forest should take advantage of opportunities to convert some of the existing cattle<br />

allotments on these districts to sheep allotments for the following reasons: (1) sheep are controlled by<br />

herders; (2) sheep are less dependent on riparian areas and consequently have less negative impacts<br />

on riparian areas; (3) there are less range improvements needed on sheep allotments (fencing) and so<br />

costs will be less in construction and maintenance; (4) better utilization of forage occurs and little if<br />

any abuse occurs on the total range allotment; (5) Bitterbrush stands can be maintained in a more<br />

usable condition for wildlife, and most of the understory component on the Chiloquin and Chemult<br />

District is Bitterbrush.<br />

<strong>Response</strong><br />

The Forest Plan establishes guidelines for converting types of livestock on individual allotments. These<br />

guidelines place priorities for converting types of livestock based on: present type of livestock is not<br />

meeting forage utilization goals and objectives, present type of livestock is creating and/or contributing<br />

to resource damage, another type of livestock will meet other resource goals and objectives, and status<br />

of allotment. Analysis of individual allotments will determine the need to change existing type of livestock,<br />

followed by a revision and update of the individual allotment management plan.<br />

Comment<br />

The other part of range is noxious weed control and it is felt that due to logging activity and minimum<br />

investment in noxious weed control, the Forest is setting itself up for future lawsuits in the Sprague<br />

River and Hildebrand area from adjoining private landowners. There needs to be two funding levels<br />

established for noxious weed control and containment. One funding level for manual and biological<br />

control and one funding level if herbicide use is available and allowable. Another area the Forest should<br />

monitor is the Klamath District where landownerships are intermingled or the Forest joins private lands.<br />

It is felt the minimum investment should be set at between $10,000 to $14,000 for manual and biological<br />

control and containment, and about $7,000 for the use of herbicides if their use is allowed. Again, I<br />

feel staffing and funding needs to be increased for better monitoring and getting a quality job done.<br />

<strong>Response</strong><br />

Noxious Weed Control will continue to be a legitimate activity on the Forest. A Forest Noxious Weed<br />

Control Plan in cooperation with the Klamath County Weed and Rodent Control and State of Oregon,<br />

Department of Agriculture-Noxious Weed Control. The plan establishes a base level for requesting<br />

funding, priority of weed species to control, level of control, and type of control methods that may be<br />

used. It also provides guidelines for an annual work plan, define responsibilities of individual agencies<br />

and groups involved in noxious weed control.<br />

t<br />

Comment<br />

In the Environmental Consequences section of the DEIS, the discussion of the effects of grazing on<br />

other resources is extremely scanty and inadequate. The effects on native plant communities is not<br />

even mentioned, yet many negative effects have been documented, including alteration of native<br />

community structure, elimination of vulnerable species, introduction of exotic invasive weed species<br />

that out compete native species, destruction of the vital moss-lichen soil cover layer, and loss of soil<br />

substrates by increased erosion. None of these effects are mentioned nor is there any mention of how<br />

effects on native vegetation will be monitored or mitigated, other than the extremely vague range condition<br />

monitoring program.<br />

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<strong>Response</strong><br />

Allotment management plans identify the livestock grazing prescription to be used in maintaining and/or<br />

improving the condition and trend of the plant communities, areas that are sensitive or that need special<br />

protection are identified, and the necessary measures are implemented through a combination of range<br />

improvements and levels of forage utilization which can range from total exclusion of livestock to 40%<br />

utilization. Annual Grazing Plans provide follow-up direction to the allotment management plan. There<br />

are other studies that show that proper livestock grazing can be used to maintain the integrity of plant<br />

communities (ex. Leonard Volland's 'Condition and Trends in The Bluegrass Plant Communities').<br />

The Forest Plan sets the overall direction and priorities for areas to be grazed or to be restricted from<br />

grazing. The revised and updated allotment management plans follow guidelines established in the<br />

Forest Management Plan.<br />

Soil Erosion and soil movement as a result of livestock grazing except for very few areas on the Forest<br />

has not been recognized as a major problem. Corrective measures are being implemented to deal<br />

with these situations. This includes exclusion of livestock by fencing, watershed structures, and/or less<br />

forage allowed to be utilized by livestock, and season of use adjustments which further restrict the<br />

time livestock are allowed to graze a particular area within an allotment.<br />

Comment<br />

We strongly object to the proposed continuation of the overgrazing substantial portions of the Wilderness<br />

Areas on the Winema National Forest. It should be WNF policy to not renew livestock grazing leases in<br />

wilderness areas when they expire, as livestock directly conflict with primary wilderness resources. We<br />

request that the WNF immediately begin this process by relocating all allotments that are in less than<br />

good condition to transitory range in timber management ares outside the Wilderness.<br />

<strong>Response</strong><br />

The Forest's wilderness areas do not have any livestock allotments located within their boundaries.<br />

The final Forest Plan does not allocate any areas inside the wilderness areas for domestic livestock<br />

grazing other than recreational and Packer stock use.<br />

Comment<br />

Effects of the alternatives, the preferred Alternative E included, do not address the social and economic<br />

impact to the permittees that currently utilize the forage resource of the Winema National Forest. No<br />

reasoning is provided to justify the reduction in the 19,000 AUM's currently allowed to the 13,000 AUM's<br />

presently utilized other than the current economic condition of the livestock industry. Provisions should<br />

be made in the plan to allow for the full utilization of the 19,000 AUM's currently allowed when economic<br />

conditions improve.<br />

<strong>Response</strong><br />

The Final Forest Plan sets and implements the standards and guidelines for livestock use on the Forest.<br />

Livestock use will be blended with other resource uses and needs. Forage allocation for livestock will<br />

be determined on an allotment by allotment basis, through updated range analysis, and revised and<br />

updated allotment management plans, and livestock Head Months may be increased or decreased<br />

depending on the condition and trend of the forage base, wildlife needs, watershed protection, sensitive<br />

areas identified on the individual allotment.<br />

The Final Forest Plan and EIS have been modified to reflect that the 13 thousand AUM's is only an<br />

estimate of current use. Existing allotment plans establish 19,000 AUM's as the upper limit available for<br />

livestock use on the Forest. This remains the upper limit until allotment plans are updated.<br />

Comment<br />

Range management (Management Area 11) is excluded from the management area's section of the<br />

Proposed Land Resource Management Plan, and is included only in the appendices. Further, we object<br />

to the proposal that all grazing activities be discontinued in Management Area 14. This is impractical<br />

in areas where livestock grazing is interspersed with Management Area 14 areas.<br />

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<strong>Response</strong><br />

Final Forest Plan recognizes livestock as a legitimate use of National Forest Lands, in some of the<br />

required management areas livestock use will continue to be allowed, forage utilization guidelines may<br />

be restricted in these areas, depending on the needs of the specific required management area. Livestock<br />

will be recognized as a forage management tool and will be utilized to maintain and/or improve the<br />

forage resource of the required management areas.<br />

Management Area 11 is not included in the plan because it was not part of the preferred alternative.<br />

However, this does not preclude grazing under most other management areas.<br />

Comment<br />

Alternative E (Preferred Alternative) does not include range management in the alternative design criteria.<br />

The exclusion of range management does not allow the current permittees an opportunity to review or<br />

respond to the proposed Alternative E (section 11, page 50).<br />

<strong>Response</strong><br />

Range management was not included in the alternative design criteria, because the Forest felt that it<br />

could meet current and future range needs and demands without implementing special design criteria<br />

for range management.<br />

Range management was not excluded from Alternative E, however no lands were allocated to<br />

Management Area 11 in this alternative.<br />

Comment<br />

We are concerned with, and object to, the inference throughout the plan that domestic livestock grazing<br />

should be excluded from tree plantations by fencing. This is not in line with well-documented research<br />

conducted by land grant universities and applied practices of private forest companies. Both have<br />

demonstrated that livestock grazing is compatible with tree plantations and that grazing of tree plantations<br />

will increase tree production by reducing vegetation competition.<br />

<strong>Response</strong><br />

The Final Forest Plan continues to recognize livestock as a legitimate use of Forest Lands. Standards<br />

and Guidelines for livestock grazing in tree plantations will be based on the age of the plantation, the<br />

type of forage available, the amount of livestock related damage to tree plantations that is acceptable,<br />

and the ability of the individual permittee to manage his(her) livestock in the plantations. Fencing will<br />

be one tool to control livestock use in tree plantations to minimize conflicts, and meet management<br />

requirements for both livestock and other resources.<br />

Comment<br />

The range standards and guidelines fail to address the competition and interaction between livestock<br />

and wildlife; whether a proper amount of forage is allocated to livestock given the needed improvement<br />

of deer habitat; and what effect allocation of forage to livestock has on tribal treaty rights. The forest<br />

needs to provide the animal unit forage equivalents for deer, elk and cattle. Each of these issues must<br />

be analyzed and discussed before the final plan is adopted. If analysis indicates a shift in allocation of<br />

range resources is necessary to protect tribal rights, the final plan should include necessary amendments.<br />

<strong>Response</strong><br />

Forest Standards and guidelines take into account in the allocation of the forage resource that livestock<br />

are not the only users of forage. The allocation of forage is based first on the needs of plant communities<br />

to maintain or improve condition and trend of the communities, soil stability is accounted for, wildlife<br />

needs are considered, and then any available forage remaining is allocated for livestock. Livestock are<br />

one of several management tools available to keep the forage resource in the most usable state for<br />

wildlife.<br />

Those allotments located on former reservation lands, as the allotment management plans are updated<br />

and revised, will consider allocating forage to domestic livestock so that conflicts are minimized and/or<br />

eliminated.<br />

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Comment<br />

What kind of habitat improvement projects are effective in improving damage done by livestock grazing?<br />

How has their effectiveness been demonstrated?<br />

Restriction of domestic livestock grazing, timber harvest, or road construction in areas adjacent to<br />

streams and wetlands is described as a mitigation measure. The FEIS/Plan should include an explanation<br />

of how these measures will be implemented (e.g. allotment plan and timber sale contract conditions).<br />

<strong>Response</strong><br />

Habitat improvement projects that can restore damaged areas include exclusion of livestock by fencing,<br />

placing barriers, developing other water sources, revegetation with plant species preferred by wildlife,<br />

and not necessarily by livestock. Monitoring of habitat improvement projects annually determines the<br />

effectiveness of the project. Any shortcomings and/or falldowns are rioted and necessary corrective<br />

measures are implemented so that those particular projects are successful, and future projects can be<br />

implemented without repeating past mistakes. (The Forest Service provides opportunities for its employees<br />

to make suggestions in improving all types of projects so that projects are successful. Forest Service'<br />

Manuals and Handbooks establish additional standards and guidelines that have proven to be the<br />

most successful over a number of years in developing habitat improvements.)<br />

Comment<br />

An allotment map and summary information by allotment on existing and planned uses, upland and<br />

riparian ecological condition and trend, and planned improvements showing method and time frame<br />

should be provided in the plan.<br />

<strong>Response</strong><br />

The Forest submits a Range Area and Allotment Classification Report to the Region, this report identifies<br />

those allotments that are underdeveloped, allotments that are in good condition, allotments where<br />

resource damage is occurring. At the present time, there are 23 allotments, 17 are rated as quality<br />

extensive, four allotments are vacant, two allotments rated as underdeveloped, management strategy<br />

for the allotments has been identified as extensive management of the environment and livestock.<br />

Three of the vacant allotments may not be stocked again due to potential conflicts with other resources.<br />

The Forest Plan establishes standards and guidelines, the allotment management plan provides priority<br />

to the improvements needed on the allotment, annual management plans provide annual direction in<br />

developing improvements on the individual allotment based on funding, improvement priority as compared<br />

to other allotments on the District. The annual grazing plan also provides annual direction in dealing<br />

with problem areas on the allotment. Allotment Management Plans are periodically updated and revised<br />

to keep management of the allotment current so that existing problems and any potential problems<br />

can be dealt with. Allotment Maps are updated at this time, so that changes on the allotment can be<br />

made.<br />

Comment<br />

The plan does not display the location (map), condition and trend of watersheds and livestock allotments,<br />

and identify lands in less than satisfactory condition and plans for restoration and rehabilitation.<br />

<strong>Response</strong><br />

The Forest Plan establishes and provides the standards and guidelines for overall management of<br />

allotments on the Forest, the allotment management plan provides the specific direction for individual<br />

allotments, based on Forest Standards and Guidelines, Annual Management Plans provide annual<br />

direction to the grazing permittee using the Forest S&G's, and allotment management plan direction.<br />

Allotment Management Plans are updated periodically to keep allotment management current with the<br />

Forest S & G's, and any changes needed in management to accomplish the S & G's. Maps are a part<br />

of the Allotment Management Plan, and the Annual Grazing Plan, and used at the project.<br />

K - 89

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Comment<br />

Trout unlimited recommends that the Forest eliminate grazing on the Sycan River in accordance with<br />

the statement in the Fremont N.F. plan (p.54) that this action is a prerequisite for meeting the objectives<br />

of restoring water quality and good ecological riparian condition to that river.<br />

<strong>Response</strong><br />

The Forest Plan establishes necessary coordination with adjoining Forests on management of shared<br />

resources, and in this case the Fremont Forest is the lead forest for management of the Sycan River.<br />

The River Management Plan for the Sycan River establishes the specific direction for other uses that<br />

will be allowed on the Sycan River Corridor as established by legislation, regulations, and agreed to<br />

by the involved Forests and other user groups. If livestock use is determined to be a non-compatible<br />

use, then it will be restricted from the Sycan River Corridor.<br />

Comment<br />

The Forest needs to display allotment data as required in Forest planning -36DFR219.20- 'A. Lands<br />

suitable for grazing and browsing shall be identified and their condition and trend shall be determined'<br />

and 'lands in less than satisfactory condition shall be identified and appropriate action planned for<br />

restoration.<br />

<strong>Response</strong><br />

The FEIS has been updated to include this data.<br />

Comment<br />

An allotment map with accompanying tables showing permitted uses would be helpful in our analysis.<br />

<strong>Response</strong><br />

The FEIS has been updated to include this information.<br />

Comment<br />

The plan states that attention will be given to improving conditions, particularly in riparian areas. The<br />

State of Oregon supports the Forest's effort to properly manage and restore riparian areas. Standards<br />

and guidelines presented in the DEIS have identified a number of management strategies for improving<br />

range and riparian conditions. Due to the intense interest in riparian management, however, proposed<br />

systems of grazing management and associated practices should be more completely detailed in the<br />

plan.<br />

<strong>Response</strong><br />

Grazing systems and practices are tools used to achieve desired conditions. These are appropriate<br />

addressed in Allotment Mangement Plans rather than at the Forest Plan level.<br />

Comment<br />

One potential method of riparian rehabilitation listed in the DEIS is elimination or reduction of livestock<br />

in those areas. While specific riparian areas may require reduced grazing or exclusion of livestock for<br />

some period to promote resource recovery, the Forest should not overlook use of livestock as 'resource<br />

management tools' to meet riparian and forage goals. In addition, fencing to provide seasonal exclusion,<br />

development of alternative watering facilities, and placement of salt away from riparian areas can reduce<br />

the impact of livestock grazing on riparian zones. See the Department of Agriculture's comments for<br />

more details.<br />

<strong>Response</strong><br />

All the methods mentioned are appropiate tools to distribute livestock use. These are addressed in the<br />

Allotment Management Plans.<br />

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Comment<br />

Fall green up should be reserved for big game productivity and survival. Livestock use on winter and<br />

transition ranges should be discontinued after June 30 and September 30, respectively. The shrub<br />

component of these ranges need management emphasis to provide browse for big game. Prescribed<br />

fire in MA1 0 should only be used as a tool for needed habitat improvement. Ending dates for livestock<br />

use and restrictions on underburning must be included in Forest-wide standards and guidelines.<br />

ODFW recommends grazing curtailment on big game winter ranges after June 30; reservation of fall<br />

green up on transition ranges after September 30 for big game; no grazing of riparian zones in less<br />

than good condition; and protection of water sources. Special protection measures will be necessary<br />

to ensure successful aspen regeneration.<br />

<strong>Response</strong><br />

At the present time permitted livestock grazing does not extend past September 30, on transition ranges.<br />

Permitted Grazing on Winter Range is generally off by the middle of September. Livestock grazing is a<br />

tool that is available to keep the browse in a vegetative state that is more usable for big game. Monitoring<br />

of livestock use on winter ranges determines whether or not browse is being maintained for wildlife.<br />

Season of Use is adjusted accordingly when conflicts between livestock and big game use is occurring.<br />

To this date, livestock use on big game winter range has not been identified as a problem because<br />

low numbers of big game using the winter range, and there is only one active allotment on the currently<br />

recognized big game winter range on the Forest. Livestock use on underburned areas is deferred for<br />

at least one grazing season and usually two seasons. Allowing livestock to utilize underburned areas<br />

depends on, time of fire, fire intensity (cold/hot), condition of the understory plant community after the<br />

fire.<br />

Comment<br />

ODFW is concerned about the absence of grazing allotment data. An allotment map and summary<br />

tables with essential information by allotment (see General Comments) should be provided for comparison<br />

with on-the-ground conditions. ODFW is particularly interested in plans to correct resource damage<br />

problems, with a time frame for planned improvements.<br />

<strong>Response</strong><br />

An allotment map and associated tables have been added to the FEIS. A timeframe for Allotment<br />

Management Plan Revision Update has been included in Chapter 5 of the Forest Plan.<br />

Comment<br />

In some areas, much of the livestock use on the Forest takes place in riparian areas. Riparian areas<br />

are also one of the most important habitats on the Forest for wildlife. Reduction of ground cover and<br />

shrubs in riparian areas can, and has, significantly reduced habitat potential for wildlife. FSM 2526<br />

policy gives preferential consideration to riparian-dependent resources over non-dependent resources.<br />

Allotment plans need to emphasize wildlife values.<br />

<strong>Response</strong><br />

Standards and Guidelines have been developed to emphasize riparian and wildlife values.<br />

Comment<br />

P.111-52.<br />

Range Management. The DEIS states that two types of primary rangelands exist on the Forest: bitterbrush<br />

and meadows. Most of the meadows are described as riparian. To what extent are other rangelands<br />

(i.e., uplands or transitory range) available to reduce grazing pressure on riparian areas? (DEIS 111-52).<br />

<strong>Response</strong><br />

Some upland areas are available for livestock use on the Forest, other areas may not be available due<br />

to other resource priorities. Those areas available may not be used presently due to lack of water,<br />

these areas are being identified in project work (ex. Timber Sale Assessments, Revising and Updating<br />

of Allotment Management Plans). Other considerations in allowing livestock use on these areas, are<br />

K - 91

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soil conditions, plant phenology, type of forage available, and other resource uses and priorities. The<br />

Forest's primary type of transitory and/or upland range is the LPIBB or PP/BB plant associations.<br />

Comment<br />

P.111-53.<br />

(Paragraph 1). The results of the 20 years of range studies should be summarized and included it in<br />

the final EIS. (See Recommendations and General Comments).<br />

(Paragraph 2). When were the Williamson River and Sycan River fenced, and how much has been<br />

fenced? (DEIS 111-53-1):. Areas of the upper Williamson River are still part of grazing allotments.<br />

Unauthorized livestock use in the fenced areas is a continuing problem.<br />

(Paragraph 4). Early range users had little concept of or regard for water quality and fish and wildlife<br />

resources, nor for forage and soils.<br />

Significant Interactions. (Sentence 2) Add fish habitat and water quality to the list of impacts from<br />

concentrated livestock grazing in riparian zones.<br />

How many over-use problem areas are there on the Forest? (DEIS 111-53-2). How big are the problem<br />

areas, and where are they? (DEIS 111-53-3).<br />

<strong>Response</strong><br />

Range Studies are a project level work activity. The Forest Plan sets Standards and Guidelines in<br />

monitoring range activities according to FSH 2209.01.<br />

Area Ecologists have described ecological sites, and ecological ratings for plant communities, these<br />

will be incorporated into monitoring activities, so management for the desired seral plant community<br />

and ecological condition can be achieved.<br />

The Williamson River has four and one half miles of fence constructed since 1979, The Sycan River<br />

has had approximately 2 1/2 miles constructed during the same time frame. More fencing is being<br />

planned to help control livestock. In addition, more personnel are being brought on to deal with<br />

non-permitted livestock use, along with other violations occurring on the Forest.<br />

Exceeding utilization standards varies from year to year, this is dependent on climatic conditions, plant<br />

development, permitted livestock numbers, and permit compliance.<br />

Comment<br />

P.111-54.<br />

(Paragraph 4). The Forest needs to take more steps to reduce conflicts between livestock and riparian<br />

and aquatic habitats. How much of a reduction has there been in degradation of water through<br />

management practices? (DEIS 111-54).<br />

<strong>Response</strong><br />

Increased emphasis has been placed on Riparian Management in the FEIS. The statement of reduction<br />

in water quality was a stalemate of judgement. No hard data is available quantitative changes due to<br />

management practices.<br />

Comment<br />

P.IV-42.<br />

(Paragraph 1). 'None of the alternatives make any investment in range improvements." Why has the<br />

Forest made this decision? (DEIS IV42). The Forest states that some streambanks are in a degraded<br />

condition, new tree plantations may need fencing, and RNA's will need protection from grazing. Are<br />

the range allotments fully developed and improved to meet the proposed stocking level? (DEIS IV-42).<br />

<strong>Response</strong><br />

The Forest plan will invest in range improvements, as AMP's are revised and updated, priorities will be<br />

established for range improvements on existing allotments, based on riparian and sensitive areas that<br />

need protection, water developments needed for both livestock and wildlife, fencing systems needed<br />

for movement and control of livestock. Priorities for improvement construction will be based on range<br />

area-classification report.<br />

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Comment<br />

B-76.<br />

(Paragraph 1). How much of the Forest is managed for intensive range production? (App.B-76).<br />

<strong>Response</strong><br />

None of the Forest is managed for intensive range at the present time.<br />

Comment<br />

D-10. Range<br />

1. The DEIS states that most of the grazing on the Forest occurs in 'riparian areas which are composed<br />

of meadows and mosic lodgepole pine communities.1 In light of this fact range allotment plans should<br />

emphasize fish and wildlife species.<br />

<strong>Response</strong><br />

Increased emphasis has been placed on Riparian Management in the FEIS.<br />

Comment<br />

D-96. Range 1.<br />

Forage utilization levels need to address objectives to improve range conditions.<br />

<strong>Response</strong><br />

Forage utilization standards are set which are in effect until site-specific information is available through<br />

range analysis. The utilization standards, if implemented, should provide for range condition improvement.<br />

Comment<br />

PP IV-128<br />

Range. How will the Forest effectively remove cattle from the MA 14 allocations? (PP IV-128).<br />

<strong>Response</strong><br />

The Forest Plan has been revised. Grazing is allowed in MA 14 if compatible with other resources.<br />

Comment<br />

PP V-1 1.<br />

14. All problem allotments need ongoing monitoring and evaluation.<br />

<strong>Response</strong><br />

Monitoring of problem areas will be addressed in the development of AMPs.<br />

Comment<br />

Livestock Grazing Program, IV-27: The objectives for improving the range resource, particularly riparian<br />

areas, should be structured to yield multiple-resource benefits to water resources in addition to wildlife<br />

habitat, water quality, and livestock grazing. The secondary benefits accruing to water resources,<br />

specifically better distribution of seasonal discharge, improved ground water storage capacity, and<br />

enhancement of stream structure may result from the management emphasis. However, these elements<br />

should be included and receive, if not equal treatment, at the very least recognition of their importance<br />

to watershed integrity.<br />

The emphasis on water development to distribute range animals is commendable and consistent with<br />

what the Department recognizes as best management practices. But 'the program should also examine<br />

other best management practices such as alternative stocking rates and seasonal use of riparian areas<br />

which can increase forage utilization by livestock and yet maintain riparian zone stability and vegetative<br />

vigor. Minimal maintenance design should not preclude use of enclosures where necessary to maintain<br />

or enhance riparian conditions.<br />

<strong>Response</strong><br />

Increased emphasis has been placed on Riparian Management in the FEIS.<br />

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Comment<br />

The LRMP states that 'The livestock grazing program on the Winema will in all probability continue in<br />

its present decline due to the poor economic conditions of the livestock industry. When this statement<br />

was no-doubt written, the livestock industry was experiencing low market prices and herd reductions<br />

nationwide. As is common to the cyclical nature of this industry, however, that trend has reversed and<br />

market conditions have improved. Whether or not this will create a demand for increased grazing on<br />

the Winema is unknown, but it would seem shortsighted to base projections for long term AUM availability<br />

on the short term economic vagaries of an industry with such historically cyclical market conditions.<br />

<strong>Response</strong><br />

As of the FEIS no allowable permit requests have been made. Demand for grazing on the Winema as<br />

represented by permit requests has declined.<br />

Comment<br />

The excellent discussion of forestwide standards and guidelines for range management contained in<br />

the DEIS, addresses several of the concepts mentioned above. This discussion is extremely helpful in<br />

gaining an understanding of the forest range management program. We found it interesting, however,<br />

that the LRMP should state that 'range improvements... will emphasize water developments' (page<br />

IV-27), but that the DEIS states 'No alternatives make any investments in range improvements' (page<br />

IV42). Construction of water developments, in our experience, generally requires some investment of<br />

time and resources.<br />

<strong>Response</strong><br />

The Forest plan will invest in range improvements, as AMP's are revised and updated, priorities will be<br />

established for range improvements on existing allotments, based on riparian and sensitive areas that<br />

need protection, water developments needed for both livestock and wildlife, fencing systems needed<br />

for movement and control of livestock. Priorities for improvement construction will be based on range<br />

area-classification report.<br />

Comment<br />

The department is enthusiastic about the cooperative agreement with the Klamath County Weed Board<br />

to maintain inventory records, prepare an annual plan for control of noxious weeds and provide a<br />

coordinated effort to control these pests in Klamath County. It would seem appropriate to provide at<br />

least an outline of that weed control plan in the DEIS.<br />

<strong>Response</strong><br />

A Noxious Weed Plan has been developed in cooperation with Klamath County Weed and Rodent<br />

Control and the State of Oregon, Department of Agriculture - Noxious Weed Control.<br />

Comment<br />

The Sycan River and the Williamson River Gorge should be recommended for inclusion in the Wild &<br />

Scenic Rivers program. The preferred alternative refers to both these areas in glowing terms as regards<br />

their scenic value, and designation as 'wild and scenic' would provide protection to these values and<br />

riparian areas also.<br />

<strong>Response</strong><br />

Portions of the Sycan River have been legislatively designated as Wild and Scenic.<br />

K - 94

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Comment<br />

The Plan should contain a map of grazing allotments. Forage should be allocated by allotment. Grazing<br />

systems should be prescribed by allotment. Utilization levels should be discussed by allotment. Key<br />

indicator species should be identified by pasture and allotment. The existing condition and trend should<br />

be identified by pasture and allotment. The predicted condition and trend should be identified by pasture<br />

and allotment for each alternative, and each pasture and allotment should have specific range<br />

management actions prescribed in the EIS. The construction standards for rangeland developments<br />

should be in the plan.<br />

Grazing is a major federal action. The Forest does not have the option of deferring grazing decisions<br />

to Allotment Management Plans.<br />

<strong>Response</strong><br />

A general map of allotments has been included in Chapter 3, FEIS. The detailed information requested<br />

is largely unavailable and is, in any case, more appropriately addressed in Allotment Management<br />

Plans after Range Analysis. The AMP is the tool to address site-specific items and as pasture management<br />

and improvement standards.<br />

Comment<br />

Page B-75, para. 3. The final plan should address how much forage would be left for native wildlife.<br />

<strong>Response</strong><br />

40% of total forage is allocated to grazing by wildlife and livestock. 20% is allocated to livestock if no<br />

conflicts occur with wildlife.<br />

K - 95

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Recreation<br />

Comment<br />

I, then, fully urge that each of the following areas and acres as located on the Winema National Forest<br />

only, be dedicated as Wilderness; as each such area with acres feature superb wilderness attributes,<br />

and to be added to our National Wilderness Preservation system at this time:<br />

AREA<br />

ACRES<br />

Aspen 1,500<br />

Badlands 910<br />

Brown Mountain 3,600<br />

Clover 490<br />

Marsh 1,275<br />

North Boundary 805<br />

Odessa 180<br />

Sky Lakes 19,450<br />

Devil's Garden 595<br />

West Boundary 2,950<br />

Mount Thielsen 3,020<br />

Yamsay 7,815<br />

... plus an additional 110,000 acres. So as to establish a total of some 246,000 acres of dedicated<br />

wilderness to be located on the Winema National Forest, only; and to be included in our National<br />

Wilderness Preservation System, at this time.<br />

To include rivers, streams - creeks in our National Wild and Scenic River System. Including the following<br />

rivers: Williamson, Sycan, and Sprague.<br />

<strong>Response</strong><br />

All of the areas mentioned were evaluated during the R.A.R.E. II (Roadless Area Review Evaluation)<br />

process and were found to be lacking critical attributes for their inclusion into the National Forest<br />

Wilderness System. These areas were again considered during the formulation of the 1984 Oregon<br />

Wilderness Bill and were not included. No additional areas on the Forest have been identified in inventory<br />

as being suitable for wilderness designation. No additional wilderness is being recommended in the<br />

Preferred Alternative, although portions of the areas mentioned will continue to be managed in their<br />

current roadless condition as shown in Appendix C of the FEIS.<br />

The Sycan River has been added to the National Wild and Scenic River System by Congress since the<br />

DEIS was released. The Williamson and Sprague Rivers were not found to have outstanding remarkable<br />

features so classification was not recommended. However, the Williamson River Gorge will be managed<br />

as a "Unique AreaN with no harvest and a recreation, wildlife and watershed emphasis.<br />

Comment<br />

Many recreational assets have been attributed to the high standard road system being built to service<br />

the timber projects, in which you know that we have little interest. The plans have closed 90% or more<br />

of these after the timber is cut. How do you explain this contradiction.<br />

<strong>Response</strong><br />

The Winema's high standard road system has been previously constructed and in place for many<br />

years. Very little of this road system has been closed after the timber sale, but has remained open to<br />

provide long term access for administrative, public, and recreational purposes. Almost all of the roads<br />

being built now are low standard timber access road only, and no major recreational assets have been<br />

identified in the written road objectives. The roads that have been blocked to use have been identified<br />

K - 96

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as intermittent or temporary road needs. These roads have been closed or blocked for a variety of<br />

reasons, including reduction of open road densities in wildlife areas, reduction of road maintenance<br />

expenditures, for re-establishment of vegetation, and for protection of resources.<br />

Comment<br />

These commentators mentioned various aspects of development of the Intertie Trail including various<br />

combinations of the following:<br />

Why is the intertie trail that would connect the Pacific Crest Trail to the Desert Trail omitted in the plan?<br />

The east-west intertie trail must not end at the Winema Boundary.<br />

I would urge you to complete the east west intertie trail from the Desert Trail to the Pacific Crest Trail.<br />

Five miles of new trail is totally inadequate. The proposed management plan does not address the<br />

needs of people who wish to use the Forest for recreation now and in the future.<br />

<strong>Response</strong><br />

The Preferred Alternative in the DEIS proposed that the Intertie Trail be only minimally developed primarily<br />

using existing roads and route markers. Due to the strong support voiced by the public during the<br />

comment period, this trail has been added to the Activity Schedule in the Forest Plan. Funding will be<br />

requested to complete a feasibility study which will determine the best trail location and construction<br />

standards to meet public needs. The trail will ultimately tie the proposed Fremont National Recreation<br />

Trail to the Pacific Crest Trail completing the Desert Trail to PCT intertie.<br />

Comment<br />

Although the Williamson River above the Klamath Marsh in not included as a candidate for inclusion in<br />

the Federal Wild and Scenic System, I believe it qualifies for designation as a 'recreation river" under<br />

the system and urge that such a recommendation be included in the plan.<br />

<strong>Response</strong><br />

The Forest found that portions of the Williamson River above Irving Creek were free flowing, but identified<br />

no Noutstandingly remarkable feature' that would qualify the river for inclusion in the National Wild and<br />

Scenic River System, so in accordance with the Act the analysis process did not continue to the<br />

classification process. Please see Appendix E of the EIS for details of the study process.<br />

Comment<br />

Brown Mountain: in the preferred alternative it is allocated to a semiprimitive recreation strategy; this is<br />

interpreted to be NON-motorized recreation.<br />

<strong>Response</strong><br />

The allocation in the Preferred Alternative for Brown Mountain is semiprimitive non-motorized in the<br />

summer and motorized in the winter which permits use by over-the-snow vehicles.<br />

Comment<br />

Finally, regarding wilderness, I have strong concern that the existing group-size limits in Sky Lakes<br />

Wilderness Area be maintained. I understand that the Forest Service is receiving pressure to open the<br />

area up to large groups, particularly those on horses. I have nothing at all against horse groups in the<br />

wilderness area, but I feel that these areas were, as the law states, set aside for human use--but use<br />

that is compatible with keeping the opportunity to experience solitude...an increasingly rare and valuable<br />

commodity in the ever-more crowded world of the late 20th and early 21 st centuries.<br />

<strong>Response</strong><br />

Maximum party size and livestock limits are established for each wilderness and wilderness setting<br />

based on vegetation and soil impacts and social factors, such as number of expected encounters with<br />

other parties. These group size limits are displayed in the Standards and Guidelines for Management<br />

Area 6 - Wilderness in Chapter 4 of the Forest Plan. A monitoring program will be used to determine if<br />

these limits are sufficient to meet resource protection and solitude guidelines.<br />

K - 97

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Comment<br />

What is the difference between recreation use and recreation demand? I am not asking about supply<br />

and demand.<br />

<strong>Response</strong><br />

Recreation demand is projected future recreation use based on a given set of population, demographic,<br />

and activity participation rate assumptions.<br />

Comment<br />

Table 111-25 shows Dispersed Recreation use at 197,500 RVD's, in 1983. Table 11-1 shows Dispersed<br />

Recreation use at 310,000 RVD's, in 1986 thru 1990. What made the RVD's increase 57 percent from<br />

1983 to 1986 and not show another increase until 1990?<br />

<strong>Response</strong><br />

Table 11-1 in the Draft Forest Plan showed projected dispersed recreation RVD's from the R-6 Regional<br />

Guide. The 310,000 RVD's was the decade annual average for 1986-1995 and should not have been<br />

displayed as use for any single year except for the decade mid-point 1990. This figure also included<br />

wilderness use that was not included in the 197,500 RVD's displayed in the DEIS. These tables have<br />

beentrevised to-more clearly compare projected with current use.<br />

Comment<br />

What are the definitions for Developed Rural and Developed Roaded Natural? The Glossary defines<br />

Developed Recreation as; 'Outdoor recreation requiring significant capital investment in facilities to<br />

handle a concentration of visitors on a relatively small area. Examples are down hill ski areas, resorts,<br />

and campgrounds.' I believe that definitions will conflict or one will find that Oa relatively small area' will<br />

be quite large; or one can ask Arelatively small' as compared to what?<br />

<strong>Response</strong><br />

The terms refer to recreation use occurring in developed sites within the 'Rural' and 'Roaded Natural'<br />

Recreation Opportunity Spectrum (ROS) Classes. The ROS classification is based on the extent to<br />

which the natural environment has been modified, the type of facilities provided, the degree of outdoor<br />

skills needed to enjoy the area, and the relative density of recreation use. Each class is described in<br />

the Glossary.<br />

The areas allocated to Developed Recreation are 'relatively small' as compared to the of acres allocated<br />

to all other uses of the National Forest. All alternatives allocate less than one percent of the Forest to<br />

this management area.<br />

Comment<br />

'Standards and Guidelines should be measurable to be meaningful,' (D-1). Yet I cannot find one place<br />

where the criteria is given to determine the social carrying capacities (Persons at one time, PAOT), for<br />

wilderness, roadless or developed recreation areas. This also applies to annual capacities.<br />

<strong>Response</strong><br />

From the Recreation Information Handbook (page 121.22--12-13), the 'People at One Time' (PAOT)<br />

criteria for developed sites capacities are as follow:<br />

A. Developed Sites. Enter the number of persons at one time the site, as presently developed, can<br />

safely and reasonably accommodate.<br />

There is no absolute measure of the capacity of a site in terms of the number of persons who can or<br />

should use it at one time. The estimate must be made on a judgment basis, taking into consideration<br />

environmental factors and matters related to human health and safely. Do not deliberately include<br />

overuse which will impair the the developments or the surrounding forest atmosphere. The following<br />

are guidelines:<br />

(1) For campgrounds and picnic grounds, multiply the total number of camping or picnicking<br />

units by 5.<br />

K - 98

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(2) For organization camps, hotels, lodges, resorts, and recreation residences, estimate<br />

overnight capacity. Overnight capacity may be measured by a pillow count. Include the<br />

capacity of any day-use facilities surplus to the requirements of overnight guest.<br />

(3) For other commercial-public-service sites, swimming sites, boating sites, winter-sports<br />

sites, interpretive and information sites, and observation sites, enter the safe capacity of<br />

the key facility which first acts to limit or govern use that is, for restaurants, the seating<br />

capacity; for swimming sites, the beach area, bathhouse, or parking lot capacity; for boating<br />

sites, the dock or parking lot capacity; for winter-sports sites, the capacity of parking lots,<br />

spectator space, and/or uphill equipment.<br />

For wildernesses and roadless areas the capacities are estimates based on the amount of use that is<br />

observed to cause resource damage or to exceed social criteria such as numbers of other parties<br />

encountered or other campsites visible. The guidelines in the 1986 ROS Book, which is part of the<br />

process records for the FEIS, were used to develop area capacities. Since these capacities are derived<br />

more subjectively, use will be monitored to refine estimates.<br />

Comment<br />

In Table 111-32, the RVD capacity does not appear to be even close to realistic numbers, assuming<br />

those are annual capacities. I believe the RVD's shown in this table are less than 20 percent ofithe<br />

annual carrying capacity.<br />

<strong>Response</strong><br />

These capacities were developed based on both resource capabilities and social factors, such as<br />

solitude measured by frequency of encounters with other groups and visibility of other campsites. The<br />

capacities are further limited by the short duration of the major use season for these areas.<br />

Comment<br />

How far is '2 days of cross-country travel,' (D-79). It must be measurable to be meaningful.<br />

<strong>Response</strong><br />

This definition of Primitive Trailless areas has been superseded by the Pristine WRS class described in<br />

the Standards and Guidelines for Management Area 6 - Wilderness. The reference to '2 days travel'<br />

was dropped from the definition.<br />

Comment<br />

For the DEIS-LRMP to be meaningful to the reviewing public, it must contain the necessary information<br />

for the reviewer to arrive at conclusions without referring to the Forest Service libraries. Page D-70<br />

refers to FSM 2320, R6 Supplement 56, 11/81. I checked with Fremont N.F. staff and they said that it<br />

appears that this Supplement is outdated and no longer exists. What prevented the Management<br />

Standards from being included in the DEIS-LRMP?<br />

<strong>Response</strong><br />

The referenced Supplement was superseded by FSM 2320, R-6 Supplement 81, 4/87. The direction<br />

contained in this supplement has been incorporated into the Standards and Guidelines for Management<br />

Area 6 - Wilderness in the Forest Plan.<br />

Comment<br />

Wilderness areas were established for the primitive recreation user, yet the Forest Service proposes<br />

to: Restrict types of use; limit length of stay; close campsites; restrict numbers of campers; allow only<br />

day use; and eliminate fish stocking.<br />

Has the Resource Manager yet realized the primary cause of visitor problems, in wilderness areas,<br />

stem from developed trails? From some level of authority the land manager believes that there is an<br />

obligation to lead the user through the wilderness by the hand; and that Big Brother must protect the<br />

user from himself.<br />

K - 99

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<strong>Response</strong><br />

Wildernesses were not only established for the primitive recreation user, they have another objective<br />

and that is as a biological reservoir..OValuable for it's scientific and educational uses, and as a benchmark<br />

for ecological studies.. managed.. to ensure that human influence does not impede the free play of<br />

natural forces or interfere with natural successions in the ecosystem..' The restrictions on visitor use<br />

mentioned are to ensure that human influence does not negatively impact the wilderness environment.<br />

Trails, likewise, are management tools to manage visitor use to minimize impacts and to facilitate public<br />

access for folks with a wide variety of capabilities.<br />

Comment<br />

The thirteen roadless areas discussed in Appendix C contain 32,218 acres,as shown in Table C-2.<br />

However Table C-8 has over allocated acres form a low of 26,694 acres in Alternative C to a high of<br />

193,570 acres in Alternative G. Is it possible that these Acres should have read RVD's?<br />

If these are RVD's, no Standards or Guidelines are given to support the numbers listed. There is no<br />

correlation between Tables 0-6 and C-8, and I am sure that there should be one.<br />

<strong>Response</strong><br />

Table2C-8 did have a number of errors. Since it duplicated much of the information presented in Table<br />

C-6, the table was not included in the FEIS.<br />

Comment<br />

I find it very odd that in nearly every case none of the potential uses, for the several roadless areas, is<br />

in current use, according to Table C-5. Current recreation uses appear to be just a guess, and some<br />

aren't even a good guess.<br />

<strong>Response</strong><br />

Displaying information graphically can sometimes lead to the assumption that the variables being<br />

monitored are discrete; it is the nature of graphic display. Logic tells us that undoubtedly the 'potential<br />

usesw shown may also be happening. A particular management area could be listed in the 'current<br />

uses' section too. Some of the 'potential uses' listed can only occur legally if the management prescription<br />

for a specific area is changed in an alternative.<br />

Comment<br />

There was no logical reason given for allocating 1,857 acres of the Brown Mountain roadless area to<br />

semiprimitive non-motorized recreation, in Alternative E. The west side of the Forest is so heavy with<br />

roadless areas now, that it is about ready to topple into the ocean. It is the type of logic used with<br />

Brown Mountain that makes other decisions in the DEIS-LRMP suspect.<br />

<strong>Response</strong><br />

The allocation of semiprimitive non-motorized in summer and motorized in winter provides for recreation<br />

activities in an undeveloped setting which are not permissible within wilderness, such as snowmobiling.<br />

Very little semiprimitive area exists on the Forest outside of wilderness.<br />

Comment<br />

The Badlands Roadless Areas is in the Cowboy Burn salvage area and is no longer roadless. This<br />

new input should change the acres you have calculated as existing roadless.<br />

<strong>Response</strong><br />

No new roads were constructed to fight the Cowboy Fire, some dozer trails were put in to cut a fireline.<br />

Some new roads and spurs have been constructed to facilitate timber salvage operations. No new<br />

roads were put into the Badlands Roadless Area. All dozer trails are being rehabilitated and returned<br />

to a natural state.<br />

K - 100

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Comment<br />

There is only mention of dispersed recreation facilities on Kiamath District. These facilities should also<br />

be located on Chemult and Chiloquin Districts.<br />

<strong>Response</strong><br />

The Activity Schedules for recreation facility and trail construction in the Forest Plan proposes facilities<br />

to support dispersed recreation on all three Districts.<br />

Comment<br />

There is no new trails construction slated for the first five decades. There could be trails built into the<br />

Williamson River Gorge and Devils Gardens. There probably are other scenic areas at Chemult also.<br />

<strong>Response</strong><br />

In the FEIS preferred alternative new trails are being planned on all the Districts. Refer to the Trail<br />

Construction Activity Schedule for a list of proposed projects.<br />

Comment<br />

It is gratifying to find numerous references to snowmobiling, directly or implied, in the management<br />

areas most obviously appropriate, such as Areas #1, 2, 2A, 2B, 2C and 14. (Chap. IV - Forest Management<br />

Direction). In other areas such as 3, 4, and 7, recreation is not completely ignored, but described in<br />

vague or indefinite terms. Should we assume snowmobiling will or will not be permitted in these areas?<br />

The Plan for Area 12, Timber Production, (important because of it's size) does say specifically that 'a<br />

variety of dispersed recreation activities will be permitted (IV - 121). Since dispersed recreation as<br />

defined in 11-10, 11-1 1, and 111-6 includes spectrum classes in which snowmobiling is acceptable, we<br />

assume it is permitted, but would feel more comfortable with a more specific reference.<br />

<strong>Response</strong><br />

The standards and guidelines for Management Area 3 (Scenic Management) specifies these areas will<br />

be managed to the standard of semiprimitive motorized or roaded natural recreation opportunity spectrum<br />

classes and Management Area 12 (Timber Production) will be managed as roaded modified. Snowmobiling<br />

use is encouraged in these ROS classes.<br />

In Management Area 4 (Unique Areas), recreation activities will be managed through site-specific<br />

management plans to prevent degradation of the special interest resource. However, no snowmobile<br />

use restrictions are anticipated at this time. Snowmobiling will not be encouraged in Management<br />

Areas 7, 9 and 10 which have wildlife emphases and prohibited within MA 6 (Wilderness).<br />

Comment<br />

Facilities Forestwide Standards and Guidelines (IV-60) describes the anticipated closing of roads no<br />

longer needed. Can such roads be used for snowmobiling? Just as some trails are built or improved<br />

by snowmobile clubs, perhaps these could be maintained by users to the extent needed, with some<br />

even being groomed. We assume new roads can be used for recreation which conforms to the Plan<br />

for the specific area involved.<br />

<strong>Response</strong><br />

The roads which are designated as no longer needed, and intended to closed, have no identified<br />

future needs such as timber access or recreation uses, including snowmobiling. These roads are almost<br />

exclusively low standard short length roads, many of which dead end or duplicate other access available.<br />

In most cases, such roads could be used for snowmobiling if the need were identified. The road would<br />

be managed to provide for this use in cooperation with user groups.<br />

Comment<br />

Finally, we note the terms 'snowmobile groups, (IV-33), 'all-terrain vehicles' (IV-33) and *off-road vehicles'<br />

(1-3) are all used. (Yet another term, *over-the-snow vehicles' is used in certain other publications).<br />

We suggest there may be places where a specific, rather than a general term should be used, since<br />

conditions appropriate for some all-terrain vehicles are different than for others.<br />

K- 101

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<strong>Response</strong><br />

The terms 'snowmobile,' wall terrain vehicle' and 'off road vehicle' refer to different types of vehicles in<br />

the Plan (e.g. snowmobiles, three wheelers and four wheel drive vehicles, respectively) and were not<br />

supposed to have been used interchangeably.<br />

Comment<br />

The Forest-wide standards and guidelines should specify a higher level of trail protection and restoration.<br />

The trail system can no longer be allowed to be destroyed by other management activities.<br />

<strong>Response</strong><br />

Protection of existing facilities and investments, such as trails, is an on-going consideration and<br />

requirement when conducting all management activities, and in the environmental analysis for specific<br />

projects or timber sales, if there is an identified need or concern. Protection of existing facilities and<br />

investments is also included within the provisions of contract requirements when accomplishing forest<br />

management activities. Standards and guidelines addressing protection of trails have been added to<br />

Chapter 5 of the Forest Plan.<br />

Comment<br />

The recent report from the President's Commission of Americans Outdoors identifies this area as among<br />

the most rapidly growing segments of outdoor recreation. The proposed plan will reduce the opportunities<br />

for primitive recreation, eventually displacing all roadless recreation into the Mountain Lakes and Sky<br />

Lakes Wildernesses.<br />

<strong>Response</strong><br />

All lands on the Winema National Forest capable of producing primitive recreation opportunities as<br />

defined in the ROS standards are within existing wilderness. The FEIS Preferred Alternative does allocate<br />

semiprimitive areas outside of wilderness to management areas that provide for recreation in a roadless<br />

environment, including Brown Mountain, Yamsey Mountain and Pelican Butte.<br />

Comment<br />

Why? Currently there is 9% of the Forest as roadless, with an increase of 8700 additional acres to be<br />

added with the new plan. This should be sufficient to meet anticipated demand for roadless areas,<br />

and allow the rest for multiuse.<br />

<strong>Response</strong><br />

The areas remaining roadless will provide semiprimitive recreation opportunities outside of wilderness<br />

where some activities are prohibited, such as snowmobiling. These areas are primarily classified as<br />

not being suitable for timber production.<br />

Comment<br />

My major concern is winter recreation on the Winema National Forest. I have been cross country skiing<br />

in the area for over 20 years, and am the author of a recent book on 'Southern Oregon Cross Country<br />

Ski Trails.' I am pleased with the number of cross country ski trails on the Forest, however, I do not<br />

want this recreational interest to be neglected. The Forest Plan does not address this use in much<br />

detail, thus I would like to see more emphasis placed on developing and signing trails, and constructing<br />

additional Sno-Parks for vehicles. The increased interest in this sport certainly justifies providing more<br />

cross country skiing opportunities and emphasis in the Forest Plan.<br />

<strong>Response</strong><br />

The Forest has an a current program of providing and expanding recreation opportunities, including<br />

cross country skiing, as funding permits. The land allocations and capital investment program included<br />

in the Forest Plan should add emphasis to this effort.E<br />

K- 102

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Comment<br />

Finally, I do not support increased logging in the vicinity of Crater Lake National Park. Old growth timber<br />

should be preserved as a buffer around the Park; to provide habitat for wildlife and to preserve the<br />

scenic view from the Park. A similar consideration should be applied near the boundaries of the Sky<br />

Lakes Wilderness Area and Mountain Lakes Wilderness Area.<br />

<strong>Response</strong><br />

Legislation has established the existing wildernesses and Crater Lake National Park to include the land<br />

area necessary for protection and management of resources in those areas. The Forest lands adjacent<br />

to these areas are allocated to~various resource uses based upon the capabilities of these areas.<br />

Comment<br />

A monitoring program should be part of the final plan. Because uneven-aged management is visually<br />

more pleasing, there should be less need to set aside suitable timberland for dispersed recreation.<br />

<strong>Response</strong><br />

A detailed monitoring plan is included in Chapter 5 of the Forest Plan. The use of uneven-aged<br />

management will indeed provide a more natural appearing setting for dispersed recreation use. Only<br />

4,243 acres of land suitable for timber production is allocated to semiprimitive recreation in the FEIS<br />

Preferred Alternative.<br />

Comment<br />

The Forest should consider a public information program describing how they intend to manage pine<br />

so the Forest will be visually attractive and continue to provide the historical supply of Ponderosa pine.<br />

<strong>Response</strong><br />

Providing public information is an ongoing part of Forest management activities. Explaining major changes<br />

in management of the Forest, such as the management of ponderosa pine, will be a major focus during<br />

Plan implementation.<br />

Comment<br />

SOTIA supports the preferred altemative's recommendation not to designate Wild and Scenic rivers on<br />

the Winema. SOTIA recommends that the final plan include provisions for expanding developed recreation<br />

sites in the Williamson and Sycan River areas to accommodate greater recreation opportunities, and<br />

manage the river corridors to protect visual quality.<br />

<strong>Response</strong><br />

The Sycan River has been legislatively designated as a Wild and Scenic River. The Williamson River<br />

Gorge will be managed as a Unique Area with emphasis on protecting scenic qualities. The Activity<br />

Schedules in the Forest Plan proposes expansion of Williamson River Campground and construction<br />

of a horse camp and a trail system in the Sycan area. Other developments will be considered if needed<br />

to meet demand.<br />

Comment<br />

The draft EIS fails to comply with this requirement because it does not address how the recreation<br />

opportunities that would be created on the Forest by implementation of the proposed alternatives are<br />

coordinated with existing recreation opportunities, not only those existing on the Forest itself, but also<br />

those existing on adjacent state, federal and private lands. In evaluating the recreation demand, the<br />

Winema does not appear to take into account recreational opportunities existing outside the Forest.<br />

Outside resources must be considered when evaluating the proposed alternatives on this issue.<br />

<strong>Response</strong><br />

The description of Forest recreation opportunities in Chapter 3 of the FEIS, has been revised to include<br />

opportunities provided by others in the area. The availability of recreation opportunities in adjacent<br />

areas is key to analyzing recreation demand, especially in our case when these opportunities include<br />

K- 103

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Crater Lake National Park, Upper Klamath Lake and two State Parks as well as adjacent National Forests<br />

and local parks. These opportunities were considered in determining which facilities and settings the<br />

Forest will provide and which segment of the projected demand we will satisfy. Coordination currently<br />

is performed with neighboring National Forests, Klamath County, Crater Lake National Park, Klamath<br />

Basin National Wildlife Refuges, and the Bureau of Land Management for planning and routine<br />

management activities.<br />

Comment<br />

Under the preferred alternative, 18,573 acres of Winema National Forest land would remain undeveloped<br />

by the second decade. The Winema cannot violate the will of Congress and administratively create<br />

wilderness that takes an act of Congress to create. If Congress had intended these areas to be removed<br />

from active forest management, it would have designated them as wilderness. Congress, however,<br />

carefully considered the majority of these areas for wilderness and made the decision to release them<br />

from multiple use management. The Winema cannot defy this clear congressional mandate, and must<br />

leave the creation of wilderness to Congress.<br />

<strong>Response</strong><br />

No additional areas are being allocated or recommended as wilderness in the Forest Plan. The areas<br />

remaining undeveloped by the second decade are primarily not suitable for timber production and are<br />

not needed for other development. Some of this area is allocated to semiprimitive recreation with no<br />

programmed harvest, some to minimum management which is unsuitable for timber harvest, and other<br />

areas to land allocations available for development or harvest but not scheduled for entry until after<br />

the second decade.<br />

Comment<br />

Our primary concern with wilderness area management is the management philosophy of making the<br />

use of these areas to difficult or regulated that users will be discouraged and not visit these areas.<br />

This negative management theory is suggested by such practices as closing close trails or trailhead<br />

access to heavily used areas to make longer trips necessary, intentionally designing trailheads and<br />

parking areas to handle less than expected numbers of users on peak days, not stocking lakes with<br />

trout to discourage people from visiting them and our biggest concern, limiting maximum party size to<br />

such small groups that even two families riding horses can not visit a wilderness area together.<br />

<strong>Response</strong><br />

Wilderness areas are managed to provide a special experience where, as directed by Congress, solitude<br />

in a natural environment can be achieved, where there is freedom to explore unhindered in a primitive<br />

landscape and the area is retained in the purest natural state. Limiting visitor use to protect wilderness<br />

resources is one management technique. This could include party size limitations, permit requirements,<br />

not maintaining trails to a high standard, downgrading trailheads, and not providing high level access<br />

to trailheads.<br />

Comment<br />

We also feel the Forest has many excellent horseback recreational opportunities available outside of<br />

the wilderness areas that should be developed. We suggest the Forest consider improvement of any<br />

trailhead that is just a wide spot in the road. The Forest has many such trailheads. Turn-arounds, parking<br />

areas, camp spots, corrals and water developments are all items for consideration at any such trailhead.<br />

These are the type of improvements that can be made outside the wilderness areas and at many locations<br />

other than wilderness trailheads that may provide horseback riding opportunities.<br />

<strong>Response</strong><br />

Projects that will improve or create opportunities for the horse using public outside wilderness are<br />

scheduled in the Recreation Facility and Trail Activity Schedules in the Forest Plan.<br />

K- 104

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Comment<br />

References to the retention of roadless area characteristics on a portion of Sky Lakes B roadless area<br />

for possible consideration for later wilderness designation should be eliminated from the draft and all<br />

of the area should be open to harvest entry without limitation except that designated for potential ski<br />

area development.<br />

<strong>Response</strong><br />

Most of the Sky Lakes-B roadless area, including the potential winter sports area, is not suitable for<br />

timber production and is currently in a roadless condition. The preferred alternative proposes to continue<br />

managing this area for current unroaded uses with the option to develop a winter sports complex on a<br />

portion of the area.<br />

Comment<br />

Skiing up the East Canal trail and see pink flags along the eastside. What's the story? The Forest is<br />

large enough that you should be able to keep the loggers out of this whole recreation area.<br />

<strong>Response</strong><br />

Although the Forest seems large, the overwhelming demands for its resources seldom allow the allocation<br />

of its lands for exclusive single resource use. It is felt that timber harvest can be compatible with, much<br />

of the recreation activity that occurs on the Forest. Where significant recreation activity may occur the<br />

harvest is often modified by managing for scenic values or by excluding all programmed harvest. The<br />

land allocation in the vicinity of the Canal Ski Trail is to Scenic Management and Old Growth Management.<br />

Both allow cross-country skiing activity and permit no harvest or modified harvest activities.<br />

Comment<br />

How about a ski trail parallel to the Sunset trail, and parallel to Varney Creek trail, and a nice loop on<br />

the NE side of Brown Mountain, with a connection to one of the Fish Lake trails? How about a hiking<br />

trail to the top of Brown Mountain?<br />

<strong>Response</strong><br />

The Forest is actively planning new ski and hiking trails as listed in the Trail Construction Activity Schedule<br />

in the Forest Plan. New ski trails are normally developed with the assistance of user groups. The<br />

development of ski trails suggested can be pursued by contacting the Klamath Ranger District.<br />

Comment<br />

It is time that the WNF institute a system of restrictions on total visitor numbers in the WAs. Resource<br />

degradation due to excessive human use has become a serious problem. Many areas have suffered<br />

vegetation loss, erosion, and pollution from overuse. It is time that this problem be acted on by restricting<br />

both group size and total number of entries during peak seasons.<br />

<strong>Response</strong><br />

Wilderness Implementation Schedules have been completed for each wilderness area. Included in<br />

these schedules are management techniques, including limiting party size, which will be implemented<br />

to prevent resource degradation and restore wilderness character. These are summarized as standards<br />

and guidelines for Management Area 6 - Wilderness in Chapter 4 of the Forest Plan.<br />

Comment<br />

Roadless areas are necessary to provide undisturbed wildlife habitat and primitive recreational<br />

experiences. They also provide an ecological and spiritual reservoir as the remainder of the earth<br />

undergoes increasing pressures of human occupation. The value of roadless areas is increasing<br />

proportionately to those pressures.<br />

K - 105

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<strong>Response</strong><br />

Agreed. These are some of the reasons that most of the roadless area on the Forest has been designated<br />

as wilderness. Some additional areas outside of existing wilderness will also continue to be managed<br />

in a roadless condition for these uses.<br />

Comment<br />

It is quite evident that the Plan analysis and subsequent provisions for recreation opportunities failed<br />

to adequately consider the information available on public needs and use trends developed in the<br />

most current edition of the Statewide Comprehensive Outdoor Recreation Plan (SCORP) as is required<br />

in 36 CFR 219.2(e) since the plan documents do not recognize and respond to important aspects of<br />

this information. The plan documents essentially reflect the trends toward relatively greater increasing<br />

demand for developed sites and trails but it is very important that there is a thorough, cited consideration<br />

of SCORP in the Final to conform to regulations.<br />

<strong>Response</strong><br />

Recreation demand projections have been updated using more recent use data and findings of recent<br />

national and regional studies, including those to be used in updating the Oregon SCORP. Results are<br />

displayed in Chapter 3 of the FEIS.<br />

Comment<br />

Conflicts between competing' winter sports activities are mentioned in the DEIS (111-74). Most perceived<br />

or real conflicts can be equitably resolved by trail and snow play area zoning and most importantly<br />

adequate parking space for all types of winter sports enthusiasts since most "conflicts' are the result<br />

of competition for parking.<br />

<strong>Response</strong><br />

Zoning motorized and nonmotorized uses has been used successfully on the Forest to reduce conflicts.<br />

Additional sno-parks are also proposed for construction in the Activity Schedule to reduce competition<br />

for parking.<br />

Comment<br />

We support management of the national forests to provide a broad range of recreational opportunities.<br />

Under the proposed plan, the management of semiprimitive areas is somewhat unclear and should be<br />

explained better. More data is needed to understand potential conflicts between growing uses like<br />

cross-country skiing and snowmobiling and how they can be managed. See State Parks and Recreation<br />

comments for more details.<br />

<strong>Response</strong><br />

The standards and guidelines for Management Area 1 (Semiprimitive Recreation) have been expanded<br />

to clarify management of these areas (Forest Plan Chapter 4). Additional discussion of individual recreation<br />

uses has also been added to the FEIS.<br />

Comment<br />

Under all alternatives, ample supply for roaded natural and roaded modified opportunities will prevail<br />

throughout the planning horizon. Demand for primitive opportunities in wilderness will nearly reach<br />

supply by the year 2030. Current capacity for semiprimitive Motorized (SPM) and semiprimitive<br />

Non-Motorized (SPNM) exceeds demand. However, the preferred alternative would reduce roadless<br />

areas providing semiprimitive opportunities from over 32,000 acres to 8061 acres.<br />

<strong>Response</strong><br />

The FEIS preferred alternative increases the semiprimitive recreation allocation to 22,590 acres, by<br />

increasing the size of the Yamsey and Brown Mountain areas and by adding a portion of Pelican Butte<br />

to this allocation. Additional trails and trailheads area planned in or near these areas as an alternative<br />

to using wilderness trails.<br />

K - 106

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Comment<br />

Specific forms of dispersed recreation are impossible to examine due to a lack of data. For example,<br />

the plan cites that winter use of trails by motorized vehicles has increased dramatically, that cross-country<br />

skiing has also increased and that conflicts between the two uses are emerging. The plan provides no<br />

analysis of this use nor indication of how the forest will accommodate it in the future.<br />

<strong>Response</strong><br />

Completing analysis and providing direction for specific situations is beyond the scope of the Forest<br />

Plan effort. The Forest plan allocates land to various management areas and establishes direction to<br />

guide management of activities to achieve objectives and goals for those management areas. The<br />

allocation with its standards and guidelines will provide the basis for guiding management of various<br />

activities, winter sports in this example.<br />

Comment<br />

The final EIS should provide a summary of the potential allowable sale quantity contribution of each<br />

unroaded area in addition to undeveloped acres remaining in each area for each alternative during the<br />

first five decades.<br />

<strong>Response</strong><br />

Refer to Appendix C for timber volumes by roadless area.<br />

Comment<br />

The appendix (page C-8) also contains the statement that O...there are no check in stations for [the<br />

three] wilderness [and that] all figures are estimated, based on personal interviews with visitors using<br />

the areas., The Final EIS also needs to show historic wilderness recreation use to clearly articulate the<br />

use statistics and assumptions regarding potential future demand need to be reasonable and supportive.<br />

<strong>Response</strong><br />

The statement in the appendix, page C-9, I All figures are estimated, based upon personal interviews<br />

with visitors using the areas' is incorrect. Use estimates were derived from data from wilderness permits<br />

required for wilderness visitors to most wildernesses prior to 1985. This data was supplemented by<br />

observation and random sampling of use by field employees.<br />

Comment<br />

We question whether increased acreage in this recreational setting will actually result in more semiprimitive<br />

recreational use on the forest.<br />

Analysis should also consider the supply of SPNM recreation on adjacent national forests, including<br />

California.<br />

It would appear that SPNM is not the high priority on the Winema that it is on otherforests. A full discussion<br />

of the trade-offs incurred in order to supply the demonstrated and projected recreation demands should<br />

be presented in the Final EIS along with the discussion of demand level derivation.<br />

<strong>Response</strong><br />

The projected need for semiprimitive recreation on the Forest is based upon historical use of the Forest<br />

in these areas and regional demand projections. The area on the Winema suitable for this designation,<br />

however, is very limited since most of the unroaded areas are in wilderness.<br />

Comment<br />

Currently, the draft Plan states there are 32,218 roadless acres. Only 8,658 acres will remain roadless<br />

under the Forest Service's proposed plan. To propose developing most of the roadless acres on the<br />

Forest demonstrates an incredible disregard for the resources roadless areas protect. The final Forest<br />

Plan must recommend protecting more roadless areas and acres than the Draft Plan.<br />

K - 107

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<strong>Response</strong><br />

The FEIS preferred alternative allocates 22,590 acres to semiprimitive recreation areas. In addition,<br />

over 93,000 acres are already designated as wilderness which maintains these area in a permanent<br />

roadless condition that protects roadless area resources.<br />

Comment<br />

There are 2 abandoned trails up Pelican Butte, the old Rocky Point Trail, and the Pelican Butte Trail.<br />

The possibility of restoring these trails should be explored, perhaps using local volunteers for construction<br />

and maintenance, but only if compatible with raptor nesting requirements.<br />

<strong>Response</strong><br />

The Forest recreation and trail capital investment program, a part of the Forest Plan, includes a proposed<br />

project to develop a trail system around Pelican Butte in connection with a proposed horse camp at<br />

Big Meadows. Any effects of the proposal on raptors or other resources will be analyzed in a site-specific<br />

environmental assessment prior to designing the project.<br />

Comment<br />

RecreaVon -- The Winema Forest Plan shows that more roads are not needed to satisfy future, projected<br />

demand of this recreation form: Future demand is predicted to be only 8.3 percent of capacity. Unroaded<br />

recreation, however, is predicted to reach capacity within 45 years. Nonetheless, the Plan proposes to<br />

develop many roadless areas...<br />

<strong>Response</strong><br />

The FEIS preferred alternative allocates 22,590 acres to semiprimitive recreation areas. In addition,<br />

over 93,000 acres are already designated as wilderness which maintains these area in a permanent<br />

roadless condition that protects roadless area resources.<br />

Comment<br />

We call upon you to fundamentally redirect your management strategy toward a recreational emphasis<br />

which includes all types of recreation including a balanced level of opportunities for semiprimitive<br />

motorized recreation.<br />

<strong>Response</strong><br />

Areas that offer a semiprimitive experience outside of wilderness (available for motorized use) are limited<br />

on the Forest. In the FEIS preferred alternative approximately half the available area will be managed<br />

for semiprimitive motorized recreation in the summer. Most will be available for motorized use in the<br />

winter.<br />

Comment<br />

I would strongly request that you add a strategy to consider the successes of user-cooperative programs<br />

such as Adopt-a-Trail/Road.<br />

<strong>Response</strong><br />

The Forest has utilized volunteer efforts on many occasions in the past, in seeking input, and coordination,<br />

and actual accomplishment of projects. These efforts have been very successful and have allowed<br />

accomplishment of projects with limited budgets. It is our intent to continue such successes with volunteers<br />

and user-cooperator groups and programs, such as Adopt-a-Trail/Road.<br />

Comment<br />

We call for a re-evaluation of closure criteria of public lands to 4WD and ORV usage.<br />

<strong>Response</strong><br />

Off-road vehicle use will be managed considering the resource values, promoting safety of users, and<br />

minimizing conflicts with other uses. Specific restrictions regarding off-road vehicle use are contained<br />

K - 108

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in the Management Area Standards and Guidelines in Chapter 4 if the Forest Plan. Other area ORV<br />

and 4WD closures may be implemented if unacceptable resource or facility damage occurs.<br />

Comment<br />

I would like to see more trails open to off-road vehicle use. Recently, I went into the Chemult Ranger<br />

District to inquire about same and after about 1/2 hour research, they said there is only one that they<br />

knew was designated for O.R.V. use, was 6 miles long and was named the "Rye' Trail.<br />

<strong>Response</strong><br />

Nearly all of the existing trail system on the Forest is within or directly accesses wilderness where motorized<br />

use is prohibited by law. Construction of additional trails outside of wilderness is a priority in Trail<br />

Construction Activity Schedule in the Forest Plan.<br />

Comment<br />

We ask that primitive roads be addressed in the plan so as to maintain a dispersed recreational pattern.<br />

We have sought help and direction of Forestry and have three areas in mind for investigation and<br />

planning. (Map of areas submitted with comment).<br />

Where does the high clearance trail come into your plan? There are areas that can be developed and<br />

reopened to this type of recreation. Some specific areas in the Chiloquin and Chemult areas have<br />

been mapped by the local four-wheel drive club, Four Runners of Klamath Falls, for your consideration.<br />

A plan for four-wheel drive use is not clearly provided with the plan as it is now written. We ask that<br />

our form of recreation be addressed and we are willing to work with you.<br />

<strong>Response</strong><br />

The standards and guidelines in the Forest Plan indicate if ORV use is permissible, seasonally restricted<br />

or prohibited in each Management Area. These will serve as the basis for the ORV Implementation<br />

Schedule. ORV use may be restricted or prohibited in additional areas as outlined in the Monitoring<br />

Plan (Forest Plan Chapter 4). In addition designated (recommended) ORV use areas and routes will<br />

be developed in conjunction with user groups. These on-going changes will be added to the ORV<br />

Implementation Schedule as they occur.<br />

Comment<br />

S&Gs for MAs#7 should specifically prohibit entry and/or use of these areas by ORVs and livestock,<br />

so as to better preserve the integrity of the ecological characteristics of these old growth communities.<br />

Livestock can cause significant degradation of understory and ground-cover conditions, potentially<br />

affecting small mammals and the predators that feed on them. ORVs can have similar effects, in addition<br />

to causing stress to other species of wildlife native to the old growth ecosystem. Such disturbances<br />

are unjustified and inappropriate in areas to be managed to retain natural ecosystems.<br />

The final plan for the WNF should specifically prohibit ORV use in hiking areas and in sensitive habitat<br />

areas. The final plan should also clearly comply with and refer to Executive Order 11644, Use of Off-Road<br />

Vehicles on the Public Lands, and portions of the NEPA implementing regulations that expressly restrict<br />

ORV activities on public lands to those areas where such activities ari clearly not in conflict with other<br />

resources, such as wildlife and native plant habitat, non-motorized recreation, scenic values, riparian<br />

zones, and others. Both overall policy and management S&Gs in the Final plan should clearly reflect<br />

the intent of this Executive Order. We do not believe that either the WNFs existing ORV management<br />

plan or the S&Gs of the PA in regard to ORV use in environmentally sensitive areas are in compliance<br />

with E.O. 11644.<br />

<strong>Response</strong><br />

The Standards and Guidelines for each management area specifies whether ORV use is permitted,<br />

seasonally restricted or prohibited. In compliance with E.O. 11644 off-road vehicle use will be restricted<br />

or prohibited in areas receiving resource or facility damage. Monitoring damage caused by ORV use is<br />

a monitoring objective in the Forest Plan Monitoring Plan.<br />

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Comment<br />

We request that the WNF institute a policy similar to that developed by the Gifford-Pinchot and other<br />

National Forests that prohibits ORVs from all trails leading into established Wilderness Areas. This is<br />

an appropriate and long overdue action. We recommend that this policy be extended to those trails<br />

approaching RNAs, riparian and wetland areas, and other sensitive habitat areas.<br />

<strong>Response</strong><br />

Currently all trails on the Forest that directly access wilderness are closed to motorized and mechanized<br />

use. This restriction will be continued to protect the wilderness resource. Other ORV restrictions are<br />

addressed in the Management Area Standards and Guidelines.<br />

Comment<br />

Potential for ORV/wildlife conflicts need to be more closely addressed, since resource damage may<br />

occur. When would the off-road vehicle implementation plan be developed? (App. D-5).<br />

<strong>Response</strong><br />

The Forest Plan Monitoring Plan prescribes monitoring actions to determine if resource damage is<br />

occurring.<br />

Comment<br />

Page D-5, number 7. The final document should include at least a summary of the off-road vehicle<br />

plan and its tentative date of implementation.<br />

<strong>Response</strong><br />

The Standards and Guidelines in the Forest Plan indicate if ORV use is permissible, seasonally restricted<br />

or prohibited in each Management Area. These will be implemented upon implementation of the Plan.<br />

These Standards and Guidelines will serve as the basis for the ORV Implementation Schedule. ORV<br />

use may be restricted or prohibited in additional areas as outlined in the Monitoring Plan (Forest Plan<br />

Chapter 4). In addition designated (recommended) ORV use areas and routes will be developed in<br />

conjunction with user groups. These on-going changes will be added to the ORV Implementation Schedule<br />

as they occur.<br />

Comment<br />

We firmly maintain that ORV use is incompatible with most all other uses of the national forest. As<br />

such, their use should be strictly regulated and confined to areas, adequate in size, where they will be<br />

sufficiently separated from other forest uses, especially recreation and wildlife, in such a manner that<br />

the value of other resources will not be diminished. Specifically, ORV usage areas should be designated<br />

so that noise will not carry into other recreational and important wildlife areas.<br />

<strong>Response</strong><br />

ORV use is a legitimate use of National Forest lands where legally authorized, not contributing to<br />

unacceptable resource damage and not conflicting with other legitimate Forest uses. Due to the potential<br />

for ORV use to cause damage and conflict, it will be a closely monitored and managed. Separation of<br />

motorized and nonmotorized uses is one management technique currently used.<br />

Comment<br />

Is the term Non-game hunting a misnomer? Just what is non-game hunting? I believe that Table 111-20<br />

and associated narratives are unreliable without supporting documentation. Is it possible that the WFUD's<br />

listed in Table 111-20 should have been combined and included in Table 111-21? P.111-66. Paragraph 1.<br />

The Forest needs to define nongame hunting.<br />

K- 110

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<strong>Response</strong><br />

The term Non-game hunting, refers to varmint shooting for which projected demand was displayed<br />

separately in the DEIS. In the FEIS updated projections for hunting, fishing and non-consumptive wildlife<br />

use are shown under in the Recreation section of Chapter 3.<br />

Comment<br />

The term *hunter days' in Table 111-19 is not properly defined; which further confuses the issue when<br />

the DEIS also used the terms Recreation Visitor Days (RVD's) and Wildlife and Fish User-days (WFUD's).<br />

The DEIS would have us believe that hunters and fishermen do not engage in any amenity, such as:<br />

hiking, sightseeing, photography, backpacking etc.<br />

What are WFUD's? What are RVD's? The Glossary states that, WFUD's are: 'Twelve visitor hours which<br />

may be aggregated continuously, intermittently, or simultaneously by one or more persons.' RVD's are<br />

defined as: 'Twelve visitor hours, which may be aggregated, continuously, intermittently, or simultaneously<br />

by one or more persons."<br />

If the resource manager has reliable data and wants to identify WFUD's by persons, taking or attempting<br />

to take game animals of all species, as a bracketed component of RVD's, this would be logical. It is<br />

impossible to identify all WFUD's, so they should be left in RVD's where they belong.<br />

<strong>Response</strong><br />

'Hunter Days,* 'Wildlife and Fish-User Days,' (WFUD's) and 'Recreation Visitor Days, (RVD's) all are<br />

measures of recreation use consisting of twelve visitor hours. The term used depends on the primary<br />

activity the person is engaged in. All use figures are only estimates based on such data as deer and<br />

fishing licenses, campground head counts and fee envelopes and fire and law enforcement patrol<br />

observations. The Wildlife and Fish User-day also includes non-consumptive uses such as wildlife<br />

viewing and photography. WFUD's are identified separately as a subset of RVD's because they are<br />

visitor use associated with the fish and wildlife resource and are valued at a higher rate for economic<br />

analysis purposes.<br />

Comment<br />

Table IV-1 shows WFUD's at 64,900 in the first decade and 79,100 in the fifth decade. Table 111-20<br />

shows WFUD's at 39,000 in 1980 and 45,000 in 2000. Table 111-21 shows WFUD's as 1,212,000 in 1980<br />

and 1,391,000 in the year 2000. Table 111-20 is telling us that the Winerna National Forest had an average<br />

of 3,320 persons at one time, for 12 hours each, of the 365 days in 1980; this is wildlife and fish only<br />

and does not include any other recreation user. Is this data reliable?<br />

Information in Tables Il-1 and 111-21 continues to confuse the issue of RVD's and WFUD's.<br />

<strong>Response</strong><br />

Table IV-1 showed WFUD estimates for the Winema National Forest only. The other tables referenced<br />

displayed use estimates for some activities for all Central Oregon Forests. In the FEIS updated demand<br />

projections for just the Winema National Forest are shown in the Recreation Section of Chapter 3.<br />

Comment<br />

How does the Resource Manager determine when the dispersed recreational user is engaging in any<br />

wildlife or fish use, if the user isn't packing a gun or fishing rod?<br />

<strong>Response</strong><br />

All visitor use figures are estimates based on observations supplemented by data collected from a<br />

number of sources. Recording the primary activity engaged in is a judgement call just like discerning<br />

whether a visitor is camping or picnicking.<br />

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Comment<br />

The National Forest is supposed to belong to all the people of the U.S. Then why is it that you turn the<br />

whole National Forest over to a very small group of hunters every year.<br />

<strong>Response</strong><br />

Hunting on the National Forest is a State controlled activity. It is not an exclusive use period for hunters.<br />

Other recreation opportunities may be pursued by other users at the same time, if they wish.<br />

Comment<br />

P.11-141.<br />

(Paragraph 1). The Forest should state that data from the U.S. Fish and Wildlife Service (USFWS) national<br />

recreation survey indicates the monetary value of non-consumptive wildlife use may equal or exceed<br />

the value of hunting and fishing.<br />

<strong>Response</strong><br />

The RPA values for hunting, fishing and non-consumptive wildlife use used to value WFUD's in the<br />

FEIS are $30, $15 and $25 respectively (see Appendix B).<br />

Comment<br />

P.11-145.<br />

Table 11-7 Old-Growth Habitat. "Dispersed Recreation" - Most of the opportunity on the Forest for a<br />

semiprimitive hunting experience has been precluded. How will the Forest meet the concerns of hunters<br />

for excessive roading and less of a quality hunting experience? (DEIS 11-145-1) "% of forest in old-growth<br />

condition" What is the definition of "old-growth condition?" (DEIS 11-1 45-2).<br />

<strong>Response</strong><br />

The percentage of the Forest managed in semiprimitive ROS classes has been increased slightly in<br />

the FEIS, however, the inventoried amount of this ROS class outside of wilderness is very limited on<br />

the Winema. Hunting in wilderness or substitution of roaded ROS class hunting are the primary options.<br />

Road densities will be reduced in many areas through selective road closures.<br />

Old-growth habitat and old-growth stands are defined in the Glossary.<br />

Comment<br />

P.111-65.<br />

(Paragraph 3). The Forest has made the assumption that current demand for fishing and hunting is<br />

equal to current use. ODFW believes that current demand exceeds current use. If Forest streams were<br />

in optimal condition for fish production, use would be considerably higher than current levels.<br />

<strong>Response</strong><br />

This assumption is probably correct. As conditions for fish production are improved, use will be monitored.<br />

Comment<br />

P.111-74. Paragraph 4.<br />

The possible conflict between bird watching and eagle nesting is a poor example when compared with<br />

more common and serious interactions between wildlife, recreation, and vegetation manipulation.<br />

<strong>Response</strong><br />

This section has been revised to include additional interactions.<br />

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Comment<br />

PP IV-3.<br />

Recreation. High road densities and reduced hiding cover increases hunter success and decreases<br />

the length of the hunting season. The Forest must have a goal to maintain or increase hunting RVD's.<br />

<strong>Response</strong><br />

Forest-wide standards and guidelines have been developed addressing road densities and mule deer<br />

hiding cover. Hunting RVD's will depend to a large extent on deer populations and the State hunting<br />

regulations in effect. The Forest has no goal to increase hunting on the Forest.<br />

Comment<br />

P.IV-1 04.<br />

Deer Hunting and Fishing. The effects of the alternatives on hunting opportunity and experience need<br />

to be addressed. High road densities and reduced cover increases vulnerability of bucks and bulls to<br />

harvest, resulting in hunting restrictions.<br />

<strong>Response</strong><br />

The effects of the alternatives on deer populations are addressed in the Effects on Wildlife in Chapter<br />

4 of the FEIS.<br />

Comment<br />

B-94.<br />

(Last Paragraph and Table B-1 2). Should values of wildlife and fish user days be shown apart from<br />

recreation benefits and values? (App. B-94).<br />

<strong>Response</strong><br />

Fish and wildlife user days have been displayed and valued separately in the FEIS (See Appendix B),<br />

but are also included as a part of the total RVD use in the Recreation Section of Chapter 3.<br />

Comment<br />

Some data for hunting and fishing on the forest is provided. For example, mule deer hunter days are<br />

projected to increase 20% by the year 2000. Yet, the plan provides no information as to how this use<br />

is to be accommodated. Non-game hunting and wildlife viewing demand is estimated for Central Oregon<br />

forests and shows increases in demand of about 15% from 1980 to 2000. What portion of this demand<br />

may occur the Winema? How will it be accommodated?<br />

<strong>Response</strong><br />

Updated projections for hunting, fishing and wildlife viewing are presented in the Recreation Section of<br />

Chapter 3. Based on recent recreation consumption surveys and projections, a much smaller increase<br />

in hunting use is expected. Non-game hunting was not tracked separately in these surveys, but is<br />

included in the hunting total. Since most hunting on the Forest occurs in dispersed settings, the Forest<br />

has no plans to add facilities to accommodate hunting use.<br />

Comment<br />

I feel if you close a road or area due to enhancing deer and elk habitat you should close that area to<br />

everyone not just the people who work in the area, but also the people who use it for recreational<br />

purpose, such as snowmobile, etc., 4-wheelers, general public.<br />

<strong>Response</strong><br />

Generally, closures are established to protect wildlife from adverse disturbance. Such closures would<br />

apply to recreation and other uses. If a closure is established for habitat protection, some recreation<br />

uses may still be compatible with the closure.<br />

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Comment<br />

I also do not see why so much is designated Area 3, Scenic Management, when a lot of it does not<br />

even have a road through it.<br />

<strong>Response</strong><br />

Most areas designated scenic management fall into two categories. First, foreground areas along selected<br />

travelways, use areas (such as recreation sites) or important waterways, that are managed with tighter<br />

controls on management activities to minimize potential adverse effects from dramatically altering the<br />

forested landscape through harvest practices (see Pages D-43 - 52 in the DEIS, Appendix). This area<br />

is limited to 1/4 mile to 1/2 mile from the road, depending on the topography.<br />

Second, middleground areas, (seen from up to 3 miles to 5 miles) as viewed from the same travelways<br />

are managed fairly similar to Timber Production Area 12; the difference in scenic management is that<br />

there is a limit to the amount of area that can be in created openings (or clearcut) at any one time<br />

(see Table D-15 on page D-58 of the DEIS, Appendix). This does not place a limit on silviculturally<br />

treating an entire area through thinning, selection cutting, partial removal, and other treatments typically<br />

used to manage timber. The result in the middleground view is that the forest is managed for timber<br />

production in a way that maintains a natural appearing forest.<br />

It is true that the opportunities will be reduced, but there will still be opportunities for roadless recreation<br />

in the Yamsay and Brown Mountain areas. See the description for Alternative E in the DEIS or FEIS for<br />

additional information.<br />

Comment<br />

In comparing the Plan's Preferred Alternate (Alt. E) with some of the other Alternatives, one is struck<br />

by the priority given in the Preferred Alternative to the production of resource outputs. For example,<br />

Alt. E will result in the conversion of 45% of the Forest from a natural appearing to an obviously modified<br />

environment in 10 years (DEIS Table 11-3B):. In contrast, with Alternative G only 5% of the Forest will be<br />

converted. And yet both alternatives will meet the Forest's share of total county-wide harvest, and<br />

produce only a 5% difference in county-wide employment.<br />

<strong>Response</strong><br />

In the recommended Forest Plan Alternative, Alternative J, there is a lower emphasis on commodity<br />

outputs while maximizing the use of uneven-aged management. Alternative G in the DEIS also maximized<br />

the use of uneven-aged management which maintains a general forest-cover condition while reducing<br />

the amount of clearcutting.<br />

Comment<br />

The draft plan allocates over 160,500 acres to scenic management areas, including: (1) 35,757 acres<br />

managed to achieve foreground retention VQO's; (2) 48,767 managed to achieve foreground partial<br />

retention VQO'S; and (3) 75,992 acres managed to achieve middleground partial retention VQO'S<br />

(DEIS Table 11-2). The objective of timber management on these acres is to provide "a natural appearing<br />

environment.' When even-aged systems are used, long rotation periods and limitations on the size<br />

and distribution of harvest units are used to achieve this objective (DEIS 11-65). These constraints are<br />

more severe on the foreground retention areas and less severe on the middleground partial retention<br />

areas. The timber volume and PNV tradeoffs resulting from these allocations is not described in the<br />

DEIS. 5/ However, it appears that the draft plan's visual quality objectives are the primary factor responsible<br />

for its reduced timber production potential.<br />

5/ The volume and PNV tradeoffs resulting from these and all other significant timber harvest constraints<br />

should be clearly disclosed in the FEIS.<br />

<strong>Response</strong><br />

The timber volume and PNV tradeoffs resulting from allocation to scenic quality is not nearly as severe<br />

as it may have appeared in the DEIS. Significant timber harvest comes from these areas. The tradeoff<br />

analysis is included in Appendix B in the FEIS.<br />

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Comment<br />

The Forest used foreground retention in areas that occur within 0.5 miles from designated visual<br />

corridors,public use areas, and water bodies. The planning team used extended rotations of 250 years<br />

and limiting openings to 8 percent per period to apply this objective. The current Forest condition has<br />

stands of 190 years. The Winema's present Forest structure has no stands that meet the 250 year<br />

objective of retention. We believe the rate of harvest should be used to meet the scenic objective.<br />

<strong>Response</strong><br />

Except in mixed conifer and lodgepole pine plant communities where maximum percentage in created<br />

opening will still be applied, uneven-aged management will be emphasized on the Forest using basal<br />

area distribution.<br />

Comment<br />

Thus, these stands (average age 160) do not contribute to the harvest volume until the average age<br />

reaches 250. We recommend that the Winema also evaluate allowing multiple CT options and earlier<br />

harvest ages for the visual emphases.<br />

<strong>Response</strong><br />

The long rotation of trees in the foreground has five commercial thinnings. Uneven-aged management<br />

will maximize wood production while maintaining a forest-cover condition.<br />

Comment<br />

What activities will be used to maintain or enhance' scenic quality?<br />

<strong>Response</strong><br />

Vegetative management activities are the primary tools for managing scenic quality. Activities such as<br />

prescribed fire, small clear cuts, partial removals, and even-aged management and thinning are treatments<br />

used to maintain or enhance scenic quality. Other activities, such as revegetating wildfire areas help to<br />

prevent erosion and re-establish the forest. Planning vegetative management activities over time and<br />

space within a viewed area can improve vegetative diversity, assure a forested environment into the<br />

future, and allow for attractive feature, such as peaks, lakes and streams, to be seen from travelways.<br />

Comment<br />

We need to understand the benefits and costs of different levels of visual protection for your primary<br />

and secondary travel routes and recreation sites. Both as a contributor to the setting for the increasing<br />

tourist industry in Klamath county and as a contributor to the quality of life in Oregon, scenic quality<br />

on the Forest is a resource that must be carefully considered in the Forest Plan. Given the large area<br />

of forest that may be covered by these objectives, it is especially important that we understand the<br />

trade-offs involved and that they be minimized. As mentioned above, expansion of uneven-aged<br />

management to more of your key visual areas may help achieve this objective.<br />

<strong>Response</strong><br />

We agree. We are using uneven-aged management to minimize conflicts between timber harvest and<br />

scenic quality.<br />

Comment<br />

P.11-12. Display 11-1.<br />

Scenic Management - FG Retention has a maximum strategy of 8 percent of the area in opening. Appendix<br />

B of the DEIS (page 170) states the 8 percent limit will not be used during the first two decades. What<br />

limit will be used during the first two decades? (DEIS 11-12).<br />

<strong>Response</strong><br />

That is correct as it appeared in the DEIS. The constraint was applied appropriately in the FEIS.<br />

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Comment<br />

P.11-51.<br />

It should be stated here that the 8 percent opening limit for foreground retention will not be applied in<br />

the first two decades.<br />

<strong>Response</strong><br />

In the modeling for the FEIS, the constraint was applied appropriately.<br />

Comment<br />

B-147.<br />

The semiprimitive nonmotorized recreation strategy is designed to maintain the area's natural character.<br />

How can this objective be met with 16 percent of the area in openings each decade? (App. B-147).<br />

<strong>Response</strong><br />

There is no timber harvest programmed for semiprimitive Recreation management areas although<br />

salvage in case of catastrophes or to meet the objectives of this land allocation is permitted. If such<br />

situations occur, the guideline for openings would govern development of methods to achieve the<br />

natural character goal for the area.<br />

Comment<br />

PP IV-85. Description.<br />

This description is a change from that displayed in DEIS App. D-56. why has the distance changed<br />

from '.5 to 5 miles' to 'up to .5 miles?' (PP IV-85).<br />

<strong>Response</strong><br />

PP IV-85 was incorrect. This has been changed in the FEIS.<br />

Comment<br />

PP IV-105. Recreation.<br />

4. 'The visual quality level will be maximum modification. This is an unacceptable standard for riparian<br />

areas. This standard does not meet the desired future condition goal for riparian zones. The visual<br />

quality goal for riparian areas should be retention.<br />

<strong>Response</strong><br />

In the recommended Forest Plan Alternative the riparian areas were modeled to achieve the partial<br />

retention visual quality objective across the Forest. Individual management area standards and guidelines<br />

may allow for a higher or lower visual quality objective consistent with the management area objectives.<br />

Comment<br />

Visual Management - (DEIS, page 111-85, App., page B-146). The Winema has chosen to impose constraints<br />

for visual management in every alternative. Like the MMRs previously discussed, the standards and<br />

guidelines for visuals have been implemented without public review, without the exploration of alternative<br />

strategies, and without an adequate tradeoff analysis.<br />

<strong>Response</strong><br />

The DEIS was the vehicle for exploring alternative strategies and providing opportunity for public review<br />

and comment. The FEIS reflects response to public comments and a detailed tradeoff analysis was<br />

completed which appears in Appendix B.<br />

Comment<br />

The extreme effects of imposing harvest restrictions through extending the time required for I...an opening<br />

no longer being an opening ... [until]... the vegetation within it reaches 20 feet in height...' are not well<br />

discussed in the plan. Also, the standards and guidelines for management of the 124,800 acres of<br />

background partial retention, and subsequent discussion of the effects on forest output have apparently<br />

K- 116

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een omitted. Because timber outputs are greatly and directly affected by these requirements, the<br />

Department requests that the following information be provided in the final EIS by the Winema:<br />

1. A summary of the costs, in terms of present net value and allowable sale quantity, of the<br />

minimum level of visual management included in DEIS alternatives.<br />

2. An analysis of the tradeoffs that would occur if the visual management constraints were increased,<br />

reduced, or eliminated.<br />

3. An analysis of how increased use of uneven-aged management would affect the need for<br />

these constraints.<br />

4. An explanation of how the seemingly arbitrary diameter and harvest dispersion requirements<br />

were selected and an analysis of the tradeoffs that would occur should different requirements<br />

be used (higher or lower).<br />

5. A summary of the anticipated recreation use (demand) on the secondary roads that are<br />

designated for visual management.<br />

<strong>Response</strong><br />

-The requirement for scenic resources where an opening is no longer an opening when vegetation in<br />

it reaches 20 feet in height reflects a compromise throughout the Region. At least 40 feet in height is<br />

actually needed where the young tree crop begins to blend into the branches and boughs of adjacent<br />

mature trees and the cut edge becomes less obvious to the viewer.<br />

-This Forest has chosen to focus on the highest priority scenic lands. The background partial retention<br />

areas are not allocated to scenic management; there are no constraints or effects on timber harvest.<br />

The regional policy direction allows no less than the visual quality objective of maximum modification,<br />

this is achieved through harvest design. Standards and guidelines provide encouragement to achieve<br />

a higher standard if it can be practically achieved. There is no consequence for achieving the minimum<br />

resource requirement of maximum modification except for public perception and feedback.<br />

-Timber outputs are not 'great and directly affected by these requirements.,<br />

-A summary of costs, PNV, ASQ and Tradeoffs are reflected in the large chart in Chapter 11 and in<br />

Appendix B.<br />

-Increased use of uneven-aged management will affect scenic quality significantly. On the positive<br />

side, the perceived ugliness of clearcuts will be reduced and there will be more age diversity per acre.<br />

However, there will be a liquidation of large trees early on and more acreage will be treated in less<br />

time. The forest will appear very open with a distinct emphasis on small trees because of the basal<br />

area distribution. The few scattered large diameter trees will not be enough to retain or partially retain<br />

the character of our existing forest appearance. Diversity on a larger scale will be reduced because<br />

everything will look similar over a large area and appear distinctly 'managed."<br />

-'the seemingly arbitrary diameter and harvest dispersion requirements' for scenic resources was not<br />

at all arbitrary. The diameter sizes were based on actual tree measurements of trees that contained<br />

the desired character for the species sought. Form, line, color and texture are key elements for analyzing<br />

and managing scenic quality. To achieve the desired character of the plant communities, key components<br />

were tree diameter size, bark color and tree form. Retaining the characteristic landscape generally<br />

means retaining all size classes with emphasis on the most distinctive aesthetic characteristics. The<br />

dispersion constraints for openings were a function of rotation age. Rotation age was derived from the<br />

length of time required to achieve the desired conditions. Computer modeling also substantiated the<br />

percentage of created openings that could be placed into a landscape to achieve the various visual<br />

quality levels. This was done at all condition levels from natural appearing down to heavily altered<br />

landscapes.<br />

-The anticipated recreation use (demand) on the Forest as a whole was derived from the Pacific Northwest<br />

Outdoor Recreation Consumption Study, the Oregon Project, which was completed in cooperation with<br />

State agencies. The classification of roads in relation to scenic management is based on actual use<br />

and type of use, not participated use. The Forest has an ongoing system for traffic counts, both numeric<br />

and visual. This data becomes part of the formula that is identified in the national 'Visual Management<br />

System' that determines the level of visual quality that is expected by the public. The data is contained<br />

in the forest planning records.<br />

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Comment<br />

Guidelines for visual management should also address the question of implementing an effective visual<br />

management program in areas where a scattered, fragmented ownership pattern occurs.<br />

<strong>Response</strong><br />

The Winema National Forest is primarily blocked public ownership. There is no question of program<br />

implementation.<br />

Comment<br />

Timber Management Tradeoffs - (DEIS, page 11-74) An essential part of the Department of Forestry's<br />

review of the national forest plan is to evaluate the tradeoffs involved in each alternative's land allocations.<br />

The DEIS and the Winema planning team seem to lack some of the basic information needed to accomplish<br />

this task. For example, except for Alternative D each alternative provides a minimum level of visual<br />

management through the allocation of at least 24,911 suitable acres to Management Area 3 (the Preferred<br />

Alternative (E) allocates 161,816). The text on page 111-86 states that '...currently 91 percent of the Forest<br />

'is in a visual condition in which nature dominates and human activities are not easily noticed [and<br />

that] only 9 percent of the Forest is in a moderately to heavily altered state." The text goes on to note<br />

that '...it is expected that demand for scenic quality will increase in conjunction with the increase in<br />

recreational use and the increased marketing emphasis in Klamath County on tourism.' Unlike the<br />

other listed constraints, however, no estimate of the harvest falldown is given.<br />

<strong>Response</strong><br />

The percent of full yield produced for timber harvest varies by the type of scenic allocation. It is not a<br />

straight line relationship. Allowable sale quantity is impacted by timing choices and intensities that<br />

mask the effect of acres allocated to a certain resource allocation.<br />

Comment<br />

Impacts from timber harvest activities on these viewsheds need to be considered in the Winema DEIS.<br />

NPS would like the Forest to consider running the Visual Management System inventory for views from<br />

Rim Drive east into the Winema Forest. The Forest Service is concerned about vistas and scenic corridors<br />

along Sun Pass Road; it is recommended that the same consideration be given to Rim Drive in Crater<br />

Lake NP.<br />

<strong>Response</strong><br />

In the FEIS, the middleground part of the RIM Drive viewshed was mapped and incorporated into the<br />

preferred alternative. The Sun Pass road was not allocated to scenic emphasis in the preferred alternative.<br />

Comment<br />

Approximately 12 percent of the Forest offers non-roaded recreation opportunities for the pursuit or<br />

observation of fish and wildlife. The management of these areas in a roadless condition will help meet<br />

the wildlife policy for the State of Oregon by providing for optimum fish and wildlife recreational and<br />

aesthetic benefits for present and future generations of the citizens of the State.<br />

<strong>Response</strong><br />

In the FEIS preferred alternative, almost 11 percent of the Forest will be managed to provide an unroaded<br />

setting. Additional currently unroaded areas are also expected to remain unroaded during the plan<br />

period.<br />

Comment<br />

The Winema Plan proposes the construction of only 5 miles of new trails (Plan at IV-33); the east-west<br />

'route markers,' referenced at DEIS 11-51, are not substitutes for trails. The sparsely populated Fremont<br />

Forest, upon implementation of its plan, would have nearly twice the mileage of trails as the Winema.<br />

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<strong>Response</strong><br />

The levels of recreation opportunities and related facilities (such as trails) provided in the Preferred<br />

Alternative has been re-evaluated. This was in response to public comment and to consider direction<br />

and opportunities contained in the recent National Recreation Strategy. Please refer to the FEIS and<br />

Forest Plan which incorporates the re-evaluation.<br />

Comment<br />

It does not address recreation in the Chemult area. Nordic ski trails, snowmobile trails, up-grading our<br />

existing camping facilities (showers, hookups, RV sites, dump stations...). Only Alternative F plans a<br />

trail around the Jackson Creek, Yamsay area, turn old guard stations into warming huts for Nordic<br />

skiing, ice fishing at Miller Lake, coordinate with other Forests for a snowmobile trail, Johnson Meadow<br />

snowmobile trail and warming hut...<br />

<strong>Response</strong><br />

The Forest Plan has been revised to increase emphasis on recreation Forestwide in response to the<br />

new National Recreation Strategy direction. Existing developed sites are scheduled to be upgraded<br />

to provide facilities and services requested by the recreating public. Additional development is scheduled<br />

in the Implementation Plan to expand recreation opportunities, including construction of nordic,<br />

snowmobile and hiking/riding trails in the Chemult area. Recreation staffing has been increased on the<br />

Forest, including at Chemult, to plan, execute and promote this expanded program.<br />

Comment<br />

In Table IV-1, should the PAOT under Developed Recreation Sites 13 be some other unit of measure? It<br />

doesn't seem logical to construct or reconstruct PAOT.<br />

<strong>Response</strong><br />

Persons At One Time (PAOT) is an measure of average design capacity for developed sites. For<br />

campgrounds and picnic areas a family unit has a PAOT of five, so a development with 20 units would<br />

have a total designed PAOT capacity of 100. RWF<br />

Comment<br />

Access to our Federal and Public lands must be provided for the handicapped, elderly and non-athletic.<br />

<strong>Response</strong><br />

The Winema National Forest is generally well roaded outside of designated wilderness. Access roads<br />

to recreation sites are maintained for passenger car use. New and replacement facilities, including<br />

some trails, will be designed to provide barrier-free access for elderly and persons with disabilities.<br />

Comment<br />

Projections for recreational activities on the forest are on an upward trend and the FS should, therefore,<br />

be planning for increased use, not stable or decreasing recreational pursuits. We need more, not less,<br />

recreation area.<br />

<strong>Response</strong><br />

Overall recreation use on the Forest is projected to increase, with participation in some activities increasing<br />

more rapidly than others. Updated recreation projections have been added to Chapter 3 of the FEIS.<br />

The Recreation Facility and Trail Activity Schedules in Appendix B in the Forest Plan list proposed<br />

developments needed to meet this increased demand.<br />

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Comment<br />

If there was a road into the Wilderness Areas a lot more people could enjoy them.<br />

<strong>Response</strong><br />

The Wilderness Act prohibits roads and the use of motorized equipment within wilderness.<br />

Comment<br />

The DEIS lists a number of potential Special Interest Areas on the Forest but we were surprised to see<br />

that the Sand Creek Pinnacles were not included. This geologic wonder was listed as a lunique site'<br />

on the forest, however, along with several other areas that did receive mention as potential Special<br />

Interest Areas (SIA's) too. The description of the potential SIA's in Chapter 3 would have benefited by<br />

the inclusion of a map locating the boundaries for the sites and a bit more discussion of the natural<br />

and cultural values that are present at each area. Also there were no Klamath Indian religious sites<br />

noted in the list of SIA's but this was presumably to prevent destruction of these sites.<br />

<strong>Response</strong><br />

The Sand Creek Pinnacles were not initially included because it was felt that the significant geologic<br />

formations had already been included within the Crater Lake N.P. boundary. Further investigation has<br />

revealed that there are still geologic formations on the national forest land along Sand Creek that warrant<br />

Unique Area consideration. This is also true of other potential special interest areas that have been<br />

analyzed. Because of the small acreage size of many potential special interest areas, it is not easy to<br />

locate them on alternative maps. However, maps are available to view at the Winema National Forests<br />

Supervisor's Office. The Klamath Indian religious sites are protected by the Freedom of Information<br />

Act, the AIRFA of 1978 and the ARPA of 1979.<br />

Comment<br />

However, reasons should be given for not designating the remaining sites as SIA's in the preferred<br />

alternative. The priority ranking that was assigned to each site in Table 111-28 (p. 111-77) indicates that a<br />

number of the historic sites are considered high priority. Why were these not included in the preferred<br />

alternative, especially since they are of minimal acreage and presumably with few resource conflicts?<br />

<strong>Response</strong><br />

The potential Special Interest Areas were often not recommended as a Special Interest Area because<br />

it was felt that allocation to management areas such as scenic, riparian, or minimum management<br />

would achieve a similar result, in that they would remain in a fairly natural condition. Historic sites on<br />

the forest are covered by several Acts that require inventory and evaluation for significance and any<br />

subsequent protection. It is true that these are limited in size.<br />

Comment<br />

The preferred Alternative E map shows two units of Developed Recreation (Management Area 2) north<br />

of Highway 140. The units appear to overlap our State Highway Maintenance Station. If that is the<br />

case, there would be a serious conflict between the recreation use and our snow removal/routine<br />

maintenance activities. We also would not want to encourage public use around our housing and other<br />

facilities. The Developed Recreation area would not permit any new structures to be constructed.<br />

<strong>Response</strong><br />

The Developed Recreation Management Area north of Highway 140 was intended to depict areas near<br />

Billie Creek approximately one-half mile west of the Maintenance Station. A buffer area with topographic<br />

and vegetative screening will be maintained between the Station and any new facilities constructed.<br />

Comment<br />

If we could get the Forest Service to close the lower road to the creek (The Highway Dept. would be<br />

very happy because of the way the road enters the highway right at the turn at the bottom of the hill)<br />

and have someone patrol the camping area, -this would stop a lot of the indiscriminate shooting that<br />

goes on, also there is a tremendous amount of small dead timber near where they put their boats in.<br />

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This is an awful fire hazard not so much for your Forest land but we and our neighbors have quite a<br />

lot of money invested in our homes and property.<br />

<strong>Response</strong><br />

This situation was handled outside the planning process.<br />

Comment<br />

We support the recommendations in the draft plan for developed recreation. It is our opinion that dispersed<br />

recreation levels are too high in the plan and do not match demand while developed recreation demand<br />

is underestimated. The general age of the population is increasing, and so is their desire for developed<br />

recreation.<br />

<strong>Response</strong><br />

Recreation demand has been reanalyzed based on updated use data and recent State and National<br />

demand projections. The results of this analysis are presented in Chapter 3 of the FEIS.<br />

Comment<br />

The Forest Service needs to be pro-active towards increased recreational development rather than<br />

re-active. Leadership needs to be taken and demonstrated, which is not the present case. The Forest<br />

Service is too conservative and needs to take a risk towards future development of Pelican Butte.<br />

<strong>Response</strong><br />

In accordance with the new 'Recreation Strategy, the Winema National Forest is taking a more pro-active<br />

role in assessing recreational needs, upgrading facilities and promoting opportunities through partnerships<br />

with user groups and other agencies. The Recreation Facility and Trail Activity Schedules in the<br />

Forest Plan outlines planned recreation development and improvement projects.<br />

An option to develop a portion of Pelican Butte for winter sports is maintained in the Forest Plan. The<br />

current development proposal is being analyzed in a separate site-specific EIS.<br />

Comment<br />

Page 11-9, 2nd paragraph. This discussion implies that the Winema's recreation demand is generated<br />

only from the populations of Klamath, Jackson, and Josephine counties. The role and impact of population<br />

growth and recreational visitation from Deschutes, Lake, Modoc, and Siskiyou counties should be<br />

clarified in the demand projections.<br />

<strong>Response</strong><br />

This section has been revised to reflect a reevaluation of recreation demand based on State and National<br />

demand projections as well as local and regional population growth.<br />

Comment<br />

The statement that 'recreation and tourism have not played a dominant role in the development of the<br />

local economy' is inconsistent with local economic data and analyses. It is widely recognized and<br />

documented that recreation and tourism is the 'third legs of the local economy after agriculture and<br />

wood products industries.<br />

<strong>Response</strong><br />

While we agree recreation and tourism is an important component of the local economy, we don't feel<br />

it has been a dominant factor when compared to the agriculture and wood products industries.<br />

Comment<br />

Your recreational planning models appear to understate both the value and the trends in recreational<br />

use. I believe the recreational supply-demand analysis also leads to understating future use of the<br />

forest. This seems particularly true for the net new trails planned. The growth in snowmobiling and<br />

cross country skiing warrant more development than planned and contribute critical seasonal employ-<br />

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ment. I believe that a niche market in horse packing and trail riding can develop with encouragement<br />

from the Forest Service.<br />

<strong>Response</strong><br />

Recreation demand has been reestimated based on updated data and assumptions which are more in<br />

line with the new ORecreation Strategy." The results are displayed in Chapter 3 of the FEIS. The Activity<br />

Schedules in the Forest Plan has been expanded to schedule upgrading/expanding of existing facilities<br />

and adding some new facilities, including trails for winter and horse use. Outfitter-Guide permits can<br />

be issued to authorize commercial horse packing and trail riding. Restrictions on party size within<br />

wilderness limits such operations until additional trails suitable for horse use are developed outside<br />

wilderness.<br />

Comment<br />

On the Forest, the Klamath District has and is the primary focal point in recreation. It is felt that the<br />

other districts should be managed more actively to reach their full potential in the recreation area.<br />

These districts have been de-emphasized, and I think the Forest should more completely address the<br />

recreational opportunities on these districts, provide the funding to develop these opportunities, and<br />

the necessary staffing to develop, maintain and increase the recreational opportunities on these districts.<br />

These opportunities include everything from birdwatching, cross-county skiing, horse use to ATV's and<br />

snowmobiles. There is no mention of investments into recreation and this needs to be done.<br />

<strong>Response</strong><br />

See previous comment. Recreation opportunities are emphasized Forest-wide in the FEIS Preferred<br />

Alternative.<br />

Comment<br />

What are the 'variety of other uses, that other unroaded areas will be subjected to?<br />

<strong>Response</strong><br />

The 'other uses' are dependent on the capability of each area. For instance the Aspen area in the<br />

Preferred Alternative has portions allocated to Old Growth Management, Timber Production, and Minimum<br />

Management. A detailed breakdown of allocations for each inventoried roadless area by alternative in<br />

shown in Table C-6 in Appendix C.<br />

Comment<br />

No perceptible change in the Forest by the end of the first decade?? There are already very perceptible<br />

changes in the aesthetic and biological conditions in many areas.<br />

<strong>Response</strong><br />

That is true. There will be a perceptible change in the Forest by the end of the first decade. The Chemult<br />

District has changed due to the mountain pine beetle epidemic, the Klamath District will continue to<br />

change due primarily to the armillaria root rot disease that is increasing, and the uneven-aged<br />

management in the pine types will maintain a forest cover condition but change the vegetative structure.<br />

Comment<br />

Where on Klamath R.D. will recreation developments go? Are any of these areas in current roadless<br />

management?<br />

<strong>Response</strong><br />

Recreation developments would be expanded or established primarily in the Developed Recreation<br />

management area allocations. All existing developed recreation sites and areas on the Klamath District<br />

are included in these allocations. Some developments may be planned for other management areas to<br />

achieve recreation management direction for those management areas. Planned developments are<br />

listed in the Activity Schedules in Appendix B in the Forest Plan.<br />

The Pelican Butte Recreation Area is proposed for development within the Sky Lakes B area and some<br />

trail construction is currently planned in the Brown Mtn., Yamsey Mtn. and Sky Lakes B areas.<br />

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Comment<br />

(last Par.) Specify how many acres of Yamsay and Brown Mountain areas will remain roadless, contrast<br />

with planned harvest areas.<br />

<strong>Response</strong><br />

All of the Yamsay and Brown Mountain areas is allocated to semiprimitive recreation and will remain<br />

roadless. The acreage allocations for all roadless areas can be found in Table C-6 in Appendix C of<br />

the FEIS.<br />

Comment<br />

How much acreage would the annexation of Crater Lake National Park and Sky Lakes Wilderness Area<br />

include?<br />

<strong>Response</strong><br />

Sky Lakes Wilderness is already a part of the Winema and Rogue River National Forests and we have<br />

no plans to annex Crater Lake National Park.<br />

Comment<br />

We have several concerns with your overall treatment of the values of recreation on the Forest. First, in<br />

your use of composite recreational values based on the recreational opportunity spectrum class, the<br />

value of specific types of recreational activities is understated. This particularly undervalues the high<br />

quality hunting and fishing that occur on the Winema. We recommend that recreational values be<br />

recast by specific activities.<br />

<strong>Response</strong><br />

Hunting and fishing use, as well as non-consumptive wildlife uses, have been valued separately as<br />

Wildlife and Fish User Days (WFUD's). Downhill skiing was also valued separately at a higher rate per<br />

visitor day. Average ROS class values were used for all other developed and dispersed uses, because<br />

of the large number of activities involved.<br />

Comment<br />

The economic values of recreational activities have been discounted by 37 percent. In addition,<br />

recreational values have been assigned by a 0 percent per year real price trend throughout the life of<br />

the plan while a one percent per year real price trend for timber was used for harvest scheduling analyses.<br />

We believe these adjustments to be unsupported and result in a serious under-evaluation of the<br />

contribution recreation makes to Present Net Value (PNV).<br />

<strong>Response</strong><br />

This method of valuation was based on National planning direction.<br />

Comment<br />

Wilderness - (DEIS, page 111-82, App.) The text states that "...dispersed recreation use in wilderness<br />

has not increased over the last few years... [and that]...current wilderness use is below the potential<br />

capacity of the available wilderness.... However, a 10 percent increase in wilderness use is projected<br />

from 1985 to 1995 based on population trends. The text also states that use is expected to increase 5<br />

percent per decade during the next four decades -- which disagrees with the 10 percent projected for<br />

the current decade. While these numbers need to be clarified in the Final EIS, it appears that the Winema<br />

may have projected an overly optimistic view of the potential future use of these areas. The population<br />

age is increasing, especially in southern Oregon, which would lead to the possible conclusion that<br />

more sedentary recreation and more roaded, developed recreation will be in demand. The Final EIS<br />

should also relate expected population demographics to projected use changes by recreation type.<br />

<strong>Response</strong><br />

Both the Wilderness and Recreation sections of Chapter 3 have been revised to include updated use<br />

projections.<br />

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Comment<br />

Where possible, the plan should identify recreational use in terms of the major specific recreational<br />

activities as well as by ROS classification. Projections of such use should take into account historical<br />

growth in the forest, the differential growth rates of the activities, and the possible effects of recreationists<br />

from outside the three county areas.<br />

<strong>Response</strong><br />

Recreation use projections have been revised using updated data and recent State and National<br />

projections by activity. Results are displayed in Chapter 3 of the FEIS.<br />

Comment<br />

Examples given of recreational use by ROS class are potentially confusing. For example, current demand<br />

for over 92,000 acres of 'Primitive' wilderness is given as over 38,000 RVD's per year while current<br />

demand for 32,000 acres of oSemiprimitive Motorized and Non-motorized" recreation is given as 800<br />

RVD'S per year. This appears to be an extremely low demand for semiprimitive recreation, especially<br />

when compared to the demand cited for primitive recreation. It also is at extreme variance with the<br />

demand for semiprimitive recreation cited by other forests in Oregon.<br />

<strong>Response</strong><br />

The very low use shown for semiprimitive recreation is due to the nature of the areas that make up the<br />

32,000 acres in this ROS class. Much of this area consists of small isolated tracts that are relatively<br />

inaccessible. Demand projections for this ROS class have been updated based on current data. Results<br />

are shown in Chapter 3 of the FEIS.<br />

Comment<br />

Capacity and demand for developed recreation is defined in terms of developed recreation opportunity<br />

classes. In terms of these classes, capacity exceeds demand. While this analysis may be adequate in<br />

terms of the land base available, it is insufficient in terms of the facilities necessary for developed recreation.<br />

The plan should analyze the adequacy of facilities at Lake of the Woods and Rocky Point to meet<br />

future use. The adequacy of smaller developed sites throughout the forest should also be addressed.<br />

<strong>Response</strong><br />

The recreation section in Chapter 3 in the FEIS has been expanded to include information on existing<br />

uses. Recreation use projections have been revised based on expanded and updated data. Developed<br />

site capacities have also been analyzed by recreation area or complex to determine need for additional<br />

facilities to meet future use.<br />

Comment<br />

However, projections of future conditions throughout the planning horizon (pp IV-69 to IV-79) raise<br />

concern in some areas. For example, State Highway 140 is projected to improve to unatural appearing'<br />

than to go to nslightly altered"; State Highway 52 from Nslightly altered' to "moderately altered.' Other<br />

areas with similar fluctuations are: Westside Lake of the Woods, Sprague River Road, Silver Lake Road,<br />

Squaw Flats, Varney Creek Trail (to "heavily altered") Williamson River (to wheavily altered' in the first<br />

decade). Sycan Ford and others. Many of these are not only major thoroughfares through the forest<br />

but important recreational areas. We believe it is not only important to improve visual conditions in the<br />

long run but also to maintain existing visual qualities. It is recognized that removal of bug killed lodgepole<br />

may be responsible for much of the projected visual decline. That needs fuller description in the plan.<br />

In areas along the major travel routes and recreation areas where dead lodgepole is not the issue,<br />

existing acceptable and stable visual qualities should be maintained where possible.<br />

<strong>Response</strong><br />

We agree that it is important to improve long-term visual conditions and maintain existing visual qualities<br />

but consistent with the visual quality objective associated with a specific land area The DEIS shows a<br />

short-term inability to achieve desired scenic condition in the first decade or two in several viewsheds.<br />

This is sometimes due to mountain pine beetle infestation or other disease, but also because the amount<br />

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of area that can be in "created opening, (scenic definition of vegetation less than 20 feet in height) is<br />

often already exceeded. In the FEIS FORPLAN constraints better reflect capability in scenic management<br />

areas to achieve desired future conditions.<br />

Comment<br />

In the DEIS, Tables IV-23 and IV-24, an analysis of the acreage in management area 3 is compared to<br />

the visual quality objective inventory. This is useful information; however, it does not tell the complete<br />

story. The reader should be able to compare by alternative the acreage to be managed as inventoried<br />

for each management area, not just management area 3. This would allow the reader to evaluate how<br />

many acres inventoried with a high standard of visual protection have been dropped out of each alternative<br />

and would be managed with little visual protection if the alternative was adopted.<br />

<strong>Response</strong><br />

A table has been created in the FEIS that better reflects the allocation of viewshed parts to other<br />

management emphases.<br />

Comment<br />

The forest plan should include a full recreation plan, including potential developments as well as<br />

allocations. Your discussion of treatments for dispersed recreation sites is inadequate. You need further<br />

discussion of trails, especially the Fremont National Recreation Trail. And you need more consideration<br />

for a broader spectrum of recreation.<br />

<strong>Response</strong><br />

A detailed recreation plan for the Forest is beyond the scope of the Forest plan effort. The planning<br />

effort has considered current recreation need, opportunity and potential. Additional discussion of<br />

dispersed recreation area and activities have been added to Chapter 3 of the FEIS. Proposed recreation<br />

development, including trail construction, is identified in the Activity Schedules in Appendix B of the<br />

Forest Plan.<br />

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Roads and Corridors<br />

Comment<br />

The proposal would create a level E grade of road on the Forest to include all above400 travelways<br />

which are primarily suited for high clearance/4WD use. Level D is not suitable because the plan stated<br />

that these are either constructed for local access to timber and closed after cutting, or will be maintained<br />

for administrative use only (i.e. always closed).<br />

<strong>Response</strong><br />

The terrain on the Winema is relatively flat and there exists and extensive system of roads on the Forest,<br />

ranging from high standard to primitive roads. With the exception of Wilderness and Semi-primitive<br />

Unroaded Areas, access to almost all areas of the Forest, including remote areas, on roads suitable<br />

for high clearance/4WD currently exists and would continue to exist in the Forest Plan. The FEIS and<br />

Forest Plan does not categorize roads into Level A to D, but instead in Levels of Access, consisting of:<br />

1) access suitable for passenger cars, 2) access suitable for high clearance vehicles, 3) intermittent<br />

access (open/closed), and 4) short term roads (to be removed from the road system). These levels<br />

were shown on Pg. 111-101 of the Draft EIS and in FEIS.<br />

Creating a new category of Level E roads (suitable for high clearance/4WD) would be duplication of<br />

those roads identified to be suitable for high clearance access in the EIS and Forest Plan. We feel that<br />

the purpose and intent of creating a Level E road is already being met in the existing access level<br />

categories. Also, since Levels of Access are described, not Categories A to D, creation of a Level E<br />

road would not be consistent. Also, we would note ORV/4WD objectives within the written objectives<br />

for the road and manage accordingly. Roads are closed for the purpose of reducing high road densities,<br />

for such purposes as maintaining wildlife habitat, reducing road maintenance costs, etc. Closing these<br />

roads does not result in denying access to Forest land areas, including remote areas, but does reduce<br />

the open road densities within individual areas. The forest also intends to produce Forest travel plans<br />

and maps, which would display the availability of high clearance/4WD/ORV uses.<br />

Comment<br />

I would strongly request that you add a strategy to consider the successes of User-cooperative programs<br />

such as Adopt-a Trail/Road.<br />

<strong>Response</strong><br />

The Forest has utilized volunteer and cooperative efforts on many occasions in the past, to seek input,<br />

to coordinate, and for actual accomplishment of projects. These efforts have been very successful and<br />

have allowed accomplishment of projects with limited budgets. It is our intent to continue such successes<br />

with volunteers and user-cooperator groups and programs. Standards and Guideline #6, Page IV-36,<br />

of the Draft Forest Plan speaks to continued coordination with user groups.<br />

Comment<br />

Your plan does not recognize the large network of existing and previously open network of old forest<br />

roads/logging roads/stage roads which are shown on topo maps as "jeep trails' as the substantial<br />

opportunity it is.<br />

<strong>Response</strong><br />

The Forest Road System, comprised of over 6000 miles of roads, has been inventoried and categorized<br />

into travel access levels. A large percentage of the roads consist of old Forest roads and are open<br />

and available for ORV/4WD use. When a Forest Travel Plan and map are produced, it is our intent to<br />

identify in more detail, ORV/4WD opportunities and locations. This would be done by working with the<br />

various 4WD/ORV organizations to develop and agree upon opportunities. We have in the past worked<br />

with 4WD/ORV associations. The opportunity is recognized in the Proposed Forest Plan in that the<br />

majority of the Forest is open to ORV/4WD uses. The plan does provide for 4WD/High clearance use<br />

on a large percentage of the network of primitive travelways.<br />

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Comment<br />

Many recreational assets have been attributed to the high standard road system being built to service<br />

the timber projects, in which you know that we have little interest. The plans have closed 90% or more<br />

of these after the timber is cut. How do you explain this contradiction.<br />

<strong>Response</strong><br />

We do not feel that there is a contradiction. The statement that 90% of the high standard road system<br />

has been closed is not correct. The Winema's high standard road system has been previously constructed<br />

and in place for many years. Very little of this road system has been closed after the timber sale, but<br />

has remained open to provide long term access for administrative, public, and recreational purposes.<br />

Almost all of the roads being built now are low standard timber access road only, and no major recreational<br />

assets have been identified in the written road objectives. The roads that have been closed to use<br />

have been identified as intermittent or temporary road needs. These roads have been closed for a<br />

variety of reasons, including reduction of open road densities in wildlife areas, reduction of road<br />

maintenance expenditures, for re-establishment of vegetation, and for protection of the resource.<br />

Comment<br />

Winter driving conditions in viewshed areas could be improved on primarily E-W trending roads if some<br />

trees were removed to the south. This would allow the sun to melt snow or ice on highways, improving<br />

driveability. Also, the highways might be in better condition if snow and ice were melted to stay off the<br />

highway. It is presumed uneven-aged harvest to the south side of primarily E-W trending highways in<br />

viewshed management would improve driving conditions in winter and also lessen road surface<br />

deterioration with more sun shining on the pavements.<br />

<strong>Response</strong><br />

We agree that there are opportunities to do the above types of management to improve driving conditions<br />

and that there would be benefits on certain roads and highways in terms of hazard tree removal, opening<br />

up of vistas in viewshed corridors, and for the reduction of deer kill along main travel corridors. It should<br />

be noted that very few of the roads under the jurisdiction of the Forest Service are paved. The opportunities<br />

spoken to in your comment pertaining to paved roads applies mainly to the paved high standard road<br />

system, which is under the jurisdiction and maintenance of the State of Oregon, Klamath County, or<br />

others.<br />

Comment<br />

The increase of road building in your plan also deteriorates the protection for our wildlife. The construction<br />

of roads by our government for private industry to use to harvest our timber resource is a sore spot<br />

with me anyway. Building roads into areas that serve as cover for our herds of elk is damaging to their<br />

survival.<br />

<strong>Response</strong><br />

The primary road system is in place. Levels of road construction described in the plan are necessary<br />

to adequately carry out the Forest's Mission. Almost all of these planned roads would be low standard<br />

intermittent access roads and would be closed to access during periods of time when access is not<br />

required. Please refer to the FEIS, Appendix D, and to the Forest Plan, Chapter 4 which discusses<br />

direction and standards and guidelines pertaining to management of open road densities and road<br />

closures.<br />

The Forest Plan specifies that approximately 360 miles of minimum standard local roads will need to<br />

be constructed in two decades for timber harvest. These roads are required to complete the Forest<br />

Transportation plan. However, within the same time periods, the Forest Plan also shows a net reduction<br />

in the total miles of roads on the Forest, even with the new road construction. This is because many<br />

existing roads not needed for future management activities have been identified. These roads have<br />

been or will be closed-to use and will be returned to the productive land base. The overall net effect is<br />

a reduction in the total Forest road miles. In the past the Forest has implemented an aggressive program<br />

of closing roads to use. Over 1700 miles of intermittent access and short term roads roads have been<br />

closed to use, to reduce open road densities, to return short term roads to the productive land base,<br />

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and to reduce road maintenance expenditures. Under the Preferred Alternative, roads would continue<br />

to be closed when not needed, to reduce high open road densities.<br />

Comment<br />

Let the Timber companies build their own roads and totally restore them after any current sales.<br />

<strong>Response</strong><br />

Almost all of the roads constructed on the Forest, whether long term system roads or temporary roads,<br />

are constructed by the timber companies, through provisions within the timber sale contract. Intermittent<br />

or temporary access roads constructed by timber companies are closed to use or restored, either by<br />

the timber purchaser, or through a collection deposit with the provisions of the timber sale.<br />

Comment<br />

Congress has directed the Forest Service to administer the National Forests for multiple use. Yet for<br />

over 25 years this mandate had virtually been ignored and instead the Forest Service has emphasized<br />

logging and road construction. And doing this while losing money--selling its stock-in-trade far below<br />

the cost of production.<br />

<strong>Response</strong><br />

The Forest Service makes many investments in multiple use. The Forest Service was a leader in developing<br />

wilderness areas, campgrounds have been developed at many major attractions, visual corridors are<br />

maintained along major travel routes, habitat is developed and maintained for both harvested and<br />

non-harvested wildlife species. The list could go on and on. National Forests were established to provide<br />

goods and services for the public, not to be set aside as preservation areas. The Winema is a very<br />

cost effective Forest. Our timber receipts far exceed the cost of road construction and timber management<br />

costs.<br />

Comment<br />

The Winema Plan proposes the construction of only 5 miles of new trails (Plan at IV-33); the east-west<br />

T route markers," referenced at DEIS 11-51, are not substitutes for trails. The sparsely populated Fremont<br />

Forest, upon implementation of its plan, would have nearly twice the mileage of trails as the Winema.<br />

<strong>Response</strong><br />

The levels of recreation opportunities and related facilities (such as trails) provided in the Preferred<br />

Alternative has been re-evaluated. This was in response to public comment and to consider direction<br />

and opportunities contained in the recent National Recreation Strategy. Please refer to the FEIS and<br />

Forest Plan which incorporates the re-evaluation.<br />

Comment<br />

Logging practice and road building methods need to be carefully considered so as to minimize soil<br />

disturbance and sedimentation. The vegetating of road cuts and fills is required and native plants need<br />

to be used; do not bring in outside species.<br />

<strong>Response</strong><br />

The terrain of the Forest is mostly gentle; only about 5% of the Forest has slopes greater than 35%.<br />

Because of this gentle terrain and the porous pumice and ash soils that are capable of absorbing and<br />

transmitting water very rapidly, the Forest does not have a major problem with surface soil erosion or<br />

landslides. The potential for excessive surface erosion is limited to that 5% of the Forest with slopes<br />

over 35%, and to a limited number of concern areas. Many of the standards and guidelines for logging<br />

practices and road construction and reconstruction are written to reduce and minimize soil disturbance,<br />

sedimentation, and erosion. These standards guidelines were contained in the Draft EIS and Proposed<br />

Forest Plan, and are contained in the FEIS, Appendix D, and in the recommended Forest Plan, Chapter<br />

4. The need to revegetate road cuts and fills is considered when situations warrant.<br />

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Comment<br />

Facilities Forestwide Standards and Guidelines (IV-60) describes the anticipated closing of roads no<br />

longer needed. Can such roads be used for snowmobiling? Just as some trails are built or improved<br />

by snowmobile clubs, perhaps these could be maintained by users to the extent needed, with some<br />

even being groomed. We assume new roads can be used for recreation which conforms to the Plan<br />

for the specific area involved.<br />

<strong>Response</strong><br />

The roads which are designated as no longer needed, and intended to be closed, have no identified<br />

future needs such as timber access or recreation uses, including snowmobiling. These roads are almost<br />

exclusively low standard short length roads, many of which deadend or duplicate other access available.<br />

We would want to work with the SNOWMOBILE ASSOCIATION and CLUBS to determine if some of<br />

these roads do in fact serve snowmobiling needs or opportunities. In the past, prior to closing any<br />

roads, we have held public meetings to provide information and seek input regarding the intended<br />

closures. We have modified our planned closure program based on input received and intend to continue<br />

this policy.<br />

Comment<br />

There are some potential conflicts between the plan statements and the operational requirements for<br />

State highways. In the appendices to DEIS, page D-45 under facilities 2. 'Transportation and Utility<br />

corridor location and associated facilities would be avoided in this management area (scenic).<br />

There is no specific statement recognizing the unique requirements of the transportation corridors,<br />

specifically the State highway routes. Those requirements are addressed in Section V 'Maintenance' of<br />

the Memorandum.<br />

The standards and guidelines should recognize the substantial amount of existing facilities and the<br />

potential need for expansion of those facilities.<br />

<strong>Response</strong><br />

It was intended that this standard and guideline applied to the location of ' 'new corridors and their<br />

associated facilities. This standard and guideline has been revised to differentiate between 'new' and<br />

'existing, corridors.<br />

The National, State and Local significance and unique requirements of transportation and utility corridors<br />

was recognized in the DEIS (chapter III, Page 109-113. In Chapter 4 of the DEIS, Page 96-99, this<br />

significance is further recognized in that actual corridor designations for existing corridors are proposed<br />

in all alternatives. These proposed designations have also been added to the Forest Plan and appear<br />

in Chapter 4, under the section entitled Transportation and Utility Corridors.<br />

Comment<br />

The Proposed Land and Resource management Plan, p. IV-75, Management Area 3: Scenic Management,<br />

needs to be balanced by operational needs. 'The desired future condition is a natural-appearing forest<br />

environment --.' The operational needs of highways need to be recognized i.e., large trees cannot be<br />

permitted very close to the traveled way.<br />

'Landscapes or portions of landscapes not meeting visual quality levels because of negative visual<br />

elements, such as skid roads, activity residues, or cable corridors will be rehabilitated as opportunities<br />

occur, with consideration for the resource values present.'<br />

This concept could be added to Section IX of the 'Memorandum.' That particular section of the<br />

'Memorandum' covers most of the Scenic Management concerns.<br />

<strong>Response</strong><br />

A major highway is usually considered an inclusion within a scenic management allocation which typically<br />

would achieve the modification visual quality objective and be the points from which the scenery is<br />

viewed. The Forest has a hazard tree program that includes the areas adjacent to public roadways.<br />

This analyzes all sizes of trees for potential removal or modification if found to be hazardous to the<br />

public.<br />

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Comment<br />

Specifically, there is a need to manage roadside vegetation in zones.<br />

The zone from the edge of the pavement out to 8-10' needs to be kept bare to:<br />

maintain surface drainage, maintain subsurface drainage, reduce fire hazard, eliminate breakup of<br />

pavement by plants, reduce deterioration of roadside hardware, maintain visibility, and provide for<br />

snow storage.<br />

Zone 2 would extend from the first zone outward to meet all operational needs. This zone basically<br />

covers the roadbed prism and beyond where necessary.<br />

Control of vegetation in this zone is necessary to:<br />

improve drainage, maintain visibility of signs, increase sight distance on curves, increase sight distance<br />

at intersections, control danger trees and noxious weeds,provide visibility of pedestrian and animals,<br />

remove trees that shade the highway and perpetuate icy spots, remove trees that cause a strobe light<br />

effect on drivers because of the continuous light/shade, and remove roadside obstacles that can be<br />

hazardous to an errant vehicle.<br />

The third zone would provide a transition to adjacent land use, conserve desirable vegetation and<br />

enhance views. A vegetative management system similar to that described in USDA Handbook No.<br />

483, as irregular clearing and feathering is desirable. This would consist of a zone of grass and/or<br />

uniform, very low-growing shrubs to provide a backdrop for animal visibility especially that would still<br />

offer the traveler a visual penetration into the forest of about 300 feet. This would prevent the tunnel<br />

appearance which seems to have a hypnotic effect.<br />

<strong>Response</strong><br />

We largely agree with the statements above, except for Zone 3, which would be determined on a case<br />

by case basis during project planning. Viewshed or vegetative management guides for implementing<br />

the Forest Plan would provide guidance relative to desired future vegatiative condition, user safety and<br />

other identified needs and opportunities.<br />

Comment<br />

The City believes that the Forest Service should revise the standards or define the term 'transportation<br />

and utility corridor in such a way that it is clear that all access roads are not transportation corridors.'<br />

Also, the term Oavoided' is not defined in either the LRMP or DEIS, although Winema staff have indicated<br />

that this term has a specific meaning to the Forest Service. Even if not relevant to the Pelican Butte<br />

area, the City suggests that this term be defined in the final LRMP and EIS.<br />

<strong>Response</strong><br />

It is not intended that any road is a Transportation Corridor. The definition is in the DEIS, Glossary,<br />

Page GL-33, and in the Proposed Forest Plan, Glossary, Page GL-33. The intent and definition of utility<br />

and transportation corridors was also discussed in the DEIS, Chapter III, Page 109, 1st Paragraph.<br />

Chapter 4, Page 97 of the DEIS displays the existing corridor designations. Existing corridors were<br />

designated in all alternatives. The corridor designations shown in Table IV-31 on Page IV-96 of the<br />

DEIS have been added to the Forest Plan, along with a short discussion of the intent and definition of<br />

transportation and utility corridors.<br />

Exclusion Areas and Avoidance Areas are defined and described in the DEIS, Chapter 4, Page IV-97<br />

and 98. This same information has been added to the recommended Forest Plan, and definitions included<br />

in the glossaries.<br />

Comment<br />

The LRMP also states that 'transportation and utility corridor location and associated facilities will be<br />

avoided in this management area." Winema staff have informed the city that transportation and utility<br />

corridor' has a specific meaning to the Forest Service, and that all roads are not 'transportation corridors."<br />

However, the phrase is not defined in the LRMP or DEIS. Without a definition, it is possible for future<br />

Forest Service officials or others to interpret the LRMP text so that any road is a transportation corridor.'<br />

If so, the location of a road in a Scenic Management area would be 'avoided' according to the LRMP,<br />

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which seems to be inconsistent with the standard concerning design of roads and other facilities discussed<br />

above.<br />

<strong>Response</strong><br />

Transportation and Utility Corridors were defined in the DEIS and in the Glossaries. Please refer to the<br />

<strong>Response</strong> to the above.<br />

Comment<br />

Will new roads automatically be scheduled for closure?<br />

<strong>Response</strong><br />

When 'new* roads are determined to be needed for management activities, the proposed road has a<br />

road management objective prepared which specifies the resource objectives served, environmental<br />

constraints, design criteria, and how the road is to be operated and maintained. The road objective<br />

establishes whether the road access need is intermittent, or constant service. If the need is for intermittent<br />

access, and there are no access needs after the timber sale or other activity ends, then the road is<br />

scheduled for closure. The closure is accomplished, either by the timber sale or through collected<br />

deposits for road closure. In most cases, a deposit is collected which is used to accomplish the closure.<br />

Almost all of the new roads to be constructed on the Winema will be intermittent access roads, to be<br />

closed when access is not required.<br />

Comment<br />

(Notes, #32) How much is a *minor' amount of collector road construction?<br />

<strong>Response</strong><br />

Ten miles of collector road construction is anticipated. This was stated in Section III, Page 103 of the<br />

DEIS and in Section IV, Page 35 of Proposed Land Management Plan.<br />

Comment<br />

Why will considerable investments' to the transportation system be needed if only "minor additions to<br />

the road system are foreseen?<br />

<strong>Response</strong><br />

This statement, in Section IV, Page 21 of the Proposed Land Management Plan referred to considerable<br />

investments for I transportation systems, reforestation, and protection (fuels treatments, control of insects,<br />

disease, and animal damage). The cost of new additional roads is only a portion of this total cost. Also<br />

included in the investment cost are those costs associated with road reconstruction on existing roads,<br />

road maintenance, road closures, and road management and road operation costs on existing roads.<br />

The level of new road construction and road reconstruction was shown in Section IV, Page 35 of the<br />

Proposed Land Management Plan, and in Table IV-1 (Page IV-9). Even though the majority of the forest<br />

road system is constructed, sizable investments are still required to complete the transportation system<br />

and to bring certain existing roads to standard, through reconstruction and maintenance of roads.<br />

Comment<br />

Cooperation for road 'management' is mentioned, what is road 'management'? Be specific in addressing<br />

need for road closures.<br />

(last Para.) First sentence poorly worded and conveys little information; needs re-write.<br />

<strong>Response</strong><br />

Road Management refers to the overall management of all road activities, in accordance with established<br />

road management objectives, as discussed in Section IV, Page 58 of the Proposed Plan. The range of<br />

these activities was described in Section IV, Page 57 and 58, of the Draft Plan. A portion of the forest<br />

road system is not required to be open continually and access is required only intermittently, when<br />

there is a timber sale or other access need. These roads are closed during non-use periods. The need<br />

to close roads and the associated benefits were spoken to in the DEIS, Section III, Pages 102 and<br />

104, and in the Proposed Forest Plan, Standards and Guidelines Section, Page IV-41 and IV-59. In<br />

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esponse to public comment, additional information on road closures and standards and guidelines<br />

was included in the final FEIS and the Forest Plan.<br />

Regarding the last paragraph, first sentence on Page IV-35, this sentence has been rewritten to clarify<br />

the intent.<br />

Comment<br />

Guideline 1 under Facilities (p. IV-127), would appear to mandate the construction of roads in RNA's.<br />

We strongly object to this provision. We can visualize no form of research or other approved use of<br />

the RNA's on the WNF that would necessitate road construction, and we request that you clearly prohibit<br />

road construction for any reason in RNAs.<br />

<strong>Response</strong><br />

This standard was not intended to mandate the construction of roads in Research Natural Areas (RNA's).<br />

It is a standard to be applied if it is determined that road access within a RNA is required for management<br />

of the RNA. A Standard and Roads would not be constructed unless the intent and management of<br />

the RNA actually required road access to achieve the management goals of the RNA. This intent is<br />

also emphasized regarding issuance of easements and rights of ways.<br />

Comment<br />

I think road must be built through the Wilderness Area as well as all other Forests.<br />

<strong>Response</strong><br />

With certain exceptions, construction of roads in designated National Forest Wilderness is prohibited<br />

in the Wilderness Act. Reference: Wilderness Act of 1964 and Code of Federal Regulations, Section<br />

36, 293.6.<br />

Comment<br />

Roading Costs - (DEIS, page 11-95, App. B) The preferred Alternative (E) plans for 21.7 miles/year of<br />

timber purchaser road construction in addition to a minor amount of the 16.2 miles/year of collector<br />

road construction during the first decade. Very little discussion is provided about timber purchaser<br />

road construction costs even though this is a major cost category tracked in FORPLAN. A summary of<br />

acres of harvest shows that 31 percent or 9,700 acres of regeneration harvest will be done during the<br />

first decade without identifying type of harvest method. How much of this will be tractor and how much<br />

cable yarded? We question the assumption that roading costs would be the same for cable systems<br />

as for tractor systems. It is possible that the steeper ground where cable systems are used for yarding<br />

engenders higher dollar per mile roading costs which offset the lower road densities required. In fact,<br />

however, on much tractor ground, there are, or should be, very low road costs. In any case, road costs<br />

are of high enough significance that a thorough analysis should have been presented rather than<br />

simply assuming that the costs are the same.<br />

<strong>Response</strong><br />

1. The 16.2 miles/yr. referred to above is not new road construction. This annual mileage consists<br />

entirely of reconstruction of the existing Arterial and Collector Road System. This figure, as shown in<br />

Table 11-3a, on Page 11-95, was titled Arterial and Collector Road Reconstruction.<br />

2. The costs discussed above were not assumed to be the same and did vary in the analysis. These<br />

costs varied in the analysis depending on road density, location, the percent of ground sideslope, and<br />

the standard of road. This range of construction costs is shown in Table B-9 (Pg. B-89), which shows<br />

the range in costs per mile for local road construction and reconstruction. As noted on Page B-87 of<br />

the Appendix, it was not the intent to document the development of all these cost estimates in the<br />

Appendix. Further documentation of management costs is available in the Forest's process records.<br />

Comment<br />

However, it is unclear, or at the least difficult to surmise from the alternatives and the way the plan is<br />

presented, how road closures will be undertaken to reach the desired density and at what rate. There<br />

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is no discussion of road density relative to stream density under existing or proposed management<br />

direction. Management plans for the road system should be clearer and more detailed and include a<br />

discussion of road density relative to stream density.<br />

<strong>Response</strong><br />

In response to public comment, more information on road densities and road closures has been added<br />

to the FEIS and the Forest Plan.<br />

Comment<br />

The Forest was supplied a copy of the comprehensive results of the 1984 survey of big game hunters<br />

in Oregon. The survey involved input from 5,000 hunters who attended workshops, and an additional<br />

17,000 hunters who returned questionnaires. The results show a high demand for semi-primitive hunting<br />

experience on the Forest are extremely limited. To help meet this demand ODFW recommends the<br />

Forest establish and administer hunting season area closures of roads.<br />

<strong>Response</strong><br />

The Forest currently has one hunting season closure in effect, on the Chemult Ranger District. Other<br />

closures would be considered. -<br />

Comment<br />

According to FSM 4/87 R-6 Supp. 40, 2635.02, the Forest, in coordination with ODFW, must develop a<br />

comprehensive road management plan that includes fish and wildlife objectives. ODFW will provide<br />

more specific input and desired open road densities on the Forest during road management planning.<br />

The Forest should address vehicle travel management using Federal authorities listed in the Forest<br />

Service Manuals (FSM 7110, FSM 2355.1).<br />

<strong>Response</strong><br />

Road management planning would be done in accordance with the new R-6 Supplement 2600-90-3,<br />

2630, dated August 1990.<br />

Comment<br />

P.V-93.<br />

TABLE IV-29. Why would alternatives A-H all have the same total miles of road access by the fifth decade<br />

when the ASQ varies from 77.6 MMBF to 181 MMBF, and roadless acres vary from 17,714 to 29,964?<br />

(DEIS IV-93).<br />

<strong>Response</strong><br />

The reason for the small variation in total miles of road among alternatives (Except ALT.I) is stated in<br />

the 3rd paragraph on Page IV-93 of the DEIS. It is correct that there will be a small variation in road<br />

miles due to the variation in roadless areas acres in the alternatives.<br />

Comment<br />

D-27.<br />

26. On line one change *may' to 'shall."<br />

<strong>Response</strong><br />

The standard has been rewritten and is in Chapter 4 of the Forest Plan and in Appendix D of the FEIS.<br />

Comment<br />

PP IV-5.<br />

(PARAGRAPH 5). How many miles of roads would be constructed to access the roadless areas? (PP<br />

IV-5-1).<br />

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<strong>Response</strong><br />

The number of miles to be constructed has been added to this paragraph, and reflected in the other<br />

tables in the FEIS and Forest Plan which refer to miles of road construction. The number of miles is<br />

approximately 70 miles total.<br />

Comment<br />

Road densities are much too high on the forest. We recommend densities of one mile per section or<br />

less on winter range, 1.5 miles per section on your transition range and on important elk range, including<br />

all spring range, and not more than 2 miles per section on any other portion of the forest. The plan<br />

should discuss the methods for closing roads and a schedule for same.<br />

<strong>Response</strong><br />

The intent of the following direction regarding management of road densities and closing of roads has<br />

been incorporated into the FEIS and the Forest Plan. This direction has been added to Chapter 4 of<br />

the Forest Plan.<br />

1. The objective will be a Forest with the minimum number of roads which are needed for management<br />

activities and for public access. The Winema will manage road densities to meet management<br />

area direction and objectives, to meet access management objectives, and to reduce road<br />

management and maintenance costs.<br />

-Roads which are not needed for future management or public access will be closed and returned<br />

to vegetative production.<br />

-Roads not needed for recurring management or public access will be closed until the next activity<br />

requires access.<br />

2. The previous direction to manage open road densities to an approximate average of 2.5 miles<br />

per square mile has been discontinued. Rather than a overall forestwide average road density<br />

goal, the goal will be minimum numbers of roads to meet management and public access needs,<br />

and a system of open roads consistent with Management Area direction and objectives. The<br />

open road system which supports the areas direction and objectives will be determined through<br />

area or project analysis and documented in the road management objectives and road management<br />

plan.<br />

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Society/Economics/Employment/Budgets<br />

Comment<br />

In reviewing the Forest Service Preferred Alternative, it is noted the sale of Lodgepole and Ponderosa<br />

pine timber types have been altered so that the anticipated revenue to Klamath County will be reduce.<br />

You proposed reduction in the sale of Ponderosa pine will reduce Klamath County's portion of the<br />

Winema National Forest receipts.<br />

<strong>Response</strong><br />

The Preferred Alternative in the DEIS was not altered with any intent to reduce revenue to Klamath<br />

County. The estimated returns to the county for each alternative are shown in a table in the Chapter 2<br />

discussion of Social and Economic Resources. Historic trends in payments to the county are provided<br />

in 'The Local Economy' section of Chapter 3. The preferred alternative from the Draft EIS (Alternative<br />

E) is estimated to generate slightly more returns to the county than the no action alternative (Alternative<br />

A). The preferred alternative in the Final EIS (Alternative J) is estimated to generate slightly lower returns<br />

than the no action alternative. The lower returns of Alternative J are a result of generally lower timber<br />

volumes due to timber inventory updates, conversion to uneven-aged management and additional<br />

emphasis given to other resources. The returns would have been even lower except that we were able<br />

to account for the higher values of the larger diameter ponderosa pine that will be removed while those<br />

stands are converted into an uneven-aged structure. All of these value estimates are based upon historic<br />

timber values. It is not yet clear whether current restructuring in the wood products industries will have<br />

major impacts on log prices in the long run. We can speculate that log prices will rise faster than general<br />

inflation due to supply reductions that seem to be developing in both the public and private sectors<br />

region-wide.<br />

Comment<br />

Individual survey information, described by Finsterbusch as 'the backbone of SlAs* is entirely lacking<br />

in the DEIS and its appendices. These reflects both the emphasis on existing aggregate date, and<br />

Office of Management and Budget constraints upon Federal Government sponsored surveys.<br />

<strong>Response</strong><br />

In another publication (Finsterbusch, Kurt, 'Estimating Policy Consequences for Individuals, Organizations,<br />

and Communities,' in Methodology of Social Impact Assessment, Dowden, Hutchinson and Ross,<br />

Inc., Stroudsburg, Penn) Mr. Finsterbusch states "the social consequences of economic impacts can<br />

be crudely measured by surveys after the fact, but can be only vaguely estimated beforehand on the<br />

basis of past research.! We were unable to uncover much in the way of past research particularly<br />

along the lines of pertinent individual survey information, thus we relied upon existing aggregate data<br />

and reasoned interpretations of that data to differentiate the social impacts of the alternatives.<br />

Comment<br />

The short term trend (since 1977) is towards reduced employment in the wood products industry as<br />

per laborer outputs increase. The DEIS fails to display long-term historic employment trends.<br />

<strong>Response</strong><br />

Employment trends in the wood products industry result from many factors, one of which is improving<br />

efficiency in the industry. 'The Local Economy' section of Chapter 3 includes total employment figures<br />

from 1967 through 1989 for Klamath County and selected employment figures by industrial sector<br />

back to 1979. The following figures show lumber and wood products employment for Klamath County<br />

as far back as we've been able to obtain them (State of Oregon, Department of Employment) as well<br />

as all the data on lumber production available (Western Wood Products Assn) for the county.<br />

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KLAMATH COUNTY<br />

HISTORICAL LUMBER AND WOOD PRODUCTS EMPLOYMENT<br />

AND<br />

LUMBER PRODUCTION<br />

YEAR EMPLOYMENT LUMBER INDEX YEAR EMPLOYMENT (MMBR INDEX<br />

(MMBF)<br />

(MF<br />

1958 3,360 - - 1974 4,210 483 8.7<br />

1959 3,370 - - 1975 3,980 457 8.7<br />

1960 3,130 - - 1976 4,380 500 8.8<br />

1961 2,710 - - 1977 4,640 548 8.5<br />

1962 2,720 - - 1978 4,970 534 9.3<br />

1963 2,680 - - 1979 4,910 503 9.8<br />

1964 2,970 392 7.6 1980 4,370 380 11.5<br />

1965 3,030 398 7.6 1981 3,760 351 10.7<br />

1966 3,110 437 7.1 1982 3,430 365 9.4<br />

1967 3,220 455 7.1 1983 3,750 450 8.3<br />

1968 3,440 495 6.9 1984 3,750 436 8.6<br />

1969 3,490 464 7.5 1985 3,500 378 9.3<br />

1970 3,460 452 6.9 1986 3,380 437 7.7<br />

1971 3,670 505 7.3 1987 3,680 473 7.8<br />

1972 4,060 515 7.9 1988 3,660 406<br />

1973 4,280 528 8.1 1989 3,740 -<br />

9.0<br />

The column labeled INDEX' is simply the employment figure divided by the lumber figure and represents<br />

total employment per MMBF of lumber produced. Note that the lumber and wood products includes<br />

other things besides lumber production so this is only a rough indicator of production efficiency. For<br />

example the addition of a secondary manufacturing facility could increase employment in the sector<br />

with no change in lumber output. We don't have any way to properly account for this, but if we make<br />

the assumption that other factors affecting wood products employment are constant or proportional to<br />

changes in lumber production employment, we can do a little interpretation of the data. First it appears<br />

that when lumber production drops the industry is slow to reduce the work-force thus becoming relatively<br />

less efficient during market shifts (e.g. 1979-1981 and 1987-1988). Second, the index numbers for the<br />

mid 1960's and the mid 1980's don't show any trend toward higher efficiency. The same amount of<br />

lumber was produced in 1966 as in 1987, but the index for 1987 is higher. This doesn't necessarily<br />

show that efficiencies are not occurring, just that the gross data available does not support that contention.<br />

We have not seen any more detailed data which would support your contention for Klamath County<br />

producers, however one would expect that mills would try to be more efficient in order to remain<br />

competitive.<br />

Comment<br />

The overall economy is characterized as agricultural and natural resource dependent. The SIA suggests<br />

that it tends to be cyclic (boom and bust).' A major proportion of current income within the county is<br />

from rent, dividends and government transfer payments. No long term data are provided regarding<br />

this aspect of the economy. The extent to which transfer payments might replace or supplement income<br />

from manufacturing industry is not explored. Interactions between the various aspects of the economic<br />

environment are only superficially described.<br />

<strong>Response</strong><br />

An expanded discussion of the relationships between the various sectors of the local economy is included<br />

in Chapter 3 of the FEIS. While transfer payments can help to support the service sectors in the economy,<br />

they can not replace income derived from manufacturing sectors. Most displaced workers will not be<br />

eligible for retirement and disability insurance payments (the fastest growing transfer payments).<br />

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Unemployment benefits are limited and thus can not be considered a long term solution to declining<br />

employment in manufacturing. While increasing transfer payments indicates shifts in the structure of<br />

local society, it is not an answer for workers displaced in other sectors of the economy.<br />

Comment<br />

According to the DEIS there is very little data available on human lifestyles in Klamath County. Heavy<br />

reliance is placed upon U.S. Census Bureau data to determine aggregate population distribution and<br />

demographic features. Though data is only provided for the most recent (1980) census, there is limited<br />

discussion gross aspects of the 1970 population. Very little information is provided on the value systems<br />

and social institutions of the County's non-Indian residents.<br />

<strong>Response</strong><br />

Additional information is in the Socioeconomic Overview which is among the Planning Records. That<br />

document also relies heavily upon 1980 Census data since that is what is available. Special emphasis<br />

is given to the Native American population because of the Klamath's Tribe's special tribal status and<br />

their direct dependence upon Forest resources for their cultural needs. The discussions in Chapters 3<br />

and 4 have both been rewritten to address these concerns better.<br />

Comment<br />

Historic, short term population trends are discussed for the County as a whole. The distribution of<br />

population between rural 'fringe communities' and the urban Klamath Falls center is sparsely described.<br />

Population trends from the recent past were projected into the future for two decades. Methods used<br />

for making projections are not described either in the text of the DEIS or in accompanying appendices.<br />

<strong>Response</strong><br />

Population projections are notoriously inaccurate particularly when local economies are experiencing<br />

significant shifts. They are also not particularly helpful in the kinds of decisions associated with National<br />

Forest Management. Projections are discussed in the Socioeconomic Overview (Planning Records),<br />

but were not brought forward to the FEIS.<br />

Comment<br />

In my opinion, 'No Change' is the appropriate baseline alternative for comparing the effects of<br />

implementation. It more accurately reflects existing management of the National Forest. Social and<br />

economic conditions described in aggregate data resulted from Forest Service management under the<br />

'No Change' alternative. The 'No Action' alternative fails to address the requirements of 36 CFR 219.12<br />

(f) (7) which states in part<br />

'At least one alternative shall reflect the current level of goods and services provided by the<br />

unit and the most likely amount of goods and services expected to be provided in the future<br />

if current management direction continues.' (Emphasis added.)<br />

Comparisons of future trends based upon 'No Action' will not be comparable with historic conditions<br />

since this alternative is actually a change in policy direction.<br />

<strong>Response</strong><br />

The 'No Change' alternative does not depict current management on the Forest because certain legislative<br />

actions have required changes (particularly NFMA). These changes are reflected in Alternative A, the<br />

'No action' alternative, which is intended to describe the way the Forest is actually being managed.<br />

The 'No Change' alternative would be comparable to historic conditions if those conditions are assumed<br />

to be static. Conditions of Forest management have continually changed in the past and continue to<br />

do so. That evolution is expressed in the 'No Action' alternative in an effort to estimate the future amounts<br />

of goods and services that continuation of current management direction (not simply current management)<br />

will bring. The 'No Change' alternative is described along with the other alternatives so that you can<br />

use it as a baseline if you wish.<br />

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Comment<br />

According to Henshaw, the intended function of an environmental impact statement 'is to differentiate<br />

the significant and functionally degrading or improving impacts..." By its overwhelming focus on the<br />

physical and biological impacts resulting from the proposed alternative, the Forest Service has failed<br />

to address potentially significant social and human implications that might result from selection of the<br />

more extreme alternatives. For example, the rapid expansion or contraction of the resource dependant<br />

economy of Klamath County might cause increased social fragmentation as described in 'boomtown'<br />

social impact literature. Since 30% of the Klamath County budget is funded by timber receipts form the<br />

National Forests, a significant decline in the harvest level would presumably impact social services<br />

such as roads, schools, police and fire protection.<br />

These impacts would be in addition to the increased unemployment in manufacturing and service<br />

sectors of the economy. They were not addressed in the SIA or in the economic analysis.<br />

<strong>Response</strong><br />

The social and human implications of the various alternatives are discussed in the 'Effects of the<br />

Alternatives on Society' section of chapter 4. The effects on the Klamath County budget and the<br />

implications of that are discussed in the same section and also in the 'Effects on the Local Economy'<br />

section of chapter 4. These sections have been rewritten for the FEIS to better address your concerns.<br />

Comment<br />

Finsterbusch summarized the work of several authors who discuss the effects of long-term unemployment<br />

on individuals and families. He reported that a large decline in income causes families to experience<br />

social isolation as they can no longer afford the pastimes of their former friends and acquaintances. In<br />

addition they suffer a reduction in standard of living, and often have to move to less expensive dwellings<br />

when they adjust living expenses to their current means. Would these same phenomena not occur<br />

should an alternative be selected that results in substantially lower harvest levels for the National Forest?<br />

<strong>Response</strong><br />

Any action that reduces family income can be expected to causes effects like this among families that<br />

are unable or unwilling to relocate to areas where they can obtain jobs that will allow them to retain<br />

their socioeconomic status.<br />

Comment<br />

Conversely, significant expansion in manufacturing jobs associated with the high harvest levels in some<br />

alternatives might cause other significant impacts to social structures. For instance there may be increased<br />

needs for police or fire protection. Crime rates and social insecurity may increase causing a reduction<br />

in the well-being of certain groups or individuals. Alternative D results in significantly higher projected<br />

employment in the lumber and wood products industry.<br />

In the likely event that labor will migrate into the area in response to increased job opportunities, would<br />

not similar 'boomtown' strains on social services occur?<br />

<strong>Response</strong><br />

The unemployment levels as displayed in Chapter 3 could supply much of the labor force for any<br />

reasonably foreseeable expansion in the wood products industries. Should a major increase in activity<br />

occur, some in-migration would result. It is not anticipated that this would seriously strain public services<br />

because of the high incomes associated with these types of jobs. It is also not anticipated that new<br />

comers to fill and support timber related jobs would seriously upset the social structure because<br />

functioning segments of society which could absorb these people currently exist.<br />

Comment<br />

The DEIS contention that adverse social impacts will be spread proportionately among women and<br />

minorities is unsubstantiated. Freudenburg showed that social and psychological impacts of rapid<br />

growth may differently affect groups. Youth and homemaker wives may bear a disproportionate share<br />

of the stress associated with rapid social change.<br />

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The DEIS fails to acknowledge and deal with social and psychological stresses that would be associated<br />

with alternatives that result in large changes in employment and economic well-being.<br />

<strong>Response</strong><br />

While Freudenburg (Freudenburg, W.R. 1982. 'The Impacts of Rapid Growth on the Social and Personal<br />

Well-Being of local Community Residents.' In: Weber,B.A. and R.E. Howell. Coping with Rapid Growth<br />

in Rural Communities. Westview Press, Inc. BoulderCO.) makes the point that these groups may be<br />

affected differently, he also characterizes much of the basis for this assertion as 'hunches.' Be that as<br />

it may, the key difference between the type of social impacts that Freudenburg talks about and those<br />

that we can expect to see here revolve around the extreme situations where these impacts are seen.<br />

The boom town literature, which you quote, mostly deals with situations where a whole new sector<br />

(often oil production) is added to or removed from a small economy. Here, we are talking about changes<br />

in size of existing sectors in a fairly robust economy.<br />

Comment<br />

The DEIS discusses the attitudes of interested parties when the issues are presented in Chapter I. It<br />

does not specifically address the probable reaction of interested parties to any particular alternative.<br />

Nor does it discuss specifically how alternatives respond to individual issues.<br />

<strong>Response</strong><br />

Identifying the reaction of interested parties to the alternatives being considered is the primary purpose<br />

of the DEIS. The draft allows the Forest Service to identify reactions of the public through their written<br />

responses. A summary of these public responses along with the agency response to the many comments<br />

are contained in this Final Environmental Impact Statement (FEIS) in Chapter 5 (which you are now<br />

reading).<br />

The response of the alternatives to the issues is discussed in Chapter 2 of this Final EIS. Indicators of<br />

the differences between the alternatives and the way they address the issues are included in the tables<br />

in Chapter 2. The discussion of the effects on the local society in Chapter 4 summarize these differences<br />

in human terms.<br />

Comment<br />

While the biological and physical environments are discussed in great detail, there are gaping voids in<br />

the economic and social impact portions of the DEIS. Much of the economic data is based upon a<br />

single decade or less. A longer time frame is necessary in order to even out the peaks and valleys<br />

and make long term trends evident. Likewise, much of the social impact assessment was based upon<br />

data from a single year.<br />

It is impossible to establish a trend in the absence of historical record. There is no way valid projections<br />

in population growth or demography can be made based upon such scanty data.<br />

<strong>Response</strong><br />

We have rewritten much of the social and economic impact discussion both in Chapter 3 and in Chapter<br />

4. We have focussed more on trends in Chapter 3 and have displayed historical data for as far back<br />

as consistent numbers are available. We also used an analysis of trends in the local economy that<br />

was developed by the State Department of Human Resources.<br />

In all cases, the best available information was used to describe the social and economic environments<br />

and to predict changes. Since the plan under consideration is for a 10 to 15 year period only, the<br />

performance of the economy for the last 10 years is a good indicator of the near future. In the case of<br />

job and income predictions, the most current information relating forest outputs of goods and services<br />

to local jobs and incomes is now 1982 rather than 1977 as used in the Draft EIS so that information<br />

has been updated.<br />

Comment<br />

Given the special emphasis on Klamath Tribal Rights and upon the well-being of tribal members, detailed<br />

surveys to determine wants and needs would seem justified. Particularly since much of the Forest<br />

management direction is targeted towards improving their economic and social condition, surveys<br />

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should be planned as a part of the monitoring effort. In the absence of specific, survey type data it will<br />

not be possible to determine whether social goals of the Forest Plan are being met.<br />

<strong>Response</strong><br />

We have worked closely with the Klamath Tribe in development of Alternative J to ensure that their<br />

concerns are appropriately considered.<br />

Comment<br />

Monitoring Forest Plan implementation is excessively focused on quantitative measures of output or on<br />

physical or biological conditions. More explicit treatment of economic or social conditions is needed.<br />

For example, how will the Forest respond should market conditions decline to the point that the demand<br />

for timber is well below projections? What are the implications for the forest management or fire protection<br />

of growing fringe communities? Will growing fragmentation of land ownership affect the potential for<br />

future timber supplies from private lands?<br />

If so, how will the Forest respond? The issue of increasing population in fringe communities is raised<br />

in Chapter III of the DEIS, but not developed further in discussions of the consequences of implementation.<br />

Cromwell indicates that expanding urban populations along the forest fringe may result in significant<br />

problems if managers fail to recognize and cope with them as colonization occurs.<br />

<strong>Response</strong><br />

In general these concerns are handled within the context of normal forest operations to the extent they<br />

are within our control. For example, if market conditions decline dramatically, timber that is offered for<br />

sale will not be purchased. The resultant effects on the local economy would typically be beyond our<br />

control (we can't force industry to purchase the timber or force them to retain workers when they don't<br />

buy timber). If deviations in timber volumes sold became excessive, the Forest Plan can be reviewed<br />

and modified or amended as necessary to deal with the problem. Changes in society are affected by<br />

Forest Management as described in the EIS but they are also affected by many other things. Monitoring<br />

changes in society would be an interesting academic exercise, but would not provide much help in<br />

Forest Management. It is important to remember that the iterative nature of Forest Planning will lead us<br />

to redevelop and reanalyze alternative Forest management strategies in 10 to 15 years. At that time,<br />

the long term trends, which you have pointed out as being so important, can be viewed in the context<br />

of a coherent management approach.<br />

Comment<br />

The DEIS discusses the topic of Below Cost timber sales at great length. The discussion is misleading<br />

since it implies that the sale program is the only area in which government subsidizes a resource in<br />

order to achieve social objectives. For example, the DEIS states that actual range use is 13,055 AUM's.<br />

What it does not say is that the grazing fee is about $1.32 per AUM. Thus total Forest revenue from<br />

grazing is less that $18,000 per year.<br />

How many range conservationists does the Forest have on its staff? Surely there is at least one. The<br />

range program must therefore be 'below cost'. A similar analysis could easily be done with the recreation<br />

program, the wildlife program, or the cultural resources program. Provision of firewood is among the<br />

driving issues for the DEIS. Is firewood a money maker, or in reality, is it subsidized by funds from<br />

commercial timber sales? How much money does wilderness return to the treasury over the costs of<br />

operation?<br />

<strong>Response</strong><br />

The topic 'Below Cost Timber Sales' discussion in the DEIS is in response to a national issue specific<br />

to the cost of timber harvest and road construction compared to the dollar benefits from those activities.<br />

You are correct in your assertion that other resource programs could be considered 'below cost' in<br />

this context. From the efficiency standpoint we look at all benefits associated with the resource even<br />

though real dollars are not necessarily collected from resource users. This is addressed in Section 8<br />

of Appendix B.<br />

The Winema National Forest sells firewood for a value that generally defers the administrative cost of<br />

the firewood program. In the case of dead Lodgepole pine (the major firewood source), the money<br />

collected for firewood compares favorably with the commercial value of the material.<br />

Ad<br />

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Comment<br />

Timber sale is your only money making multiple use. I've heard the Winema is very efficient, make it<br />

more so.<br />

<strong>Response</strong><br />

The Winema is managed under national direction and for multiple uses. The purpose is to manage the<br />

land for the best possible use, not just to make money. The Forest Plan is an effort to balance the<br />

needs of often conflicting land uses. We will continue to strive to operate all of our programs as efficiently<br />

as possible.<br />

Comment<br />

If Forest Service curtails the logging industry as they plan, their staff should be reduced appreciatively.<br />

That monies should be returned to the State of Oregon. They have increased their staff throughout<br />

State by a great deal last 6-8 years. For the amount of timber sold, tree planting, etc., they have way<br />

too many employees. Oregon is losing a great deal of money!<br />

<strong>Response</strong><br />

The Forest Service is part of the Department of Agriculture which is national as opposed to State funding.<br />

There is no relationship between the budget of the State of Oregon and the Forest Service other than<br />

the money we return to the counties under the 25% fund receipts.<br />

Comment<br />

Revise your economic data to update the timber jobs multipliers. The current data used in the plans is<br />

based upon 1977 information and overstates the numbers of timber based jobs the Forest produces.<br />

Use current economic data to show the actual balance of economic data to show the actual balance<br />

of economic outputs to local communities. Don't overstate timber values.<br />

<strong>Response</strong><br />

The most up-to-date analysis model for jobs and income (IMPLAN) used in development of the DEIS<br />

was based upon 1977 data. A recently updated IMPLAN model uses 1982 data as it's base. The 1982<br />

base relationships are used in the numbers provided in the FEIS. Timber values are based upon historical<br />

data and expected future trends.<br />

Comment<br />

The Forests should be sold to private individuals or corporations and the sale proceeds applied to the<br />

National debt.<br />

<strong>Response</strong><br />

This recommendation is not permissible under current law and beyond the scope or intent of Forest<br />

Planning.<br />

Comment<br />

Everything of value should be privately owned. Government has no legal right to own anything of value.<br />

<strong>Response</strong><br />

This concept is contrary to the U.S. Constitution and well beyond the scope of Forest planning.<br />

Comment<br />

Stop all foreign shipment of all raw forest materials. Send the finished product only and put men back<br />

to work in this country.<br />

<strong>Response</strong><br />

With certain exceptions, logs from the National Forests are not to be exported. The issue you raise is<br />

currently being debated in Congress and is well beyond the authority of the Winema National Forest<br />

to implement.<br />

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Comment<br />

I have made a continuous study of who sells property in Klamath County. I can document that among<br />

rural Klamath County Communities in 1986, sales of repossessed houses made up approximately 25%<br />

of the total number of residential properties sold. Particularly in communities such as Chiloquin, I suspect<br />

many of the foreclosures were brought about by the 80-83 recession in the timber industry. In Klamath<br />

Falls during 1986, apx. 13% of properties sold had previously been repossessed. This abnormal market<br />

activity has results that extend beyond our particular community. Problems in the Oregon Department<br />

of Veterans Affairs loan program being felt by its investors (citizens of Oregon) are, at the very least,<br />

compounded by an erratic and declining economy.<br />

<strong>Response</strong><br />

No response necessary<br />

Comment<br />

A representative from the Forest Service needs to be attending and being more involved in economic<br />

issues and potentials in the County. Economic corridors on the land use plan need to be identified<br />

and placed on maps, to encourage future development.<br />

<strong>Response</strong><br />

This comment seems to be concerned with industrial development on National Forest lands. Certain<br />

kinds of developments can occur on National Forest lands where resources exist and can be appropriately<br />

used. Examples are mining, oil and gas recovery, geothermal and hydroelectric power generation and<br />

recreation developments. Exploration for geothermal resources in currently underway on the Forest.<br />

Proposals for a major ski area at Pelican Butte are being evaluated and can be accommodated under<br />

the Forest Plan.<br />

Comment<br />

Further, I have a concern about the distribution of Federal Forest receipts. The ratio of funds to schools<br />

and to County roads is in desperate need of change. Our County roads are in fine shape. Some are<br />

paved over several times and are currently serving the County, and some of the few drivers that use it.<br />

But, our schools are in dire need of funds. The distribution needs to be reversed. A study needs to be<br />

done of this situation and some measures taken towards change. Our youth deserve the investment<br />

more so than our already developed County roads. Again, the Forest needs to be pro-active in examining<br />

this issue and get its head out of the sand.<br />

<strong>Response</strong><br />

The Twenty-Five Percent Fund Law (35 Stat. 251 as amended) directs the Forest Service to pay the<br />

states an amount equal to 25% of National Forest receipts, and prescribes only that this payment I...be<br />

expended as the state... may prescribe for the benefit of the public schools and public roads of the<br />

county...' The Forest has no control over the matter as it is a decision made by the state government.<br />

Comment<br />

As you know, Klamath County is hurting very badly, with unemployment and a decrease in the total<br />

population since 1980. This cannot continue, the Winema N.F. is a principal landowner in the County.<br />

Creative ideas to increase the economy and fully utilize the land needs to be undertaken. An economic<br />

committee for looking at alternatives,land use, and opportunities needs to be created.<br />

<strong>Response</strong><br />

The Forest planning effort has addressed the various potential uses of National Forest lands in light of<br />

public demands both for more economic activity as well as demands for less economic activity. The<br />

Forest Plan was selected as a balance between divergent views on these issues.<br />

Comment<br />

As indicated above, the derivation of 696 jobs from 'ski area development" should be clarified to explain<br />

the calculation and distinguish between direct and indirect job creation.<br />

K - 142

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<strong>Response</strong><br />

The discussion on potential jobs from ski area development has been removed from the EIS. The Forest<br />

plan retains the option for this development. Detailed evaluation of the impacts of a ski area development<br />

will be pursued with an environmental analysis independent of the Forest Plan analysis.<br />

Comment<br />

In addition to the previously questioned employment derivation, this table includes $8.2 million in 'potential<br />

income from ski area development.' The origin and derivation of this income estimate should be clarified.<br />

<strong>Response</strong><br />

The discussion on potential income from ski area development has been removed from the EIS. The<br />

Forest plan retains the option for this development. Detailed evaluation of the impacts of a ski area<br />

development will be pursued with an environmental analysis independent of the Forest Plan analysis.<br />

Comment<br />

The discussion of the city's hydroelectric funding incorrectly suggests that financing options are limited<br />

to such a source, when in fact the municipality and other potential developers have a wide variety of<br />

funding options available to them.<br />

<strong>Response</strong><br />

This discussion has been removed from the EIS.<br />

Comment<br />

We suggest that the FEIS include an analysis for each of the alternatives describing: (1) the impact on<br />

projected resource outputs if required funding levels are not realized; and (2) how the alternative could<br />

be modified to meet its most critical output targets if actual budgets are less than specified in the plan.<br />

This information could prove vital to both industry and the Forest Service as we work with Congress to<br />

get the appropriations needed to maximize net public benefits from the Winema National Forest. It<br />

could also have implications for selection of the final forest plan.<br />

<strong>Response</strong><br />

Generally resource outputs would be reduced proportionately to the reduction in funding provided for<br />

each resource. Thus if funding for sale preparation were cut in half, we could expect to have about<br />

half the volume available for sale a year or two in the future. Cuts in recreation budgets would have<br />

minimal effects on dispersed types of recreation in the short term although trails would likely deteriorate<br />

and use might become less in the long run. Cuts in recreation budgets would be seen most rapidly in<br />

campgrounds where services would be reduced immediately. These types of effects would vary more<br />

by the level of funding than by alternative and estimates for each alternative would not be particularly<br />

useful in comparing the alternatives so we made no attempt to do this. Our normal out-year budgeting<br />

process involves estimates of the effects on outputs under different funding scenarios.<br />

Since funding levels vary each year, it would take several years of implementation to determine whether<br />

or not an alternative was being effectively implemented. We have included a monitoring item to determine<br />

whether funding received by the Forest is consistent with the budget estimates developed by the Forest<br />

Plan. At some point, significant variations could result in modifications to the Forest Plan which would<br />

attempt to maximize the net public benefit with lower funding levels and could result in a different mix<br />

of outputs. Thus, we see these issues as being handled more directly in the implementation phase<br />

than in the selection of an alternative for implementation.<br />

Comment<br />

We believe that the draft plan must be revised to reduce the risk of unacceptable economic and social<br />

effects.<br />

<strong>Response</strong><br />

We have redeveloped the discussions on economy and society in Chapters 3 and 4 to better depict<br />

these effects. The Proposed Plan gives additional consideration to resources other than timber and<br />

K- 143

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thus tends to have a higher risk of adverse social and economic effects although we do not consider<br />

the level to be Nunacceptable."<br />

Comment<br />

Because of our substantial concerns over the details of the present net value analysis, we support the<br />

use of a maximum timber objective function in the preferred alternative. This should be combined with<br />

a PNV "rollover" to assist the forest in harvest scheduling over the next decade.<br />

<strong>Response</strong><br />

The Proposed Plan (Alternative J) used the maximize PNV" objective function rather than the "maximize<br />

timber followed by a PNV rollover. Since the timber resource has the largest effect on PNV and since<br />

Alternative J already gets as much ponderosa pine as is available with uneven-aged management, we<br />

doubt that using your approach would make much difference.<br />

Comment<br />

The economic value of timber must be adjusted so that it is comparable to the economic values of<br />

recreation and wildlife.<br />

Certain outputs, such as recreation, fisheries and certain wildlife outputs are given values in the draft<br />

EIS economic analysis. These values are derived from the 1985 RPA program and are based upon the<br />

'willingness to pay" concept. The timber resource, however, is not based upon a willingness to pay<br />

concept, but rather is derived from real values which represent competition in the marketplace. Because<br />

timber is sold in a competitive market, the value of that timber does not reflect what a consumer is<br />

willing to pay for it, but rather what a consumer must pay for it. It is possible to derive willingness to<br />

pay values for the timber resource just as it is for recreation, fisheries and wildlife outputs which are<br />

given values in the draft EIS economic analysis. The Winema did not do so, and therefore, the economic<br />

analysis contained the DEIS seriously under-represents the value of the timber resources.<br />

<strong>Response</strong><br />

Your comment implies that individuals would be willing to pay much more for lumber, but that for some<br />

reason the price is kept low. The major factor which keeps lumber prices from being higher is that<br />

when they are raised, people buy less thus reducing total profits in the manufacturing/wholesale/retail<br />

chain. People buy less at higher prices because they aren't willing to pay more. In any case, the timber<br />

values on a per acre basis are so much higher than other resource values that raising their values<br />

further would not have much effect on land allocations or harvest scheduling in an alternative, such as<br />

Alternative J, which is heavily constrained by other resource considerations.<br />

Comment<br />

Many forest users taking the time to comment on your draft plan wish to know the procedure how<br />

their information is evaluated. We understand all responses are coded into the computer for recall on<br />

many forest issues, such as timber harvest level, support for a new winter sport site, wildlife, and etc.<br />

We would suggest that one additional way for information retrieval is by congressional districts. The<br />

reason for this is due to much what you hope to accomplish on the Winema is tied to your budget<br />

from Congress. We would think if you could show the public position on many of your projects this<br />

may be helpful in gaining the funding requirements.<br />

<strong>Response</strong><br />

We sorted the comments by specific topics so that they could be assigned to appropriate specialists<br />

for response. We also weighed the preponderance of comment on the issues in a subjective way. We<br />

didn't "count votes" because people have too many and varied views on each issue to make that<br />

particularly useful. For the same reason it is difficult to identify a definitive "public position on any issue<br />

- people differ too much. We've summarized "What People Said" for each issue in Chapter 1 of this<br />

EIS. We didn't try to break out the comments by Congressional District, but encourage elected<br />

representatives to read the EIS, including the summary of public comment and this Appendix. We trust<br />

that individuals who feel strongly about a particular issue will contact their representatives directly.<br />

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Comment<br />

Increase funding levels of the following programs to get them closer to parity with timber management:<br />

a. Wildlife & Fisheries; b. Recreation; c. Cultural Resources; d. Law Enforcement; and e. Range<br />

Management.<br />

<strong>Response</strong><br />

Forest budget requests for upcoming years are based on the Forest Plan preferred alternative. The<br />

final preferred alternative, with its increased emphasis on recreation and wildlife, will result in larger<br />

requests in this area. Actual forest funding levels are determined by the amount of these kinds of funds<br />

made available by Congress, which takes into account Forest Service requests, but also may be modified<br />

to meet National priorities. Once a budget for a particular resource, be it timber or wildlife or range or<br />

whatever, is approved by Congress for the Forest Service, we are, by and large, prevented from shifting<br />

money from one resource area to another.<br />

Comment<br />

The cost breakdown on page IV-1 7 of the Proposed Land and Resource Management Plan indicates<br />

that only $12,000.00 are planned for trail construction each year. By shifting 1% from both the timber<br />

and road budgets a considerably larger amount of money would be available for trail construction. The<br />

cost of operating the Forest, as indicated by Table IV-2, show a definite bias toward timber harvesting<br />

and road construction. With 96% of the operational cost being allocated to timber, roads and fire<br />

suppression little is left for recreation,wildlife and watershed management. It is hard to see how this<br />

can be considered multiple use management.<br />

<strong>Response</strong><br />

The trail construction estimate has been increased to $127,000 per year, about 1.5% of the direct timber<br />

and road costs. It's not particularly informative to use tudget figures to evaluate the concept of<br />

multiple-use. Dispersed non-motorized recreation demands, for example, can be satisfied at relatively<br />

low costs because it doesn't cost much to let people walk and camp at dispersed locations across the<br />

Forest. Timber production, on the other hand, is quite costly to administer due to the plethora of concerns<br />

that must be addressed in order to produce a satisfactory result in both an environmental sense and<br />

in terms of insuring that the public interest is protected. A better way to evaluate whether or not multiple-use<br />

is being implemented is to compare the expected output levels for the various resources (Chapter 2)<br />

to estimates of demand levels (Chapter 3). This is done in Chapter 4 of this EIS.<br />

The budget estimate was not developed by taking a total dollar figure then allotting it, on some basis,<br />

to the various resources. Rather, the costs of supporting each resource at the output levels determined<br />

for the alternative were individually calculated and then totaled.<br />

Comment<br />

The proposed departure will only delay the decline of the local timber industry and related employment<br />

which has grown dependent on national forest timber supplies. Payments to local counties will also<br />

decline markedly in the future. The inevitable may be delayed for twenty years, but then the decline in<br />

the allowable sale quantity will have severe impacts on the local communities. Alternatively, the immediate<br />

implementation of sustained yield management would lead to more moderate reductions in the timber<br />

supply and related employment in the short term, but would lead to more stability in the long run.<br />

<strong>Response</strong><br />

Alternative J, the preferred plan, is not a departure alternative although the program to salvage dead<br />

and dying lodgepole pine will cause some of the effects you mention.<br />

Comment<br />

We must take partial exception to the statements (LMP 11-5) that timber supply from the Forest does<br />

not effect price. While it may be true that there is no great influence upon product market prices from<br />

variances in the Forest timber supply, stumpage prices will be very sensitive to the adequacy of hat<br />

supply within economic limitations to the considerable extent that the Winema wields a monopolistic<br />

influence within the local timbershed. Also in this same discussion of local supply and demand, (ibid)<br />

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it should be realized by the plan authors that there is not necessarily a fixed, directly proportional<br />

relationship between lumber and housing demand. In recent years, we have found that while housing<br />

starts are far from historic highs, lumber consumption has steadily increased due to expanding repair,<br />

remodel, industrial and export markets.<br />

<strong>Response</strong><br />

The discussion in Chapter 3 on *Local Timber Supply and Demand' talks about this situation. Stumpage<br />

prices do vary depending upon the total supply that is available, but, as you imply, the height to which<br />

prices can rise is limited by the height to which lumber prices can rise before consumers begin to use<br />

substitute materials. We agree that there is no fixed, directly proportional relationship between lumber<br />

and housing demand, but that does not deny the existence of a relationship between the two.<br />

Comment<br />

Specifically, we question the use of a one percent price trend for all stumpage values regardless of<br />

species. Basing stumpage values for small diameter mixed species logs (a commodity not currently in<br />

high demand) on a one percent price trend appears speculative, while recent market history for ponderosa<br />

pine indicates a price trend higher than one percent may be in order for that species.<br />

<strong>Response</strong><br />

We have added a monitoring element to help track this situation.<br />

Comment<br />

The plan and DEIS do not include an analysis of what effect lower budgets could have on management<br />

decisions. This omission is of concern to the Tribe for several reasons.<br />

1. Without adequate funding, the anticipated habitat improvements, monitoring and mitigation measures<br />

may not be possible, and the cumulative effects on tribal treaty rights could be disastrous.<br />

2. Without an analysis of an alternative with a lower budget, there is no way to determine whether<br />

different management techniques would be used, whether anticipated mitigation measures would be<br />

deleted, or what alternative actions the Forest would take. Failure to analyze an alternative with a lower<br />

budget prevents decision makers from becoming aware of potentially more efficient management<br />

techniques, lower capital costs, or lower mitigation costs.<br />

The Fremont National Forest has acknowledged its responsibility to provide habitat sufficient to meet<br />

the Tribe's treaty rights and needs, and the Winema must do so as well. Fulfilling this responsibility at<br />

lower funding levels will require changes in proposed management activities. The current planning<br />

process is the appropriate means to address this likelihood.<br />

<strong>Response</strong><br />

The alternatives described in the EIS are alternatives for management of Winema resources. An alternative<br />

based upon funding levels isn't really appropriate. We expect funding levels to go up and down as in<br />

the past, however, regardless of the funding levels, the Plan will give us consistent direction to strive<br />

for agreed upon goals. The Plan gives us management direction; any one year's funding level won't<br />

change that direction. We have included a monitoring item to ensure that the situation is tracked and<br />

adjustments are made if significant deviations are found.<br />

We have been working closely with the Tribe in development of the Forest Plan.<br />

Comment<br />

Fish, wildlife and recreation outputs have variable response factors and have been underestimated<br />

and undervalued in quantifying outputs, effects, and tradeoffs between economic benefits.<br />

<strong>Response</strong><br />

We don't agree that the outputs are undervalued or underestimated. The key thing, here, is that they<br />

are developed in the same way for each alternative so they are comparable across the alternatives.<br />

Comment<br />

The Forest Service projects that an increase of 841 new jobs will result from their preferred Alternative<br />

E. It is unlikely that this increase will occur for several reasons. Their projections are based on 1977<br />

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data, a period when wood products industry employment averaged 4,640 in Klamath county. Presently,<br />

during a period of peak production levels, employment in the industry totals only 3,800. The relationship<br />

between production and jobs has changed considerably. The entire projected gain would be needed<br />

just to restore employment in wood products to the base year levels.<br />

Second, the job changes across alternatives should not be viewed as absolute employment changes.<br />

Rather, they should be used only for relative comparative purposes.<br />

The No Action alternative shows an increase of 367 jobs; therefore, the preferred alternative should be<br />

discounted by at least this much to approximate better a comparison to recent levels.<br />

<strong>Response</strong><br />

We used the most recent data available to develop estimates of numbers of jobs. All of the figures<br />

have been updated using an input/output model (IMPLAN) with 1982 base data as described in Appendix<br />

B. For Alternative E the estimate is now 394 additional jobs rather than 841. We have not been able to<br />

obtain the detailed data necessary to support the assertion that there has been a significant change in<br />

labor efficiency in lumber production in Klamath County, but we suspect that this is occurring.<br />

We agree that these are not absolute numbers, but are of reasonable use only in a comparative sense.<br />

The No Action alternative shows an increase of 31 jobs since updating the model. It's not clear why it<br />

would be appropriate to adjust any alternative by this amount to improve the comparative analysis<br />

since the No Action alternative is a projection of Forest management trends into the future.<br />

Comment<br />

The Forest Service projects a large increase in employment because the proposed allowable sale<br />

quantity of 199 MMBF is considerably above the 1976 to 1985 average timber harvest of 11 8.6 MMBF.<br />

More recent years have amounted to 177 MMBF in 1985, 223 MMBF in 1986, and 262 MMBF in 1987.<br />

Since lumber and wood jobs are linked to the harvest level, and the proposed allowable sale quantity<br />

is lower than the average of the last three years' harvest, it is unlikely that a job gain above current<br />

employment levels will occur as a result of the Forest Service's preferred Alternative E. Furthermore,<br />

the proposed allowable sale quantity is based on an accelerated harvest of lodgepole pine - a species<br />

that does not produce as many jobs per MMBF as ponderosa pine.<br />

<strong>Response</strong><br />

We have updated the estimated job figures so that Alternative E is now estimated to increase employment<br />

by 394 jobs. This is in comparison to a 1980 through 1989 base period. Total sawtimber volume in<br />

that period averaged 170.5 MMBF per year. The average lodgepole pine harvest was about 40 MMBF<br />

per year during the same period in comparison to 15 MMBF per year estimated for Alternative E.<br />

Comment<br />

The Forest Service should expand its economic analysis to include Jackson County. Current data<br />

indicates that almost one-third of Winema stumpage flows into southwest Oregon, primarily Jackson<br />

County. Further, retail and wholesale trade in Jackson County rely on basic industries that are dependent<br />

upon the Winema National Forest.<br />

<strong>Response</strong><br />

The estimates of income and employment take into account the differing structures of the Jackson<br />

and Douglas County economies. We have retained the emphasis on the Klamath County economy<br />

because even though a substantial portion of Winema logs go to these counties for processing, they<br />

represent a relatively small portion of the total volume processed there.<br />

Comment<br />

The Forest Service should address the impact of the plan on other taxes such as road, harvest, state<br />

income, and property taxes.<br />

<strong>Response</strong><br />

We have not specifically added a discussion on most of these topics because they don't add much to<br />

the comparison of alternatives. Taxes related to timber harvest depend on volume levels, which is<br />

discussed and income taxes depend on income levels, which is discussed. Road use taxes relate to<br />

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log and lumber haul which depends on volumes harvested, which is also discussed. Effects on property<br />

taxes are discussed in the Effects on Society" section of Chapter 4.<br />

Comment<br />

Funding and an outline for monitoring local economic conditions (e.g., employment by sector and<br />

county, unemployment, population, and personal income) have not been included. If the intent of this<br />

extensive planning effort is to achieve specific desirable outcomes, then it is critical that sufficient effort<br />

and funding be included in the budget for monitoring and evaluating progress on an annual basis.<br />

<strong>Response</strong><br />

It is not the intent of this Plan to effect specific outcomes in the local economy. There are so many<br />

other factors involved in the function of the local economy that it would be impossible for us to control<br />

it even if that were our desire. Our intent is to give due consideration to potential effects on the economy<br />

as a result of our actions. We are focussing our efforts on monitoring those socioeconomic factors<br />

that are measurable and which directly link our activities to the local economy. The returns to the County<br />

are the most direct and measurable item available.<br />

Comment<br />

The Forest Service requires a 16.3 percent increase in their budget compared to current levels in order<br />

to implement their preferred alternative E. In light of tight Federal budgets, this increase is not by any<br />

means assured. The Forest Service should indicate which activities it would scale back if its budgetary<br />

requests are not met.<br />

<strong>Response</strong><br />

Activities that would be scaled back depend upon the National priorities that cause Congress to fund<br />

one area over another. These priorities change from year to year so it would take several years of<br />

funding to identify an overall trend. We have included a monitoring element to track this. If deviations<br />

from the Plan are significant enough, the Plan can be amended.<br />

Comment<br />

Employment and Income Effects: The Winema only supplies about 15% of timber processed by Klamath<br />

County mills. While this percentage will increase substantially over the next two decades, there is simply<br />

no logical basis on which to assume that the adoption of the Preferred Alternative would result in the<br />

generation of 841 new jobs (see Table IV-33). No detailed analysis of the derivation of the employment<br />

and income totals presented in this Table is provided. Further, projections are based on 1977 data, a<br />

period when forest industry employment averaged 4,640 in Klamath County. Presently, during a period<br />

of peak production levels, employment in the industry totals only 3,800 - would need almost the entire<br />

projected gain just to restore employment in lumber and wood products to base year levels!<br />

<strong>Response</strong><br />

The jobs and income estimates are based upon the total Forest program and the assumption that the<br />

logs will be processed in either Klamath, Jackson or Douglas Counties. It is assumed that 65% will be<br />

processed in Klamath County, 34% in Jackson County and 1% in Douglas County. These figures are<br />

based upon the 1985 (most recent) version of Oregon's Forest Products Industry (Howard and Ward,<br />

PNW Station, Resource Bulletin PNW-RB-149). The IMPLAN model is described in Appendix B with<br />

references to other sources for details on the methodology. The data has been updated to 1982 (most<br />

recent data available) and all estimates of jobs and income have been adjusted. It is important to realize<br />

that the highest utility in these numbers is in the comparison of alternatives not as an absolute estimate<br />

of economic activity.<br />

Comment<br />

The economic assumptions used to determine the job impacts of the various alternatives need to be<br />

more fully explained. Updated information that reflects current job numbers should be included in the<br />

final EIS. Page 111-4, LRMP indicates that up to 1,537 jobs Owould be created in decade 1 if the plan is<br />

implemented. A more accurate statement would explain that this prediction does not represent a change<br />

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from current employment levels, but rather a change from hypothetical employment levels of the no<br />

change alternative.<br />

<strong>Response</strong><br />

The discussion and estimates have been updated. The change is from a base created by averaging<br />

Forest outputs from 1980 through 1989 and calculating total jobs and income the same way as was<br />

done for all the alternatives.<br />

Comment<br />

Local Economies - (DEIS, 111-1 15) The Forest appears to have erred in confusing residentiary with basic<br />

economic activities. Basic industries are those that generate exports with whose receipts purchases of<br />

outside goods and services can be made. Forest industry and the tourism industry are parts of the<br />

economic base. With this in mind, the chart on page 111-1 16 needs additional explanation. Although<br />

wood related dollar gross output may be less than 50 percent of total gross output, analysis completed<br />

for our next Forestry Program for Oregon assessment shows that the lumber and wood products sectors<br />

accounts for over 70 percent of the basic private employment in Klamath County.<br />

In addition, 1977 data is out-dated and inappropriate for use in the analysis; it should be updated.<br />

This plan may not become final until 1989, by which time the data would be almost a decade old.<br />

<strong>Response</strong><br />

The entire discussion has been rewritten to be more pertinent. The most recent IMPLAN data base<br />

available is for 1982. All the job and income estimates in the EIS were updated using this model.<br />

Comment<br />

INDUSTRY JOBS - (DEIS, 111-121) The discussion about automation continuing to reduce the number<br />

of jobs is speculation. Secondary manufacturing of wood products is cursorily mentioned. However,<br />

this and other high value-added wood products could increase employment rather than decrease<br />

employment, albeit using different technology. Oregon in the past has been famous for making low<br />

quality wood products out of high value stumpage. This is changing; employment trends are expected<br />

to change as well.<br />

<strong>Response</strong><br />

We agree, the entire section has been rewritten.<br />

Comment<br />

Effects of the Alternatives on Local Economy - (DEIS, IV-101) The projections of economic growth are<br />

based on Winema timber harvests only, and do not include harvests of other national forests or ownerships<br />

in the Klamath or adjacent timbersheds. This should be made clear. We believe the forest should present<br />

information on the total economic picture, including those alternative timber harvest changes that can<br />

be reasonably expected.<br />

<strong>Response</strong><br />

Our intent is to clearly differentiate between alternatives in the area of social and economic impacts,<br />

not to attempt to predict or speculate about the actions of others. We have included a discussion<br />

developed by the State of Oregon in Chapter 3 that should adequately address your concerns in this<br />

area.<br />

Comment<br />

A departure in ponderosa pine to maintain historical levels is required by the Plan and will contribute<br />

substantially to the economic stability in the Klamath Basin.<br />

This statement is completely false. Figure IV-1 of the plan shows wild fluctuations in the Allowable Sale<br />

Quantity which would be extremely damaging to the local community.<br />

<strong>Response</strong><br />

Alternative J, the preferred plan, was developed in response to public comments and deals with these<br />

issues differently than Alternative E.<br />

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Soils<br />

Comment<br />

Can Eastern Oregon, the pumice desert areas of the Winema be treated with the same decision making<br />

as any other forested area? It definitely should not! The impact in the pumice areas are devastating to<br />

future rapid growth. (There is no rapid growth in large Ponderosa forests where pumice is the predominate<br />

first layer of earth.<br />

<strong>Response</strong><br />

Almost all Ponderosa pine stands on the Winema are timber site productivity class 4 and 5 with a<br />

majority being site 5. The pumice sites can be sensitive to work, but in many ways, are less sensitive<br />

to work than other soils because they are far less apt to compact. Growth measurements on young<br />

pine stands indicate that productivity is being maintained or possibly increased with early stocking<br />

level control.<br />

Comment<br />

In my opinion clear cutting has destroyed much of Oregon's Forest in my lifetime...probably from erosion,<br />

lack of replanting and change in soil temperature.<br />

<strong>Response</strong><br />

Clearcutting is a viable regeneration system. All clearcuts on the Winema are planted except for some<br />

in lodgepole pine, which will naturally regenerate, and since the Winema is so flat, very little erosion<br />

occurs. Overall soil temperatures may be lowered in the first years after a clear cut but will eventually<br />

warm to normal levels after the young trees become 10 to 15 feet tall.<br />

Comment<br />

The proposed uneven aged management of 144,000 acres of ponderosa pine forests on former tribal<br />

lands is a good starting point for maintaining vegetation diversity on this portion of the Forest but the<br />

practice needs to be coupled with a prescribed burning program to insure that the stands do not convert<br />

to pine associated or fir dominated forests. Prescribed burning should in fact be instituted across the<br />

Forest to help return the vigor to some of the stands and to assist in the control of forest pests.<br />

Re-introduction of fire into the east Cascades forests will also help return the composition of the forests<br />

to more Ponderosa pine dominated stands, which more closely simulates the natural composition of<br />

the forest and which is the preferred species by timber interests and local economics.<br />

<strong>Response</strong><br />

The 144,000 acres of ponderosa pine forest that is planned for uneven-aged management has ponderosa<br />

pine as the climax species. Therefore there is no need to use fire to assure maintenance of ponderosa<br />

pine. It is planned to manage some of the pine associated in uneven aged management favoring<br />

ponderosa pine. This will be accomplished through various silvicultural practices that will favor ponderosa<br />

pine.<br />

Based on some current research there is some question on the desirability of a prescribed burning<br />

program on pumice soils to maintain stocking or reduce natural fuels. There is a potential for reduction<br />

of site productivity as the result of the burning.<br />

Comment<br />

The two paragraphs given to the effects on soil in chapter IV are particularly inadequate.<br />

The standard that would allow detrimental effects on soil productivity on 20 per cent of an activity area<br />

is inadequate to meet the basic Forest Service mandate to assure that productivity will be maintained.<br />

That this permissive standard is to be monitored by 'review of EAs' only compounds the problem. Soil<br />

condition can only be determined by monitoring soil, not documents.<br />

Page V-1 0 of the Plan: Monitoring question 10: Twenty percent loss of soil productivity level is an<br />

unacceptable result of management activities. Monitoring should assure that losses never exceed 10%,<br />

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and management activities should be designed to maintain or improve soil productivity. All future<br />

resources of the Forest depend on continued soil productivity.<br />

<strong>Response</strong><br />

The standard you refer to was established as a tool to monitor impacts of management on long-term<br />

productivity. We strive to protect a minimum of 80% of an activity area from any detrimental soil impacts<br />

(from past, present, and future roads, landings, skid trails, etc.). Within the 20 percent area, productivity<br />

is reduced, but seldom eliminated. The standard serves as a warning device to indicate that productivity<br />

may be significantly affected if the 20 percent threshold is exceeded. The threshold is not the goal.<br />

The management goal is to maintain or improve the inherent productive capacity of the soil. Both<br />

adherence to the standard and effectiveness of the standard will be monitored. Management practices,<br />

and even the standard, will be revised if warranted. Chapter IV of the FEIS has been revised to better<br />

explain how this standard is applied.<br />

Comment<br />

In addition, the plan should identify the sensitivity of riparian areas by watershed to allow analysis of<br />

the effects of harvesting on soil productivity and water quality. The Tribe urges that no timber harvesting<br />

be allowed in riparian areas if it would result in any further degradation of water quality or fish habitat.<br />

<strong>Response</strong><br />

The E.A. for a management activity in the area will take in consideration the sensitivity of the riparian<br />

area. Standards and guidelines will be used to take this sensitivity into consideration and also prevent<br />

any degradation of the riparian values, water and fish resource.<br />

MA8 and discussions on BMP's have been revised to discuss management of riparian areas to maintain<br />

their values. Timber harvest is allowed in riparian areas only under very strict controls. No harvest is<br />

scheduled near Class 1, 11, and Ill streams. Standards and guidelines and BMP's with monitoring should<br />

ensure that values are adequately protected. Insufficient data is available to make such an analysis on<br />

a watershed at the Forest Plan level. Forest plan monitoring will collect the necessary data. Watershed<br />

analysis will be donw during project level planning.<br />

Comment<br />

P.111-4. Soils (Paragraph 5).<br />

How much land has been taken out of production due to impacts to soils? (DEIS 111-4-1). How much<br />

land has reduced productivity due to impacts to soils? (DEIS 111-4-2). Where are these lands? (DEIS<br />

1114-3).<br />

<strong>Response</strong><br />

It is unknown how much land has been taken out of production. These lands are scattered throughout<br />

the Forest where there are roads, landings, skid trails, trails, etc. Discussion of current conditions have<br />

been added to Chapter 3. Future impacts have been estimated in Chapters 11 and IV of the FEIS.<br />

Comment<br />

1 3a. Include exposed' in the standard 'No more than a cumulative total of 15 percent of an activity/project<br />

area will be compacted, displaced, or puddled to a degree that degrades vegetative productivity.'<br />

Deleting the phrase *to a degree that degrades vegetative productivity' might make the standard appear<br />

less subjective. This would make the standard strictly a quantitative measurement.<br />

<strong>Response</strong><br />

"Exposed' soil does not necessarily mean that it is damaged or that it will erode. The standard you<br />

refer to will protect soils from physical damage. Other standards specify minimum levels of residues to<br />

remain on the soil for erosion protection and nutrient cycling. Taken together, the application of standards<br />

and guidelines should adequately maintain long term soil productivity. Soils can tolerate a certain level<br />

of damage without degrading vegetative productivity. The tolerance of soils to damage can be quantified,<br />

and these tolerances have been included in the standard.<br />

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Threatened and Endangered Plants and Animals<br />

Comment<br />

It was surprising to find no mention of sensitive plants in the Forest Plan, however, as there were Standards<br />

and Guidelines put forth for animal species of concern. This deficiency should be corrected in the<br />

Final Forest Plan. The Forest Plan should also address the sensitive species surveys of project areas<br />

that are required by Forest Service Region 6 policy. In addition to required surveys in project areas,<br />

The Nature Conservancy is also requesting that National Forests undertake inventories of currently<br />

protected areas on the Forest to further the knowledge of rare species distribution and abundance. It<br />

is important to conduct surveys in wilderness areas, Research Natural Areas, Special Interest Areas,<br />

and other protected sites as there may be direct<br />

implications for management of rare species on other lands where the species is found. For instance,<br />

if currently listed sensitive species are found to be in great abundance in secure, designated areas<br />

then a recommendation can be made to remove the species from the Forest Service sensitive list.<br />

<strong>Response</strong><br />

You are correct. Pages III 20-24 of the DEIS discussed sensitive plants on the forest. None of the<br />

information was carried forward in the Plan as it should have been. Information regarding sensitive<br />

plants has been updated in the FEIS and Forest Plan.<br />

Comment<br />

Wildlife species of concern were also listed in the DEIS in Chapter III (p. 111-63) and the list is essentially<br />

complete except for one omission and several corrections in species status. The corrections in the list<br />

are for the two fish species, the Lost River Sucker and the Shortnose Sucker, which have been officially<br />

proposed for listing by the U.S. Fish & Wildlife Service and are in the mandatory review period before<br />

listing. The species are both proposed for listing as Endangered which has important management<br />

implications for their critical habitats. The Final Forest Plan should note the final status of these species<br />

and should also indicate that the Forest intends to take appropriate management actions, including<br />

protection of their habitat, to protect the species.<br />

<strong>Response</strong><br />

Your comment is partially correct. No species were omitted from the list you refer to. The advent for<br />

sucker listings has been on going for several years, with the Winema N.F. as an active participant. The<br />

listing is now complete and we will so recognize in the FEIS with appropriate guidelines.<br />

Comment<br />

Three rivers on the Winema National Forest were evaluated for eligibility for wild and scenic status with<br />

the Sycan and Williamson rivers being determined to be eligible. We feel the analysis portrayed in<br />

Appendix E of the DEIS omits one important category--threatened, endangered, and sensitive<br />

species--that should be considered in the evaluation for eligibility. The Williamson and the Sprague<br />

rivers are critical habitat for the Lost River Sucker which is currently proposed for endangered listing<br />

by the U.S. Fish & Wildlife Service. This species will likely be formally listed by mid-1 988. Furthermore,<br />

the Williamson also provides habitat for the shortnose sucker which is also proposed for endangered<br />

listing.<br />

<strong>Response</strong><br />

Appendix E-14 recognizes segments Two and Three of the Lower Williamson and the Sprague River<br />

from the Williamson to Chiloquin Dam as primary habitat for the Lost River and shortnosed suckers,<br />

along with their Threatened and Endangered staus as mentioned above. 'Critical habitat when applied<br />

to a T&E species has a legal definition. The USF&WS has identified Upper Klamath Lake and tributary<br />

streams as primary habitat for the species. They however, have not identified critical habitat.<br />

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Comment<br />

In case of the Winema N.F., it is unclear from the draft plan as to what effects the proposed management<br />

plan will have upon the Forest's botanical resources. The plan attempts to promote the claim that<br />

management activities will not negatively affect sensitive plants, but the supporting statements are<br />

vague assertions or grandiose claims that lack supporting data For example, the DEIS states (111-21)<br />

'timber harvest poses a limited threat, because sensitive plants generally do not occur in forested<br />

plant communities but rather in unique areas, such as meadows and scab flats., Perhaps, then sensitive<br />

plant management should be integrated with rangeland management? This might be a logical approach,<br />

but one must have doubts that this approach would be effective, given the further (completely<br />

unbelievable) assertion that Ograzing of domestic livestock will not be a threat to the sensitive plants on<br />

the Foresto (DEIS 111-21).<br />

The reality of the situation is that the Forest harbors sensitive plants in a variety of habitats, from grasslands<br />

and meadows, to Forest lands, and high elevation habitats. Potential management conflicts (and grazing<br />

of livestock is often a major conflict) may occur in any of these habitats. Thus we feel that the Forest<br />

has a responsibility to pay full consideration to the fate of sensitive species, and not try to pass off the<br />

issue with a few paragraphs of unfounded assertions.<br />

<strong>Response</strong><br />

Forest Standards and Guidelines for range management require the permittee to comply with multiple<br />

use concept, which includes compliance with the threatened and endangered species requirements(this<br />

includes vascular plants). These standards and guidelines include maintaining and/or improving<br />

ecological condition of the different plant communities on the allotment. Implementing these guidelines<br />

through the allotment management plans, sensitive areas are either excluded from livestock grazing,<br />

or utilization standards, and season of use are adjusted to restrict the time and amount of forage that<br />

can be removed. Allotment Management Plans are periodically updated and revised to account for<br />

new situations as they are encountered on the ground. Annual grazing plans provide annual direction<br />

to the permittee for areas that need to be avoided, or protected from heavy livestock use.<br />

All activities must be evaluated for the occurrence of sensitive plants or animals, and the risk to the<br />

species must be analyzed. Species management guides are to be developed for each species.<br />

Comment<br />

It is particularly important to clarify the statement that Ono threatened or endangered vascular plants<br />

are known to occur on the Forest.' Though there are no federally listed species on the Forest, there<br />

are a number of candidates for listing that do occur. Candidate species may well qualify for formal<br />

listing, but have not yet been listed due to the great backlog of candidate species. All candidates should<br />

be managed as if they were listed. This means that full inventories of Forest lands for these species<br />

should be conducted, and management guidelines should be prepared to ensure that other management<br />

actions do not further contribute to the species' decline. Also, now that the State of Oregon has a<br />

formal endangered species program, coordination of management needs and approaches should<br />

include that program.<br />

<strong>Response</strong><br />

All activities must be evaluated for the occurance of sensitive plants or animals, and the risk to the<br />

species must be analyzed. Species management guides are to be developed for each species.<br />

Comment<br />

We feel the only way to effectively meet the needs and challenges of endangered and sensitive plants<br />

is for the Forest to maintain a permanently employed botanist on the staff. This person should be an<br />

experienced field botanist, preferably with graduate training in plant taxonomy or ecology. Only in<br />

exceptional cases will employees trained in other fields possess sufficient background to implement<br />

such a program. This level of training is necessary so that the employee can conduct specific research<br />

into the ecology and life history of each species, so that management can be based upon sound biological<br />

data, rather than casual observation and inference.<br />

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<strong>Response</strong><br />

The Area 4 Forests, which include this Forest, have Ecologists that are hired to study and make necessary<br />

inventories for T&E Plants in addition to classification of plant communities, these professionals are<br />

present to help the Forest in implementing necessary protection measures for vascular plants needing<br />

such action. These personnel, also, work in cooperation with universities, the Forest Service Research<br />

Lab, in conducting studies needed to implement sound management for plant species that are in the<br />

threatened, endangered, and/or sensitive categories.<br />

A Forest Botanist is currently on our staff.<br />

Comment<br />

We would also like to point out that none of these roadless areas, or any of the others on the Forest,<br />

appear to have been adequately censused for the presence of Sensitive Plant species. This should be<br />

remedied.<br />

<strong>Response</strong><br />

The FEIS,(Chapter 3) presents the Pacific Northwest Region's April 1990 revised list of plants considered<br />

sensitive that have been documented or are suspected as occuring on the Forest. Consideration of<br />

sensitive species is part of any site specific projects conducted on the Forest. Areas with proposed<br />

activity have priority for survey, areas such as roadless areas or Wilderness will be lowest priority for<br />

survey since no immediate impacts are expected. As the backlog of acres to be surveyed is reduced,<br />

Wilderness will be surveyed.<br />

Comment<br />

We recommend that the WNF develop the management of native plants as a formal planning issue.<br />

This issue development should include the provision of more specific and comprehensive Forestwide<br />

S&Gs for Sensitive plant species, a commitment to the development of Management Guides (including<br />

long-term monitoring of populations) for all of the Forest's Sensitive plant species, and the provision of<br />

an inventory of some potential Botanical Special Interest Areas on the WNF. These would represent<br />

strong steps towards an effective program of protection for the Forest's unique botanical resources.<br />

We request that the WNF take these steps as soon as possible. We suggest that you refer to the draft<br />

LRMPs of the Siskiyou and Gifford-Pinchot National Forests as models of how other Forests have at<br />

least begun to adequately address the issue of native plant/Sensitive species management.<br />

<strong>Response</strong><br />

All activities must be evaluated for the occurance of sensitive plants or animals, and the risk to the<br />

species must be analyzed. Species management guides are to be developed for each species.<br />

Comment<br />

Logging, even in temperate zones, has endangered or eliminated assorted species of flora and fauna.<br />

Biological cures for diseases have been developed from rare plants. It is theoretically possible that the<br />

entire species of mankind could be eliminated with the extinction of one endangered plant which has<br />

the potential for curing a known plague or disease, or a disease of the future that is unknown to us<br />

presently.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

Two sucker species, the Lost River Sucker and the shortnose sucker, have been proposed for listing<br />

as endangered species by United States Fish and Wildlife Service. The Endangered Species Act imposes<br />

procedural and substantive requirements on management activities which may adversely affect the<br />

species or their habitats. The Forest Service must fully disclose the effect implementation of the proposed<br />

plan will have on the suckers, consult with U.S. Fish and Wildlife Service and avoid taking any action<br />

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which might jeopardize the species. Failure to fulfill even procedural requirements of the Act may subject<br />

the forest plan to court action for injunctive relief. Thomas v. Peterson, 753 F.2d 754 (9th Cir., 1985).<br />

<strong>Response</strong><br />

Both suckers are currently listed as endangered. An interagency cooperative study to determine the<br />

factors limiting the suckers is underway. The Forest will consult with USFWS on any activity that will<br />

potentially impact sucker habitat.<br />

Comment<br />

The DEIS states that there are no known federally threatened or endangered plant species on the<br />

Winema National forest. We agree. We appreciate inclusion of the list of sensitive plants in the DEIS,<br />

although the Department of Agriculture's botanist has several specific suggestions on how to improve<br />

it. We also recommend that a clear policy on sensitive species management be developed by the<br />

Forest and included in the Plan. A good example of such a management policy is included in the Rogue<br />

River National Forest DEIS.<br />

<strong>Response</strong><br />

All activities must be evaluated for the occurance of sensitive plants or animals, and the risk to the<br />

species must be analyzed. Species management guides are to be developed for each species.<br />

Comment<br />

The Forest needs to provide more explicit information in wildlife in the above categories. More information<br />

on habitat requirements and habitat protection measures needs to be presented for sensitive species<br />

such as northern spotted owl, great gray owl, and bull trout. ODFW offers its assistance with the<br />

development of habitat management plans. The following are some comments and recommendations<br />

by species:<br />

Peregrine Falcon - The peregrine falcon nests in Crater Lake National Park near the Forest. The<br />

potential for peregrine falcons nesting on the Forest needs to be addressed.<br />

Bald Eagle - ODFW supports the protection of all existing and potential winter roost sites and<br />

nest sites. The status of the bald eagle warrants intensive habitat protection to meet the goals<br />

of the Pacific States Bald Eagle Recovery Plan.<br />

Golden Eagle - ODFW supports protection of inventoried nest sites.<br />

Northern Spotted Owl - ODFW recommends management areas be at least 2,200 acres in size,<br />

well distributed, and dedicated as oId-growth habitat.<br />

Purple Martin - Purple martin are a Federally listed sensitive species.<br />

Osprey - All osprey nest sites located in riparian or upland areas should be accorded full protection.<br />

Sandhill Crane - Marshes and meadows should be allocated to MA 8. Marshes and meadows<br />

that have been adversely impacted by management activities need to be rehabilitated.<br />

Bull Trout - The only plausible opportunity to maintain relic populations of bull trout (a Federal<br />

candidate species) at current levels or better is through maintenance of roadless areas and<br />

implementation of strict standards for protection of riparian habitat and water quality.<br />

Great Gray Owl - Meadows and surrounding forest cover need to be allocated to MA 8 or other<br />

allocations restricting timber harvest. Management activities must benefit this unique owl.<br />

<strong>Response</strong><br />

Chapter III of the FEIS lists plant and animal species considered sensitive by the Pacific Northwest<br />

Region. Species management guides will be developed for these species within the planning period.<br />

These will be developed in cooperation with ODFW.<br />

Specific information regarding the species listed follows:<br />

Peregrine falcon - The Forest will monitor potential habitat for occurance.<br />

Bald Eagle - The bald eagle warrants special management defined in Management Area 9. This<br />

management area includes and provides management guidance for winter roosts and nest<br />

sites.<br />

Golden Eagle - This species is not on the R6 Sensitive Species List. However, standards and<br />

guidelines provide for protection of golden eagle nest sites during nesting activity periods.<br />

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Spotted owl - Spotted owl habitat areas are reserved in Management Area 7. Guidelines for this<br />

species are in accordance with the Supplement to the Final EIS of the Regional Guidelines.<br />

Purple Martin - This species is not on the R6 Sensitive Species List and is not known to occur<br />

on the Forest.<br />

Osprey - Osprey nest sites are protected during nest activity periods.<br />

Sandhill crane - Marshes and wet meadows are allocated to Management Area 8, Riparian Areas<br />

in Alternative J, FEIS Preferred Alternative.<br />

Bull Trout - This species is protected by Forestwide standards and guidelines in Soil and Water,<br />

and standards and guidelines in MA 8.<br />

Great Gray Owl - This species is not on the R6 Sensitive Species List for the Forest. However,<br />

nest sites are protected during nest activity periods.<br />

Comment<br />

P.IV-49<br />

Threatened, Endangered, and Sensitive Species. What would be the effects of the alternatives on the<br />

peregrine falcon? (See Recommendations).<br />

<strong>Response</strong><br />

Peregrine falcon nest in Crater Lake National Park. The falcon from the Park may feed on waterfowl<br />

and other birds on the Forest, but this has not been documented. There are potential nesting areas<br />

on the Forest. These will be monitored for occupancy.<br />

Comment<br />

D-8.<br />

Bald Eagle. January 1 - August 31 needs to be labeled nesting.' Dates for roosting need to be November<br />

1 to March 15.<br />

<strong>Response</strong><br />

Management Area 9 has nesting and roosting periods for bald eagle.<br />

Comment<br />

The spelling of two species epithets need correction: bolanderi on page 111-22 and erythrorhiza on page<br />

111-24. Also, the taxonomic status of Erigeron decumbens var. robustior has recently been re-evaluated,<br />

and this taxon is now considered not to occur in Oregon according to a soon-to-be published paper<br />

by John Strother and William Ferlatte of the University of California at Berkley. The Winema National<br />

Forest may cite ODA as a source of this information.<br />

<strong>Response</strong><br />

Sensitive plant and animal species lists are updated annually by the Pacific Northwest Regional Office.<br />

Comment<br />

The planning document implies that Table 111-4 has been compiled after consultation with the lists of<br />

species in 'Rare, Threatened, and Endangered Plants and Animals of Oregon:, published by The Oregon<br />

Natural Heritage Data Base (ONHDB) in 1985. The Forest should be aware that an updated, 1987<br />

version of this reference is now in print and has been for several months. ODA believes that the table<br />

would be further improved if it indicated that suspected level of sensitivity of the individual species<br />

presented. This information can be generally gathered from the ONHDB publication cited earlier. For<br />

example, many of the species listed are now considered by botanical authorities in Oregon no longer<br />

be in jeopardy of extinction, or, they may be perhaps sensitive in Oregon but not in adjacent states.<br />

The recognition of these taxa in some way is appropriate by the Forest, but they should be distinguished<br />

from those plants which are in more immediate need of study and protection.<br />

<strong>Response</strong><br />

Tables have been updated to reflect the latest status for all species. This list is updated annually by<br />

the Pacific Northwest Regional Office.<br />

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Comment<br />

The last paragraph of the section on Threatened, Endangered, and Sensitive vascular plants, on page<br />

111-21, starts with the following sentence: wGrazing of domestic livestock will not be a threat to the sensitive<br />

plants on the Forest." ODA would be very interested in seeing the data on which this statement is<br />

based, as nothing concerning threatened and endangered species is mentioned under the Range<br />

Management section located on pages 111-52-55.<br />

<strong>Response</strong><br />

This statement has been reworded to 'generally will not be a threat.' This is the opinion of the Area 4<br />

Ecologist, a professional botantist.<br />

Comment<br />

A brief reference to grazing and sensitive species is given on page IV-14, under the Environmental<br />

Consequences section. There is a vague implication at this point that grazing may affect these taxa,<br />

but it is indicated that this activity 'will be managed to prevent the degradation of the range resource<br />

which will generally protect the sensitive plants.' Similar comments are offered with respect to recreational<br />

use of national forest property. A statement should be inserted here that specifically says how such<br />

management will be accomplished, If the Forest does not have professional botanists on staff, then<br />

employment or consultation of such expertise should be proposed as the method by which sensitive<br />

species management will be undertaken. An estimate of the Forest's annual financial commitment to<br />

this effort should be provided somewhere in the DEIS.<br />

<strong>Response</strong><br />

The Area 4 Forests, which include this Forest, have Ecologists that are hired to study and make necessary<br />

inventories for T&E Plants in addition to classification of plant communities, these professionals are<br />

present to help the Forest in implementing necessary protection measures for vascular plants needing<br />

such action. These personnel, also, work in cooperation with universities, the Forest Service Research<br />

Lab, in conducting studies needed to implement sound management for plant species that are in the<br />

threatened, endangered, and/or sensitive categories.<br />

A Forest Botanist is currently on our staff.<br />

Comment<br />

ODA recommends that a clear policy on sensitive species management be presented by the Winema<br />

National Forest. It is surprising that sensitive species conservation has not been identified as a public<br />

issue or concern by the Forest, these being defined on page 1-7 (DEIS) as 'subject(s) of wide-spread<br />

public interest related to teh management of the National Forest System.' Inasmuch as there are federal<br />

and state laws in effect in Oregon dealing with endangered species, plans should be developed to: 1)<br />

systematically determine the extent and biological requirements of sensitive species populations on<br />

the Winema National Forests; 2) devise a clear policy for mitigation of potential management conflicts;<br />

and 3) promote interagency contacts and determine consultation procedures with respect to this resource.<br />

<strong>Response</strong><br />

The Area 4 Forests, which include this Forest, have Ecologists that are hired to study and make necessary<br />

inventories for T&E Plants in addition to classification of plant communities, these professionals are<br />

present to help the Forest in implementing necessary protection measures for vascular plants needing<br />

such action. These personnel, also, work in cooperation with universities, the Forest Service Research<br />

Lab, in conducting studies needed to implement sound management for plant species that are in the<br />

threatened, endangered, and/or sensitive categories.<br />

A Forest Botanist is currently on our staff.990.<br />

Comment<br />

Threatened, Endangered and Sensitive Species: The plan fails to fully assess current status of these<br />

species, the habitat requirements of these species and the impacts to habitat by alternative.<br />

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<strong>Response</strong><br />

The current status of the species which are listed as threatened, endangered, and sensitive is discussed<br />

in Chapter 3 of the FEIS. The specific habitat of each species is documented by Oregon Heritage<br />

Natural Database. The specific requirements of each species in its habitat is generally not known and<br />

will require research to obtain. The impacts to species that affect large acreages of the Forest, such as<br />

bald eagle and spotted owl, are shown in Chapters 2 and 4. Other species, such as the sensitive plants,<br />

occupy very small sites and will generally reflect no impact on output of the Forest Plan. The Forest<br />

will evaluate and address the effects of any site-specific activity on a sensitive species through a biological<br />

evaluation process.<br />

Comment<br />

Plants: We do not find an acceptable strategy for protecting sensitive plant species in the plan. Contract<br />

stipulations do not protect plants unless the contractors, or contracting officers are botanists. We feel<br />

that the plan would benefit from an operational policy on protecting plant species.<br />

<strong>Response</strong><br />

The Area 4 Forests, which include this Forest, have Ecologists that are hired to study and make necessary<br />

inventories for T&E Plants in addition to classification of plant communities, these professionals are<br />

present to help the Forest in implementing necessary protection measures for vascular plants needing<br />

such action. These personnel, also, work in cooperation with universities, the Forest Service Research<br />

Lab, in conducting studies needed to implement sound management for plant species that are in the<br />

threatened, endangered, and/or sensitive categories.<br />

A Forest Botanist is currently on our staff.<br />

Comment<br />

DEIS IV-49, Threatened, Endangered, and Sensitive Species: This section and references contained in<br />

this section do not give a clear assessment of effects to threatened, endangered and sensitive species<br />

by alternative. If management lans, standards and guidelines, and management area prescriptions for<br />

bald eagle are to be consistently applied regardless of alternative, a statement should be provided<br />

indicating that there will be no change in management regardless of alternative selected. However,<br />

based upon our review of available information, alternatives appear to differ in the degree to which<br />

potential habitats for listed species will receive special management consideration. What these differences<br />

may mean in terms of effect to listed species and their recovery should be concisely stated.<br />

<strong>Response</strong><br />

The current status of the species which are listed as threatened, endangered, and sensitive is discussed<br />

in Chapter 3 of the FEIS. The specific habitat of each species is documented by Oregon Heritage<br />

Natural Database. The specific requirements of each species in its habitat is generally not known and<br />

will require research to obtain. The impacts to species that affect large acreages of the Forest, such as<br />

bald eagle and spotted owl, are shown in Chapters 2 and 4. Other species, such as the sensitive plants,<br />

occupy very small sites and will generally reflect no impact on output of the Forest Plan. The Forest<br />

will evaluate and address the effects of any site-specific activity on a sensitive species through a biological<br />

evaluation process.<br />

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Comment<br />

PLAN IV-1 07 to IV-1 17, Management Area 9: The Service recommends that the Forest consider expanding<br />

this management area to include identified historical and potential habitat for peregrine falcons and<br />

shortnose and Lost River suckers. See comments on DEIS 11-62.<br />

<strong>Response</strong><br />

Management Area 9 provides specific guidance for the management of bald eagle habitat.<br />

Peregrine falcon nest in Crater Lake National Park. The falcon from the Park may feed on waterfowl<br />

and other birds on the Forest, but this has not been documented. There are potential nesting areas<br />

on the Forest. These will be monitored for occupancy.<br />

Both suckers are currently listed as endangered. An interagency cooperative study to determine the<br />

factors limiting the suckers is underway. The Forest will consult with USFWS on any activity that will -<br />

potentially impact sucker habitat.<br />

K - 159

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Timber Management<br />

Comment<br />

Has any provision been made for seed selection or gene enhancements to provide better stock for<br />

replanting?<br />

<strong>Response</strong><br />

Yes, provisions have been made to provide genetically improved stock for reforestation. The Winema<br />

N.F. has 5267 trees selected for seed production as well as four seed orchards established, and two<br />

additional orchards are being developed at this time.<br />

Comment<br />

Costs in Table IV-2 show average annual timber sales costs are $7.4 million including replanting, etc.<br />

Yet in Table 111-14 of the DEIS you show costs of only $3.7 million for 1985. Show realistic costs in all<br />

places.<br />

<strong>Response</strong><br />

Table IV-2 in the draft Forest Plan is an estimate of the cost of implementing the preferred alternative<br />

whereas Table 111-14 of the DEIS shows some historic expenditures for timber management on the<br />

Forest. Table IV-2's higher value indicates the higher investments needed to implement uneven-aged<br />

management, reforest the dying lodgepole pine and increase the timber stand improvement program.<br />

Comment<br />

The timber sale areas in green stipple on the Alternative E Map could be sold off to the highest bidders<br />

so as to allow the private enterprise, or timber companies to manage harvest areas. Then the Federal<br />

government would no longer be in a business which can conflict with a capitalist orientation.<br />

<strong>Response</strong><br />

From the passage of the Organic Act (June 4, 1897) to the passage of the Multiple Use-Sustained<br />

Yield Act (June 12, 1960) the mission of the U. S. Forest Service has always been conservation and<br />

management of forested federal lands to ensure a continuous supply of all resources. Selling of our<br />

timber lands would be a violation of our mission.<br />

Comment<br />

To justify a departure from sustain yield harvest by saying it will Istabilize" economy of the area makes<br />

as much sense as getting out on a limb and then cutting off the limb. We've allowed overcutting for<br />

years so the economy of the area is now dependent on it--the price of lumber falls, the housing market<br />

goes down, so you need to cut more to make less. The mill yards are full. Why use up in a few years<br />

natural resources that have taken hundreds of years to come into existence just to put a temporary<br />

band-aid on the local economy?<br />

<strong>Response</strong><br />

According to the timber supply projection made by the Oregon State Department of Forestry, timber<br />

harvest on private lands is expected to decline 36%. Increasing the harvest on National Forest lands<br />

will offset this reduction in harvest while the timber on private lands grows and become economical to<br />

harvest. This shifting of the harvest from private to Federal lands and then back again, will maintain an<br />

even flow of timber to local mills.<br />

There was considerable public comments against a departure from long-term sustained yield from the<br />

Winema National Forest so Alternative J, the Forest Plan, is not a departure.<br />

Comment<br />

Even-aged management and large clearcuts encourage catastrophic burns. It is economically preferable<br />

in the long-term to reduce the size of clearcuts and promote mixed stands.<br />

K- 160

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<strong>Response</strong><br />

The Forest Plan will emphasize uneven-aged management on the ponderosa pine and pine associated<br />

working groups.<br />

Comment<br />

I am concerned over the fact that we are planning for only a 10-15 year period, because if a commodity<br />

alternative is chosen, it will severely restrict our management options during each future planning period,<br />

i.e., once the decision is made to build roads into roadless areas, and to log much of the remaining<br />

old growth we have lost this resource and these options for realistically all time.<br />

<strong>Response</strong><br />

The planning process is developed to look at both short term and long term issues. The 10-15 year<br />

planning period helps us to respond to changing needs. Our 1 50-year planning horizon facilitates a<br />

look at what long term options are eliminated by short term actions. The roading of roadless areas<br />

and regeneration harvests of old growth does eliminate those conditions for our lifetime.<br />

Comment<br />

As a suggestion, may I point out the most successful logging practices of the Gilchrist Logging Co.<br />

and the Pacific Logging Co. of Northern California (before being taken over). They have demonstrated<br />

for several generations in the same families that Selective Logging can be done profitably and sustain<br />

a continuous yield of good trees as opposed to wasteful and destructive clear cutting with its inevitable<br />

and irreversible erosion.<br />

<strong>Response</strong><br />

We agree that uneven-aged management is a viable option and will be prescribed for many acres.<br />

Even-aged silvicultural systems will still be prescribed for some diseased stands and other stands<br />

needing a fresh start. Clearcutting may appear destructive and wasteful in some cases, but it actually<br />

maximizes wood fiber production and is a very efficient way to harvest timber. Analysis indicates that<br />

insignificant amounts of erosion occur due to harvest activities. The! Forest Plan will emphasize<br />

uneven-aged management on the ponderosa pine and pine associated working groups.<br />

Comment<br />

Stop being captive to timber and grazing interest, stop managing for the short run only, become active<br />

in supporting a total ban of all log shipments from the U.S. (private, state, or federal)-great nations<br />

ship finished goods, not raw materials.<br />

<strong>Response</strong><br />

Currently, there is a law banning the export of logs from federal lands. The decision to ban the export<br />

of private and/or state timber is one that can only be made by each state's legislature or by Congress.<br />

Comment<br />

Overcutting of timber. The plan cuts beyond a sustained yield level and eliminates both old growth<br />

and tree diversity. Cutting levels should be reduced to preserve old growth and maintain a mixed-age,<br />

sustained yield forest.<br />

<strong>Response</strong><br />

The preferred alternative in the DEIS was a departure from sustained even flow to maintain the ponderosa<br />

pine harvest and to harvest the dying lodgepole pine. Tables are included in Chapter 2 of the FEIS<br />

which gives the projected amount of old growth on the Forest for each alternative. The preferred alternative<br />

maintains a minimum level of old growth to maintain viable populations of dependent wildlife species.<br />

In addition, extra oldgrowth was allocated in the ponderosa pine to maintain 10 percent oldgrowth.<br />

The Forest will have much more variation between age classes in 50 years than it has today but the<br />

amount of old mature trees will be greatly reduced. The species mix will not change. Most of the Forest<br />

is climax ponderosa pine or lodgepole pine and little species variation occurs in these stands.<br />

K - 161

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Comment<br />

I also feel that not enough old growth timber is being preserved for the long-term; the Forest Service<br />

should protect at least several thousand additional acres of those magnificent old stands of ponderosa<br />

pine for which the upper Klamath Basin was once famous.<br />

<strong>Response</strong><br />

The preferred alternative has been modified to maintain 10 percent of the ponderosa pine working<br />

group as oldgrowth.<br />

Comment ,<br />

It seems to destroy the natural ecological system of the Forest when even-aged fast-growing stands<br />

are proposed as 'forest management." I submit that such a plan over the long haul is mismanagement!<br />

<strong>Response</strong><br />

Natural pine stands on the Winema in the early 1900's tended to be mature single story stands with<br />

little or no understory vegetation. Aggressive effective fire control, which started about 50 years ago,<br />

has allowed young trees to become established under the mature trees giving a multiaged stand. Our<br />

current multistoried stands are quite unnatural.<br />

Managed stands definitely look different than stands left for natural systems to operate. There are no<br />

natural ecosystems on the Forest. All stands, even the wilderness areas, are subject to fire suppression<br />

which greatly alters natural thinning and regeneration systems. Management tries to mimic nature by<br />

controlling competing vegetation during regeneration phases (burning or mechanical scarification),<br />

controlling stocking levels (precommercial and commercial thinning), and by making room for new<br />

trees by removing mature trees. The final Forest Plan includes uneven-aged management on ponderosa<br />

pine and pine associated stands to lessen the visual impacted of timber harvest.<br />

Comment<br />

Let the timber companies build their own roads and totally restore them after any current sales.<br />

<strong>Response</strong><br />

Almost all of the roads constructed on the Forest, whether long term system roads or temporary roads,<br />

are constructed by the timber companies, through provisions within the timber sale contract. Temporary<br />

or intermittent access roads constructed by timber companies are closed to use or restored, either by<br />

the timber purchaser, or through a collection deposit within the provisions of the timber sale.<br />

Comment<br />

The Preferred Alternative is inadequate in its ability to protect the diverse ecosystems within the Forest.<br />

The plan calls for a departure from even flow, sustained yield harvests to production of even-aged<br />

stands. This results in loss of both genetic and species diversity. I fear the yield tables used to determine<br />

the future timber supply are optimistic, and urge reconsideration of them.<br />

<strong>Response</strong><br />

The plan provides for several methods to achieve diversity in age and structure: 59,140 acres will be<br />

managed as old growth; 91,385 acres as wilderness; 3,045 acres as research natural area; 22,590<br />

acres as a semiprimitive non-motorized recreation areas; and, 43,573 acres will receive minimum<br />

management. In addition, approximately 400 thousand acres of ponderosa pine and pine associated<br />

stands will be managed using uneven-aged silvicultural systems. The yield tables were all reviewed<br />

and are based on research data.<br />

Comment<br />

The change in management practice, from selective harvesting to clearcutting will cause a departure<br />

from even flow sustained yield for both lodgepole and ponderosa pine stands in the Forest. Uneven-aged<br />

management practices have proven to be a better long term strategy on every count.<br />

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<strong>Response</strong><br />

The Forest is not planning to change from uneven-aged to even-aged silvicultural practices. We are<br />

already using even-aged silvicultural practices and plan to start using some uneven-aged silvicultural<br />

practices. Changing from even-aged to uneven-aged silvicuitural practices does not effect sustained<br />

yield; either system can be managed to produce whatever flow is desired.<br />

Uneven-aged management has not proven to be the best for all situations. Uneven-aged management<br />

will minimize horizontal diversity between stands, which will be detrimental to animals which use edge<br />

habitat, such as deer and elk. That is only one of the many situations where uneven-aged management<br />

will not be best.<br />

Comment<br />

I have asked before and I will ask again, 'What will be left for our grandchildren if the old growth cutting<br />

is not stopped?" Why can you not continue with your plan for uneven-aged timber, management? Have<br />

you done an INDEPENDENT assessment of the environmental impact of grazing in riparian areas before<br />

giving out permits?<br />

<strong>Response</strong><br />

I will address your questions in order:;<br />

1. The figures in Chapter 4 of the FEIS shows how vegetation age will change over time for selected<br />

alternatives. In the alternatives with the highest timber harvest the acres of overmature stands<br />

decreases to about 150,000 acres and then increases to over 200,000 in about 70 years.<br />

2. Previous plans did not call for uneven-aged management. The preferred alternative does call for<br />

uneven-aged management on almost 300,000 acres. The Forest Plan directs use of uneven-aged<br />

management on ponderosa pine and pine associated stands when practical.<br />

3. All range allotment management plans have an environmental assessment which would include<br />

an assessment of the impact of livestock grazing on riparian habitat.<br />

Comment<br />

I can see no reason why the Forest Service and the forest products industry can not create programs<br />

that will enable the cutting of trees for a profit and still keep our forest beautiful. A reasonable answer<br />

is requested.<br />

<strong>Response</strong><br />

The Forest plan calls for implementing uneven-aged management practices. The main reason this<br />

change is being considered is to maintain a pleasant looking Forest while maintaining needed levels<br />

of timber harvest.<br />

Comment<br />

Massive clearcuts of diseased lodgepole stands would have a devastating effect on some cavity nesting<br />

species.<br />

<strong>Response</strong><br />

A normal lodgepole pine stand only has scattered mortality and offers limited habitat for cavity nesting<br />

species. The increased mortality from the mountain pine beetle epidemic has greatly increased the<br />

habitat for cavity nesting species. This habitat is short lived, because lodgepole pine snags rot off and<br />

fall in about seven years. Harvesting the dead and dying lodgepole pine will reduce the available habitat<br />

from the present level, but harvesting will not reduce the habitat below normal levels.<br />

Comment<br />

We strongly support your proposal that over 140,000 acres of former reservation lands, principally<br />

ponderosa pine forest lands, receive uneven-aged timber management. We agree with your assessment<br />

that this silvicultural practice is more compatible with wildlife values.<br />

K - 163

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<strong>Response</strong><br />

I am sorry if we led you to believe that we feel uneven-aged management is more compatible without<br />

wildlife values. We believe that uneven-aged management will benefit species that benefit from vertical<br />

vegetation diversity, but will be detrimental to species benefiting from horizontal vegetation diversity<br />

and edge. The vice versa is true for even-aged management.<br />

Comment<br />

In Table C-7, the Long-Term Sustained Yields (MMCF/YR) are questionable. Under Alternative E, just<br />

to list a coupe of cases, this Table shows that Skylakes-B would produce 120,000 CF/YR on 39 acres,<br />

allocated to timber production, or 3,076 CF/AC/YR. The table shows that West Boundary would produce<br />

169,000 CF/YR from Zero acres allocated to timber production. Allocation figures are taken from Table<br />

C-6.<br />

<strong>Response</strong><br />

We have the wrong units on Table C-7 in the DEIS. The table should have been in thousands of cubic<br />

feet (MCF) in stead of millions of cubic feet (MMCF).<br />

Comment<br />

In Table IV-9, it seems odd that 37% less standing inventory, in 2030, will grow 74% more fiber each<br />

year than the present annual net growth. Does this mean that some low productivity sites will be converted<br />

to high productivity sites, or is this the true result of managed stands?<br />

<strong>Response</strong><br />

The increased growth is the result of converting old stands to young vigorous stands. For example,<br />

the mature ponderosa pine stands on the Winema are growing 34 cubic feet per acre per year whereas<br />

young managed stands will grow 45 cubic feet per acre, per year. The mature mixed conifer stands<br />

are growing 63 cubic feet per acre, per year whereas young managed mixed conifer stands grow over<br />

a 100 cubic feet per acre per year.<br />

Comment<br />

In Table C-4, the Standing Volume Suitable AC/MMCF does not look realistic. As I understand this<br />

Table, it would take 4.6 acres to contain one million cubic feet (MMCF) of standing volume in the Aspen<br />

roadless area. This would calculate to 217,391 CF/AC. The standing volume per acre, in 1981 for the<br />

Forest, was about 2,000 cubic feet per acre. The numbers in the last column of Table C-4 need to be<br />

verified and/or further explained. I believe that it would have been more meaningful to give the actual<br />

standing volume for each roadless area, and I request that this be done in the final EIS.<br />

<strong>Response</strong><br />

The column referred to should have read: Standing volume on suitable acres in millions of cubic feet.<br />

Comment<br />

Some spokesmen in the timber industry and in forest management claim that forests are renewable.<br />

Given enough time, that is true. But the current desire to cut down even the remaining old growth<br />

forests reveals that the other forest lands have not grown fast enough to meet our nation's hunger for<br />

lumber. Let's face the truth. We are cutting down forests faster than they can grow.<br />

<strong>Response</strong><br />

The forest is currently growing about 118 million board feet per year (1981 inventory statistics). The<br />

average annual harvest for the last 10 years (1979-1988) was 166 million board feet per year. Normally,<br />

during the time period a forest is being changed from an old growth to a managed second-growth<br />

forest, harvest exceeds growth because the mature forests grow at such a slow rate compared to<br />

immature forests; and, the quicker the stands are reforested with young trees, the quicker the higher<br />

growth rates can be captured.<br />

The Winema plans to keep about 10 percent of the area available for timber harvest in old-growth. All<br />

other stands would be harvested and converted to immature stands.<br />

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Comment<br />

National forest management is trending towards even-aged stands of single species of trees. This will<br />

be depriving future forest ecosystems of the much needed plant and animal diversity. This, I believe, is<br />

very wrong and the future managers will pay the price. Protecting the biological diversity is the main<br />

reason for protecting the roadless areas, riparian zones, the old-growth, large dead and downed trees,<br />

a diversity of tree species and size classes. This concept is not given sufficient emphasis in the plan.<br />

<strong>Response</strong><br />

The plan addresses diversity in many ways. Areas managed with uneven-aged silvicultural systems will<br />

have a lot of vertical diversity within stands, but little horizontal diversity between stands. Areas to be<br />

managed with even-aged silvicultural systems have restrictions on cutting unit size so optimum diversity<br />

between units is achieved but within stand diversity is minimum.<br />

The forest has been converted to fir dominated stands where ponderosa pine once dominated. The<br />

reforestation program will concentrate on reestablishing the historic mix of pine and fir on the forest.<br />

Comment<br />

The plan states 87,000 acres of lodgepole pine will be harvested in the first decade. I feel this is misleading.<br />

It indicates that these are pure stands of lodgepole pine. Current salvage harvesting at Chemult District<br />

has included multiple board feet of ponderosa pine as well as lodgepole. I feel the plan should be<br />

clear about all species that are salvaged because of the mountain pine beetle.<br />

I am also confused about the amount of acres that have already been salvage harvested at Chemult.<br />

Are they included in this 87,000 acre figure?<br />

<strong>Response</strong><br />

The plan refers to the acres of the lodgepole pine working group that will be harvested in the first<br />

decade. The mature, single story lodgepole pine working group is 17% ponderosa pine. This ponderosa<br />

pine is suffering high mortality and is also being harvested along with the lodgepole pine.<br />

The data base was updated to the end of FY 88. The harvest acres in the plan would be the harvest<br />

from that time.<br />

Comment<br />

The plan states that 38% of the ponderosa pine stands will have been managed for 50 years as<br />

uneven-aged management after the first decade. This is not possible since those acres are not currently<br />

being managed as uneven-aged stands. They may have been managed as uneven-aged by the U.S.<br />

Bank, but since 1974, the Forest Service has been managing them as even-aged.<br />

<strong>Response</strong><br />

This is an error and is corrected in the FEIS.<br />

Comment<br />

The plan states the old-growth component will be reduced from 645,000 to 246,000 acres in 5 decades.<br />

This is misleading. It should be made clear that these acres remaining are not included in the 793.1 M<br />

acres of suitable timber production land.<br />

<strong>Response</strong><br />

The 246,000 acres of old-growth in Decade 5 includes 180,000 acres on lands with no programmed<br />

harvest; 44,000 acres on lands with a programmed harvest except the lands with a management intensity<br />

of minimum level; and, 22,000 acres on lands with a programmed harvest, but with a minimum level<br />

management intensity.<br />

Comment<br />

The plan is very concerned that it maintains historical levels of harvest.' Yet, these levels are so high<br />

that they cannot be maintained after 5 decades. I feel this is not sustained yield, but 'get it while you<br />

can' philosophy. In 50 years, there will not be enough timber left to sustain this basin economically.<br />

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The harvest levels should be pulled back to levels that are sustainable. (I don't have a figure for you,<br />

but it should be calculable with the FORPLAN model.)<br />

<strong>Response</strong><br />

The Forest Plan has been recalculated to maintain a sustained even flow. See Alternative J for details.<br />

Comment<br />

Table IV-3 indicates that all thousand acres of uneven-aged management will be harvested the first<br />

decade. This should also have been stated elsewhere. This is misleading to the public who wanted<br />

uneven-aged management, such as the Klamath Indian Tribe. This incredibly accelerated harvesting of<br />

these stands will not result in the all age stands they envisioned but in a checkerboard of harvest<br />

units.<br />

<strong>Response</strong><br />

The harvest type is also shown in Table 11-3a in the DEIS and Table 2-5 in the FEIS.<br />

Leveling of the uneven-aged treatment between decades was a concern of many folks. The final preferred<br />

alternative leveled the number acres of selection harvest between decades.<br />

Comment<br />

Old Growth. Old trees are important for wildlife, people, aesthetic, etc., but most important of all, they<br />

are necessary to provide the 'blueprint' for a sustainable forest (as opposed to 'sustained yield" of<br />

timber sawlogs). Nowhere in the world have we successfully grown a third generation 'forest.' Humanity's<br />

forest becomes a tree from--nature's forest is a diverse ecosystem. Old growth must be preserved in<br />

sufficient quantities of various timber types, of different age groups, to ensure perpetuation of the forests.<br />

NFMA clearly states forests should be managed for a "sustained yield [sustainable forest] in perpetuity."<br />

<strong>Response</strong><br />

The plan provides for several methods to achieve diversity in age and structure: 59,140 acres will be<br />

managed as old growth; 91,385 acres as wilderness; 3,045 as research natural areas; 22,590 acres as<br />

semiprimitive non-motorized recreation areas; and, 43,573 acres will receive minimum management. In<br />

addition approximately 400 thousand acres of ponderosa pine and pine associated stands will be<br />

managed using uneven-aged silvicultural systems.<br />

Comment<br />

Congress has directed the Forest Service to administer the national forests for multiple use. Yet, for<br />

over 25 years, this mandate had virtually been ignored and instead the Forest Service has emphasized<br />

logging and road construction. And, doing this while losing money--selling its stock-in-trade far below<br />

the cost of production.<br />

<strong>Response</strong><br />

The Forest Service makes many investments in multiple use. The Forest Service was a leader in developing<br />

wilderness areas, campgrounds have been developed at most major attractions, visual corridors are<br />

maintained along major travel routes, habitat is developed and maintained for both harvested and<br />

non-harvested wildlife species. The list could go on and on. National forests were established to provide<br />

goods and services for the public, not to be set aside as preservation areas.<br />

The Winema is a very cost effective forest. Our timber receipts far exceed the cost of road construction<br />

and timber management costs. See Below Cost Timber Sales in Chapter 3.<br />

Comment<br />

Timber Harvest Practices. The allowable harvest schedule for any decade shall thus be limited to a<br />

quantity equal to or less than the planned sale. NFMA (Section 13(a)) states that timber sales shall be<br />

of 'a quantity equal to or less than a quantity which can be removed from such forest annually in perpetuity<br />

on a sustained-yield basis.' Yet, Forest Service managers continue to draw up long range plans to<br />

accelerate their timber programs.<br />

K - 166

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<strong>Response</strong><br />

Federal Code of Regulations 36 CFR Part 219.16 Timber Resource Sale schedule gives the rules for<br />

departing from the base sale schedule. The departure analysis for the DEIS is found on pgs. B-1 85<br />

through B-189.<br />

Comment<br />

It should be clear to the Forest Service that clearcutting is not acceptable to the public. NFMA says<br />

this may be used if it is the optimum method. The Forest Service has interpreted this too liberally. ff<br />

clearcutting methods are used, it should be done in smaller sized entries (5-10 acres), contour cuts,<br />

lineal, as opposed to checkerboard squares of (40+ acres), and only on land which without risk will<br />

be assured of regeneration.<br />

<strong>Response</strong><br />

Clearcutting is not used very much on the Winema National Forest. It is mainly used to harvest diseased<br />

stands, such as the Armillaria root rot areas on the Klamath District or the dwarf mistletoe areas which<br />

occur throughout the Forest. The disease-free ponderosa pine and pine associated stands on the<br />

Forest will be managed with uneven-aged silvicultural systems.<br />

Comment<br />

The Forest Service continues to lose money on sales. There should be a policy of no below-cost timber<br />

sales. Longer rotation--at least 150 years--should be the policy in all land management plans. Allow<br />

the forest to regrow as nature intended it to do--not as an agricultural crop.<br />

<strong>Response</strong><br />

The Winema has a very positive balance sheet for its timber program. Chapter 3 gives information<br />

about below cost sales.<br />

The Winema tries to design its sales to not be below cost. Some thinning sales are below cost and<br />

many of the lodgepole pine sales are below cost. The sales are made to minimize costs or to enhance<br />

another resource.<br />

Rotation lengths are determined by the culmination of mean annual increment of wood measured in<br />

cubic feet. Some management areas, such as visual foreground retention has a much longer rotation<br />

to provide the desired stand conditions. Choosing rotations past the culminating of mean annual increment<br />

for areas of general forest, would simply reduce the productivity of the Forest and increase costs.<br />

Comment<br />

Are there stands of ponderosa pine never touched that can be saved as a part of our heritage - a gift<br />

to people we will never know? This question. must be answered truthfully and now before cutting program<br />

begins. Please contact me for information on areas that could be proposed areas for very select cutting.<br />

<strong>Response</strong><br />

There are allocations within the plan that will prevent the removal of all old growth ponderosa pine.<br />

Approximately 52,000 acres of the ponderosa pine working group and 16,000 acres of the pine associated<br />

working group which are suitable for timber production are allocated to no harvest management areas.<br />

Comment<br />

Can Eastern Oregon, the pumice desert areas of the Winema be treated with the same decision making<br />

as any other forested area? It definitely should not! The impact in the pumice areas are devastating to<br />

future rapid growth. (There is no rapid growth in large ponderosa forests where pumice is the predominant<br />

first layer of earth.<br />

<strong>Response</strong><br />

Almost all ponderosa pine stands on the Winema are timber productivity site class 4 and 5 with a<br />

majority being site 5. The pumice sites can be sensitive to work, but in many ways, are less sensitive<br />

to work than other soils because they are far less apt to compact.<br />

K - 167

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Comment<br />

In my opinion, clearcutting has destroyed much of Oregon's forest in my lifetime...probably from erosion,<br />

lack of replanting and change in soil temperature.<br />

<strong>Response</strong><br />

Clearcutting is a viable regeneration system. All clearcuts on the Winema are planted except for some<br />

in lodgepole pine, which will naturally regenerate, and since the Winema is so flat, very little erosion<br />

occurs.<br />

Comment<br />

Please consider that departure from even-flow sustained yield will ultimately be destructive to the<br />

ecosystem.<br />

<strong>Response</strong><br />

There is nothing inherently destructive about departure from sustained even flow. The same silvicultural<br />

treatments will be applied, just over a shorter time period. Over the long run, the Forest will produce<br />

the same amount of wood; it will just vary between decades.<br />

The preferred alternative in the FEIS reversed the decision in the DEIS so the Forest no longer plans<br />

to use a departure from sustained even flow.<br />

Comment<br />

In generally reviewing your plan, it appears that the ASQ is too high due to backlog of unreforested<br />

areas, credits taken for intensive management practices are as yet unconfirmed. Roading is beyond<br />

the maximum amount for protection of big game.<br />

<strong>Response</strong><br />

The ASQ is calculated using the current conditions of all forested lands. Non-stocked areas are included<br />

and only start accumulation volume once they are reforested. The Winema has no current reforestation<br />

backlog. All non-stocked areas are in the current reforestation plan or have been left non-stocked to<br />

meet other resource needs.<br />

Precommercial thinning is used extensively in the plan and we have good research data to substantiate<br />

expected growth response.<br />

The number of open roads is greater than needed to manage some parts of the Forest and in those<br />

areas roads are being closed.<br />

Comment<br />

The Forest Service should live up to their last Forest Plan plus the wilderness study designations.<br />

<strong>Response</strong><br />

The Forest is reaffirming the allocation for developed recreation on Pelican Butte. The wilderness<br />

allocations were made in the 1984 Oregon Wilderness Act.<br />

Comment<br />

The concept of multiple use management as mandated by the National Forest Management Act of<br />

1976 and other legislation, calls for balanced consideration to all uses of the Forest. The benefits from<br />

each use must be continuous and sustained. Essentially all uses need be considered not just the use<br />

of trees. The National Forests should not take on the aspects of industrial tree farms and be placed<br />

under monoculture management where a theoretical maximum amount of timber is harvested each<br />

year at a rate that may or may not be sustainable. With monoculture management, all other uses tend<br />

to become subordinate to timber.<br />

<strong>Response</strong><br />

The following is the definition of Multiple Use:<br />

The management of all the various renewable surface resources of the National Forest System<br />

so that they are utilized in the combination that will best meet the needs of the American people;<br />

K- 168

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making the most judicious use of the land for some or all of these resources or related services<br />

over areas large enough to provide sufficient latitude for periodic adjustments in use to conform<br />

to changing needs and conditions; that some lands will be used for less than all of the resources;<br />

and harmonious and coordinated management of the various resources, each with the other,<br />

without impairment of the productivity of the land, with consideration being given to the relative<br />

values of the various resources, and not necessarily the combination of uses that will give the<br />

greatest dollar return or the greatest unit output.<br />

To meet this definition, a series of land allocations were made with each having a different level of<br />

timber management ranging from no harvest to intensive timber management. Some allocations<br />

emphasize dispersed recreation, others emphasize developed recreation, still others emphasize scenic<br />

values. In these allocation timber is a subordinate resource.<br />

Comment<br />

Considering the relatively poor timber growing capacity of the land and the fact that the Forest has<br />

been cut through several times, we question if the increased levels of harvest above that of the past<br />

decade would be sustainable without serious damages to the biological diversity and forest environment.<br />

<strong>Response</strong><br />

The increased harvest is not sustainable as proposed in the Preferred Alternative of the DEIS. The<br />

harvest level must drop substantially in the 5th Decade to let the Forest growth catch up to the cut.<br />

Page 11-80 of the DEIS shows how the allowable sale quantity would change over time. Chapter 4 addresses<br />

how other resources would be impacted by the harvest level.<br />

The preferred alternative in the FEIS no longer is a departure from sustained even flow so the ASQ of<br />

19.4 MMCF is sustainable.<br />

Comment<br />

These complex relationships must be maintained to prevent future 'waldsterben' or Forest death now<br />

encroaching upon the forest of Central Europe. Acid rain has taken most of the blame, but according<br />

to Chris Maser, Researcher, Forest Science Laboratory, Corvallis, some of the problem lies with the<br />

loss of the biological strength from centuries of monoculture management where many of the original<br />

ieforms have long been gone.<br />

<strong>Response</strong><br />

We have the same concerns; and, to address these concerns we have initiated several practices, such<br />

as leaving large debris in logging areas to provide habitat for small animals, bacteria and fungi. The<br />

dead and down woody material standard and guideline give the direction to maintain woody debris.<br />

Comment<br />

Current harvesting practices on the ponderosa pine will eventually remove all of the old growth unless<br />

efforts are made to reverse this trend.<br />

<strong>Response</strong><br />

There are allocations within the plan that will prevent the removal of all old growth ponderosa pine.<br />

Approximately 52,000 acres of the ponderosa pine working group and 116,000 acres of the pine associated<br />

working group which are suitable for timber production are allocated to no harvest management areas.<br />

Comment<br />

Ongoing research is beginning to uncover many unsuspected attributes of old-growth forests to the<br />

ecology of an area It is home, not only for the mature trees that make up its outward appearance, but<br />

to many birds and animal large and small, as well as plants, shrubs, insects, microbes and fungi. Many<br />

of them live in a symbiotic relationship that seems to have a good effect on trees, especially over the<br />

long run. These older trees are inhabited by certain nitrogen fixing lichens that are not present in younger<br />

trees.<br />

K - 169

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<strong>Response</strong><br />

Yes, this is true; and, for the reasons you stated 59,140 acres would be managed in an old growth<br />

condition as well as 91,385 acres in wilderness and 3,045 acres in research natural area. The 22,590<br />

acres in semiprimitive non-motorized recreation and the 43,573 acres in minimum management would<br />

be area receiving no site disturbing activities.<br />

Comment<br />

The Preferred Alternative E, which is a departure, is bad in that it continues the overcutting of the<br />

ponderosa.<br />

<strong>Response</strong><br />

Alternative E is a departure and the harvest level of ponderosa pine proposed in that alternative is not<br />

sustainable. Alternative J, the FEIS preferred alternative, is not a departure and is designed to maintain<br />

a sustained even flow of ponderosa pine sawtimber.<br />

Comment<br />

In reviewing the Forest Service Preferred Alternative, it is noted the sale of lodgepole and ponderosa<br />

pine timber types have been altered so that the anticipated revenue to Klamath County will be reduced.<br />

Your proposed reduction in the sale of ponderosa pine will reduce Klamath County's portion of the<br />

Winema National Forest receipts.<br />

<strong>Response</strong><br />

The Preferred Alternative in the DEIS was not altered in any way to reduce revenue to Klamath County.<br />

Page 111-34 gives information on the local timber supply and demand. The average ponderosa pine<br />

harvest for the period 1976-1985 was 63.5 million board feet per year. The Alternative E would sell<br />

ponderosa pine at approximately 80 million board feet per year. There were only two years during that<br />

1 0-year period that the harvest of ponderosa pine exceeded 80 million board feet.<br />

The Preferred Alternative in the FEIS, Alternative J, does lower the harvest of ponderosa pine to a<br />

sustainable 54 million board feet per year. It is projected that this will lower the projected payments to<br />

Klamath County by about 10 percent from Alternative E.<br />

The projected payments to Klamath County under Alternative J would be approximately 25 percent<br />

less than the 1989 payment to the County.<br />

Comment<br />

The monoculture forests which are planted after clearcuts are inferior to diverse forests as wildlife habitat<br />

and susceptible to disease and insect infestations.<br />

<strong>Response</strong><br />

Clearcuts that have been planted do have ecological characteristics that are different than the ecological<br />

characteristics of mature forests. They are not inferior, just different. Plantations are most beneficial to<br />

species which flourish during the earliest ecological stages while other species are dominant in high<br />

forest conditions.<br />

Comment<br />

The short term trend (since 1977) is toward reduced employment in the wood -products industry as<br />

per laborer outputs increase. The DEIS fails to display long term historic employment trends.<br />

<strong>Response</strong><br />

Pages 111-118 and 111-1 19 in the DEIS give the trends in employment.<br />

Comment<br />

The overall economy is characterized as agricultural and natural resource dependent. The SIA suggests<br />

that it tends to be 'cyclic (boom and bust).' A major proportion of current income within the county is<br />

from rent, dividends and government transfer payments. No long term data is provided regarding this<br />

K - 170

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aspect of the economy. The extent to which transfer payments might replace or supplement income<br />

from manufacturing industry is not explored. Interactions between the various aspects of the economic<br />

environment are only superficially described.<br />

<strong>Response</strong><br />

The economy is described on pgs. 111-1 15 through 111-1 21 in the DEIS.<br />

Comment<br />

Your lodgepole is hardly worth enough to be worth the accelerated cutting; and, the accelerated cutting<br />

of ponderosa, while perhaps of economic advantage to local communities now, will create a shortfall in<br />

time, especially since many experts feel that regeneration will be slower than anticipated.<br />

<strong>Response</strong><br />

The lodgepole pine value used in FORPLAN is approximately $60 per thousand board feet. The recent<br />

values have varied greatly from less than $10 per MBF to currently over $70 per MBF. At $60 per MBF,<br />

lodgepole pine is worth salvaging.<br />

Maintaining the current harvest levels of ponderosa pine is beneficial to local communities by filling the<br />

demand for ponderosa pine timber, while private lands are not filling the demand. Once cut over private<br />

lands grow back, the private lands can once again fill demand.<br />

Comment<br />

It is my hope that the Forest Service will do a complete assessment of environmental impacts of grazing<br />

and logging and will do more to protect the riparian areas along streams.<br />

<strong>Response</strong><br />

Chapter 4 describes the impacts of timber harvest and grazing on riparian areas. Detailed analysis of<br />

the impacts of timber harvest and grazing will be analyzed in timber sale environmental assessments<br />

and in the environmental assessments for grazing allotment plans.<br />

See the Forest Plan for the Forestwide Standards and Guidelines and the Standards and Guidelines<br />

for Riparian Zone for the measures that will be used to protect riparian areas along streams.<br />

Comment<br />

I suggest two programs to sustain our forests: Every logging contract contain a provision for replanting.<br />

A deposit from the sale is withheld to guarantee the replanting and evaluated in 5 to 10 years and the<br />

refund based on the new healthy, young trees.<br />

<strong>Response</strong><br />

The Forest Service collects funds for reforestation, timber stand improvement and other renewal resource<br />

enhancement from each timber sale. These funds are deposited into a coop account and the timber<br />

sale is reforested using funds from this account. Each year the fund is checked, and if excess funds<br />

have been collected, they are returned to the Treasury.<br />

Comment<br />

This diverse native Forest is a complex interacting system which has taken millions of years to evolve<br />

and we evolved within this system. Any action which harms or eliminates this system, i.e., road building,<br />

clearcutting, burning and planting monoculture trees is undermining our heritage and our ability to fall<br />

back on this system should our earth experience a catastrophic event of the magnitude that it would<br />

eliminate the artificial systems our society depends on today. The current rate of exploitation of our<br />

natural resources and the cumulative effect of pollution caused by the processing and consumption of<br />

these resources may cause a catastrophic event of this magnitude.<br />

<strong>Response</strong><br />

Our Forests are a very complex system as you state, but even areas on the Forest, which have never<br />

had a road built or timber harvested are not functioning in a natural system. Fire was effectively removed<br />

from the system in the early 1 900's, so the system has not been natural since that time. Fire did natures<br />

harvesting and site preparation for regeneration. Now this same function is performed by timber sales.<br />

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The Forest definitely looks different with timber sales doing the regeneration rather than intense fires,<br />

but the Forest is not more susceptible to harm from a catastrophic event because of this artificial<br />

regeneration system.<br />

Comment<br />

With 52% of the land in Klamath County owned by the federal government, the Winema as well as<br />

other government agencies, is obligated to maintain a high level of income from the lands to pay their<br />

share of local taxes.<br />

<strong>Response</strong><br />

The Forest Service, by law, is obligated to multiple use management. The income from the Forest is<br />

dictated by the value of the sustainable harvest which meets all resource needs.<br />

Comment<br />

We think the use of departure as a means for maintaining the economic stability of the Klamath Basin<br />

is against the intent of the concept as allowed under the National Forest Management Act of 1976.<br />

Another benefit of uneven-aged management is the maintenance of diversity in forest ecosystems.<br />

Diversity is emerging as a key concept in maintaining the long term productivity of forests. Forest<br />

ecosystems are complex entities that are not well understood at present. The tree farm concept may<br />

not work all that well on many forested sites. By maintaining a variety of age and size classes, by not<br />

disposing of all logging residue, and by using a light hand on the land, productivity in the long term<br />

may be enhanced. There are many questions yet unanswered in this regard. We believe that it is best<br />

to take a conservative approach so that we can maintain our options rather than make mistakes that<br />

may take centuries to correct.<br />

<strong>Response</strong><br />

The regulations for choosing a departure alternative are included in 36 CFR 219.16. The departure<br />

analysis is included in the Departure Analysis in Appendix B.<br />

Both even-aged and uneven-aged management system have benefits. Uneven-aged management will<br />

enhance vertical diversity within stands, but it will minimize horizontal diversity between stands, and<br />

will minimize edge.<br />

Comment<br />

Forest managers want to spray pesticides, herbicides, and fertilizers on the Forest. Only organic methods<br />

should be used that will not pollute the water system.<br />

<strong>Response</strong><br />

Forest managers want to maintain a Forest where the various renewable renewable surface resources<br />

can be to best meet the needs of the American people. Sometimes pesticides, herbicides and fertilizers<br />

are needed to meet this goal.<br />

Comment<br />

Question: What assumptions are made on future value of pines and firs, i? large and small DBH? If<br />

the assumption is made that future values of larger DBH trees in both types (pine and fir) would be<br />

higher, would this extend the rotation lengths? My observation here is that rotation lengths are shorter<br />

now than in the previous Forest Plan, and I am not convinced that it increases PNW enough to offset<br />

loss of long term sustained yield level.<br />

<strong>Response</strong><br />

A real price inflator of 1% per year compounded for 50 years was used. The relative price between<br />

small and large material did not change but the absolute difference between the small and large material<br />

increased for the 50 years.<br />

The rotation length is determined by the culmination of mean annual increment. The economic rotations<br />

are much shorter but, by law, the rotation length used for Forest Service planning can't be shorter<br />

than the culmination of mean annual increment.<br />

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Economic rotations are much shorter than the culmination of mean annual increment, so changing the<br />

real price inflator of the larger diameters would not change the rotation length.<br />

Comment<br />

Question: Will future timber sales be sold in cubic feet?<br />

Will district target volumes be measured in cubic feet?<br />

If not, I am concerned that what we say can be grown in cubic feet of wood does not get translated<br />

into an accurate estimate of what volume is scaled in board feet. In other words, what might take 10<br />

acres to produce mx volume in cubic feet, might actually take 12 acres to produce the theoretical equivalent<br />

in board feet.<br />

Also, if Forest land grows Oxm amount of cubic feet of wood, and some of it is used for firewood or poles,<br />

does this get counted in the bottom line allowable sale quantity?<br />

<strong>Response</strong><br />

Future timber sales will be sold in cubic measure and the Washington Office is currently developing<br />

the regulations to implement cubic measure sales. We don't know in which year this change will be<br />

made.<br />

District targets will be given in cubic measure when all sales are sold in cubic measure.<br />

The Forest Plan will be monitored in cubic measure not board feet. Cubic measure is a standard cruise<br />

output for reporting purposes. Yearly targets given to Ranger Districts in board feet will simply vary<br />

from year to year, so the planned cubic foot ASQ is achieved.<br />

Comment<br />

DEIS, Table 11-3A - Timber yield categories 50-99% = 166.1 M acres for Alternative E.<br />

Question: What volume is assumed? Midpoint? or 99%? Or does it depend on resource allocation? If<br />

so, what is the estimate for each resource where yield is less than 100% of potential?<br />

<strong>Response</strong><br />

The timber yield categories displayed in Table 11-3A were calculated in the following manner.<br />

a) Full yield are all lands allocated to management Area 12A and 12B.<br />

b) The 50-99% of full yield category are all lands with a programmed harvest except<br />

management Area 12A, 12B.<br />

c) The 1-49% of full yield category are lands with a programmed harvest allocated to<br />

management Area 14.<br />

The actual volume depends on the resource allocation. Table 2-10 in the FEIS shows the timber<br />

management intensity chosen for all lands with a programmed harvest.<br />

Table 4 in Managed Yield Tables for Land and Resource Management Planning on the winema National<br />

Forest Volume 1 summarizes the yields for all the management intensities for all the management<br />

areas. This is too large to repeat here, but as an example Management Area 3 yields approximately<br />

25% less than Management Area 12.<br />

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Comment<br />

DEIS, 11-84, Table 3A - Allowable sale quantity for diameters 6' - 8.9' = 0 MMCF.<br />

Question: Why? If commercial thin programmed = 5.2 M acres, and volume in board feet for 8' (midpoint<br />

in range = r - 8.9") (Nettleton's Rule of Thumb: radius (3.5') squared x 5 (short tree) = 61 board<br />

feet).<br />

y=300-x<br />

Ave.<br />

stand DBH=12"/<br />

///I ///<br />

// 1/1/// I ////<br />

/ / 1////12 I //<br />

8"t 10" 12", 141" 16",<br />

In HTH from below, trees to be removed < 12".<br />

If total = 300 TPA, and we leave 150 TPA, 150 TPA are cut.<br />

If only 10% of trees are 7" - 8.9' and total = 15 TPA - 1st HTH,<br />

15 TPA X 5,200 AC = 78,000 trees<br />

78,000 trees X 61 bd ft tree = 4.76 MMBF = NO CREDIT!!<br />

Why are merchantability specs for HTH i 7' DBH, 4' top (Forest Standards and Guides) and no credit<br />

is received for this on Table 11-3A (Pg. 11-84 DEIS)?<br />

Why is there a difference between harvesting an 8' tree in a thin vs. an 8' tree in a clearcut? Why say,<br />

on one hand, that it is merchantable, and on the other hand, that it is not?<br />

There are a number of reasons why this Plan should call for a consistent ation standard of 7' DBH and<br />

get credit for this in the allowable sale quantity:<br />

a. Wise use of resources calls for increased ation of wood, not the opposite.<br />

b. Not getting credit for this size material means more trees have to be cut to reach the same<br />

allowable cut.<br />

c. Efficient mills that have invested in modern equipment to handle small logs are penalized,<br />

and other mills are favored.<br />

d. Forest Service should be the leader in the trend to use resources (wood) efficiently, rather<br />

than let several large companies tell us what they want to standard to be.<br />

e. Appendix D-1 6, 24. "Timber harvest ation standards...7' DBH to a 4' top... for lodgepole and<br />

all commercial thinning..."<br />

If it's to be cut, why no credit?<br />

f. For more than a decade, stands and pine plantations have been managed with an assumption<br />

that its first commercial entry is at 8'.<br />

If that first entry timing is changed and no yield is credited below 9',what do we do with all the<br />

wood in these stands?<br />

Does this force the district to conduct a second precommercial thin in the pine plantations?<br />

<strong>Response</strong><br />

The portion of Table I11-A on the DEIS, page 11-84, refers to the average stand diameter of harvested<br />

stands; it does not give the diameter of all material harvested. This is clarified in the FEIS. (Table 2-5)<br />

The merchantability standards for the allowable sale quantity are given in Table 3-6 in the Regional<br />

Guide for the Pacific Northwest Region. Material harvested during the plan period not meeting the<br />

merchantability standards will not be chargeable against the allowable sale quantity. Now, this does<br />

K - 174

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not mean the Forest will discourage ation of material not meeting merchantability standards, it only<br />

means that sub-merchantable material is not charged against the ASQ. In this way, everyone knows<br />

how much saw timber will be marketed. The Forest Plan proposes to harvest 15.3 mmcf of material not<br />

meeting the regional merchantability specifications. This material includes all dead trees, cull logs, and<br />

other small material such as posts and rails.<br />

Overstocked pole sized stands will still be thinned and in most cases, the small logs will be milled into<br />

lumber. The Regional plan specified normal sawlog merchantability standards, but some locations will<br />

have established small logs mills that can manufacture lumber from small logs.<br />

Comment<br />

Keeping ponderosa pine harvest at historic levels is one thing; increasing it almost 20% is a significant<br />

change, which may not be desirable at this time, for the following reasons:<br />

a. This may divert focus from need to deal with lodgepole and increase logistical problems.<br />

b. Table 11-3E, Pg. 11-127, shows that this departure would go against the basic objectives of the<br />

Forestry Program for Oregon.<br />

If we don't have to cut more PP, then why choose to, when future options then become more<br />

limited? (Also, see Pg. 111-139, Timber Supply Projection.) Would this not be a short-sighted move,<br />

set us up for problems two to three decades out, and cause a disruption in the long term stability<br />

of this community?<br />

Also, in the January 1, 1988, edition of the Herald and News, an industry representative said, *Our<br />

interest is in maintaining historic cutting levels of ponderosa pine, not necessarily increasing them:<br />

I see no logic to support this increased harvest level, and believe it should be adjusted in the final<br />

plan.<br />

<strong>Response</strong><br />

After a great deal of concideration, it seems that we agree. The Forest Plan is not a departure and is<br />

designed to maintain a sustainable level of ponderosa pine harvest.<br />

Comment<br />

Appendix D-15 - 11. '... goal of satisfactory stocking within 3 years." Does this refer to planted stock or<br />

natural regeneration? Is this sentence clear?<br />

<strong>Response</strong><br />

Yes, our goal is to have natural regeneration within three years of site preparation, but we are fully<br />

aware that in some cases it may take ten years or longer. At the end of three years, a stocking survey<br />

will tell us if the reforestation is proceeding satisfactorily, and if it isn't, a new prescription will be written<br />

and implemented to correct the problem.<br />

Comment<br />

We can sustain and increase our ponderosa pine at above 90 million.<br />

<strong>Response</strong><br />

Our analysis shows that after meeting management requirements, but with little land allocated to maintain<br />

visual quality objectives, we could maintain a harvest level of ponderosa pine of about 80 MMBF.<br />

Comment<br />

Because much of the timber will be diseased and should be removed and new trees planted.<br />

<strong>Response</strong><br />

The Winema National Forest is generally healthy, except for the overstocked, overmature lodgepole<br />

pine, and the root rot problems in the mixed conifer. The ponderosa pine is quite healthy and there is<br />

no insect or disease reason to accelerate the harvest of ponderosa pine.<br />

K - 175

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Comment<br />

People need affordable housing. The price of timber is already higher than it ever has been. If the<br />

proposed reductions in harvest go through, housing costs will go even higher and the average person<br />

cannot afford a new house now.<br />

<strong>Response</strong><br />

The price of housing will continue to increase but the cost of lumber in a home has little to do with its<br />

selling price. A $70,000 home in Klamath Falls that sells for $200,000 in central California, has the<br />

same lumber cost.<br />

Comment<br />

Years ago the Forest Service planned for a sustained yield harvest. But they have had to cut back.<br />

Because so much is being locked up each year--where will it stop?<br />

<strong>Response</strong><br />

The general public is becoming more and more interested in non-consumptive uses of the National<br />

Forests. The lands available for timber harvest will continue to decrease until the demand for recreation<br />

lands and the demand for timber production come into equilibrium.<br />

Comment<br />

The Forest is already over cut. There is not sufficient old growth there now. How can you keep over<br />

cutting and expect to have any forest for future generations?<br />

<strong>Response</strong><br />

In 1981, 86% of the Winema National Forest was covered with mature stands or two-storied stands<br />

with a mature overstory. (See Table 11-6 in the DEIS). By 1988 that percentage of mature stands of<br />

timber had dropped to 66%. This amount of mature timber is more than adequate to meet old growth<br />

needs.<br />

The Forest will continue to get younger as older stands are harvested, but the Forest will continue to<br />

be there for future generations. Alternative J, the preferred alternative, maintains approximately 10<br />

percent of the tentatively suitable forest lands as oldgrowth.<br />

Comment<br />

Historic data supports this as a sustainable level of harvest.<br />

<strong>Response</strong><br />

Our analysis shows that after meeting management requirements, but with little land allocated to maintain<br />

visual quality objectives, we could maintain a harvest level of ponderosa pine of about 80 MMBF.<br />

Comment<br />

It should be part of the plan to use the most advanced techniques available to reforest our lands as<br />

quickly as possible.<br />

<strong>Response</strong><br />

We will continue to aggressively reforest non-stocked suitable forest land.<br />

Comment<br />

Soil compactibility, soil nutrient depletions are causing projected yields to be way too short-sighted.<br />

The question is, what percentage of today's national forests will be around, and at what level, in 300<br />

years?<br />

<strong>Response</strong><br />

In 300 years, our forests will be in a fully regulated condition. Trees will be much younger, but production<br />

will be higher than today.<br />

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Comment<br />

I'm not a Forester, nor an expert, but I can stand on any high ground in Southern Oregon and tell you<br />

that we are over harvesting.<br />

<strong>Response</strong><br />

A very high percentage of the Winema National Forest is forested with mature and two-storied stands.<br />

A fully regulated forest would have about 25% of the area in young plantations, 25% in pole size stands,<br />

25% in small sawlog sized stands, and 25% of stands at or near maturity. The Winema is far from reaching<br />

this point of harvesting.<br />

Comment<br />

I want to express my concern about your proposed 10-year Forest Plan for the Winema Forest. I oppose<br />

it because of the effect it will have on jobs which will be lost and problems the community will suffer<br />

when revenue receipts are reduced.<br />

<strong>Response</strong><br />

Table 3-8 shows the historic harvest levels on the Winema N.F. The planned allowable sale quantity in<br />

the Forest Plan is substantially lower than the harvest level of the last ten years. The economic tables<br />

in Chapter 2 show our projected impacts of this level of harvest.<br />

Comment<br />

Consider the intensification of cultural treatments to increase growth on land dedicated to commercial<br />

forest management, including even-aged management and clearcutting of stands that no longer lend<br />

themselves to all-aged management.<br />

<strong>Response</strong><br />

The primary reason for using uneven-aged management is to maintain a high forest cover, which is<br />

more visually acceptable to the general public. We will only clearcut stands in the uneven-aged<br />

management areas to control insect or disease problems, not to increase yields.<br />

Comment<br />

The lodgepole pine was formerly only a very minor component of the allowable harvest and should not<br />

be allowed to confuse the issues relating to the traditional species composition of the allowable cut.<br />

<strong>Response</strong><br />

Previous timber resource plans were not developed to maintain an even flow of all species. All species,<br />

including lodgepole pine, were used to calculate the previous allowable sale quantity, and we will need<br />

to do that again.<br />

Comment<br />

Treat the conversion of the bug infested lodgepole pine as an issue entirely separate from the allowable<br />

harvest over the near term.<br />

<strong>Response</strong><br />

The National Forest Management Act does not allow for us to keep live green lodgepole pine as an<br />

entirely separate issue. The allowable sale quantity must be calculated using the entire land base<br />

suitable for timber management.<br />

In an attempt to clarify this issue, the dead lodgepole pine was removed from the yields tables so it is<br />

no longer part of the ASQ.<br />

Comment<br />

The Forest Service is selling out the last of our old growth ecosystems, the Forest Service is taking the<br />

Forest from the mountains instead of some trees from the Forest!I<br />

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<strong>Response</strong><br />

The Winema National Forest is not selling out the last of the old growth ecosystems on the Forest.<br />

Approximately 10% of the forest is wilderness areas, which will never be harvested. There is also over<br />

100,000 acres of the forest allocated to old growth, research natural areas, semiprimitive recreation<br />

areas and unique areas which will not be harvested. Only 720,000 acres out of 1,046,000 acres have a<br />

programmed timber harvest.<br />

Comment<br />

Also, the Forest Service wanting to use herbicides is so absurd and dangerous! The only thing it's<br />

good for is the chemical companies' pocket books!<br />

<strong>Response</strong><br />

The Winema National Forest uses very few herbicides. There is no record of a large herbicide treatment<br />

on the Forest. We may use herbicides in the future, but only when it is the only way to accomplish<br />

management objectives.<br />

Comment<br />

My 40 years experience as a Forester, tells me that 90 MM of ponderosa pine can be produced with<br />

imagination, innovation, and hard work.<br />

<strong>Response</strong><br />

Our analysis shows we could maintain about 80 MBF per year if we implemented a maximum timber<br />

alternative.<br />

Comment<br />

Also, the streams in the Forest are practically all gone because of no trees for water storage. Also the<br />

trees that have been logged have fallen in the streams. They should be cleared away and logging<br />

should not be allowed on the banks of the streams.<br />

<strong>Response</strong><br />

Forest hydrology research have shown that stands of trees use much more water than brush and<br />

grass. The Winema National Forest does have streams and springs that do not flow water during the<br />

summer as they use to, but that is because the Forest has much denser tree cover now than it ever<br />

did in the past. Even so, we are not planning to harvest areas to increase water flow.<br />

The standards and guidelines for the Forest Plan spell out the procedure we will use to protect riparian<br />

zones. There is no planned harvest within 100 feet of class I and 11 steams or within 50 feet of class IlIl<br />

streams.<br />

Comment<br />

As mentioned earlier, much of the Winema, at one time, supported ponderosa pine stands; but, are<br />

now overrun with lodgepole pine. Many ponderosa areas, when cut, are planted to lodgepole pine. I<br />

feel this is a short term insight. Sure, lodgepole is easier to plant seedlings; but, the Forest Service<br />

realizes little or no revenue from lodgepole, which is vulnerable to pine beetles in extreme dry seasons.<br />

<strong>Response</strong><br />

The Winema is still primarily forested with ponderosa pine. We generally plant ponderosa pine in all<br />

plantation, except for the lodgepole pine areas, which are planted to lodgepole pine.<br />

A few years ago, we did clearcut some ponderosa pine stands in areas that became too cold to support<br />

ponderosa pine seedlings. The areas were replanted to lodgepole pine. This kind of problem will not<br />

happen in the future, because the uneven-aged stands will provide adequate protection to the site so<br />

they won't get too cold for ponderosa pine.<br />

K- 178

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Comment<br />

It is also my belief, more timber should be sold as Small Business Set-Asides because small mills cannot<br />

operate at a loss for very long, whereas large multi-national companies can. Then, when the small mill<br />

goes broke, the big one comes in and buys it for a song and sing it themselves. I also do not approve<br />

of buyouts for those who overbid timber in the early 1980's nor do I think a period of 3-5 years should<br />

pass between timber sale contract award and actual logging of said sale. Timber sold should require<br />

harvest within 18 months. Some of the major mills have been able to accumulate a 5-year backlog of<br />

timber sales.<br />

<strong>Response</strong><br />

The Small Business Administration Set-Aside Program is an agreement between SBA and the Forest<br />

Service to maintain historic sell levels to small business. Every five years, the structure of the local<br />

timber industry is analyzed to see if the SBA share of the timber sell should be changed. An increase<br />

in the SBA Set-Aside Program would only happen if more of the local mills became small business.<br />

The buyout program was a law passed by Congress to minimize the impact on timber industry of the<br />

economic recession of the early 1980's. We do not anticipate this program happening again, but it<br />

could if Congress so wishes.<br />

The length of timber sales have been shortened. Sales that used to have a 3-5 year time for logging<br />

now have a 2-3 year time for logging. Buyers also must make down-payments and mid-point payments<br />

along with stumpage payments. These factors all have timber industry complaining that they can't<br />

build an inventory of stumpage under contract. Buyers are also only given one (1) year extension if<br />

they qualify. To qualify the buyer must have removed 75% of the stumpage and have completed all<br />

contractual requirements on the areas harvested.<br />

Timber industry does not have the lee-way to get large amounts of stumpage under contract as they<br />

did in the early 1980's.<br />

Comment<br />

The Bill of Rights says any American citizen is entitled to 200 posts and 20 tiers of wood per year.<br />

<strong>Response</strong><br />

The Bill of Rights is Amendments 1-10 of the Constitution of the United States. No reference was found<br />

to posts or wood in the Bill of Rights.<br />

Comment<br />

Additionally, the Forest Service's assumption of a 100% cut of the ASO is unrealistic and will skew the<br />

data. Historically, the actual cut has been below the ASO, with the cut amount below the ASQ varying<br />

over time and national forest. Various economic and market conditions have prevented a harvest of<br />

100% of the ASQ. Another point of contention is at the bottom of page 111-35 of the D.E.I.S. where the<br />

Plan states that harvest levels are now declining, after being at their highest levels in the early 1970's.<br />

The table cited in support of this statement does not show data from the early table cited in the early<br />

1970's, so the reader has no way of verifying this statement. The data in the table starts with the year<br />

1977. There is no steady decreasing pattern evident in this table, but rather a pattern of high harvest<br />

levels in the late 1970's followed by declines through the recession of 1982, and thereafter, typified by<br />

increasing harvest amounts through the mid-1 980's to levels that, in some cases, are higher than any<br />

previous historical harvest levels. When looking at the national forest data, 1984 and 1985 are the<br />

highest harvest level years on record for the data in this table. They both surpass the previous historical<br />

peak, which was in 1978. In addition, after the recession induced low harvest level in 1982, there have<br />

been dramatic increases in harvest levels. This information needs to be explained in greater detail and<br />

in a much clearer format to allow a clear understanding by readers.<br />

<strong>Response</strong><br />

The Winema National Forest Timber Resource Plan had a programmed harvest of 155.7 MBF per year.<br />

The actual sell during that period was 150.3MMBF per year, which is not significantly different. Now,<br />

during that same time the potential yield was 199.2 MMBF, but it was never planned to sell at that<br />

level. Once the ASO is established, the Agency does plan to sell at that level, so I expect it will happen.<br />

K- 179

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The citation at the bottom of page 111-35 of the DEIS is Figure 111-8, not Table 111-8. Figure 111-8 shows the<br />

long term trend of timber harvest in Klamath County.<br />

Comment<br />

Historic timber sale levels cannot be maintained/drastic reductions are necessary to maintain the Forest<br />

as a forest community. Even 130 MMBF is probably not sustainable.<br />

<strong>Response</strong><br />

Table 111-8 in the DEIS shows the historic harvest levels. The historic harvest for the period from 1976<br />

to 1985 was 118.6 MMBF. (Annual growth was the same.): The Forest will continue to change from an<br />

old growth forest to a much younger managed forest. The Forest has the potential to maintain a much<br />

higher sustained harvest, depending on the timber management intensity and the number of acres<br />

available for timber harvest.<br />

Comment<br />

If it takes 100 years to grow a Douglas-Fir that can be harvested, why are Forest plans thought out in<br />

1 0-year forecasts?<br />

<strong>Response</strong><br />

Ten-year planning periods are used so the Forest Service can be responsive to changing issues and<br />

societies demands. The environmental consequences section of the FEIS present consequences over<br />

a 150 year planning horizon.<br />

Comment<br />

Because there seems to have been no problem with this amount up to now.<br />

<strong>Response</strong><br />

Many people have not been comfortable with the past level of harvest. Alternative J is a compromise<br />

between competing interests and that alternative only produces 54 MMBF per year of ponderosa pine<br />

which is well below the current harvest level.<br />

Comment<br />

I support MULTIPLE USE of National Forests. I do not support the creation of more wilderness; indeed,<br />

I do not support the retention of all of the wilderness which has already been designated. Virtually<br />

nobody uses it, the Forest Service cannot properly care for it (such as by taking firefighting equipment<br />

into it), and it serves little or no purpose for research which cannot be met in a multiple use Forest.<br />

<strong>Response</strong><br />

The Wilderness Areas were designated by Congress and can only be changed by legislative action.<br />

Wilderness is one aspect of multiple use of the Forest. Research is allowed in wilderness under controlled<br />

situations.<br />

Firefighting equipment is allowed in wilderness areas depending on the situations on the fire and the<br />

threat to resources.<br />

We do manage wilderness based on individual wilderness management plans, which allows a number<br />

of activities including grazing, disperse recreation and limited research.<br />

Comment<br />

However, using more Forest land and cutting open more ground to supply overseas markets (in essence,<br />

trading Toyotas and Toshibas, for old-growth and minerals) is a farce.<br />

<strong>Response</strong><br />

National Forest timber west of the 100th Meridian in the contiguous 48 states cannot be exported<br />

unless specifically exempt. No unprocessed logs from the Winema are exported.<br />

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Comment<br />

The Winema National Forest Draft Plan and DEIS address the maintenance of natural diversity in a<br />

number of places under a variety of topics. Unfortunately there is no general discussion of diversity in<br />

the documents that attempts to show how these topics all relate to this issue and how the Forest Plan<br />

will maintain diversity. It would be beneficial to have one place in the final EIS that integrates all of the<br />

various aspects diversity to show how the Forest is responding to the issue. The topics that relate to<br />

diversity that should be involved in such a synthesis include vegetation and wildlife diversity, protected<br />

areas (RNA's, Special Interest Areas, Wilderness Areas), rare and sensitive species, roadless areas,<br />

and riparian zone management.<br />

<strong>Response</strong><br />

The FEIS has been restructured to have a writeup on diversity under vegetation and wildlife.<br />

Comment<br />

However, the analysis does not indicate how different forest tree species groups (Ponderosa pine,<br />

pine associated, true fir, lodgepole) will respond to the effects of the alternatives. This is important<br />

from a diversity standpoint as the preferred alternative, for instance, will cut 46% of the lodgepole stands<br />

on the Forest in the first decade of the Plan, thus resulting in a dramatic change in stand age class for<br />

this species alone.<br />

s<br />

<strong>Response</strong><br />

The FEIS preferred Alternative J does not concentrate regeneration harvest in the lodgepole pine working<br />

group as did the DEIS preferred alternative. The Forest Plan will only be salvaging dead lodgepole so<br />

nature diversity will not be affected.<br />

Comment<br />

Another problem with the analysis of the effects of the alternatives on vegetation diversity is that there<br />

is no portrayal of what the natural forest age class composition would be without the effects of fire<br />

suppression or timber harvest. Since the goal of maintenance of natural diversity is to provide a<br />

representation of age classes in each tree species group across the Forest that is somewhat proportional<br />

to the natural composition then for comparison purposes it is necessary to show the natural composition.<br />

The very high levels of the 0-20 year age class and the very low levels of the 110-150 year age class<br />

that are evident in most alternatives (p. IV-12) are probably significant deviations from natural conditions<br />

and will have effects on the overall diversity of the Forest.<br />

<strong>Response</strong><br />

The amount of mature trees on the forest will definitely be less in all the alternatives that allow for timber<br />

harvest. The forest would have approximately 25 percent of the lands available for timber harvest in<br />

timber stands less than 25 years old. This is quite different than what the forest was like in 1900. At<br />

that time, old photos and surveyor notes time a story of very open mature stands of trees with little to<br />

no understory trees or other vegetation.<br />

Comment<br />

Riparian habitats are recognized as being critical links in the ecosystems on the Winema and out of<br />

the 50,000 acres of riparian zone vegetation 16,0000 acres are included in Management Area 8--Riparian<br />

Management. Unfortunately 93% of these 16,0000 acres are deemed suitable for timber harvest at<br />

some level (Plan, p. IV-63) thus the riparian systems on the Forest are not truly protected. As stated in<br />

the response to public issues section of the Forest Plan (p. 111-7), the 16,0000 acres will protect 32% of<br />

the riparian zones on the Forest, however, in reality only slightly more than 1000 acres will be completely<br />

protected from disturbance.<br />

<strong>Response</strong><br />

The FEIS Preferred Alternative J placed many more- acres into the riparian management area. 57,937<br />

acres were allocated to riparian management. Also the standards and guidelines in the Forest Plan<br />

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were changed to remove logging within 100 feet of class I and 11 stream and within 50 feet of class IlIl<br />

streams. This will protect riparian zones.<br />

Comment<br />

The Forest can sustain this amount. Our growth plots indicate a 3.5% simple growth rate.<br />

<strong>Response</strong><br />

The ponderosa net scribner board feet (for a 9 inch dbh to a 6 inch top) growth rate for the Winema<br />

National Forest is 1.4% simple growth rate, which equates to 58.5 MMBF per year.<br />

Comment<br />

If the alternative E plus plan is not approved and the allowable cut is reduced, I believe additional<br />

measures are required. In order to assure local mills a sustained timber supply, a study must be made<br />

of their requirements and then mills from out of the area would be allowed to bid only on the material<br />

above local requirements.<br />

<strong>Response</strong><br />

The regulations that allow the Forest Service to sell timber does not allow restricting bidding to a<br />

geographic area.<br />

Comment<br />

Historical data regarding the former Klamath Indian Tribe lands, private lands and other National Forests,<br />

indicate that with proper management techniques the Winema will continue to be able to produce this<br />

footage as a renewable level. Apparent errors in the original Forest Service harvest model.<br />

<strong>Response</strong><br />

Table 3-8 shows the historic harvest for the last ten years. Our analysis indicates that this level of harvest<br />

cannot be sustained.<br />

Comment<br />

90 million board feet has been an historically attainable harvest level.<br />

<strong>Response</strong><br />

Table 3-8 shows the historic harvest for the last 10 years. The historic ponderosa pine harvest is 80.0<br />

MMBF per year.<br />

Comment<br />

Forest Service should be doing much more tree planting. They have fallen behind this project.<br />

<strong>Response</strong><br />

The Winema is current with needed reforestation. Reforestation units that have failed are currently<br />

being replanted.<br />

Comment<br />

Why are these letters only given to employees of the timber industries.<br />

<strong>Response</strong><br />

The questionnaire you received was developed by a local timber industry group to solicit input to the<br />

Winema's Draft Environmental Impact Statement. The letter was passed out at each meeting they<br />

conducted which included folks from all walks of life. The Audubon Society made a similar effort.<br />

Comment<br />

Count on a resurgence of the 1981-1985 recession in South Central Oregon if the proposed Winema<br />

Preferred Alternative Plan for timber supply is implemented.<br />

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The proposed program you advocate is based on a 'departure' from non-declining yield that calculates<br />

out to a drop of 127 million board feet per year by the fifth decade. That's 36% below the present<br />

allowable program and 19% less than the average volume actually sold between 1977 and 1986.<br />

<strong>Response</strong><br />

What you state is correct in the DEIS. The allowable sale quantity would drop to 127 MMBF by the fifth<br />

decade. It is assumed that other ownerships would make up he difference.<br />

There was no support for the departure presented in the DEIS. So the preferred Alternative J in the<br />

FEIS dropped the ASQ to a sustainable 117 mmbf level. This level will have impact on the local timber<br />

industry and probably a sawmill will close before a balance is reached between supply and demand<br />

for sawlogs.<br />

Comment<br />

Perhaps that recession was unavoidable. However, the pending economic disaster, based on the<br />

proposed reduction in the federal timber supply from the Winema, is entirely within your agency's<br />

power to prevent. Simply maintain the allowable cut at 199 million board feet annually, including at<br />

least 90 million board feet of Ponderosa pine each year.<br />

<strong>Response</strong><br />

Maintaining the level of harvest you propose would require a departure from sustained even flow of<br />

sawtimber. There was a great deal of objection to that alternative so Alternative J, the preferred alternative<br />

in the FEIS, is not a departure. Alternative J will only produce about 54 mmbf of ponderosa pine and<br />

117 mmbf of total sawtimber harvest.<br />

Comment<br />

To the extent that the Forest Service will seriously consider valid comments on all issues, an acceptable<br />

harvest level in the final plan can be developed with additional computer runs after the comment period<br />

expires.<br />

<strong>Response</strong><br />

We believe the Forest Service has seriously considered all comments; as evidenced by changes to the<br />

document and preferred alternative. Specifically, additional computer runs were made based on the<br />

comments.<br />

Comment<br />

There is every indication at this time that the Winema staff is open to incorporating technical adjustments<br />

into the final plan. These should include a correction to the acreage of tentatively suitable forest land<br />

which was understated by some 24,000 acres. Increased Ponderosa pine yields should also be included<br />

for uneven aged managed stands which were too conservative when compared with other data similar<br />

to those displayed in the attached Exhibit which shows growth and yield data from Indian forests.<br />

<strong>Response</strong><br />

Yes, these corrections were made. The land base maps were corrected and the acres of tentatively<br />

suitable lands changed from 793,100 acres to 825,394. The uneven-aged management yield tables<br />

were all redone using the SORNEC version of the PROGNOSIS growth and yields model.<br />

Comment<br />

There are some grave inconsistencies within the Forest Service data also. For instance, for one large<br />

component of the Forest, growth is stated to be 18.2 cubic feet per acre while the Forest Service inventory<br />

indicates the measured growth for the same component is 33.4 cubic feet.<br />

<strong>Response</strong><br />

The difference in the growth rates between the empirical yield tables and the gross growth rate of<br />

inventoried stands come from many areas. The empirical yields are net with all cull, breakage and<br />

mortality subtracted where as the inventory growth rate is simply the measured growth rate of live<br />

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trees on an acre with no reductions. The empirical yields estimate the growth of usable volume on<br />

each acre.<br />

Comment<br />

There is also some evidence that the use of improper cost data and the maximization of net present<br />

value may result in the establishment of lower yields than necessary. These factors should be examined<br />

more carefully by the Forest Service.<br />

<strong>Response</strong><br />

A Stage II analysis was made on all the prescriptions use in the FORPLAN model. A brief summary of<br />

that analysis is included in Appendix B and the full analysis is available for review at the Winema Forest<br />

Supervisor's. Office in Klamath Falls.<br />

Comment<br />

It is reasonable and prudent to expect most elements of a timber stand to produce at a rate of at least<br />

2% of inventory. Experience on Klamath Indian Management Trust lands indicated growth rates<br />

substantially in excess of 2% as evidenced by attached pages.<br />

<strong>Response</strong><br />

The current mortality of trees caused by the mountain pine beetle and other factors is keeping the<br />

current net growth rate down to 1.1 percent. The net rate of growth is up to 2.4 percent by the second<br />

decade and to almost 3.0 percent within 50 years. This rate of growth seems reasonable for the Winema.<br />

Comment<br />

It seems the greatest problem stems from the gypsy moth infestation. I recall that the British started to<br />

have the same problem, however, they corrected it by spraying the forests with a chemical that was<br />

harmless to humans and animals. This chemical disrupted the mating cycle of the gypsy moth and<br />

ended the problem once and for all. Has this method been considered?<br />

<strong>Response</strong><br />

At this time, we do not have a problem with gypsy moth infestations. Our main problems deal with<br />

mountain pine beetle infestations and localized root rot infestations. There has been some developments<br />

to help disrupt mountain pine beetle populations but these developments are only practical on small<br />

areas such as campgrounds were very high value trees are in a small area<br />

Comment<br />

We strongly disagree with the departure proposed for the timber management plan. How can so many<br />

of the Ponderosa pine regions National Forests justify increasing the lodgepole cut all at once? What<br />

will this do to the market and stumpage prices? Do not depart from sustained yield on the lodgepole<br />

component.<br />

<strong>Response</strong><br />

Many Forests in the ponderosa pine region are increasing their harvest of lodgepole pine. Mountain<br />

pine beetle has been causing heavy mortality to the overstocked mature lodgepole pine Forests. All<br />

the Forests are trying to harvest the lodgepole pine before it loses all its value.<br />

We agree that selling the high volume of lodgepole pine will suppress market value however, we have<br />

other management objectives other than economic which we are trying to achieve. Which include<br />

needs for reducing fire hazards (which would prevent catastrophic fires and protect watershed values),<br />

maintenance of wildlife habitat and reforestation needs.<br />

Alternative J, the preferred alternative in the FEIS, removed all the dead lodgepole pine from the ASQ<br />

calculation. The programmed harvest plans to harvest about 40 mmbf of dead lodgepole pine each<br />

year until all the excess dead trees are removed.<br />

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Comment<br />

The proposed action's change of predominate harvest method of selective cutting to clearcutting will<br />

have a long term negative impact upon scenery, soils, run-off/watershed values and wildlife habitat.<br />

Use a more sensible mix of cutting methods. The long term management of the Forest should not<br />

promote a monoculture. e more uneven age management techniques.<br />

<strong>Response</strong><br />

The application of uneven-aged management has been expanded in the EIS to be applied to the<br />

Ponderosa pine, pine-associated and in some cases, mixed conifer working groups. Refer to Chapter<br />

2 for the range of uneven-aged management among the alternatives. However, even-aged management<br />

will continue to be the dominant silvicultural system used for lodgepole pine and mixed conifer stands<br />

on the Winema.<br />

Comment<br />

Firstly, we understand the Forest Service has, in this instance proposed abandonment of its sustained<br />

yield' and proposes to permit the cutting of at least 34% of suitable timber over the next 10 years.<br />

<strong>Response</strong><br />

The preferred alternative in the DEIS did harvest 31 percent of the inventoried volume in the first decade.<br />

The preferred alternative in the FEIS is no longer a departure from sustained even flow. AlternativeJ,<br />

the new preferred alternative, harvests about 19 percent of the standing volume in the first decade.<br />

Comment<br />

In comparing the Plan's Preferred Alternate (Alt. E) with some of the other Alternatives, one is struck<br />

by the priority given in the, Preferred Alternative to the production of resource outputs. For example,<br />

Alt. E will result in the conversion of 45% of the Forest from a natural appearing to an obviously modified<br />

environment in 10 years (DEIS Table 11-3B):. In contrast, with Alternative G only 5% of the Forest will be<br />

converted. And yet both alternatives will meet the Forest's share of total county-wide harvest, and<br />

produce only a 5% difference in county-wide employment.<br />

<strong>Response</strong><br />

The major difference between Alternative E and G is the amount of uneven-aged management prescribed.<br />

Alternative G is quite similar to the new Alterraive J except Alternative J prescribes somewhat less<br />

uneven-aged management in the mixed conifer and pine associated working groups. The impact on<br />

the forest appearance will be much less with the new preferred alternative J than with Alternative E.<br />

Comment<br />

I spend a lot of time in the mountains and I see an awful lot that is clearcut but not replanted.<br />

<strong>Response</strong><br />

Reforestation areas are all currently stocked on the Winema or If the first attempt failed, they are being<br />

replanted.<br />

Comment<br />

The present Forest Plan allows for the following:<br />

PP - 75m bd. ft.<br />

TF - 53m bd. ft.<br />

DF - 15m bd. ft.<br />

LP - r1m bd. ft.<br />

TOTAL - 154m bd. ft.<br />

These ASQ volumes per species should be considered a minimum management requirement for the<br />

Forest, providing these harvest levels are a sustained yield and do not negatively impact the environment.<br />

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<strong>Response</strong><br />

The present Timber Resource Plan did not specify yields by species. Page IX of the Timber Resource<br />

Implementation Plan specified the planned yield by working group. The values you presented are from<br />

Alternative A which projects the yields for the Forest if the land allocations are not changed from the<br />

current situation.<br />

Previous timber planning was not done to maintain a sustained even flow by species. To do so, causes<br />

substantial reductions in total allowable harvest.<br />

The preferred Alternative J sustains the ponderosa pine at its highest possible sustained even flow.<br />

Comment<br />

Much of what I've read concerning the Draft Plan suggests that a recession period could be imposed<br />

on Klamath County by reducing allowed yields of timber from the Winema. It seems to be implied that<br />

the currently proposed plans substitute damaged lodgepole pine yields for ponderosa pine yields<br />

which have been the mainstay of the local logging industry.<br />

<strong>Response</strong><br />

Table 3-8 shows the harvest levels for the past 10 years. The planned sell in Alternative J is considerably<br />

below the historic harvest level. The new plan proposes to maintain the ponderosa pine sell at the<br />

maximum sustainable level, given other constraints.<br />

The economic impact analysis presented in Chapters 2 and 4 suggest that the economic impact will<br />

not be as severe as some people suggest.<br />

Comment<br />

I believe that growth under even-aged or uneven-aged management will, on the same acre, be nearly<br />

the same.<br />

<strong>Response</strong><br />

Our analysis, using the PROGNOSIS model, indicates you are correct. Other folks though feel just as<br />

strongly that uneven-aged management will produce less than even-aged stands. The Forest will establish<br />

several growth and yield plots in uneven-age managed stands to determine the actual growth.<br />

Comment<br />

Timber salvage programs, not just for lodgepole pine, need to be pursued. More complete ation of the<br />

resource will alleviate at least some of the shortfall in timber harvest shown in most alternatives.<br />

<strong>Response</strong><br />

Catastrophic events, such as wildfires, are aggressively salvaged but most individual trees that die<br />

must be left for dead tree wildlife habitat. (See the alternative description in Chapter 2.<br />

Comment<br />

We would like to see the Forest use PROGNOSIS for yield estimates. This model, we understand, has<br />

been calibrated for use in your area. We believe this model is flexible enough to handle both even and<br />

uneven-aged harvesting methods and certainly enjoys wide acceptance among mensurational experts.<br />

<strong>Response</strong><br />

The uneven-aged management yield tables were redone between the Draft and Final EIS using the<br />

SORNEC version of the PROGNOSIS model. Prognosis Model outputs were compared to the yield<br />

tables used in the Draft Plan and we found the even-aged tables were very similar but the uneven-aged<br />

tables used in the DEIS were much lower than prognosis estimates.<br />

Comment<br />

The Winema Forest is ideally suited to uneven-aged management. The topography is gentle for the<br />

most part and the species on the Forest regenerate naturally. We reject the hypothesis that there will<br />

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e less yield under uneven- ged management. This decline in yield in the final plan needs to be fully<br />

supported.<br />

<strong>Response</strong><br />

We agree that uneven-aged management is appropriate for much of the Winema. It will be prescribed<br />

for most of the ponderosa pine and pine associated timber types. We do not plan to prescribe uneven-aged<br />

management in the lodgepole pine type because of marginal values and high logging costs. Uneven-aged<br />

management will be used sparingly in the mixed conifer type because of the Armillaria root rot problem.<br />

Comment<br />

The Forest should consider two strategies in their young stands: (a) grow these stands under tight<br />

spacings until they self-prune and then thin these stands to wide spacings; or, (b) prune these stands<br />

at young ages up 32 feet and then grow these stands at wide spacings.<br />

<strong>Response</strong><br />

A decision on pruning is not being made at this time. It will be left open to decide at a later. A program<br />

has been developed to evaluate pruning Douglas-fir but the program has not been developed, yet, for<br />

ponderosa pine.<br />

Pruning greatly reduces mule deer hiding cover. Our analysis shows that the dense cover stands are<br />

hard to maintain at acceptable levels without pruning so pruning is not being prescribed.<br />

Comment<br />

Natural stands of lodgepole pine show tremendous genetic variability. Seed collections from goodlooking<br />

parents should be made. Growth rate as well as straight stems should be primary selection criteria<br />

when parent trees are chosen. precommercial thinning of lodgepole pine stands near the major haul<br />

routes should be considered to remove poor quality trees and enhance the visual appearance of the<br />

stands.<br />

<strong>Response</strong><br />

Phenotypically, superior trees have been selected for lodgepole pine seed collections. We are also<br />

purchasing lodgepole pine seed from Weyerhaeuser's seed orchard at Malin. Many different prescriptions<br />

are being applied to the lodgepole pine stands near travel routes to make them visually pleasing.<br />

On a large percentage of our regeneration harvest lodgepole sites, we plan to rely on natural regeneration.<br />

An effort will be made to select seed sources that would provide the greatest genetic gain as a seed<br />

source.<br />

Comment<br />

The Forest should re-evaluate the conversion factor relationship in conversion of board feet to cubic<br />

foot scale and the corresponding impact on sustained yield harvest levels. By planning allowable harvest<br />

levels in cubic scale but measuring actual harvest in board feet, the Forest will over cut early in the<br />

rotation and undercut later in the rotation. Along this same line, we urge the Forest to upgrade the<br />

timber inventory process with a modern Forestwide inventory system., The uneven-aged yield tables,<br />

likewise, need to be updated based upon current knowledge levels.<br />

<strong>Response</strong><br />

We re-evaluated the conversion factors for board feet and cubic feet, and elected to put in FORPLAN<br />

the actual board foot yield table, which corresponds to each cubic foot yield table.<br />

The Forest Service is evaluating selling all material in cubic feet, but in any case, we will monitor the<br />

sell in cubic feet. Our standard cruise program develops both the board foot and cubic foot volume for<br />

the sale.<br />

The Regional Office is developing a new inventory process. The Winema will be reinventoried in 1991,<br />

using this new system integrated into a GIS computer mapping system. This new system, overtime,<br />

should correct our inventory problems.<br />

The uneven-aged management yield tables were re-done using the PROGNOSIS stand projection<br />

model.<br />

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Comment<br />

When managing future lodgepole pine stands, the Forest should plan on a shorter rotation. Biologically<br />

and mensurationally 60-year rotations will maintain healthier and more productive stands. These rotations<br />

can be accomplished and still meet the legislated 95% culmination of M.A.I. target.<br />

<strong>Response</strong><br />

Yes, we agree. Our lodgepole pine stands, being managed for timber production, have 60 and 70-year<br />

rotation lengths.<br />

Comment<br />

I would like to see us run another alternative without departing from even flow sustained yield for ponderosa<br />

pine. Let's see what this does to the sustainable harvest level of ponderosa pine.<br />

<strong>Response</strong><br />

The final alternative is based on maintaining a sustained even flow of ponderosa pine.<br />

Comment<br />

The time period between 1975 and 1985 included one of the most severe recessions in the timber<br />

industry's history. Timber program statistics from this time period do not accurately reflect either current<br />

demand for wood products or the timber industry's current raw material requirements.<br />

<strong>Response</strong><br />

Tables in Chapter 3 have been updated to the current year.<br />

We are aware that the local timber industry is currently producing at very high levels. The local milling<br />

capacity far exceeds the growing capacity of local forests, so we must expect a major restructuring of<br />

the local industry to get the milling capacity more in line with local growth potential.<br />

Comment<br />

Winema's planners estimate that 50 percent of the Winema's lodgepole pine has already been killed<br />

by the mountain pine beetle and that virtually all of the Forest's lodgepole pine sawtimber will be dead<br />

within the next seven years.<br />

<strong>Response</strong><br />

The mortality was checked and we found the lodgepole pine mortality was less than originally projected.<br />

The lodgepole pine empirical yields have been modified based upon the measured mortality rates.<br />

Also, the dead lodgepole pine has been removed from the ASO so only green sawtimber will be in the<br />

ASQ.<br />

Comment<br />

We are especially concerned about the preferred alternative's reduced ponderosa pine harvest levels.<br />

The Forest's timber cut and sold reports show that the Winema actually sold an average of 93.2 million<br />

board feet of ponderosa pine sawtimber per year between 1977 and 1986. The proposed plan would<br />

sell about 80.8 million board feet per year over the next ten years; a level 13 percent less than the<br />

1977-86 historic average (DEIS Table 11-23).<br />

<strong>Response</strong><br />

Table 3-8 shows the past harvest level by species. Table 3-8 is more indicative of the actual local demand<br />

than the sell. During that period many sales were defaulted and returned to the Forest Service without<br />

being cut. The harvest is scaled volumes and show what was actually used.<br />

The preferred alternative in the FEIS, Alternative J, has an ASQ of 117 mmbf per year of which 54<br />

mmbf is ponderosa pine. This is 68 percent of the historic harvest rate of ponderosa pine so we expect<br />

some restructuring of the local timber industry to occur before demand equalizes with the ponderosa<br />

pine timber supply.<br />

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Comment<br />

Given the significant green sawtimber harvest reduction proposed in the draft plan, we believe the<br />

Winema's preferred alternative will have to be revised if the Forest hopes to produce sufficient timber<br />

to maintain the economic stability of timber-dependent communities. The land allocations and ASO<br />

established in the final plan must recognize: (1) the local timber industry's current, post-recession raw<br />

material requirements; (2) the impending reduction in private timber harvest levels; and (3) the major<br />

harvest reductions proposed on adjoining national forests. As a minimum, the Winema's green sawtimber<br />

sale program for the next ten years should be as close as possible to the Forest's own historic sell<br />

level; especially in the critical ponderosa pine component.<br />

<strong>Response</strong><br />

The Forest gave all the factors you mentioned a great deal of consideration while developing the Forest<br />

Plan. Please see Chapter 3, Social and Economic Setting and Chapter 4, Effects of the Alternatives on<br />

the Local Economy.<br />

Comment<br />

We estimate, based on the limited analysis we have done to date, that Alternative E-Plus would have<br />

sufficient productive capacity to produce a first-decade ASO in excess of 210 million board feet per<br />

year, including ely 90 million board feet per year of ponderosa pine and considerably more lodgepQle<br />

pine than recent historic levels. 4/ We anticipate that ponderosa pine production, expressed in cubic<br />

feet, would remain at or near the first-decade level over at least the next fifty years. Board-foot volumes<br />

would probably decline somewhat in future decades as smaller-diameter, second-growth stands provide<br />

an increasing component of the Forest's timber sale program. We estimate that Alternative E-Plus<br />

would have sufficient productive capacity to maintain a sustainable timber sale program (all species)<br />

of ely 164 million board feet of green sawtimber per year over the long term.<br />

4/ This number equals the preferred alternative's first-decade ASQ plus the additional ponderosa pine<br />

volume needed to bring the pine component up to 90 MMBF per year. Given the differences in lands<br />

allocations between Alternative E-Plus and the preferred alternative, it is likely that the maximum potential<br />

ASQ could be even higher than 210 MMBF/year. Additional FORPLAN analysis will be required to estimate<br />

a more precise number.<br />

<strong>Response</strong><br />

Alternative E plus was run through FORPLAN as MODEL 4B. The output is available at the Forest Office<br />

for review. A summary of the model output was given to local industry representatives for their review.<br />

The summary shows the alternative would produce an ASQ of 26.4 mmcf pre year or between 124<br />

and 160 mmbf per year. The ponderosa pine yield varied between 50 and 90 mmbf per year and was<br />

51.4 mmbf in the first decade.<br />

Comment<br />

We would support an alternative that emphasizes production of large-diameter pine to the extent the<br />

Winema can achieve this objective without significant adverse impact on its overall timber sale program<br />

level. We would not support such an alternative if further analysis shows that emphasis on 'high-quality"<br />

pine production would require a significant reduction of the Forest's overall timber sale program. We<br />

see no sense in drastically reducing current harvest levels and sacrificing for large-diameter pine will<br />

somehow assure community stability over the long term. We believe that technological developments<br />

and changing market conditions over the next several decades will allow our companies to develop<br />

new markets and processing technologies to handle whatever species and size mix the Winema eventually<br />

produces. Ideally, it will be high-quality, large-diameter ponderosa pine. If not, we will adapt our operations<br />

to an existing mill out of business and people out of work only to discover later that the action was<br />

needless and provided no real benefits.<br />

The final forest plan must be based on a very careful analysis of this critical issues.<br />

<strong>Response</strong><br />

Several contacts were made with industry representatives to get an understanding of high value pine.<br />

Our understanding of a high value pine tree is one over 20 inches DBH that has growing fast enough<br />

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to produce a clear block of wood between each limb whorl. The uneven-aged management prescriptions<br />

will provide this type material.<br />

Comment<br />

Alternative E-Plus would include greater emphasis on uneven-aged management: (1) where uneven-aged<br />

management makes biological sense; and (2) to the extent it can be used without significantly reducing<br />

the Forest's overall timber production potential. Our experience on industrial lands suggests that greater<br />

reliance on uneven-aged management in the Winema's pure ponderosa pine types should offer an<br />

opportunity to ameliorate some of the real and perceived conflicts between timber production and<br />

other resource values without sacrificing significant timber production potential.<br />

<strong>Response</strong><br />

Uneven-aged management yield tables project about the same yield as the even-aged tables.<br />

Alternative J maximizes the use of uneven-aged management in the ponderosa pine and pine associated<br />

working groups.<br />

Comment<br />

The final plan should implement an aggressive ponderosa pine salvage program, especially on the<br />

north end of the Chemult District.<br />

Most industrial timber owners in Central Oregon employ aggressive salvage programs on their own<br />

lands to harvest each year's mortality before the dead trees lose their value. Most industry people are<br />

appalled at the huge volume of salvable timber that goes to waste each year on Oregon's national<br />

Forests. Loggers commonly wonder why the Forest Service requires them to clearcut stands of vigorous<br />

old-growth timber and young, rapidly-growing trees, while significant volumes of salvable, recently-dead<br />

timber are "left to rot in stands right next to the timber sales they are logging. We have found on our<br />

own lands that an effective, annual salvage program can: (1) capture significant timber value that would<br />

otherwise be lost; (2) reduce the volume of green timber that needs to be harvested each year to meet<br />

mill requirements; (3) maintain the growth potential of vigorous stands that would otherwise have been<br />

harvested in a given year; and (4) effectively extend the inventory of old, large-diameter timber available<br />

for harvest from our lands in the future. There are also environmental advantages associated with using<br />

a light, forest-wide salvage program to produce a major part of our annual harvest volume. Such a<br />

program disperses environmental and visual effects over a broader area of the forest, reduces the<br />

intensity of the impact on any given site and makes the effects of timber harvest less objectionable to<br />

the public.<br />

<strong>Response</strong><br />

Most of the Winema is deficient in large dead trees to meet the habitat needs of cavity nesters. The<br />

current mortality is being left to meet this need for large dead trees.<br />

Comment<br />

We recognize that some individuals and special interest groups would prefer to see the Forest's<br />

non-wilderness roadless lands remain undeveloped and available for future reconsideration for wilderness<br />

designation. We also recognize that management of these areas for timber production could reduce<br />

opportunities for some forms of roadless recreation on the Forest. On the other hand, we believe that<br />

Congress' intent was clear when it 'released these lands for multiple-use management rather than<br />

designating them Wilderness. In the Winema's case, these lands appear to include very little commercial<br />

timberland. Nevertheless, given the potentially severe adverse economic and social impacts of an<br />

inadequate timber sale program on the Winema, every acre is important. We firmly believe that the<br />

Forest's unroaded nonwilderness lands can produce multiple benefits, including both timber and<br />

satisfying recreation experiences, if the Forest es management practices designed to minimize rather<br />

than exacerbate conflict between various management objectives.<br />

<strong>Response</strong><br />

The roadless areas on the Winema do not contain many lands suitable for timber production. Three<br />

percent of the forest is unroaded. Of the unroaded acres, 71 percent is unsuited for timber production<br />

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which leaves 1 percent of the tentatively suitable land base in unroaded areas. Most of the suitable<br />

timber land in unroaded areas is mixed with so much unsuited lands that it is very hard to develop.<br />

Comment<br />

The draft plan would manage 26,784 acres primarily to achieve big game winter range management<br />

objectives, an increase of 4.2 percent compared to current management direction (DEIS Table 11-2).<br />

The acreage involved would be equivalent to 3.3 percent of the draft plan's suitable land base. Timber<br />

Harvest will be constrained to 'provide thermal cover." Disturbing human activities will be 'discouraged<br />

or minimized" from December 1 through April 30. Unneeded roads will be closed or obliterated. Local<br />

roads may be closed on a seasonal basis (DEIS Appendix Table B-5). The DEIS does not describe the<br />

effect these management constraints have on timber yields (whether positive or negative).<br />

<strong>Response</strong><br />

The winter range allocation has little to no effect on timber yields. Table 4-10 in the Forest Plan shows<br />

the timber management intensities used in each management area. A comparison with the timber<br />

management area shows that prescriptions with more commercial thinnings occur within the winter<br />

range to maintain more control of the stocking level. This is beneficial to mule deer and also increases<br />

the timber yield on these acres.<br />

Comment<br />

It is important to recognize, as indicated by these research findings, that: (1) nobody can definitely<br />

state how much old growth is required to maintain viable populations of 'old-growth dependent' wildlife<br />

species, or even if old growth is required at all; and (2) that managed, second-growth stands can<br />

provide many of the habitat components needed to maintain viable populations of such species. The<br />

Winema's FEIS should include an in-depth review of the recent research literature on this subject and<br />

clearly disclose these kinds of facts. The FEIS should also examine alternative ways to meet wildlife<br />

objectives without taking productive forest lands entirely out of the suitable land base, including use of<br />

intensive management techniques to provide healthy wildlife populations while still meeting demand<br />

for timber (see Appendix B).<br />

<strong>Response</strong><br />

There is a committee reviewing the oldgrowth definitions for the Region but this plan is still developed<br />

using the oldgrowth definitions in the Regional Guide.<br />

Comment<br />

Alternative E-Plus would include the same recommendations outlined in the draft plan, except for those<br />

portions of the Cherry Creek Basin outside of the Sky Lakes Wilderness Area. These nonwilderness<br />

sites include about 852 acres of tentatively suitable forested lands supporting good stands of<br />

merchantable timber. In addition, the Cherry Creek Basin recommendation has all the earmarks of a<br />

wilderness 'buffer." Such buffers are explicitly forbidden by the terms of the 1984 Oregon Wilderness<br />

Act.<br />

<strong>Response</strong><br />

One of the cells to be represented by the Cherry Creek Basin RNA was a 3rd order fir community<br />

drainage. The additional acres outside of the wilderness boundary is to make sure the cell is represented.<br />

Comment<br />

The DEIS does not adequately analyze and disclose the potentially severe adverse environmental<br />

impacts of a decision to not cut timber in roadless areas, visual corridors, dedicated old-growth stands,<br />

riparian areas and other allocations with timber harvest restrictions. This is an especially serious omission<br />

on a Forest with extensive stands of dead timber, heavy fuel loads and the potential for catastrophic<br />

wildfires.<br />

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<strong>Response</strong><br />

The DEIS was designed so some alternatives managed more or less of the management areas that<br />

restrict timber harvest. Reviewing the outputs in Chapter 2 for each alternative will show what the impact<br />

is for putting more lands in no yield or low yield land allocations.<br />

Comment<br />

The Forest inventory, conducted in 1981, used only 446 inventory plots to cover about 779,000 acres.<br />

This relatively low number of plots reflects the Forest Service's inventory design as related to the standard<br />

error objectives set for the overall inventory.<br />

<strong>Response</strong><br />

That is correct.<br />

Comment<br />

The Winema staff stratified its forest inventory into four major model components. They did not stratify<br />

the forest inventory by site productivity. The forest should be stratified by productivity class.<br />

<strong>Response</strong><br />

The mixed conifer working group was stratified separately from the pine associated working group<br />

because of the difference in productivity of the two working groups. They are both fir associated types.<br />

Other working groups did not have sufficient variation in productivity by large enough land areas to<br />

warrant additional stratification.<br />

Comment<br />

There are major differences between the Winema's first period, net growth derived from the empirical<br />

yield tables and the current net growth shown in the forest inventory plot data. The empirical yields<br />

understate the growth, as compared to the inventory, by about 30 percent. This is an important issue<br />

which we recommend the forest staff evaluate and address in the final EIS through updated yield tables.<br />

<strong>Response</strong><br />

The timber inventory growth rates are gross values where as the empirical yield tables represent the<br />

net growth which can be captured under a none managed stand condition.<br />

Comment<br />

Since the developed empirical yields already resulted in substantial reductions in growth, the Winema<br />

staff should closely evaluate its decision to add further reductions to the estimated volume of lodgepole<br />

pine.<br />

<strong>Response</strong><br />

The lodgepole pine inventory plots were revisited and found to have an average mortality since 1981<br />

of over 35 percent. The yield tables were adjusted for this measured mortality and expected mortality.<br />

Comment<br />

It is not clear whether the ASQ estimate in the preferred alternative includes salvable dead volume<br />

captured during green timber sales. The Forest should estimate the salvable dead from green sales<br />

(we believe about two million cubic feet per year). They should also estimate the volume of salvage<br />

sales sold above the accelerated lodgepole pine harvest rate. These volumes should be included in<br />

the total timber sale program.<br />

<strong>Response</strong><br />

Dead material is not included in the ASQ. The ASO is all live and green sawlog material which meets<br />

merchantability standards. The dead material will be part of the total sale quantity.<br />

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Comment<br />

The Winema Forest, through the empirical yield table generator, used standard defect and breakage<br />

reductions that only vary by species, not stand age. Since defect found in the pole and small sawtimber<br />

stands is likely below that assumed, these yield tables should be evaluated, and increased through<br />

updated yield tables.<br />

<strong>Response</strong><br />

The cull and breakage factors are values we are currently experiencing. They were developed by species<br />

rather than stand age but are still good representation of the average defect we experience.<br />

Comment<br />

Form factors only vary by 1 0-inch size classes. The Forest Service should document the procedures it<br />

used to develop these average form factors and evaluate whether more precise estimates of form<br />

factor would have an impact on the ASQ.<br />

<strong>Response</strong><br />

The form factors vary only slightly between diameter classes so it does not seem reasonable to spent<br />

any more time on form factors. The Form factors came from a fall-buck-and scale study and from the<br />

measured form classes from timber sale cruises.<br />

Comment<br />

The Forest Service should evaluate whether there are additional commercial thinning and fertilization<br />

opportunities in their existing young stands. The staff assumed that a 12-inch stand diameter and<br />

minimum volume per acre were needed to justify commercial thinnings. The Winema staff should meet<br />

with timber industry representatives to evaluate whether assumptions about commercial thinning<br />

minimums accurately reflect expectations of future thinning limitations<br />

<strong>Response</strong><br />

This is an on going situation. We have been able to achieve ation of smaller thinning material when<br />

the operation is subsidized with other funds but no commercial thinning has been practical because of<br />

all the restrictions that harvesting must meet.<br />

Comment<br />

The managed yields were developed with the assumption of one average site index per model component.<br />

This restricts the ability of the FORPLAN model to achieve resource efficiency and optional ASQ.<br />

<strong>Response</strong><br />

There is little variation in the general forest within each working group. The working groups adequately<br />

divide the forest by productivity grouping.<br />

Comment<br />

While some of the assumptions used were well documented, most of the detailed procedures for<br />

calculating the managed yields were not well defined or understandable.<br />

<strong>Response</strong><br />

The yield table documentation is available for review in the Forest Supervisors Office.<br />

Comment<br />

A five-percent reduction was made in the ponderosa pine and pine-associated working groups to account<br />

for presumed competition from understory vegetation. The Forest staff should document its decision to<br />

use the various percentage reductions and evaluate measures to mitigate these reductions (such as<br />

vegetation control). The staff should also detail why the falldown factors were greater for uneven-aged<br />

management than even-aged management.<br />

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<strong>Response</strong><br />

The discussion for the operational falldown for vegetative competition is found on page 9 of the yield<br />

table documentation which is available at the Supervisor's office. The vegetative competition was used<br />

with prescriptions that maintained an open canopy for most of the rotation.<br />

The operational falldown for uneven-aged management is found on pages 4, 5, and 6 of the documentation<br />

for the uneven-aged management yield tables. The operational falldown for uneven-aged management<br />

for ponderosa pine and pine associated working groups are within the range used for the even-aged<br />

tables. The operational falldown for uneven-aged management in mixed conifer and lodgepole pine is<br />

much higher than for even-aged management because rot will be a major problem in stands of fir<br />

managed with uneven-aged management and lodgepole will have problems with logging damage and<br />

mistletoe.<br />

Comment<br />

In most of these limited harvest areas, timber harvest was not allowed in FORPLAN until the average<br />

age of the stand reached the minimum harvest age of the management area prescription (for example,<br />

250 years in the foreground retention zone). In our opinion, this constraint is inappropriate since it is<br />

based on an average stand age for each model component and only the entry rate constraint should<br />

be used.<br />

<strong>Response</strong><br />

There is only an area in opening constraint in the foreground retention areas.<br />

Comment<br />

The ation requirements on the Winema have increased from the current plan. The Forest now requires<br />

that smaller trees must be ed in both empirical and managed stands. In the approved plan, trees 11<br />

inches DBH to a 6-inch top in the empirical stands, and trees 9 inches DBH to a 6-inch top in the managed<br />

stands comprise the minimum able size. In this current planning effort, empirical yields incorporate<br />

trees 9 inches DBH to a 6-inch top and the managed yields incorporate trees 7 inches DBH to a 4-inch<br />

top. These improved ation standards increase the per acre volume of both the Forest inventory and<br />

managed yield tables.<br />

<strong>Response</strong><br />

This is true.<br />

Comment<br />

We have found that the documentation in the Regional Office, which describes the procedures and<br />

the processes used to develop the Forest inventory date and convert it into empirical yield tables, is<br />

very limited.<br />

<strong>Response</strong><br />

John Teply, Regional Biometrication, maintains these files.<br />

Comment<br />

The mature (HRG) ponderosa pine component only used 50 plots to represent about 243,600 acres or<br />

an average of roughly 4,900 acres per plot. We consider this to be a very low level of sampling; it is<br />

noteworthy since it occurs on the largest component on the Winema Forest.<br />

<strong>Response</strong><br />

The inventory was designed to sample the model components to within + or - 10 percent at one standard<br />

deviation from the mean as measured in board foot volume. The mature ponderosa pine component<br />

was inventoried to + or - 9.6 percent at the 95 percent confidence level.<br />

K - 194

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Comment<br />

The Winema staff should be aware of the limitations these high standard deviations impose for Forest<br />

planning. Because of the high variation in the average volume per acre, using dispersion or other area<br />

volume constraints based on gross averages must be carefully evaluated. In our opinion, the limited<br />

stratification of the Forest inventory does not support the use of many of the constraints applied in<br />

FORPLAN.<br />

<strong>Response</strong><br />

Our inventory design definitely limits our ability to analyze the effects of allocations of small land areas.<br />

The inventory losses accuracy as we apply the statistics to smaller and smaller areas. But as for FORPLAN,<br />

our dispersion constraint was not limiting. Long-term sustained yield is limiting.<br />

Comment<br />

Exhibit Il-A-4 shows the tentatively suitable land base as stratified in FORPLAN by age class. The young<br />

stands (between zero and 30 years of age) total about 209,000 acres. In contrast, Exhibit Il-A-1 shows<br />

that the inventory contained about 31,500 acres of non-stocked and young seedling and sapling stands.<br />

<strong>Response</strong><br />

The table in FORPLAN (F10.8), which you used to get your information, is not working correctly. The<br />

inventory had about 32,000 acres of non-stocked and seedlings and saplings. That figure was updated<br />

to about 81,000 acres for the DEIS analysis and was further updated to about 127,000 acres for the<br />

FEIS analysis.<br />

Comment<br />

The ation standards for the managed yield tables are a 7-inch DBH to a 4-inch top. Thus, we recommend<br />

that the Winema staff adjust the pole and small sawtimber stand volumes to account for improved<br />

ation down to a 7-inch DBH.<br />

<strong>Response</strong><br />

Commercial thinnings in existing stands used a 7 inch DBH to a 4 inch top merchantability.<br />

Comment<br />

Other comments about the Empirical Yield Tables. We found major differences between the first period<br />

growth derived from the empirical yield tables and the net growth derived from the Forest inventory<br />

plot data for the same model strata. The volume growth over the entire Forest as derived from the<br />

empirical yield curves for the first decade totals about 18.592 million cubic feet annually (Exhibit Il-A-1).<br />

In contrast, the net growth shown from the Forest inventory plot data totals 27.145 million cubic feet<br />

annually. Thus, the first decade volume growth from the empirical yield curves, compared to the net<br />

growth from the Forest inventory plot data, is understated by about 30 percent. This is over 50 million<br />

board feet annually.<br />

<strong>Response</strong><br />

The inventory shows the growth occurring on the forest but makes no attempt to determine what percent<br />

of that growth will actually be ed. The empirical yield tables indicate the growth of volume which actually<br />

will be harvested.<br />

Comment<br />

This implies that significant in-growth occurring on the Winema Forest is not being picked up in the<br />

empirical yield table generation process because of the methodology being used to develop the empirical<br />

yield tables.<br />

<strong>Response</strong><br />

I believe the empirical yield tables are a good representation of the volume we will harvest including<br />

expected in-growth.<br />

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Comment<br />

We recommend that the Winema staff evaluate the differences in growth as represented by the empirical<br />

yields and address them prior to the final EIS through updated yield tables. This underestimate of<br />

growth on the Winema is significant and could contribute to substantial increases in the ASQ. They<br />

also need to re-evaluate their decision to reduce the lodgepole pine yields by such a large percentage.<br />

<strong>Response</strong><br />

The empirical yield tables were updated to the midpoint of the planning period.<br />

The empirical lodgepole pine yield tables were adjusted for current mortality so the ASQ for the Forest<br />

Plan will be live green volume and will not include salvage material. Salvage material will be included<br />

in the timber sale program quantity.<br />

Comment<br />

In its Forest inventory procedures, the Forest Service estimates the dead volume which would have<br />

merchantable value over the next ten-year period. This is commonly called the salvable dead. The<br />

salvable dead timber available for harvest is not included in the FORPLAN ASQ since the FORPLAN<br />

yields are based on net merchantable volume. For example, we estimate that the salvable dead volume<br />

in the Winema's inventory is 70.3 million cubic feet or roughly 90.2 cubic feet per acre. The first decade<br />

harvest (Management Plan, Pg 11-7) totals about 25,000 acres. Based on the 90 cubic feet per acre,<br />

the salvable dead volume on green sales would be about 2.2 million cubic feet annually.<br />

<strong>Response</strong><br />

An estimate of salvage volume is included in the timber sale program quantity.<br />

Comment<br />

The Winema staff should evaluate the defect factors used for its pole and small sawtimber stands. It is<br />

possible to correct the defect and breakage factor on these stands by changing the percentage reduction<br />

that was used. This problem could be corrected by modifying the beginning average volume per acre<br />

to reflect improved logging technology and lower defect and breakage rate of young stands.<br />

<strong>Response</strong><br />

The cull, defect and breakage values for the Forest were developed from fall buck and scale studies<br />

and values used by ranger districts for timber sale appraisals. We discussed your concern of using an<br />

average value for all working groups, but at this time we do not have information to vary the value by<br />

stand age.<br />

Comment<br />

The increased yields that will result from fertilization treatments should be incorporated into the yield<br />

tables. The cost and potential benefits of fertilization on different sites should be evaluated.<br />

<strong>Response</strong><br />

The Pacific Northwest Forest and Range Experiment Station have been evaluating fertilization on the<br />

Winema. Their research shows that the response on the forest is not large enough to cover costs so<br />

fertilization was not given additional evaluation.<br />

Comment<br />

On the Winema, the intensive managed yield tables were only developed for an average site within<br />

each model component. We question this decision, particularly for the major species such as ponderosa<br />

pine or the mixed conifer stands. There is a wide variation of site conditions and site indices within<br />

each of the model components generated by the Winema staff.<br />

<strong>Response</strong><br />

The model components were designed to address the major differences in productivity. The fir associated<br />

stands on the Klamath Ranger District were placed in the mixed conifer working group while the fir<br />

associated stands on the rest of the Forest were placed in the pine associated working group. These<br />

K - 196

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two working groups have similar species composition but major productivity differences. The differences<br />

in the ponderosa pine and lodgepole pine working groups were not of a large enough magnitude to<br />

warrant separate working groups.<br />

Comment<br />

The Yield Models. The Winema staff used a variety of techniques to develop the managed yield tables<br />

for the four model components. For the lodgepole pine model component, the LPSIM growth model<br />

was used. The major input into this model was the average site index for the lodgepole pine component;<br />

height growth curves and gross basal area factors were not needed to operate this model. We were<br />

told that the major growth functions for this model were derived from the PROGNOSIS model.<br />

<strong>Response</strong><br />

LPSIM was developed before the SORNEC version of the PROGNOSIS model. PROGNOSIS uses the<br />

LPSIM growth functions.<br />

Comment<br />

For those prescriptions that incorporate between two to five commercial thinnings, the Winema staff<br />

should detail its decision process about the stocking level both at the time of precommercial and<br />

commercial thinning.<br />

<strong>Response</strong><br />

The assumptions used in the managed yield tables are available in the working papers at the Supervisor's<br />

Office.<br />

Comment<br />

We recommend that the details of this decision be documented and analyzed. The Forest staff should<br />

delineate the number of acres which they believe had adequate stocking from advanced regeneration<br />

and the acres in which they presumed there was inadequate stocking from advanced regeneration. In<br />

addition, it seems that the advanced stocking that did occur, whether adequate or not, would have<br />

some impact on the managed yield tables unless it is destroyed during logging. The Winema staff<br />

should evaluate whether the measurement of the advanced regeneration would have a significant<br />

impact on the total ASO.<br />

<strong>Response</strong><br />

The inventory is not designed to provide this level of detail on advanced regeneration. It was assumed<br />

that the regeneration areas did not have manageable advanced regeneration.<br />

Comment<br />

In addition to documenting the falldown factors and measures that could be taken to mitigate these<br />

factors, the Winema staff should also evaluate their decision to add an additional five percent reduction<br />

in the per acre volume. This decision seems to be arbitrarily developed without a sound scientific basis<br />

for the individual component parts. Alternatives, such as vegetation control, were not evaluated. They<br />

should also compare the tradeoffs of increasing pine stocking levels against potential volume increases<br />

expected with less understory vegetation. The PROGNOSIS model can be used to evaluate this factor.<br />

<strong>Response</strong><br />

This 5 percent reduction for vegetation competition was only taken on stands that maintained open<br />

stand conditions. The 5 percent reduction is based upon growth response measured when understory<br />

vegetation was removed.<br />

Comment<br />

For some reason, the Winema staff double entered the uneven-aged management acres into the<br />

FORPLAN data base (Exh. Il-A-4). While this did not appear to incorrectly increase the ASQ, the Winema<br />

staff should explain the reasoning behind this entry.<br />

K- 197

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<strong>Response</strong><br />

We did not input the uneven-aged management acres twice. The FORPLAN model does not correctly<br />

handle uneven-aged management acres in the age report.<br />

Comment<br />

The Winema staff did not evaluate planting genetically improved stock as part of the overall strategy of<br />

uneven-aged management primarily because they believed repeated planting entries would be too<br />

expensive. This prescription might actually improve the genetic make-up and total long term yield because<br />

of improved thinning from below.<br />

<strong>Response</strong><br />

We do believe that many of the uneven-aged management treatment acres will receive some planting<br />

but we don't believe there will be a genetic gain. We believe planting in the uneven-aged management<br />

acres will be needed to maintain the current genetic base.<br />

Comment<br />

The Winema staff should describe how the maximum diameter requirement drove the model and how<br />

that compared with the even-aged stand model. It appears the staff is trying to produce a tree that is<br />

larger than the average diameter of the managed yield tables. The Winema staff should evaluate this<br />

issue; if the average diameter for uneven-aged stands is higher, the cost and benefits of this decision<br />

should be discussed.<br />

<strong>Response</strong><br />

Uneven-aged management is being prescribed to maintain an accept forested appearance while<br />

producing some timber outputs. To maximize timber production while using uneven-aged management,<br />

a maximum tree size goal of ely 14 inches would have been chosen. That tree size would not have<br />

maintained an acceptable forested appearance. We chose 24 inches as the maximum tree size because<br />

we believe it will maintain an acceptable forested appearance.<br />

Comment<br />

In the case of the lodgepole pine stands, the methodology used produced yields 114 percent of the<br />

EAM (Managed Yield Tables).' (Uneven Managed Yield Book, pg 3). Again, the Forest silviculturist<br />

reduced these yields. In this case, the uneven-aged lodgepole heights were reduced 24 percent from<br />

the managed yield table. This was the same percentage reduction as was found in the ponderosa<br />

pine working group.<br />

<strong>Response</strong><br />

The uneven-aged management yield tables were all redone using the SORNEC version of the PROGNOSIS<br />

model.<br />

Comment<br />

In our opinion, the development of the operational falldown factors, particularly those involving disease,<br />

insect, or factors related to soil compaction are not adequately presented in the draft EIS. These factors<br />

seem to be arbitrary, with little scientific background to support the actual percentages developed. We<br />

recommend that the Winema staff specifically identify those forest acres of each different model<br />

component which will experience yield reductions because of the specific activities, such as soil<br />

compaction, dwarf mistletoe, and other diseases. If there is substantially more falldown in the uneven-aged<br />

stands, the costs and benefit of this type of management should be evaluated before such management<br />

is implemented.<br />

<strong>Response</strong><br />

The development of the operational falldowns are documented in process papers and are available for<br />

review in the Forest office.<br />

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Comment<br />

The Winema staff should evaluate the management goals for the uneven-aged stands under different<br />

constraints and timing choices. In addition to using a 30-year cycle, the Winema staff should allow the<br />

FORPLAN model other timing choice options as developed through Ithe PROGNOSIS model in order to<br />

level out the entry into the uneven-aged stands.<br />

<strong>Response</strong><br />

The timing choice is based upon the amount of time it takes the average stand to regain its stocking<br />

level after each uneven-aged management treatment.<br />

Comment<br />

The Winema's proposed departure alternative for all species (including lodgepole) is a major issue<br />

that needs more evaluation. One objective of the preferred alternative was to allow the accelerated<br />

harvest of lodgepole pine in the lodgepole pine component because of the mountain pine beetle damage.<br />

Because of the FORPLAN formulation, though, the preferred alternative also proposes accelerated<br />

harvest of the other model components. We believe this is a major issue on the Winema which needs<br />

further evaluation.<br />

<strong>Response</strong><br />

The DEIS preffered alternative was developed to allow salvage of the dying lodgepole pine while<br />

maintaining the historic harvest level of ponderosa pine and the true firs.<br />

Comment<br />

The harvest schedule is a major issue. The Winema staff should work with local forest industry<br />

representatives to develop a harvest schedule that meets expected needs.<br />

<strong>Response</strong><br />

The Forest has been working with local timber industry representatives and have developed a FORPLAN<br />

run for an industry supported alternative. The industry alternative was within the range of published<br />

alternatives so was not developed into one of the FEIS final alternatives.<br />

Comment<br />

Because of the limitations of the Forest Service's present net value evaluations, we recommend that<br />

the preferred alternative be developed by using a maximum timber objective function in FORPLAN<br />

coupled with what is called a PNV "rollover."<br />

<strong>Response</strong><br />

The National Forest Management Act requires that we maximize net public benefit. Present Net Value<br />

is used as an indicator of net public benefit.<br />

Comment<br />

In its current formulation, the preferred alternative will not meet the needs of the American people for a<br />

high level output of renewable resources, and therefore violates the Multiple Use Sustained Yield Act.<br />

16 U.S.C. 531.<br />

<strong>Response</strong><br />

We believe that the preferred alternative will maximize the net public benefit when all resource values<br />

are concidered.<br />

Comment<br />

The failure of the Winema to conduct and keep a current comprehensive survey of present and prospective<br />

conditions on the Forest is a violation of 16 U.S.C. 1642b and 36 C.F.R. 219.12(d). The Winema must<br />

reevaluate its Forest inventory to provide an accurate assessment of the potential of the Winema National<br />

Forest.<br />

K- 199

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<strong>Response</strong><br />

The inventory has been updated to September, 1989; lodgepole pine inventory was updated for current<br />

mortality; uneven-aged management yield tables were redone using the latest version of the PROGNOSIS<br />

model. The Forest is just starting a new inventory which will be complete in about 3 years.<br />

Comment<br />

The time period between 1975 and 1985 included one of the most severe recessions in the timber<br />

industry's history. Timber program statistics from this time period do not accurately reflect either current<br />

demand for wood products or the timber industry's current raw material requirements.<br />

<strong>Response</strong><br />

Tables is Chapter 3 have been updated to the current year.<br />

We are aware that the local timber industry is currently producing at very high levels. The local milling<br />

capacity far exceeds the growing capacity of local forests, so we must expect a major restructuring of<br />

the local industry to get the milling capacity more in line with local growth potential.<br />

Comment<br />

Winema's planners estimate that 50 percent of the Winema's lodgepole pine has already been killed<br />

by the mountain pine beetle and that virtually all of the Forest's lodgepole pine sawtimber will be dead<br />

within the next seven years.<br />

<strong>Response</strong><br />

The mortality was checked and we found the lodgepole pine mortality was less than originally projected.<br />

The lodgepole pine empirical yields will be modified based upon the measured mortality rates. Also<br />

the dead lodgepole pine will be removed from the ASO so only green sawtimber will be in the ASQ.<br />

Comment<br />

We are especially concerned about the preferred alternative's reduced ponderosa pine harvest levels.<br />

The Forest's timber cut and sold reports show that the Winema actually sold an average of 93.2 million<br />

board feet of ponderosa pine sawtimber per year between 1977 and 1986. The proposed plan would<br />

sell about 80.8 million board feet per year over the next ten years; a level 13 percent less than the<br />

1977-86 historic average (DEIS Table 11-23).<br />

<strong>Response</strong><br />

Table 3-8 shows the historic harvest level by species. Table 3-8 is more indicative of the actual local<br />

demand than the sell. During that period many sales were defaulted and returned to the Forest Service<br />

without being cut. The harvest is scaled volumes and show what was actually used.<br />

Comment<br />

Given the significant green sawtimber harvest reduction proposed in the draft plan, we believe the<br />

Winema's preferred alternative will have to be revised if the Forest hopes to produce sufficient timber<br />

to maintain the economic stability of timber-dependent communities. The land allocations and ASO<br />

established in the final plan must recognize: (1) the local timber industry's current, post-recession raw<br />

material requirements; (2) the impending reduction in private timber harvest levels; and (3) the major<br />

harvest reductions proposed on adjoining national forests. As a minimum, the Winema's green sawtimber<br />

sale program for the next ten years should be as close as possible to the Forest's own historic sell<br />

level; especially in the critical ponderosa pine component.<br />

<strong>Response</strong><br />

These factors were all concidered in detail but the preferred alternative does not maintain local industry<br />

and we expect some major restructuring of the local timber industry will need to occur to get the milling<br />

capacity in line with available timber supplies.<br />

K - 200

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Comment<br />

Uneven-age, mixed species forest management can draw on all the acquired skills of the professional<br />

or trained forester. Hence, the culmination of such management, i.e., the harvest should not be performed<br />

by volunteer, un-skilled, or semiskilled personnel. Uneven-aged management implies some form of<br />

selection and this selection is critical (highly so) to the development of the forest until the next cutting<br />

cycle. Observations have been made on U.S.F.S. sales where there was obviously no silvicultural objective<br />

in the marking practice. Rather, there appeared to be a random selection of trees to meet some<br />

preconceived quantitative quote.<br />

<strong>Response</strong><br />

A silviculture prescription is written for each timber management activity and then monitoring occurs to<br />

make sure the prescription is properly applied. All prescriptions are certified as meeting management's<br />

objectives by a trained silviculturist.<br />

Comment<br />

We suggest that group selection be used in conjunction with uneven-aged management prescriptions.<br />

This would allow removal of groups of older, poor formed or defective trees that may not release well.<br />

It would also allow sunlight to the Forest floor to promote forage growth and provide edge conditions<br />

so important to wildlife. We would suggest these group selections to be made on areas from 1/4 to<br />

1/2 acre in size.<br />

<strong>Response</strong><br />

We agree. The plan has a maximum group size specified at 2 acres but most will be much smaller.<br />

Comment<br />

We suggest the 40,547 acres allocated to old growth as required by old growth indicator species in<br />

the LRMP could be reduced if uneven-aged management is used. Uneven-aged management will<br />

provide additional habitat in managed stands to provide a portion of these species requirements. A<br />

snag retention policy and requirements to leave prescribed numbers of cull logs in the woods during<br />

logging operations will insure additional habitat for none game species. We feel uneven-aged<br />

management can successfully be practiced in some pine, pine associated and lodgepole pine old<br />

growth areas with little if any detrimental affect on wildlife.<br />

As you can see we support uneven-aged management. That management system may produce slightly<br />

less forage and timber and it may not, but if it does produce less the trade offs are well worth it. We<br />

would expect a more natural appearing forest, a better dispersion of wildlife cover and more areas<br />

available for timber harvest.<br />

<strong>Response</strong><br />

The ecologists and wildlife biologists do not feel the stands treated by a selection harvest meet the<br />

requirements for oldgrowth.<br />

Uneven-aged management should minimize many conflicts between the competing resources but it<br />

won't provide oldgrowth, unaltered stands which many folks seem to want.<br />

Comment<br />

We are concerned that the LRMP and DEIS did not adequately address management of wet and moist<br />

lodgepole pine stands. The management of these stands to enhance their wildlife benefits such as<br />

cover and fawning/calving areas need to be identified and addressed with wildlife as a priority<br />

consideration. We add however, that in the event of heavy Mountain Pine Beetle mortality they should<br />

be selectively logged. That logging should be wildlife oriented and leave healthy trees and as much<br />

reproduction and brush as is possible. If they are not logged the snags will fall in such concentrations<br />

that big game travel will be restricted to the point of loss of the habitat, a fire hazard will be created<br />

that could be devastating and the beetle would spread to adjoining stands.<br />

K - 201

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<strong>Response</strong><br />

Chapter 4 of the Forest Plan contains the Standards and Guidelines for riparian areas. Wet and moist<br />

lodgepole pine areas are managed for their wildlife habitat.<br />

The plan does call for salvage logging the dead lodgepole pine and that should prevent the fire hazard<br />

and the loss of wildlife habitat to large accumulations of dead and down lodgepole pine.<br />

Comment<br />

Consideration should be given to clearing or thinning along high speed highways such as Highway<br />

97, where road kill is a problem due to lack of visibility. This would also help in letting sunlight to the<br />

road surface to allow natural ice melt.<br />

<strong>Response</strong><br />

Little of the Highway 97 corridor is near lands owned by the Winema National Forest. The State Highway<br />

Department has been working with private land owners along Highway 97 to purchase sufficient<br />

right-of-way so visibility can be improved along the highway.<br />

Comment<br />

Uneven-aged Management - The Winema is to be commended for this approach. Uneven-aged<br />

management is very acceptable to the public and certainly minimizes any conflicts. We do not, however,<br />

believe that we should see any reduction in yield potential on these lands. Many private lands have<br />

been managed without losses in yields and in fact the State of Oregon's response indicates that by<br />

using PROGNOSIS you will 'experience no falldown on yield for uneven-aged ponderosa pine<br />

management. Assuming no loss in yields we recommend the expansion of this system where applicable.<br />

<strong>Response</strong><br />

We agree. Our uneven-aged management yield tables were redone using the SORNEC version of the<br />

PROGNOSIS model. These new yield tables had similar yields to the even-aged tables.<br />

Comment<br />

Research Natural Areas - We do not sup-port the inclusion of the 852 acres of the Cherry Creek Basin<br />

lying outside of the Sky Lakes Wilderness Area. We certainly recognize that this is a very small land<br />

allocation and will have minimal impact on the timber sale levels. However, it does appear to be something<br />

of a wilderness buffer. If that was not the intent please inform us as to what the intent actually was.<br />

<strong>Response</strong><br />

The intent of the Cherry Creek Basin RNA was to include a 3rd order drainage. The additional acreage<br />

is needed to meet the intent of the RNA. In no way is Cherry Creek Basin a buffer to the wilderness.<br />

Comment<br />

We support the areas included in the draft plan except for that part of the Cherry Creek Basin which<br />

lies outside of the Sky Lakes Wilderness. This appears to us to be a wilderness buffer." Also, we request<br />

additional detailed inventory and classification efforts to insure that duplication is both minimal and<br />

intentional in land types set aside on wilderness, research natural areas, special management areas,<br />

and old growth. Excessive duplication would unnecessarily impact timber volumes.<br />

<strong>Response</strong><br />

The location of the RNAs are based upon inventoried needs. The Oregon Heritage Council keeps<br />

track of which plant communities are represent upon RNAs and recommends needed additions.<br />

Comment<br />

There is no way that alternative E proposed harvest levels will even let the Forest get through the first<br />

decade. I have personally looked at the plantations that have been created within the last eight years<br />

primarily on the Chiloquin and Chemult Districts, 50,000 to 60,000 acres, and the growth rates that are<br />

indicated in the plan do not correspond to the growth rates that are actually taking place on the ground.<br />

K - 202

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The Forest has plantations that are 8 to 10 years old that are less than 3 1/2 feet tall, they are not<br />

providing cover for wildlife, and are seriously affecting permitted livestock grazing, by forcing livestock<br />

to concentrate more in the meadows and riparian areas.<br />

<strong>Response</strong><br />

The Forest has plantations that are both growing faster than the average yield table and some that are<br />

growing slower than the average yield table.<br />

I believe your point is that we would not be able to maintain the harvest level projected in decade one<br />

in Alternative E. This true. Alternative E is a departure alternative that has a much lower harvest in<br />

decade two.<br />

Comment<br />

One of the more serious limitations of the plan is that plantation growth and acreage is not properly<br />

accounted for, and this will cause timber harvesting to fall down even sooner if a more prudent harvest<br />

level is not ed that accounts for these plantations and for those areas that have recently burned within<br />

the last 8 years.<br />

<strong>Response</strong><br />

The FORPLAN data base was updated to September, 1988 for all the cut over acres. The growth rate<br />

of the plantations was based upon actual measured growth rates.<br />

Comment<br />

The other factor is that the Chiloquin District has invested so many dollars in gopher control and replanting<br />

that the Forest will probably never realize any net return from the trees that finally do make it.<br />

<strong>Response</strong><br />

Plantation establishment is very expensive and was included in the cost data for the FORPLAN model.<br />

The model shows that it is cost effective to assure reforestation.<br />

Comment<br />

We are convinced that growth rates that form the basis for both the even-aged and uneven-aged<br />

management areas are understated. So while we believe the ASO should be a sustainable volume for<br />

all species but lodgepole pine, we also believe that the sustainable level is higher than your proposal.<br />

<strong>Response</strong><br />

The growth rates are based upon actual tree measurements. The growth rates are good representations<br />

of our average expected growth rate.<br />

Comment<br />

The compilation of the planning documents and the development of background data upon which<br />

they are based certainly represents a monumental and complex task. Nevertheless, I was somewhat<br />

disturbed by errors and mistatements occurring in the Plan. They made analysis difficult and lead me<br />

to suspect the ability of even many Forest Service personnel to grasp the significance of the proposals<br />

and to successfully implement the Final Plan. These include the figures in Table IV-9 and the description<br />

of Note 3 to Table IV - I which describes the 166.1M acres with 50-99% yield as including Management<br />

Area 12B (uneven-aged timber management).<br />

<strong>Response</strong><br />

Upon review, We don't see the problem with these tables. I'm sure there are some errors in the DEIS<br />

and I'm sure there will be some errors in the FEIS. The EIS and Plan are reviewed but some errors still<br />

seem to slide through. Errors discovered after the plan is published will be corrected with amendments.<br />

Comment<br />

The re-measurement of continuous forest inventory plots on Klamath Indian Trust lands over a fifteen<br />

year period indicates the diameter growth used in the Winema yield tables is too conservative. Many<br />

K - 203

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of the plots are still available and would provide a 25-year history of growth and mortality, if re-measured.<br />

Measurements during the first 15 years indicate your allowance for mortality is too high. Excerpts from<br />

a growth report based on these plots are included in an exhibit to the attached Position Paper. Reference<br />

is also made there to growth data from the Flathead Indian Reservation which supports the use of<br />

higher diameter growth rates.<br />

<strong>Response</strong><br />

The yield tables were checked and we decided the uneven-aged tables were underestimating growth.<br />

The uneven-aged yield tables were redone using the SORNEC version of the PROGNOSIS model. This<br />

model is based upon our measured inventory growth rates and upon research measurements for<br />

managed stands.<br />

Comment<br />

It is my opinion that yields will suffer with thirty year cutting cycles as you propose - especially at the<br />

stocking levels suggested in your yield tables. Diameter growth will seriously be impaired toward the<br />

end of the cycle. Logic tells me that a stocking level should be sought that will produce near maximum<br />

diameter growth rates and that level of stocking should be maintained within fairly close limits. In my<br />

opinion, the cutting cycle should not exceed 15 years. Even at yields as low as predicted in your yield<br />

tables such as 32 cubic feet per acre, this would produce a harvest level of about 2600 board feet per<br />

acre which is reasonable as witnessed by the following limited list of sales with which I have been<br />

involved.<br />

Klamath Indian<br />

Acres<br />

Volume/Acre<br />

9,066 1,376<br />

1,950 4,100<br />

5,611 2,986<br />

790 2,806<br />

2,615 2,379<br />

760 2,485<br />

Private<br />

Acres<br />

Volume/Acre<br />

573 2,970<br />

596 2,438<br />

160 581<br />

40 2,575<br />

80 2,100<br />

240 1,600<br />

<strong>Response</strong><br />

Selection harvest is a regeneration cut. It is necessary to lower the stocking level each entry sufficiently<br />

to allow regeneration to occur, not to just maintain diameter growth. Our prescriptions for uneven-aged<br />

management calls for reducing the growing stock to 25 percent of maximum stand density index or 45<br />

percent of maximum basal area. This is about 65 square feet of basal area in ponderosa pine stands.<br />

K - 204

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It then takes 30 years for the stand to grow back to the point were suppression mortality would begin.<br />

These are the assumptions behind our entry cycle in the uneven-aged management yield tables.<br />

Comment<br />

These plots were installed at the rate of about 100 per compartment in 10 compartments. This spacing<br />

resulted in an intensity range of from 12 acres per plot to 215 acres per plot with an average intensity<br />

of 113 acres per plot. A much more intensive analysis of this data can provide many answers to questions<br />

concerning the application of the selection system (and uneven-aged management) on an historical<br />

basis rather than a theoretical basis. I recommend that such an analysis be made.<br />

<strong>Response</strong><br />

We would appreciate receiving such an analysis.<br />

Comment<br />

There is every indication at this time that the Winema staff is open to incorporating technical adjustments<br />

into the final plan. These should include a correction to the acreage of tentatively suitable forest land<br />

which was understated by some 24,000 acres. Increased ponderosa pine yields should also be included<br />

for uneven-aged managed stands, which were too conservative when compared with other data similar<br />

to those displayed in the attached Exhibit which shows growth and yield data from Indian forests.<br />

<strong>Response</strong><br />

These corrections were made.<br />

Comment<br />

There are some grave inconsistencies within the Forest Service data also. For instance, for one large<br />

component of the forest, growth is stated to be 18.2 cubic feet per acre while the Forest Service inventory<br />

indicates the measured growth for the same component is 25.4 cubic feet.<br />

<strong>Response</strong><br />

The differences between the empirical yield table growth and the measured inventory growth is a reduction<br />

to account for the growth which is not captured.<br />

Comment<br />

There is also some evidence that the use of improper cost data and the maximization of net present<br />

value may result in the establishment of lower yields than necessary. These factors should be examined<br />

more carefully by he Forest Service.<br />

<strong>Response</strong><br />

Managing for maximum timber yield does not achieve the highest possible net present value. The<br />

preferred alternative optimizes timber yield while still being cost effective.<br />

Comment<br />

The preferred Alternative E is a pretty good plan and I credit the Forest Service in it's development.<br />

However, the departure of Ponderosa pine from 90 MMBF to 80 MMBF will have serious implications<br />

on the economy of the basin at a time when the economy is already very shaky. If the Forest Service<br />

absolutely must reduce harvest levels of Ponderosa pine then I suggest they come up with some mitigating<br />

measures.<br />

<strong>Response</strong><br />

Table 3-8 shows the past harvest of ponderosa pine. Maintaining a harvest of 80 mmbf per year would<br />

take a departure from sustained even flow in ponderosa pine. We received several comments requesting<br />

we select an alternative that would maintain an even flow of ponderosa pine, which is done with the<br />

preferred alternative.<br />

K - 205

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There are no mitigating measures to offset this loss in volume.<br />

Comment<br />

The Forest Service should start investing much more heavily into resource inventories. I am surprised<br />

that only 400+ permanent plots are the basis for all of these deliberations (Forest Plan). As a starter,<br />

for the first five years, until you get to a maintenance mode, you should be investing at least $.50/ac/year,<br />

or establishing a good, reliable, maintainable inventory.<br />

<strong>Response</strong><br />

The current inventory is a stratified randomly sampled inventory. It is very accurate at determining the<br />

standing inventory on the entire Forest but loses its accuracy as the stratifications are further divided<br />

for land use planning purposes. The Forest is planning a new inventory which will have a computer<br />

based map system with ely four times as many satisfactions as the current inventory. It is being designed<br />

to give accurate inventories for the smaller stratifications needed for Forest Planning. This inventory is<br />

planned to be completed during the planning period covered by the FEIS and prior to preparing the<br />

next Forest Plan.<br />

Comment<br />

No one has demonstrated sustainable forestry beyond one or two rotations. Recent data indicate that<br />

irreparable degradation must be expected if the Forest is not managed as a WHOLE SYSTEM. Habitat<br />

loss cannot be mitigated.<br />

<strong>Response</strong><br />

The management areas for the Forest Plan are a complex mix of harvest, partial harvest and no harvest<br />

prescriptions with Standards and Guideline to maintain soil structure and productivity.<br />

Comment<br />

Old growth is definitely seen as a commodity to be liquidated - the timber companies demand it - especially<br />

from the unroaded areas. And where in your plan, is the renewal of old growth? (One has to find some<br />

woodpeckers or owls in order to preserve a patch of old growth!) Where is the renewal of the forest,<br />

i.e., mixed age and species?<br />

<strong>Response</strong><br />

Old growth timber does have a very high value and is in demand by the wood products industries.<br />

Areas that will provide old-growth in perpetuity include wilderness areas, semiprimitive recreation areas,<br />

unique areas, research natural areas, and designated old-growth management areas. Table 2-4 shows<br />

the allocation to these management areas.<br />

Uneven-aged has been designated as the preferred silvicultural treatment in the ponderosa pine and<br />

pine associated timber types. This will maximize the mix of species and age classes in those timber<br />

types. We will be planting pine trees in the mixed conifer type to re-establish the historical levels of<br />

pine in that timber type.<br />

Comment<br />

How about setting aside some uneven-age mixed specie young Forests for the old growth Forests of<br />

the future?<br />

<strong>Response</strong><br />

We analyzed different ways to provide old-growth stand conditions, and found that designating stands<br />

in perpetuity was the most efficient way to achieve our old-growth objectives.<br />

Comment<br />

If the demand for timber is going to grow 'slowly' and projections for increased demand are 'considerably<br />

restrained and cautious,, and demand curves 'downward sloping," why are we departing from even<br />

flow and raising the harvest 25%?<br />

K - 206

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<strong>Response</strong><br />

The preferred alternative has been changed as follows: ponderosa pine will be managed on a sustained<br />

even-flow basis; and the lodgepole pine will be harvested at an accelerated rate to minimize loss to<br />

the mountain pine beetle, but only to the extent possible while meeting minimum mule deer habitat<br />

requirements.<br />

Comment<br />

If Kiamath Falls depends largely on out-of-county logs, with the Winema supplying only 15%, why are<br />

we increasing harvest by 25%?<br />

<strong>Response</strong><br />

We did not receive support for our departure proposal so that has been removed from the preferred<br />

alternative.<br />

Comment<br />

Does uneven-aged management, as defined by the Forest, satisfy the needs of the Tribe? If the Tribe's<br />

definition of 'enjoyable experience' includes old growth ponderosa pine, uneven-age management will<br />

not fulfill the Tribe's wishes.<br />

<strong>Response</strong><br />

It is very difficult to evaluate how folks will relate to uneven-aged management. An uneven-aged<br />

management demonstration area was harvested on the Chiloquin so we could get this type of feedback.<br />

I don't know of any tribal members who visited the site who were dissatisfied with the uneven-aged<br />

silvicultural system.<br />

Comment<br />

Why is the table in MMCF? MBF is more commonly used and may be more easily understood by the<br />

public.<br />

Is departure from even-flow consistent with the Forest Service Mission of 'Caring for the Land'? We<br />

may be serving a small number of citizens for a few years by subsidizing a declining timber market,<br />

but this is a national resource, not the Klamath Falls Tree Farm. What happens to 'historical levels' of<br />

county receipts when the Forest ASQ drops in Decade 3?<br />

<strong>Response</strong><br />

The table in the Forest Plan is in MMCF, because the Plan will be monitored in cubic feet. Wood products<br />

companies make many products out of sawlogs other than just boards, so the board foot measurement<br />

is becoming obsolete.<br />

A departure from even-flow is consistent with the concept of 'Caring for the Land." Standards and<br />

guidelines would be followed and the long-term productivity of the forest would not be impaired.<br />

The departure was proposed to help even out the availability of timber for the sawmills in the Kiamath<br />

timber shed as proposed in the Forestry Plan for Oregon. This was not supported by the public and<br />

has been removed from the final plan.<br />

Comment<br />

How many acres of lodgepole were historically cut to achieve 3.41 MMCF? Again - why do we keep<br />

switching from MMBF to MMCF?<br />

What does managing lodgepole to a 'a level of low risk for future MPB infestations' mean? Short rotations?<br />

Be specific.<br />

<strong>Response</strong><br />

The historical cut level of lodgepole pine has been 6320 board feet per acre; which equals 1254 cubic<br />

feet per acre. It would take 2719 acres to produce 3.41 MMCF of harvest.<br />

The board foot measure is becoming obsolete so the plan will be monitored using cubic feet. That is<br />

why the tables are presented in cubic feet. Board feet is also presented to help people familiar with<br />

board feet make the conversion.<br />

K - 207

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Chapter 4 of the FEIS in Effects of the Alternatives on Forest Pests speaks to minimizing losses to<br />

mountain pine beetle.<br />

Comment<br />

The use of the words "resource constraints" is not appropriate in a multiple resource management<br />

approach.<br />

How will maintaining historic levels of ponderosa pine harvest affect our ability to maintain viable wildlife<br />

populations?<br />

How will we make lodgepole less susceptible to beetle attack? Be more specific.<br />

<strong>Response</strong><br />

Coordinating requirements is more appropriate than constraints. All the resource needs are evaluated<br />

together to meet the combined needs of all.<br />

Folks think in terms of resource constraints because the usual outcome of a specific requirement is to<br />

constrain or lower the potential output of another resource.<br />

The effects of maintaining the historic sell levels of ponderosa pine are discussed in Chapter 4 of the<br />

FEIS in the section titled Effects of the Alternatives on Wildlife Communities.<br />

A vigorous stand of lodgepole pine, which is open and free to grow, is not susceptible to mountain<br />

pine beetles. Our current lodgepole pine stands are overstocked and quite old. the mountain pine<br />

beetle will continue to kill trees until vigor is restored. This is discussed in Chapter 4 of the FEIS in the<br />

section titled Effects of the Alternatives on Forest Pests.<br />

Comment<br />

Please explain what a "regulated" forest looks like. Does the public have any idea what this means?<br />

Will a regulated forest still include any unmanaged lands? How much?<br />

<strong>Response</strong><br />

A regulated forest is a forest which is organized and achieves sustained yields. A regulated forest<br />

would have equal amounts of stands in each desired age class. If for example, the forest was to be<br />

grown on a 100 year rotation, 25% of the forest would be 0-25 years old, 25% would be 26-50 years<br />

old, etc. Since we have few regulated forests in the United States, most people do not have an<br />

understanding of a regulated forest.<br />

Table 24 in the FEIS shows the number of acres in each management area. See th e description of<br />

the management area in Chapter 2 of the FEIS to see which management area are left in a natural<br />

state.<br />

Comment<br />

What will happen to receipts to the county when all the pine is gone? Is it good economics to go to a<br />

high volume departure for the short term at the expense of long-term economic stability?<br />

Why aren't roadless ares included in the list of areas with no scheduled harvest?<br />

Where is "no scheduled harvest" defined? It should be made clear to all readers that no scheduled<br />

harvest does not necessarily mean no cutting.<br />

<strong>Response</strong><br />

Table 2-19 in the FEIS shows the projected returns to the County. The species mix is very important to<br />

the projected returns to the County. The ponderosa pine harvest raises the returns to the County where<br />

the lodgepole pine, with its low value, reduces returns to the County. The two can have an off-setting<br />

effect. The departure in the DEIS preferred alternative was designed to off-set the short-term projected<br />

decline in timber supply, as indicated in the Forestry Program for Oregon, which would improve long-term<br />

economic stability. The roadless areas were allocated to several management areas, some with a<br />

programmed harvest, others without. The roadless area acres allocated to management areas with a<br />

programed harvest would be entered when ever it was best for the overall management of the forest.<br />

Appendix C in the FEIS discusses each roadless area and management area allocation for each. Table<br />

C-3 shows the acres which would not be developed during the next 15 years for each roadless area.<br />

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Salvage harvest is permissible on some lands that do not have a programmed harvest. Table B-5 in<br />

the FEIS indicates if harvesting is permissible within a management area.<br />

Comment<br />

Need more specific information on how timber management plan would be modified with changing<br />

conditions/information.<br />

165,000 cords of firewood can hardly be called 'incidental.' How many MMBF does this equal?<br />

<strong>Response</strong><br />

The sale plan, as shown in Appendix A of the Forest Plan, is reviewed yearly. Planned areas may produce<br />

more or less timber volume than expected, updated logging plans may revise road needs, etc. These<br />

are the types of situations that cause a change in the sale plan.<br />

The 165,000 cords you speak of is an estimate of the total possible firewood that could be made available.<br />

165,000 cords is ely 82,500 MBF. The current harvest of firewood is about 7,000 MBF or 14,000 cords.<br />

Comment<br />

By the end of the 5th decade the ONLY 160+ age group trees to be found will be in the uneven-age<br />

management area (according to table). This is unacceptable in a multiple use forest. How many trees/acre<br />

over 160 years old will be maintained through decade 5 in the uneven-age area?<br />

<strong>Response</strong><br />

Your comment references page IV-23 in the proposed Forest Plan. Table IV-4, which is on page IV-23,<br />

shows the planned silvicultural treatment by management area The question does not seem to relate<br />

to the table.<br />

Figure IV-1 in the FEIS shows the acres by age class projected through the planning horizon.<br />

The uneven-aged management acres are not included in the figures because all age classes are<br />

represented on every acre. The maximum residual tree size planned for varies between 24 inches DBH<br />

and 36 inches DBH depending on species and management area.<br />

Comment<br />

Are "desired" levels of mature and old growth the same as minimum levels? Just because harvest is<br />

not 'programmed' in these areas does not assure they will not be cut. Need to clarify language.<br />

<strong>Response</strong><br />

Table B-5 in the FEIS indicates if harvesting is permissible within a management area.<br />

The alternative descriptions in Chapter 2 of the FEIS indicates if the 'desired' levels of old-growth are<br />

at or above the management requirements for old-growth.<br />

Comment<br />

In light of the fact that old growth ecosystems cannot be reproduced silviculturally, the only prudent<br />

course of action for the WNF is to institute a complete moratorium on the cutting of naturally evolved<br />

old growth forests. There is a major and complex qualitative difference between a true old growth<br />

ecosystem and a second growth forest. No matrix of indicator species MMRs and silvicultural prescriptions<br />

can recreate a naturally evolved old growth ecosystem. Though we favor plans to manage already<br />

disturbed sites so as to re-establish old age classes on the Forest, we believe that all remaining<br />

undisturbed, naturally evolved old growth communities on the Forest must be preserved and dedicated<br />

in habitat for the numerous dependent plant and animal species that inhabit these magnificent<br />

ecosystems. The WNF has a vital role to play in the long-term viability of an entire ecosystem and in<br />

the survival of the numerous old growth dependent wildlife and plant species.<br />

<strong>Response</strong><br />

The Winema National Forest has been researching old records and photographs to try to determine<br />

what an old growth, undisturbed stand really is for the Winema. Our ecologist hasn't completed the<br />

determination, but it appears the ponderosa pine old-growth forests were very open stands with few<br />

understory trees and little to no ground cover. Lodgepole pine forests were probably never very old<br />

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and regenerated often. The mixed conifer forests had a high component of various pine trees in the<br />

old growth condition.<br />

These conditions do not exist on the Forest any longer. Fire control activities have eliminated the frequent<br />

fires so now pine stands have become multistoried and quite dense, the lodgepole pine has become<br />

very old and is dying very quickly, and fir trees now dominate the mixed conifer forests. Logging has<br />

removed the largest, most valuable trees from most of forest open to timber management.<br />

We believe that a portion of the Forest may be set-aside for old-growth, and that we will need to manage<br />

these stands to actually maintain a naturally occurring old-growth stand. Without management, old-growth<br />

stands on the Winema will continue to become more dominated by fir trees until ponderosa pine will<br />

be completely excluded from the forest, except in ponderosa pine climax sites.<br />

Comment<br />

I have heard it said that your yield tables are too conservative. If you have some reservations about<br />

the tables you are using, I hope that further tests can be made to determine their validity.<br />

<strong>Response</strong><br />

We did review our yield tables and have elected to redo the uneven-aged management yield tables<br />

using the PROGNOSIS growth and yield simulator. PROGNOSIS is the "state of the arts in growth and<br />

yield simulation for the Winema. We compared the even-aged management yield tables against<br />

PROGNOSIS and found there to be no difference.<br />

Comment<br />

The preferred alternative proposes surpassing the sustained yield of both lodgepole and ponderosa<br />

pines. Logging, even at sustained yields, insures that residences, apartments, commercial structures<br />

and cabinetry will continue to be built almost exclusively of wood products, a practice that condemns<br />

inhabitants to premature deaths. The use of formaldehyde, a proven carcinogen, is common in trusses,<br />

beams plywood waferboard and particleboard. Chloridane, another deadly carcinogen, is necessary<br />

and legal for termite protection. Herbicide sprays used by the Forest Service in its 'tree farm' operations<br />

have been linked to the incidence of cancers and Sudden Infant Death Syndrome in adjacent human<br />

populations.<br />

<strong>Response</strong><br />

Your concern for chemicals used during processing or for protection is outside the scope of this<br />

environmental impact statement.<br />

The use of herbicides on the Forests of the Pacific Northwest was studied and documented in the final<br />

Environmental Impact Statement titled Managing Competing and Unwanted Vegetation.<br />

Comment<br />

The Winema National Forest manages about 20,000 acres of O&C lands. These lands are particularly<br />

important to local governments since 50 percent of the timber revenue is transferred to the counties.<br />

The Final EIS should show the location of these lands, how they are treated in the various alternatives,<br />

and their contribution to county payments.<br />

<strong>Response</strong><br />

The Winema National Forest manages acres of former O&C lands. These lands are to be managed<br />

just like any other National Forest land except the lands are subject to the O&C fund distribution formulas.<br />

A map showing the location of the former O&C lands has been placed in the land ownership section<br />

in Chapter 3. Chapter 4 speaks to the effect of the alternative on O&C receipts.<br />

Comment<br />

One of the major reforestation problems facing the Klamath R.A. and the Winema Forest is summertime<br />

frost. It is a well-known problem, and I have become very familiar with it. Even-aged management systems<br />

as you propose will not allow for the regeneration of frost susceptible species such as Douglas-fir,<br />

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white fir and Shasta fir. Traditional shelterwoods and clearcuts do not afford the necessary thermal<br />

protection that these species need for regeneration.<br />

The Klamath R.A. is ing a variety of silvicultural techniques in the lands we manage in Klamath county.<br />

Heavy shelterwoods (> 160 sq. ft. basal area), narrow strip clearcuts (< 120 feet wide), group<br />

shelterwoods and single tree selection are all being practiced in the frost prone areas.<br />

On page IV-1 25, it is stated that trees larger than 24" DBH are removed at each entry of an uneven-aged<br />

management area. I would encourage the Winema Forest to consider leaving trees larger than 24a. A<br />

classical uneven-aged forest has trees representing all diameter classes, ages and species. By removing<br />

all trees larger than 24e on each entry, the forest could be losing a significant component necessary<br />

for regeneration, site productivity, and wildlife.<br />

<strong>Response</strong><br />

Choosing a maximum residual tree for uneven-aged management stands is a compromise between<br />

maximizing yields, which would use a maximum residual tree size of 16 inches, and producing a stand<br />

that has expected characteristics. Twenty-four inches reduces yields slightly but gives the larger trees<br />

many people want to see. Visual sensitive areas will have maximum residual trees 30 to 34 inches i<br />

diameter. The 24 inch maximum residual tree size has no effect on regeneration, site productivity or<br />

wildlife. Twenty inches is the largest tree needed to meet wildlife habitat in eastern Oregon.<br />

Comment<br />

The Winema National Forest yield tables are definitely overly optimistic.<br />

<strong>Response</strong><br />

The yield tables were developed using the latest stocking levels and growth information and then received<br />

a peer review before approval. We feel quite confident that the yield tables represent the growth and<br />

yield for the management intensity they represent.<br />

Comment<br />

The basic justification for the departure is the maintenance of economic stability in the Klamath Basin.<br />

The timber industry has stated that they desire a continued supply of clear, straight-grained lumber<br />

from large diameter ponderosa pine. The Winema National forest, seems to have accepted the idea<br />

that an economy based on smaller diameter fast growing trees will be superior to one based on lower<br />

volumes of mature ponderosa pine. This assumption is questionable since mature ponderosa is evidently<br />

the most economically desirable product. The departure would result in less wood being available in<br />

the future, as well as a trade-off of quality lumber for cheap wood fiber from young fast growing trees.<br />

<strong>Response</strong><br />

The Forestry Program for Oregon shows that there will be a decline in available timber from private<br />

lands in the Klamath Basin and that if Federal lands would increase their harvest during the time period<br />

that timber supplies are low, that the negative impact on the local economy could be minimized. The<br />

draft was designed to maintain the current harvest level of ponderosa pine for 40 years, which at that<br />

time, private timber would again be available. The local industry and general public did not support<br />

this concept so the final selected alternative has a sustained even-flow of ponderosa pine.<br />

Local industry felt ponderosa pine trees larger than 20 inches in diameter would meet their need for<br />

quality ponderosa pine. Our silviculture prescriptions for ponderosa pine will produce some trees larger<br />

than 20 inches.<br />

Comment<br />

The timber industry is in error when it blames declining local employment on a decline in the timber<br />

supply. The number of people employed in the timber industry has declined, and continues to decline,<br />

because of mechanization and not because of a decline in the timber supply. If the Winema converts<br />

to small fast growing stands of trees this trend toward mechanization will only be increased.<br />

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<strong>Response</strong><br />

Yes, we agree that timber industry will continue toward mechanization. We don't agree that mechanization<br />

is necessarily tied to tree size, but instead is tied to the relationship between labor costs versus the<br />

cost of mechanization.<br />

Comment<br />

During the 1970's then Regional Forester, Richard Worthington, met with local Klamath Basin Industry<br />

and Tribal members concerned with the heavy use of clear cutting practices. He and the Winema<br />

Supervisor concurred that uneven-aged management was to be used to the maximum extent possible<br />

and there should be no need to reduce harvest levels. The draft forest plan seems to indicate 80 percent<br />

of the commercial base is to be managed by even-aged management techniques. Excluding the lodgepole<br />

that essentially requires a clearcut system, are we to assume the forest is returning to a heavy clearcut<br />

policy? If so, it violates past commitments. The forest can be largely managed without clearcutting.<br />

<strong>Response</strong><br />

No, the Forest is not moving toward a clearcut regeneration system. Uneven-aged management is<br />

planned for the ponderosa pine and pine associated working groups and uneven-aged management<br />

and shelterwood regeneration systems will be used on the mixed conifer working groups wherever it is<br />

practical and still control the Armillaria root rot.<br />

Comment<br />

Empirical yield tables - The tables reportedly developed by regional office staff - without use of many<br />

decades of plot growth data already on file and the reduction of these yield tables on the Winema by<br />

50 percent in order to be safe" make these estimates unreliable, erroneous and have flawed the analysis.<br />

I can find no documentation of the origin of these projections in the material made available in this<br />

nine pound document for public review. It appears to have been a subjective decision and should not<br />

be permitted when opportunity for jobs, community and national income are at issue.<br />

<strong>Response</strong><br />

Documentation of the process which has been used is on file in the Regional Forester's office. The<br />

process has been critiqued and modified in past planning and field review indicates that yield curves<br />

are reasonable. There are some recognized shortcomings in the process, however, there are established<br />

checkpoints for evaluation and possible modifications of yields.<br />

For the final all the empirical yields were updated to the midpoint of the planning period (1994). Also<br />

between the draft and final, all the lodgepole pine inventory plots were visited to determine the current<br />

mortality in the lodgepole pine. This information was then used to adjust the lodgepole pine empiricals<br />

for mortality so the ASQ in the final only includes live and green lodgepole pine.<br />

Comment<br />

Resolved, that western national forests presently making new management plans give full consideration<br />

to the necessity of maintaining a forestland base capable of high sustained levels of timber production.<br />

To assure the stability of natural resource-based economies, the Forest Service is urged to plan to<br />

meet or exceed the Resource Planning Act sawtimber targets toward achievement of maximum net<br />

public benefits. The Forest Service is also urged to retain or enhance the economic viability of the<br />

timber sale program during the first decade of the plan period.<br />

<strong>Response</strong><br />

There are many demands by the public to maintain a visually pleasing forest as well as maintaining a<br />

wide variety of wildlife habitats. Alternative J, the preferred alternative, only achieves 62 percent of the<br />

RPA planned output. This will definitely impact the local economies and cause some reduction in<br />

employment in the timber industry.<br />

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Comment<br />

It is noted that the Forest Service no longer cites (36 CFR-221) as being part of their authorization<br />

although these regulations have not been superseded and should remain in force. Perhaps an<br />

acknowledgement these regulations by the Forest Service would strengthen their emphasis on a<br />

continuous supply of timber, stabilization of communities and opportunities for employment. Excerpts<br />

from these regulations follow.<br />

<strong>Response</strong><br />

We do acknowledge Part 221 of the CFR 36. Most of our alternatives produced a sustained even flow<br />

of sawtimber but to look at a full range of alternatives, departures were also examined. We spend<br />

many hour trying to 'Provide for coordination of timber production and harvesting with other uses of<br />

national forest land in accordance with the principles of multiple use management."<br />

Comment<br />

A priority for the Winema should be to develop and adhere to a management strategy that attempts to<br />

prevent insect and disease problems rather than reacting to them after they become epidemic.<br />

<strong>Response</strong><br />

Chapter 4, Effects of the Alternatives on Forest Pests, shows how the various alternatives address pest<br />

problems. The management strategy chosen must weigh the cost of preventing all losses to the values<br />

at risk. The selected alternative is a good compromise between the cost of prevention and the values<br />

at risk.<br />

Comment<br />

Based on the figures in table I1-3A of the DEIS, a ratio of 5.4 is used for board foot to cubic foot conversion<br />

in all alternatives. The use of an average factor for all alternatives does not accurately reflect the variation<br />

in the size of material produced by each alternative. For instance, alternative D, which emphasizes<br />

large diameter ponderosa pine would logically have a higher board foot to cubic foot conversion ratio<br />

than an alternative emphasizing production of smaller material. Since the ASQ and the LTSY are calculated<br />

using cubic feet, the conversion ratio has no affect on these figures. It does have an affect on the<br />

public's perception of the harvest level. We recommend the board foot to cubic foot conversion ratio<br />

reflect the material to be harvested in the first decade since that is the stated useful life of the new<br />

plan. This approach would provide a more realistic picture of the harvest level proposed by each<br />

alternative.<br />

<strong>Response</strong><br />

The board foot/cubic foot conversions did vary by alternative and decade. Referring to page 11-80 in<br />

the DEIS, you will see that the board foot/cubic foot conversions varied from board 5.59 to 5.13 between<br />

alternative and that the board foot/cubic foot conversions for the preferred alternative vary between<br />

5.13 and 5.48 by decade.<br />

Comment<br />

The discussion on timber supply analysis starting on page 111-34 of the DEIS indicates that predictions<br />

of supply from adjacent forests are based on 1983 RPA projections. We are concerned that those<br />

figures will be irrelevant when the planning process is completed and the new plan is implemented. A<br />

number of adjacent National Forests have proposed reduced harvest levels in their preferred alternatives.<br />

We recommend the Winema's analysis of the timber supply situation reflect the preferred alternatives<br />

of other National Forests in the area. Additionally, proposed changes in the ponderosa pine component<br />

of adjacent forest's timber sale programs should be included in the analysis.<br />

<strong>Response</strong><br />

The Fremont is the only adjacent forest with a Forest Plan, at this time, so it didn't seem to work to<br />

use interim decisions to do this analysis. Instead, the analysis was done similar to the DEIS Chapter 4<br />

but was updated using new supply and demand information. (See Chapter 4)<br />

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Comment<br />

I request that you closely examine opportunities to maintain the high quality ponderosa pine component<br />

of your timber sale program. My definition of high quality is D.B.H. of 20 or more inches, 10 percent of<br />

the volume of a timber sale with log grades higher than Grade 4, and tree ages of 100 years or more.<br />

I request that you investigate uneven-aged management and pruning to achieve this goal.<br />

<strong>Response</strong><br />

The selected alternative prescribes uneven-aged management for the ponderosa pine and pine<br />

associated working groups. ely a third of the volume removed at each entry will be in trees larger than<br />

20 inches DBH. Pruning is not planned for in this planning period. A study has not been completed to<br />

analyze the cost effectiveness of pruning in ponderosa pine.<br />

Uneven-aged management is prescribed for the ponderosa pine and pine associated working groups.<br />

This should take care of most of your concerns.<br />

Comment<br />

Because of the failure to determine the land's existing productivity and potential, the Tribe believes<br />

that restocking times used in the plan are dramatically underestimated. This miscalculation in turn<br />

affects dispersion standards, re-entry times, visual standards, forage capacity and a host of other resource<br />

output estimates. The Tribe further believes that is accurate regeneration speeds were to be used,<br />

there would be little timber volume production difference between uneven-aged management and<br />

even-aged management acreages.<br />

<strong>Response</strong><br />

The revised uneven-aged management yield tables do have similar outputs as the even-aged yield<br />

tables.<br />

Comment<br />

For these reasons, the Tribe suggests that the Forest Service design its management scheme based<br />

on the 'clues' given by the land, using acreage treated for a specific purpose per year as the standard<br />

measurement, rather than the ASO of each alternative. The Forest Service is mandated to manage the<br />

forest lands for multiple purposes. This mandate is not only found in its statutory obligations, but also<br />

in its duties as trustee of tribal treaty rights. Using acreage treated as a unit measurement requires<br />

consideration of the varying productivity and potential to produce a range of resources of different<br />

areas in the forest. It also builds in flexibility to apply the appropriate harvest method based on the<br />

conditions of the acreage and taking in to account other resource objectives.<br />

<strong>Response</strong><br />

Our past experience has led us away from unit area control to controlling on the growth potential of<br />

the Forest. The ASQ is based on the standing inventory, the growth potential and the current stand<br />

condition. This is the best basis for planning future harvest levels.<br />

Comment<br />

The number of acres shown as scheduled for regeneration harvest in the first decade must be updated<br />

to account for the recent years' sales.<br />

<strong>Response</strong><br />

The FORPLAN model was updated to September 1988.<br />

Comment<br />

The DEIS discloses that all acres scheduled for uneven-aged management will be harvested in the<br />

Chiloquin District and within the former reservation. In addition, 13% of the 'former reservation lands'<br />

according to DEIS) are scheduled for regeneration harvest in the first decade. DEIS 11-42. The scenic<br />

management dispersion standards will not be imposed in the first two decades and by decade 5, the<br />

average age of ponderosa pines which are important to the Tribe culturally drops from 125 years to 66<br />

years. The average programmed sale quantity exceeds average annual net growth for the first decade<br />

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y 100 MMBF, and exceeds long term sustained yield by 25 mmbf, assuming realistic productivity<br />

figures were used in calculating the yields. The Tribe can only conclude that the plan will allow a drastic<br />

over cut in the first two decades, seriously and adversely affecting the exercise of its treaty rights and<br />

the nature of the former reservation lands, as well as the long term economy of the Klamath Basin.<br />

These deficiencies must be remedied before adoption of the plan and EIS.<br />

<strong>Response</strong><br />

Alternative J was developed to address these concerns. All the ponderosa pine and pine associated<br />

working groups have a longterm goal of uneven-aged management. The selection harvesting has<br />

been leveled between decades. The ASQ of Alternative E was 199 MMBF where as Alternative J has<br />

an ASQ of 117 MMBF.<br />

Comment<br />

The NFMA requires that harvest levels be established to attain nondeclining even flow and limits departures<br />

from this level. Departures may occur to achieve multiple use objectives. If a schedule departure is<br />

justified by infestations of a stand or species, the timber must be substituted for timber that would<br />

otherwise be sold, unless not feasible. 16 USC 1611 (a) and (b).<br />

The plan provides for a two decade departure to convert lodgepole pine stands infested with beetles.<br />

There is no discussion of the feasibility of substituting the lodgepole for other scheduled harvests, as<br />

required by the NFMA. The final DEIS and plan should include this discussion. If substitution is feasible,<br />

other scheduled harvests should be delayed. The Act does not specify the parameters for determining<br />

feasibility, but it clearly requires more than a showing of infestation, and the justification cannot rely<br />

solely on perceived threats to community stability which is not a relevant factor under the NFMA. In<br />

addition, the Tribe questions the plan's assertion that the volume of lodgepole infested with beetles is<br />

so high. The final plan should also consider and account for the lodgepole departure harvest which<br />

has occurred since 1985.<br />

<strong>Response</strong><br />

Your reference to 16 USC 1611 (a) and (b) is not correct. 16 USC 1611 (a) and (b) states 'The Secretary<br />

may either substitute such timber for timber that would otherwise be sold under the plan, or if not<br />

feasible, sell such timber over and above the plan volume.!<br />

I believe your concern was met in Alternative J. In Alternative J the dead lodgepole pine has been<br />

removed from the ASQ. Removing the dead lodgepole pine is still a goal in Alternative J but if our<br />

estimate of the amount of dead lodgepole pine is wrong or if some of the dead lodgepole is left to<br />

provide wildlife habitat or to protect riparian zones, it will not effect the ASQ. Alternative J is not a departure<br />

from sustained even flow.<br />

Comment<br />

The yield tables also indicate that departures for ponderosa pine, true fir and Douglas-fir stands are<br />

planned, although the plan does not refer to these as departures. Table 11-3A. Implementation of the<br />

plan will drastically change the species composition in the forest, reducing community diversity, and<br />

arguably violating the Act's requirement that existing diversity of species be preserved. NFMA, 16 USC<br />

1604(g)(3)(B). In addition, the overall harvest levels cannot be considered to represent non-declining<br />

even flow as required by the NFMA.<br />

<strong>Response</strong><br />

The Act does not require the preservation of the existing diversity of species. The Act states: 'The<br />

regulations shall include, but not be limited to<br />

(3)specifying guidelines for land management plans developed to achieve the goals of the Program<br />

which--"(B) provide for diversity of plant and animal communities based on the suitability and<br />

capability of the specific land area in order to meet overall multiple-use objectives, and within<br />

the muftiple-use objectives of a land management plan adopted pursuant to this section, provide<br />

where appropriate, to the degree practicable, for steps to be taken to preserve the diversity of<br />

tree species similar to that existing in the region controlled by the plan;"<br />

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The Winema's Forest Plan will not change the diversity of tree species on the Forest but it will change<br />

the age of species on the forest.<br />

Also NFMA does not require non-declining even-flow, but requires the Secretary to plan to '(1) provide<br />

for multiple use and sustained yield of the products and services obtained..." from the National Forest.<br />

The implementing regulations for NFMA requires 'the planned sale for any future decade shall be equal<br />

to; or greater than, the planned sale for the preceding decade," but also gives instructions for departing<br />

from this principle when better multiple-use management is attained.<br />

Comment<br />

Maintaining local forest industries at an artificially high, unsustainable level is not an acceptable justification<br />

for continued over-harvest. The harvest levels proposed for the forest cannot be sustained, and must<br />

be reduced before adoption of the plan.<br />

<strong>Response</strong><br />

The implementing regulations for NFMA requires that a departure from sustained even-flow be analyzed<br />

if "(iii) Implementation of the corresponding base sale schedule would cause a substantial adverse<br />

impact upon a community in the economic area in which the forest is located.<br />

Comment<br />

The recent harvest has surely affected the standing inventory, cover forage ratios, available cover and<br />

forage, stream sedimentation, ability to meet dispersion standards, scenic qualities and other resources.<br />

The recent harvest must be accounted for in the final plan in all districts and as it affects all other resources<br />

and management requirements.<br />

<strong>Response</strong><br />

FORPLAN was updated to September 1988 for the Final EIS and Forest Plan.<br />

Comment<br />

The Tribe is particularly concerned with the proposed lodgepole departure. The lodgepole has far<br />

more value as deer fawning habitat or sustaining other resources than it does as sawtimber sold, on<br />

occasion, at a loss. The accelerated lodgepole harvest in recent years has already affected other<br />

resources. The proposed harvest levels should be reduced to a sustained yield rate to allow adequate<br />

dispersion of harvest units and to provide adequate cover and forage for deer and elk.<br />

<strong>Response</strong><br />

Alternative J has been designed to maintain a sustained even flow and has taken the dead lodgepole<br />

pine out of the ASQ. This will give the sale planners the latitude to meet other resource needs and in<br />

many cases they may use lodgepole pine acres to provide needed habitat.<br />

Comment<br />

The departure in the Ponderosa pine working group is justified by a 'substantial' contribution to community<br />

economic stability. Plan IV 20. Community stability is not a permissible justification for a departure<br />

under the NFMA. Even if it were, the plan sets up the local economy for a dramatic fall in twenty years.<br />

By anyone's standards, the plan fails to contribute to community stability and otherwise fails to justify<br />

the departure in Ponderosa pine.<br />

<strong>Response</strong><br />

Departing from an even-flow of ponderosa pine volume helps to maintain the local timber reduced<br />

harvests on private lands which have been recently harvested. The harvest from private lands will increase<br />

in 20 to 30 years, and then harvest from federal lands could be reduced.<br />

Comment<br />

No inventory of standing timber has been performed on the 135,000 acres of former reservation land<br />

acquired by the Forest in 1974. The Forest has continued to allow harvests of timber at ely the same<br />

rate as the previous bank managers. The land cannot continue to produce at this level. The continuing<br />

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over harvest has affected other resources, and has resulted in a timber deficit on the lands. The Forest<br />

must perform an inventory of these lands, calculate its long term sustained yield capacity and plan<br />

harvests only after the area has recovered sufficiently.<br />

<strong>Response</strong><br />

The entire Forest was inventoried in 1981, including the 135,000 acres of former reservation land acquired<br />

by the Forest in 1974.<br />

Comment<br />

The old growth definitions in the glossary should be clarified and references throughout the plan and<br />

EIS should specify what criteria were used in particular calculations.<br />

<strong>Response</strong><br />

The oldgrowth definitions used in the Regional Guide were used in the Forest Plan. These definitions<br />

are found on pages 3-40 through 3-41 of the Regional Guide.<br />

These definitions are under review and may be changed or clarified so we elected to keep the standard<br />

definitions in the plan at this time until a final decision is made on the definitions of oldgrowth.<br />

Comment<br />

Plan, p. IV-41, #2; the silvicultural prescriptions should be prepared or approved by a certified silviculturist.<br />

<strong>Response</strong><br />

Silvicultural prescriptions are prepared or approved by a certified silviculturist.<br />

Comment<br />

All of the proposed uneven-aged management in your preferred alternative concentrates on the 144,000<br />

acres of mature, multistoried ponderosa pine stands in and around the former Klamath Reservation at<br />

the cost of a timber harvest reduction of ely four million board feet per year. We request that you reevaluate<br />

those results to assess whether that harvest reduction has to occur. Your yield estimates were originally<br />

made with a model that had difficulty recognizing the existing condition of your timber stands. Now,<br />

the growth and yield model PROGNOSIS, that can accurately represent your existing stands, is available<br />

to you with a version especially calibrated for your area. We believe that careful analysis with this model<br />

can identify timber yield regimes that experience no fall-down on yield for uneven-aged ponderosa<br />

pine management. Please see the comments of the Oregon State Department of Forestry (OSDF) for<br />

more suggestions.<br />

An exception to this conclusion may occur if you combine your uneven-aged analysis with the specification<br />

of a larger target tree size, and associated heavier volume per acre, than recognized in your even-aged<br />

yields. Therefore, we request uneven-aged management or to the related attempt to grow bigger trees.<br />

<strong>Response</strong><br />

The uneven-aged management yield tables were recalculated using the PROGNOSIS yield simulator.<br />

The revised yields are very similar to the even-aged yields.<br />

Comment<br />

Beyond reducing the cost of uneven-aged management on the 144,000 acres identified in your preferred<br />

alternative, we request an evaluation of uneven-aged management on the remainder of your ponderosa<br />

pine, your pine-associated, and your mixed conifer. We realize that uneven-aged management becomes<br />

more and more difficult to achieve without a yield fall-down as proportion of the stand in ponderosa<br />

pine diminished and as the existing stand structure becomes less multilayered. However, numerous<br />

agencies, including OSDF, Oregon Department of Fish and Wildlife (ODFW), Economic Development<br />

Department (EDD) and the State Economist all suggest that the Winema National Forest can increase<br />

resource compatibility through more uneven-aged management, especially in important visual, wildlife,<br />

and riparian land allocations. In some allocations, such as visual retention or partial retention middle<br />

ground, it may actually be possible to increase yield over that which would be possible under even-aged<br />

management.<br />

K - 217

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<strong>Response</strong><br />

The FEIS Preferred Alternative prescribes uneven-aged management on the ponderosa pine and pine<br />

associated working groups. Uneven-aged management is not recommended in the mixed conifer working<br />

group, because the Armillaria root rot would be very hard to control in these stands.<br />

Comment<br />

In this comprehensive analysis of the benefits and costs of uneven-aged management on your three<br />

major forest types, we request that you: 1) stratify your stands so that those whose structure and species<br />

composition are most amenable to uneven-aged management will clearly stand out; 2) develop a number<br />

of yield regimes through time for each stand category to increase the probability that a regime is available<br />

that best meets the objective and constraints of your forest planning analysis; and 3) look beyond the<br />

classic textbook definition of uneven-aged management for your stands that are now two and three-storied<br />

and develop prescriptions, and associated yield regimes, that will maintain their multistoried character.<br />

<strong>Response</strong><br />

1. The present inventory does not lend itself to the stratification you suggest. A new forest inventory is<br />

being designed which will allow us to make the needed stratifications to analyze varying uneven-aged<br />

management between different stand structures.<br />

2. The FORPLAN model was designed to allow the uneven-aged.management to come into solution<br />

as needed.<br />

3. A generic uneven-aged management prescription was used in the FORPLAN model but the standards<br />

and guidelines are written to allow the project level silviculturist the leeway to design an uneven-aged<br />

management prescription which is optimal for the particular situation.<br />

Comment<br />

We are concerned that the proportion of ponderosa pine in the timber harvest will be less than in the<br />

past and that high quality ponderosa pine may disappear entirely as you move to intensively managed<br />

stands. Your proposed plan will lower the offerings of ponderosa pine by over 10 percent from the<br />

recent past, while increasing the offerings of lodgepole pine. As we all know, lodgepole pine will not<br />

provide county revenues and employment as high as quality ponderosa pine. While such a switch in<br />

species mix is needed to deal with your mountain beetle problem, you should carefully examine whether<br />

you could maintain ponderosa pine offerings at recent levels.<br />

<strong>Response</strong><br />

The FEIS preferred alternative was designed to maintain a sustained even flow of ponderosa pine. We<br />

found that it was not possible to maintain the historic ponderosa pine sell.<br />

Comment<br />

Your DEIS states that the level of ponderosa pine harvest will stay constant at this lower level for four<br />

decades and then will decrease sharply in the fifth decade which is the last decade you report of your<br />

1 5-decade planning horizon. We realize that the forest plan only applies for a 10 to 15-year period and<br />

that these longer projections serve mainly to illustrate the long-term implications of your proposed<br />

actions. Still, these results concern us because they make us wary about the Forest's plans for ponderosa<br />

pine over time. As an example, we do not know the degree to which ponderosa pine will be favored,<br />

or discriminated against, in planting and precommercial thinning, nor do we know your plans to grow<br />

high quality pine in the future.<br />

<strong>Response</strong><br />

There is no plan to discriminate against ponderosa pine in our reforestation or precommercial thinning.<br />

Ponderosa pine will continue to make up the historic proportion of the stand composition.<br />

Meetings were held with local industry representatives to get an understanding of high value ponderosa<br />

pine. They said it was ponderosa pine 20 inches in diameter or larger that had grown at a fast rate so<br />

there would be clear blocks of wood between the limb whorles. Our uneven-aged management<br />

prescriptions will provide high quality ponderosa pine.<br />

K - 218

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Comment<br />

The Winema National Forest should document and possibly reexamine its plans for maintaining the<br />

high quality ponderosa pine component of its timber sale program throughout the planning horizon.<br />

Intensive forest management methods and emerging technology in such areas as pruning and the<br />

uneven-aged management mentioned above, should be considered to allow sustained production of<br />

high quality ponderosa pine in the future. Such production potentially could provide a continuing stable<br />

forest industry in a forest setting that would also maintain the unique character of the Winema National<br />

Forest.<br />

<strong>Response</strong><br />

Uneven-aged management is being prescribed to the ponderosa pine and pine associated working<br />

groups to maiantain high levels of timber harvest while maintaining a forested setting.<br />

Pruning was not specifically prescribed but if it proves to be cost effective it will be concidered.<br />

Comment<br />

We believe that conditions on the Winema may justify a departure because of the diseased lodgepole<br />

pine stands. Yet we do not believe there is adequate explanation of your reasons for the proposed<br />

departure, nor its impacts on other resource values. We are very concerned about impacts on cover-forge<br />

ratios for big game and habitat diversity for all wildlife and potential impacts on seasonal distribution of<br />

water yields. See comments of ODFW and the Water Resources Department for details.<br />

<strong>Response</strong><br />

The FEIS preferred alternative removed the dead lodgepole pine from the yield tables and is not a<br />

departure. The dead lodgepole pine is part of the planned timber sale program quantity but is not part<br />

of the allowable sale quantity.<br />

The salvage of the dead lodgepole pine will be coordinated with the other resource needs.<br />

Comment<br />

On page 111-43 of the DEIS you state that the cost of harvest now exceeds the value of lodgepole pine<br />

harvested. Given this, will anyone buy this timber? What will it be used for--fiber, firewood, stand board?<br />

<strong>Response</strong><br />

The lodgepole pine values go up and down with the fiber market. The market for lodgepole pine is<br />

very good at the present and is selling for almost double the historic selling values.<br />

Comment<br />

Your DEIS compares the timber harvest effects of the alternatives to those of the 1979 Timber Management<br />

Plan. While the plan reports timber sales and harvest for a 10-year period (1 976-1985), the FEIS should<br />

also consider harvest levels over the last three years as a benchmark for comparison. With the forest<br />

industry's major comeback leading to accelerated harvest levels between 1985-1987, allowable sales<br />

quantity under the Winema's preferred alternative would actually show a drop from this three-year<br />

level.<br />

<strong>Response</strong><br />

Table 3-8 has been updated to 1988. There has been a major increase in harvest in the last three<br />

years. The FEIS preferred alternative will not maintain this current level of harvest.<br />

Comment<br />

Ponderosa pine is the most valuable tree species for timber products in eastern Oregon. As pointed<br />

out by our State Economist and EDD, it has and will probably continue to increase in value more rapidly<br />

than other species. Yet your analysis combines all species together in applying a one percent real<br />

price increase over time. Such an approach masks the virtue of continuing to grow high quality ponderosa<br />

pine. We request that your Forest planning analysis be improved to project the value of ponderosa<br />

pine separately from other species.<br />

K - 219

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<strong>Response</strong><br />

We elected not to make this change. The 1 percent real price inflator was based upon a long term<br />

data base. We do not have better data available to change this analysis. Other species, such as lodgepole<br />

pine, are increasing much faster in value than ponderosa pine.<br />

Ponderosa pine has a much higher value than any other species in our analysis. Changing the ponderosa<br />

pine value would not change the FORPLAN solution for the FEIS peferred alternative. Ponderosa pine<br />

is always chosen first for harvest.<br />

Comment<br />

As noted by OSDF, the Forest has tried hard to look at sawtimber supply and demand. Since your<br />

analysis was completed, considerable progress has been made on the plans for adjacent national<br />

forests. Also, newer OSDF projections are available for private land in the area and Oregon State University<br />

is currently completing a study along similar lines. All these analyses should be consulted in developing<br />

your FEIS.<br />

In this assessment, you should play close attention to your assumptions about the amount of timber<br />

entering and leaving Klamath County and the implications for sawtimber supply of all the Forests in<br />

your area proposing departures based on accelerated harvest of lodgepole pine that bottom out at<br />

about the same time. In addition, you should highlight the expected supply and demand for high quality<br />

ponderosa pine over time.<br />

<strong>Response</strong><br />

The supply and demand analysis was updated in the FEIS.<br />

Comment<br />

The timber industry could face a supply gap due to projected lower harvests from private lands over<br />

the next 10 to 20 years together with lower harvests in total from Southern Oregon National Forests.<br />

The degree to which declines in private and public lands overlap in the years ahead will have significant<br />

implications for the total timber supply available to mills. The mills could face higher stumpage prices<br />

as a result.<br />

The Forest Service should consider using the southwest Oregon Subregional Market Model that will be<br />

available soon to estimate stumpage demands for all ownerships in Oregon's timber sheds. This analysis<br />

should be incorporated in the Final Environmental Impact Statement and provided to the public for<br />

review.<br />

<strong>Response</strong><br />

This model was not used in the final but we do recognize the problem and additional supply and demand<br />

information has been included in the FEIS.<br />

Comment<br />

More research should be devoted to examining the feasibility of pruning. The purpose of pruning<br />

Ponderosa pine would be to create more high quality, clear wood. As the supply of old growth Ponderosa<br />

pine becomes more scarce, it may be prudent to explore ways to ensure a stable supply of high quality,<br />

millable Ponderosa pine.<br />

<strong>Response</strong><br />

Pruning was not incorporated in the FEIS preferred alternative but it has been left open as an option if<br />

pruning proves cost effective.<br />

Comment<br />

P.11-51<br />

(Last Paragraph) 'Half of the wet lodgepole pine communities on the Forest will be managed to provide<br />

optimum mule deer fawning habitat." How would the remaining half be managed? (DEIS 11-51-1). The<br />

Fremont National Forest has stated that they have not generally been successful regenerating wet<br />

K - 220

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lodgepole pine sites. Has the Winema been successful at regenerating wet lodgepole pine sites? (DEIS<br />

11-51-2).<br />

<strong>Response</strong><br />

All of the wet lodgepole pine is managed to meet basic water quality standards. The half, not managed<br />

for fawning habitat, goes to several management areas.<br />

We are not having trouble getting regeneration on our wet lodgepole sites.<br />

Comment<br />

P.11-67<br />

(Bottom of page) 'Management Area 7B is ed to maintain and create old-growth forest environments<br />

through the application of timber harvest practices.! ODFW makes a distinction between old-growth<br />

stands and old-growth habitat. With silvicultural practices, an old-growth stand can be created and<br />

maintained. The creation and maintenance of old-growth habitat through timber harvest has yet to be<br />

demonstrated. Disturbance to the duff layer, soil compaction and displacement, and removal of large<br />

amounts of wood fiber from the natural nutrient recycling process destroy a key component of the<br />

old-growth habitat.<br />

<strong>Response</strong><br />

Yes, this seems to be true.<br />

Comment<br />

P.111-18<br />

(Paragraph 3). The Forest has identified ten major plant communities. How many acres are there in<br />

each plant community and how many acres by seral stage are in each plant community? (DEIS 111-18).<br />

Are any hardwood plant communities located on the Forest? (DEIS 111-18-2).<br />

<strong>Response</strong><br />

The acres by plant community are available in our forest data base. A query of the data base would<br />

be supplied if requested.<br />

The forest inventory does not include the seral stage of each plant community. Seral stage can be<br />

estimated by the number of acres by silvicultural condition class.<br />

We have a few acres of aspen on the Forest but hardwoods are very limited.<br />

Comment<br />

P.IV-18<br />

Precommercial Thinning (paragraph 1). Precommercial thinning, when considered with cumulative<br />

impacts of other forest management activities, can have negative impacts on big game cover and<br />

nongame habitat. Thinning can result in an area that meets neither cover nor forage requirements for<br />

big game, and a stand that has reduced structural diversity for nongame.<br />

<strong>Response</strong><br />

Yes, this is true.<br />

Comment<br />

P.B-149<br />

Table B-24. Minimum rotation age for the riparian areas should be 250/120, not 120/80.<br />

<strong>Response</strong><br />

We agree. This has been changed in the FEIS preferred alternative.<br />

Comment<br />

D-26. 16. Landings must not be allowed in riparian zones.<br />

<strong>Response</strong><br />

Agreed. This has been added to the timber standards and guides for the riparian management area.<br />

K - 221

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Comment<br />

D-80<br />

Timber 1. Change to read:<br />

Timber harvest will be programmed only to improve big game habitat.<br />

3. Strike 'hiding.'<br />

4. Strike "hiding.<br />

<strong>Response</strong><br />

The standards and guidelines were rewritten for Winter Range for the FEIS preferred alternative.<br />

Comment<br />

PP V-15<br />

Appendices A and B of the Proposed Plan. ODFW recommends the addition of an M.A. column so the<br />

reviewer can determine which strategies apply to each proposed timber sale. The same recommendation<br />

would apply to Table B4.<br />

<strong>Response</strong><br />

Management Area has been added to Appendix A but this information is not available for the other<br />

resources at this time.<br />

Comment<br />

The appendices to the DEIS explained the pricing assumptions used for all species. However, it was<br />

difficult to ascertain from the information provided whether there was any increase assumed in the<br />

price differential between species over time due to the increased scarcity of large diameter ponderosa<br />

pine. An assumption of this nature could produce a different higher present net value for an alternative<br />

that maximized the harvest of large diameter ponderosa pine.<br />

<strong>Response</strong><br />

There is no price differential by species for the real price inflator.<br />

Comment<br />

Management practices have a significant impact on the Forest's potential to produce larger, high value<br />

pine. Practices that are being explored in other forests in the state, besides uneven-aged management,<br />

are pruning and burning. There is little discussion or analysis in the plan of the potential of these methods<br />

or the impacts they might have on harvest levels. Use of these methods should be discussed and the<br />

outputs associated with these management techniques should be portrayed.<br />

<strong>Response</strong><br />

High Value ponderosa pine was discussed with local industry representatives and we believe the<br />

uneven-aged management prescriptions will provide high value ponderosa pine. Pruning is not prescribed<br />

but is qin option if it proves to be cost effective and compatible with wildlife hiding cover requirements.<br />

Comment<br />

The plan suggests that economic stability may be achieved with a departure from long term sustained<br />

yield of smaller low value lodgepole pine and over the first four decades in ponderosa pine. The analysis<br />

to support this conclusion would be more useful if it included a discussion of the impacts on the community<br />

of a shift in the amount, size, and species mix of the volume coming of the forest.<br />

<strong>Response</strong><br />

The effects of the alternatives on the local economy have been rewritten based upon the latest implan<br />

values.<br />

Comment<br />

The plan does not adequately address the issue of the mills' dependence on larger diameter logs, nor<br />

does it address the issue of secondary manufacturers' dependence on high quality pine. What will be<br />

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the economic impact of mills having to retool to handle the smaller species in the long run? The drying<br />

time for younger pine is longer than for the older large diameter trees currently processed by the mills.<br />

More kiln capacity may need to be added.<br />

<strong>Response</strong><br />

The impact will be very large for the mills to retool for smaller logs but local industry was more concerned<br />

with the loss of growth potential that goes along with growing large trees than the problems related to<br />

retooling and developing new processes.<br />

Comment<br />

In the LRMP the target tree size for those acres using uneven-aged management is 240 DBH. There<br />

should be further discussion as to whether this size of tree is large enough to produce the quality of<br />

pine currently ed in the area and what it may mean to the community to make a change.<br />

<strong>Response</strong><br />

We believe the uneven-aged prescription will produce large ponderosa pine trees currently being used<br />

by local industry.<br />

Comment<br />

On page IV-26 of the LRMP a table depicts that 17.5 mmbf of the annual ASO in the first decade will<br />

be from commercial thinning. However, there is not much discussion as to the demand for this type of<br />

volume. Yet it is a significant portion of the proposed ASQ.<br />

<strong>Response</strong><br />

We have mills in both Klamath Falls and Medford that bid on the commercial thinning sales. These<br />

sales always sell after vigorous biding.<br />

Comment<br />

Page 11-7 of the LRMP indicates log processing and harvesting data by location. This is very useful,<br />

however in recent years there has been a large increase in the purchase of logs off the Winema National<br />

Forest that are processed out of Klamath County. In the final EIS 1986 and 1987 data should be included.<br />

<strong>Response</strong><br />

This information has been included as requested.<br />

Comment<br />

The FORPLAN model for the Forest does not differentiate between clearcutting, shelterwood and seed<br />

tree methods of regenerating even-aged timber stands. The DEIS, page 11-117, suggests the reader<br />

should not infer from the table on page 11-1 18 that 112,000 acres will be clearcut in the first decade<br />

because regeneration will be accomplished through planting as opposed to natural regeneration.<br />

However, DEIS Table 11-3A, beginning on page 11-79, does nothing to clarify harvest methods. The table<br />

indicates 709,600 acres are due to receive (have prescribed for them) clearcut/shelterwood silvicultural<br />

treatment. In addition, it further confuses readers by characterizing harvest type as overstory removal,<br />

regeneration harvest and selective harvest.<br />

It is not clear from the presentation of data how much timber will be harvested using clearcut, shelterwood,<br />

or selective cut methods in the first, second and fifth decade.<br />

<strong>Response</strong><br />

The information requested is on page 11-84 and 11-85 of the DEIS.<br />

The regeneration harvest acres are not split between clearcut, seed tree and shelterwood regeneration<br />

systems because this is determined on a case by case bases and depends upon the local situation.<br />

Comment<br />

Precommercial Thinning - (DEIS, page IV-1 8) Table IV-5 indicates 10,100 acres of precommercial thinning<br />

are planned per year during the second decade. If the first decade harvest is 9,700 acres, and every<br />

K - 223

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acre of uneven-aged management receives stocking level control at each entry, then it appears that<br />

precommercial thinning must be applied to all of the even aged management stands. Why is PCT<br />

assumed for every acre which has been regeneration harvested for all managed stands? Silvicultural<br />

advances make it possible to plant with fewer seedlings per acre than has been the case in the past.<br />

Even with natural regeneration, it is highly unlikely that every acre that has been regeneration harvested<br />

will require precommercial thinning to gain optimum stand density and growth. An analysis and<br />

reexamination of the data with an appropriate reduction in costs should be made.<br />

In addition, PCT costs used on the Winema are ely double those of forest industry in the same area. A<br />

thorough discussion of the origin and efficiency of cost figures used is in order.<br />

<strong>Response</strong><br />

Stocking level control is planned on all the uneven-aged management acres. Sometimes that will be<br />

thinning and in other cases that will be planting. For modeling purposes, it was all shown as precommercial<br />

thinning.<br />

Our costs are higher than local industry costs for precommercial thinning but Federal Contracting laws<br />

add requirements that requires higher bid prices to complete government contracts.<br />

Comment<br />

Unfortunately, even though the Forest has addressed the FPFO in the format specified in the May 2,<br />

1985, July 15, 1985, and May 13, 1986 Regional planning directions, Alternative D and NC were placed<br />

in the incorrect levels for their combination of target and/or standards. As a result, the Winema has<br />

incorrectly compared the DEIS alternatives to the FPFO objectives.<br />

<strong>Response</strong><br />

The new FPFO program objectives were used in the FEIS.<br />

Comment<br />

We know that knowledge of root disease occurrence is increasing and that certain salvage operations<br />

can exacerbate disease losses. We also know that mistletoe can be managed by clearcutting or species<br />

manipulation. However, the plan does not present specific guidelines for managing these problems<br />

and, therefore, leaves the impression of a lack of commitment to reducing losses from diseases and<br />

parasites.<br />

It is suggested that the disease discussion be expanded to include specific approaches to managing<br />

root diseases, stem decay, and dwarf mistletoe.<br />

<strong>Response</strong><br />

We have several manuals that give direction for minimizing losses to insects and diseases. It does not<br />

seem necessary to reprint that information in the plan documents.<br />

Comment<br />

The issue of harvest cutting method selection has been given significant emphasis by the public. The<br />

Winema should examine the analysis work done by the Deschutes and Ochoco National Forests on<br />

this subject as well as the practices of eastern Oregon industrial timber owners. The plan should strive<br />

to improve the knowledge of uneven-aged management application in eastern Oregon forests through<br />

silvicultural research, refined yield tables, and economic analysis.<br />

<strong>Response</strong><br />

This has been done.<br />

Comment<br />

Desired Future Condition of the Forest - (LRMP, page 4-3; DEIS, page IV-83, App. I) Embedded in<br />

most of the alternative formulations in the plan is the Winema's decision to emphasize the use of even-aged<br />

management systems. Under the preferred alternative, clearcutting is planned on nearly 80 percent of<br />

the lands scheduled for timber harvest as the most common harvesting treatment. Uneven-aged<br />

silvicultural systems will be applied on 144,000 acres or 14 percent of the lands. Are these the same<br />

K - 224

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144,000 acres noted as former reservation lands in management area 128? On sites where ponderosa<br />

pine currently exists as a natural, and often dominant, component of these stands, this decision has<br />

significant social, economical, environmental impacts and implications that have not been addressed<br />

in the DEIS.<br />

<strong>Response</strong><br />

Yes, these are the same acres.<br />

We believe that we have addressed the impacts of uneven-aged management on all resources.<br />

Comment<br />

The Winema should more closely examine the opportunities to maintain the high quality ponderosa<br />

pine component of its current and historic timber sale program throughout the planning horizon. Wise<br />

planning for the use and management of existing stands demands such an analysis. New alternatives<br />

should be developed which accomplish this goal in a cost effective manner while maintaining or increasing<br />

employment, personal income, and payments to counties. The set of alternatives presented in the<br />

DEIS fail to meet this important criteria.<br />

<strong>Response</strong><br />

We believe that our alternatives do address this issue. Page 11-84 of the DEIS shows the portion of the<br />

ASQ coming from stands with an average diameter of 18 inches or greater. Alternative D harvests a<br />

large portion of the large trees early while Alternative E gives a more even flow of large trees.<br />

Comment<br />

We suggest that, because of the formulation of departures in Alternatives D and E to allow the harvest<br />

of the lodgepole pine component to depart because of the pine beetle infestation, additional information<br />

should be provided to show the long term effects of this action. Ponderosa pine harvest levels by alternative<br />

should be displayed in MMBF and allowable sale quantity levels in decades 2 and 4 and beyond decade<br />

5 in the departure alternatives.<br />

<strong>Response</strong><br />

Pages 11-82 and 11-83 gives the harvest by species for decades 1, 2, and 5.<br />

Comment<br />

Yield Tables - (App., page B-67) The Winema National Forest should consider the use of the PROGNOSIS<br />

model recently calibrated for south-central Oregon and northern California. A preliminary analysis of<br />

this state-of-the-art model has shown these stands to be capable of greater growth than earlier yield<br />

tables.<br />

The Winema's empirical yield table was developed using the regional system modified for commercial<br />

thinning; a shift to managed yields was made for overstory removal. Managed yield tables were developed<br />

using various sources: two different yield projection models, future mortality estimates from DFSIM (a<br />

westside model), etc. The PROGNOSIS system would allow a consistent approach to stand growth<br />

and management calibrated to the conditions in south-central Oregon.<br />

Another benefit of the use of the new PROGNOSIS model is the capability of interactive simulations<br />

using the CHEAPO economics program. By combining the use of the two models, it should be relatively<br />

easy to identify the most cost-effective timber management practices on the Winema and to identify<br />

opportunities to cost-effectively increase timber growth while increasing outputs of other resources.<br />

<strong>Response</strong><br />

The uneven-aged management yield tables were redone using the SORNEC version of the PROGNOSIS<br />

model. A comparison between the even-aged yield tables and PROGNOSIS was completed and it<br />

showed there were no major differences, so we elected not to redo the even-aged tables for this planning<br />

effort.<br />

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Comment<br />

Adjustments to yield estimates were not documented but vary from between 10 percent and 28 percent.<br />

The 10 percent adjustment may appear to be reasonable but the 28 percent appears to be high. The<br />

Forest should reexamine and document the yield reductions.<br />

<strong>Response</strong><br />

The yield table adjustments are explained in the yield table documents.<br />

Comment<br />

Schedules and Real Price Trends - (App. B-81) Trends indicate that competition for a scarce resource,<br />

Oregon's timber stumpage, could increase dramatically in the coming years. This is particularly true<br />

for the area of economic influence for the Winema National Forest. The Rogue River and Siskiyou<br />

National Forests' Preferred Alternatives propose severely reduced timber sale levels. This coupled with<br />

reduced timber supplies from private lands in both the Medford and Klamath Timbersheds is expected<br />

to result in the dramatic fall of timber harvests over the next several decades.<br />

This will likely mean intense competition for Winema National Forest stumpage from both traditional<br />

purchasers and new bidders looking for additional timber supplies. It is therefore unrealistic for the<br />

Winema to conclude that a horizontal demand curve exits for the forest's timber. A demand function<br />

could be calculated for use in FORPLAN. If this is not possible at a forest level, it is possible at the<br />

timbershed level. The southwest Oregon Subregional Market Model will soon be available to make<br />

reasonable estimates of stumpage demands for all ownerships in Oregon's timbersheds. Region 6<br />

may use a similar model in their analysis of the cumulative effects of the forest plans. A similar analysis<br />

should be incorporated in the Final EIS for the Winema National Forest and provided to the public for<br />

review.<br />

<strong>Response</strong><br />

The timber supply and demand discussions have been revised in both chapters 3 and 4 of the FEIS.<br />

Tables and charts have been added to show log flows.<br />

We did not use the Southwest Oregon Subregional model.<br />

Comment<br />

Costs Incorporated into the FORPLAN Model - (App. B-82) Fixed costs are not those that vary with the<br />

levels of outputs, even if the variation is not in a linear relationship. Fixed costs are those necessary to<br />

maintain the forest at legal minimum standards. All other costs are variable, albeit not linear.<br />

An assessment was made as to whether particular programs (as a whole) would be applied in a particular<br />

alternative. Genetic tree improvement, for example. This is an incorrect methodology and should be<br />

revised. For example, in alternatives needing tree improvement programs, the basic, unchanging, costs<br />

of genetic tree improvement should be added to the variable costs of tree improvement for each alternative.<br />

The variable portion should be tied to particular forest outputs. The unchanging part should be tied to<br />

the particular alternative.<br />

<strong>Response</strong><br />

We did not change our methods for dealing with fixed and variable costs between the DEIS and the<br />

FEIS.<br />

Comment<br />

Timber Benefit Values - (App., B-91) Relative selling values for smaller diameter classes appear to be<br />

too high. Current Forestry Department planning for this area of the state uses a 10 inch minimum tree<br />

size; trees of lesser diameter will not pay their way out of the woods. An unrealistic high value for smaller<br />

logs would result if an average logging cost of $99/MBF is added to all stumpage values to derive mill<br />

pond value. Relative logging costs will be higher for stands with smaller trees. If the forest has not<br />

done so, mill pond values should be adjusted for logging costs by diameter.<br />

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<strong>Response</strong><br />

The Forest has done so.<br />

Comment<br />

Benchmark Analysis of the Effects of MMRs - (App., J-26) Results of analysis of the effects on present<br />

net values and the allowable sale quantity of achievement of MMRs are stated to be minimal. This is<br />

misleading. LTSY decreases by almost 5 percent and, while this is substantial in itself, it should be<br />

viewed within the cumulative harvest reductions occurring in Oregon.<br />

<strong>Response</strong><br />

Management requirements are not optional and our analysis shows the efficiency of achieving these<br />

requirements on the Winema is relatively high.<br />

Comment<br />

Table 111-11 & Analysis - (DEIS, 111-37) 1982 was a particularly poor year to use in an analysis of the<br />

lumber and wood products industry. This table and the analysis should be updated to 1985 using<br />

data currently available (Oregon Forest Industries, Howard).<br />

<strong>Response</strong><br />

The tables were updated as suggested.<br />

Comment<br />

The Forest did an excellent job of documenting potential timber availability in the Bend-Klamath County<br />

area. Realizing that data from the current round of NFMA planning was not available, the forest should<br />

update the National Forest portion of the analysis to reflect preferred alternatives.<br />

More localized projections are also available. In 1983, the Forestry Department made TREES projections<br />

for Klamath and Lake Counties private and other public ownerships at the request of the Winema National<br />

Forest and the Northwest Pine Association, (Attachments, Tables 1, 2, 3). Because the data was of<br />

unknown precision and accuracy, the results were presented to the major private landowners for their<br />

review. All major private timberland owners in the timbershed indicated that the projections were<br />

reasonable. Therefore, these projections should be used as well as those for the Bend-Klamath area<br />

to analyze the Winema's timber supply situation.<br />

<strong>Response</strong><br />

We agree that this would be good information but we feel that forests are making so many changes<br />

between the draft and final analysis that it would be misleading. We have elected to update our previous<br />

analysis.<br />

Comment<br />

Short- and Long-term Demand Trends - (DEIS, 111-41) The statement that current timber supply levels<br />

in the Pacific Northwest Region may be capable of meeting future demand is undocumented. It is not<br />

true in Oregon. The current preferred alternatives from Oregon's National Forests plan for timber harvests<br />

to be 10 percent below current levels (1 985-1987), in addition to the sizeable and probable falldowns<br />

projected for industrial private owners.<br />

<strong>Response</strong><br />

We recognize the that the reduction of timber harvest in the natural forests will impact timber industry<br />

by not meeting their sawlog needs.<br />

Comment<br />

Below Cost Timber Sales - (DEIS, 111-42) The analysis of below-cost sales in the DEIS is insufficient and<br />

fails to disclose important facts, such as the extent of current below-cost sales, or to provide an estimate<br />

of the number and volume of future sales which will lose money.<br />

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The forest does note that certain current and future sales are and will be below cost but the FORPLAN<br />

model is a powerful tool for this type of analysis and more in-depth analysis should be possible. The<br />

Forestry Department recommends that additional analysis be undertaken to better determine the supply<br />

of timber economically feasible to harvest, both currently and in the future.<br />

<strong>Response</strong><br />

Our analysis shows that our forest has a very cost effective timber sale program. Occasionally, we do<br />

sell sales which do not pay their total costs but these sales are made to meet other resource requirements.<br />

Comment<br />

Significant Interactions - (DEIS, 111-122) The text indicates that if large ponderosa pine is depleted from<br />

the Forest, mills may be forced to either close down or shift their processing abilities to produce other<br />

types of wood products. This is not necessarily so. Recent westside research shows that pruning can<br />

cost-effectively enhance the quality of smaller trees. Eastside research is currently underway and should<br />

show even greater gains. Therefore, even though tree size may be smaller, wood quality could be<br />

maintained. Cost-effectiveness of this treatment could be even greater if pruning were accomplished at<br />

the same time as other cultural activities such as PCT or commercial thinning.<br />

<strong>Response</strong><br />

We will keep pruning open as an option to maintain wood quality.<br />

Comment<br />

Ponderosa Pine Harvest Levels -(DEIS, IV-30) Under the preferred alternative, ponderosa pine harvest<br />

levels are projected to rise through the fourth decade. Ponderosa pine levels are the most important<br />

species to the local timber industry and create more jobs and personal income than other species<br />

harvested. With the fact that improvements in mill technology are continually allowing the lumber and<br />

wood products industry to e less desirable species. It would seem logical that ponderosa pine harvests<br />

would decrease over time rather than increase over time, then suddenly drop to half previous levels in<br />

the fifth decade.<br />

<strong>Response</strong><br />

There has been no support for a departure in ponderosa pine so the FEIS preferred alternative will<br />

maintain a sustained even flow of ponderosa pine.<br />

Comment<br />

Sawtimber Supply and Demand - (DEIS, IV-131) The Forest has made an honest attempt to look at<br />

sawtimber supply and demand. Since considerable progress has been made on the plans of adjacent<br />

forests and since other Forestry Department projections are available and since other timber availability<br />

projections are currently underway, this analysis should be updated prior to selection of a final plan.<br />

In addition, assumptions about sawtimber entering and leaving Klamath County should be reviewed in<br />

light of timber availability situations in surrounding timber sheds. For example, recent data show that<br />

66 percent rather than 53 percent of the logs milled in Klamath County originate in Klamath County.<br />

<strong>Response</strong><br />

The timber supply and demand analysis was updated in the FEIS.<br />

Comment<br />

Timber Management Costs - (App., page B-125) Tables B-20 and B-21 shows the sensitivity of the<br />

forest to price and cost trends. Over the long-run, timber harvests will depend on the cost-effectiveness<br />

of timber management. A 20 percent increase in costs results in an 11 percent reduction in first decade<br />

harvest. Therefore, the analysis should focus on the forest's cost and value discussion and how the<br />

forest can achieve increased efficiency. It should be kept in mind that just because a plan is developed<br />

for future management activities that may not be cost-efficient, doesn't mean that future foresters will<br />

follow that plan blindly, and do something that is unwise. In addition, a climate should be nurtured<br />

which promotes a healthy forest industry, one that can pay a premium for Oregon grown timber. A<br />

K - 228

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decreasing supply because of shortages from private lands will tend to make companies forego the<br />

capital investments necessary to keep local mills competitive. Therefore, it is of the utmost importance<br />

that future timber supplies on national forest lands be assured through cost-effective management.<br />

<strong>Response</strong><br />

A common objective to all alternatives is cost effective management.<br />

Comment<br />

At a minimum, the final EIS should provide two additional sets of data:<br />

First, a description of the reduction from full timber yield that would result from allocation of forest land<br />

of various productivity to each of the management areas. The Final EIS should also describe the potential<br />

to retain timber harvesting at a high level while maintaining visual quality through the use of active<br />

management techniques, such as uneven-aged (multiaged) management, and intensive management<br />

activities such as pruning and stocking level control.<br />

Second, while Table C4 contains a description of the timber inventory and tentatively suitable acres of<br />

each unroaded area the potential allowable sale quantity contribution of each unroaded area is needed.<br />

The second item is especially important since it would allow the public to measure the relative economic<br />

importance of each area and to then use that information in decision making.<br />

<strong>Response</strong><br />

We were not able to provide the analysis requested. The analysis becomes very involved because the<br />

most controlling factor is the scheduling effects, the land available for timber harvest. The scheduling<br />

effect changes for each management area for each alternative.<br />

The FORPLAN model was given the choice of both even-aged and uneven-aged management for<br />

visual areas. The model did choose uneven-aged management as being slightly more efficient.<br />

Table C-7 in the DEIS shows the timber yield potential for each unroaded area<br />

Comment<br />

Timber Inventory - (DEIS, page IV-40) The discussion of resource tradeoffs among the Winema's proposed<br />

alternatives should include information on the long-term effects of these alternatives on the timber<br />

resource. Data on the relationship between timber inventory, harvests and growth, as well as the changes<br />

over the planning horizon in the number of working group acres by age class for each alternative should<br />

be provided in the final EIS. These reports are readily available from the FORPLAN model (Reports<br />

10.6 and 10.8) and should be constructed to provide the public and the decision makers with this<br />

information for suitable, tentatively suitable, and total forested lands.<br />

<strong>Response</strong><br />

Some of the information requested is in the FEIS in the Information for Selected Benchmarks and<br />

Alternatives Table in Chapter 2.<br />

The additional information you suggest is available in the process records at the Winema N.F.<br />

headquarters.<br />

Comment<br />

The Department of Forestry supports the research program outlined by the Winema. In addition, we<br />

believe more research is needed to:<br />

1. Develop new technology to return some of the 57,949 acres removed from the suitable land<br />

base because of regeneration difficulty back to timber management status.<br />

2. Improve riparian area protection in range areas.<br />

3. Improve knowledge of marketing smaller, less economical trees on timber sales and less<br />

valuable species (white fir).<br />

4. Gain better knowledge about recreational users to improve projections of recreational uses of<br />

the Forest and the forests ability to meet that demand. Studies should include information on<br />

wilderness based on documented use studies.<br />

S. Gain better silvicultural knowledge on understory management and uneven-aged (multiaged)<br />

management.<br />

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6. Improve the forest's ability to anticipate and prevent significant mortality and growth losses<br />

from insects and diseases.<br />

7. Improve the knowledge of the habitat needs of old growth preferring wildlife species.<br />

<strong>Response</strong><br />

These items are all part of current research programs.<br />

Comment<br />

Table IV-3 shows a large increase in acres of regeneration harvested for the above departure alternatives,<br />

however, the proportion that is from lodgepole stands are not identified. Additionally, the lodgepole<br />

departure harvested during the first decade of the preferred alternative doesn't seem to be reflected in<br />

the 9.7 thousand acres shown in this table, when compared with acres harvested under Alternative C<br />

and D.<br />

<strong>Response</strong><br />

Table I-1 3 in the DEIS gives the information requested.<br />

Comment<br />

Data on the relationship between timber inventory, harvests and growth for lodgepole pine as well as<br />

changes over the departure planning horizon should be provided in the final EIS. For example, Table<br />

11-3A indicates relatively large fluctuations in the pine and pine associated species harvests during the<br />

decades shown. Harvest levels should also be provided by decade by alternative in MMBF, relating to<br />

both total harvest and ASO levels. The text also states (page IV-37) that '...Alternatives B and 'C are<br />

the only alternatives with sufficient stocking level control in lodgepole pine to prevent future timber<br />

losses from mountain pine beetle...' Discussion of future lodgepole pine management to reduce the<br />

risk of repeated beetle epidemics also needs to be included in the Final EIS.<br />

<strong>Response</strong><br />

We did not see the need to provide the inventory and growth by working group in the FEIS. This information<br />

wasn't used in the decision. Alternative J was constrained to provide a sustained even flow of ponderosa<br />

pine and the dead lodgepole pine was removed from the lodgepole pine yield tables so the ASQ no<br />

longer includes dead material. These two actions seem to have leveled the ASQ by species.<br />

Table 2-5 contains the harvest by species for decades 1,2 and 5.<br />

The risk to mountain pine beetle is discussed in Chapter 4 of the FEIS. Lodgepole pine is a very low<br />

value species compared to the other commercial species on the forest. Mountain pine beetle attacks<br />

are prevented by full stocking level control on all acres at all times. The value of the species does not<br />

warrant this investment. Alternative J, the preferred alternative, does not manage lodgepole pine to<br />

minimize damage by mountain pine beetle but is a compromise between values and expected loss.<br />

Comment<br />

Discussion of the environmental consequences of this choice of harvest dispersion was not found in<br />

the DEIS. A precise statement of the dispersion factor and its effects on harvest unit selection and<br />

economic performance is not provided. The final EIS should include this information.<br />

What rationale supports this very restrictive harvest dispersion constraint, when the Deschutes National<br />

Forest satisfied the requirements with a 58 percent constraint?<br />

The Region's Planning Issues Task Force working paper describes an alternative to this assumption.<br />

The California Forest Practices Act uses an opening duration of 5 years. This is based on allowing 2<br />

years for regeneration followed by a 3 year verification period to confirm adequate stocking has been<br />

achieved. The working paper concludes that:<br />

'It is not apparent from the available documentation why the same standards used buy the<br />

State of California would not satisfy this minimum requirement. ...[lt]... may be appropriate to<br />

address the implications of not having used this proposed standard.!<br />

The Department of Forestry requests that such an analysis be provided in the Final EIS along with<br />

information on actual 'closing time' measurements on the Winema National Forest. This information is<br />

needed to evaluate the harvest dispersion constraint.<br />

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<strong>Response</strong><br />

First, it is important to note that the dispersion constraint was never binding in the analysis. Appendix<br />

B and J contain the discussion of the dispersion constraint.<br />

The 25 percent in openings is not vary restrictive. It never became binding in the analysis. The dispersion<br />

constraint defines an opening as having crop trees less than 4.5 feet tall. This condition lasts about 10<br />

years from the time the unit is planted.<br />

Comment<br />

The Forest Products Industry cannot survive as we know it today, with constant decreases in the amount<br />

of timber we are allowed to cut each year. We need these revenues to support our schools and maintain<br />

our roads.<br />

<strong>Response</strong><br />

The number of saw mills will continue to decline and the Forest Products Industry will change in the<br />

next few years as the supply to logs decline. Schools and roads will need to be financed by taxes on<br />

the industries and people associated with the new industries in the State.<br />

Comment<br />

I believe the USFS needs to understand the desires and needs of the people whose lives and jobs<br />

and welfare are dependent on these controversial ideas. We must be taken into consideration first!<br />

<strong>Response</strong><br />

The Forest Service must choose an alternative that maximizes the net public benefit. Some people are<br />

bound to be hurt by the final decision, but the general public will benefit.<br />

Comment<br />

As described only 1% of the Forests are harvested per year and it regrows and animals habitats are<br />

not effected to the point of any danger.<br />

<strong>Response</strong><br />

Generally 2 to 3 percent of the suitable timber land is harvested each year.<br />

Effects of the Alternatives on Wildlife Communities in Chapter 4 of the FEIS indicates how the alternatives<br />

impact wildlife.<br />

Comment<br />

The explanation of the relationship between private and public timber supply is rather weak when<br />

considering the justification of projected sale and harvest levels on public lands over the next five decades.<br />

A two-paragraph discussion of private and public and interrelationships found on p. 111-41 does not do<br />

justice to the complex macroeconomic factors involved in meeting timber and wood products demand.<br />

It appears an accepted fact that previous forest practices on private forest lands must automatically be<br />

compensated by harvest on public lands. Inconsistencies in figures (e.g., Table 111-9) from the past ten<br />

years raise suspicions about this assumption.<br />

<strong>Response</strong><br />

The Local Timber Supply and Demand discussion was rewriten in the FEIS.<br />

The values in Table 111-9 are gathered by the State Department of Revenue and is quite accurate.<br />

Most respondents to the DEIS did not support the departure to help offset the projected decline in<br />

harvest from private lands so the Forest Plan calls for sustained even flow of sawtimber.<br />

Comment<br />

Harvest Methods--Silviculture. We understand that the Regional Guidelines generally specify clear-cutting<br />

followed by monoculture replanting with e 90-year rotations planned. We question the advisability of<br />

this practice. Newest research (including some in Region 6) shows that significant problems occur in<br />

the third cycle of short rotation silvicultural practices. Problems associated with this practice, which<br />

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emphasizes timber production over other forest uses, include slower growth rates and increased<br />

susceptibility to insects and disease. An epidemic in an even-age monoculture plantation could prove<br />

disastrous. The so-called super tree with its limited genetic base could exacerbate these results.<br />

<strong>Response</strong><br />

The harvest cutting methods selection criteria for the Region are found in the Regional Guide, pages<br />

3-2 through 3-7. The Regional Guide does not specify clearcutting, but gives the criteria to use to<br />

determine cutting method. The Winema is planning to use a wide range of harvest cutting methods.<br />

Table 2-9 and 2-10 show the range of timber management intensifies that are planned.<br />

Our tree improvement program has a large genetic base. We have 5300 parent trees selected and<br />

that is sufficient to maintain a broad genetic base.<br />

Comment<br />

To cite an example, Dr. Larry Irwin, with the National Council for Air and Stream Improvement, has<br />

suggested use of a modified shelterwood system to meet wildlife objectives in areas managed for<br />

'old-growth dependent' wildlife species rather than setting up dedicated old-growth zones where timber<br />

harvest is severely restricted or totally prohibited.<br />

<strong>Response</strong><br />

I will respond to your concern in the context of your letter. I do agree that we should try to minimize<br />

the conflicts between competing resources and we should use all the silvicultural systems available to<br />

achieve this goal. The final plan uses uneven-aged management on the ponderosa pine and pine<br />

associated working groups to minimize the conflicts between resources and still maintain the desired<br />

level of timber harvest.<br />

Early in the planning process the impact on the allowable sale quantity for providing old-growth was<br />

analyzed. That analysis showed that dedicated old-growth acres has less impact on ASQ than managing<br />

multiple acres of land for old-growth dependent species.<br />

Comment<br />

The DEIS has this to say about lodgepole prices (p. 11-112): 'Recent lodgepole pine values are much<br />

lower than the historical values used in this analysis. However, in the alternatives, most of the lodgepole<br />

pine types are considered suitable for timber production even though recent sales indicate marginal<br />

economic returns."<br />

In other words, lodgepole is DEFINED as being suitable for harvest, even when it is sold below cost.<br />

<strong>Response</strong><br />

As the DEIS said - the recent selling values for lodgepole pine are lower than the historical values, but<br />

during the last few months the value of lodgepole pine has risen. That is why the values used in FORPLAN<br />

are for an extended period of time from April 1977 through September 1983 to get both high and low<br />

market conditions. The economic suitability of lodgepole pine is based upon this historic value. The<br />

selling values for lodgepole pine in calender year 1989 was almost double the value used in FORPLAN.<br />

The value is very sensitive to market conditions.<br />

6,746 acres of the suitable lodgepole pine is allocated a minimum management prescription in Alternative<br />

J because the acres were not cost effective.<br />

Comment<br />

The EIS is deficient, we believe, in not specifying the future economics of lodgepole pine more precisely.<br />

The portrayed data seems overly optimistic to us in terms of price without an accompanying discussion<br />

of products that will justify the price projections. The opportunities for departure are addressed by<br />

NFMA. The criteria are not met by the Draft Plan.<br />

<strong>Response</strong><br />

The values for lodgepole pine were developed from the actual cut volume stumpage values between<br />

April 1977 and September 1983. We feel that time period adequately represents the long term value of<br />

lodgepole pine.<br />

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We feel that the departure in the alternatives meet the crit<br />

in the Departure Analysis included in Appendix B.<br />

Comment<br />

mria in 36 CFR 219.16 (a) (3). See the explanation<br />

We also suggest you look at pruning as a viable option for producing quality product. It is one of the<br />

few TSI programs with a positive B/C ratio in low site cl ass forests.<br />

<strong>Response</strong><br />

We talked with industry representatives to find out whal they considered a high value ponderosa pine<br />

tree. They said they were looking for a tree 20 inches D 3H or larger that had fast enough height growth<br />

between the whorls to produce clear blocks of wood. T hat product can be produced without pruning<br />

so we will wait on pruning until new information shows t is needed.<br />

Comment<br />

Old Growth: You need a precise definition of old growth in the plan. You should have maps that identify<br />

the current base of old growth on the forest and where the old growth will be by alternative following<br />

implementation of the plan.<br />

We ask that you delineate between the suitable and capable areas on the old growth map.<br />

<strong>Response</strong><br />

The old-growth stand definition on page A-11 of the Re gional Guide for the Pacific Northwest Region<br />

was used. A more precise definition for east side conditions is not available at this time, but Bill Hopkins,<br />

Ecologist, is trying to develop a definition for old-growth stands in Central Oregon.<br />

A map is available at the Winema Forest Office that shois the current old-growth and the acres allocated<br />

to old-growth in each alternative.<br />

We don't have the ability to delineate between suitable and capable old-growth at this time.<br />

Table 2-14 shows how the amount of old-growth acres change over time.<br />

Comment<br />

Timber Prices - The Winema National Forest recently rcceived an average of $169 per thousand board<br />

feet for its timber. Timber prices in FORPLAN average o226 per thousand and are thus about one-third<br />

higher than can realistically be expected. While FORPL AN values for ponderosa pine are almost equal<br />

to high bids, values of other species -- especially lodgE pole pine -- have been greatly overestimated...<br />

<strong>Response</strong><br />

The values used in FORPLAN were taken directly from<br />

timber harvested during the period from April 1977 thrc<br />

The timber values vary from year-to-year, but we feel tt<br />

comparison of alternatives. Current stumpage values fc<br />

the Timber Sale Statement, of Accounts for the<br />

ugh September 1983.<br />

e values are representative adequate for the<br />

r ponderosa pine are well over $400 per MBF<br />

which is much higher than the $257 value in the plan, Ibut that does not detract from the values when<br />

comparing alternatives. Lodgepole pine values are alsc higher now than during the period used for<br />

the values, but alternative comparisons are still valid.<br />

Comment<br />

Timber Price Trend -- High prices are compounded by the assumption that timber values will increase<br />

at a rate of I percent per years for the next 50 years. Cor ribined, high prices and the trend have significant<br />

effects on FORPLAN economics and can change the e rconomic ranking of some alternatives...<br />

<strong>Response</strong><br />

The effect of timber price trends is discussed in Apper dix B in the Price Trend and Cost Sensitivity<br />

Analysis Section. In summary, the timber price trends cid not effect the land base or total harvest level,<br />

but did effect species mix and management intensities<br />

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Comment<br />

Mixed Conifer and Lodgepole Pine Management -- If road costs are counted against timber receipts,<br />

management of these timber types loses money. These types made up about one-third of recent timber<br />

sales but contributed only 6.3 percent to the revenue. These findings are significant in regard to proposed<br />

roadless area development whose timber stands are almost exclusively mixed conifer and lodgepole<br />

pine...<br />

<strong>Response</strong><br />

The roadless areas on the Winema are quite small and scattered. The larger roadless areas are mainly<br />

unsuitable for timber production and only have a fringe of suitable timber lands. The arterial and collector<br />

road systems on the Forest are essentially complete so only local roads are needed to access the<br />

roadless area. Mixed conifer is the dominate timber type in the roadless areas. The mixed conifer sales<br />

on the Forest have ample value to build the roads necessary to access the roadless areas.<br />

Comment<br />

Below-Cost and Cross-Subsidized Timber Sales -- Only three of 52 timber sales sold since October<br />

1985 were below-cost, but at least 17 of the sales CHEC examined cross-subsidized low-valued timber<br />

stands with high-valued ones, resulting in an under-appraisal of $255,000. Bids of three sales were<br />

reduced by $74,000 because of cross-subsidization...<br />

<strong>Response</strong><br />

It is normal on the Winema for the lodgepole pine to appraise below cost and its removal is<br />

cross-subsidized by the other species on the timber sale.<br />

But of course, it is not logical to just high grade a stand of trees. The entire stand must be managed<br />

to achieve management's objectives.<br />

Comment<br />

Second-Growth Investments -- Even using inflated FORPLAN timber values, second-growth timber<br />

management on the Winema Forest cannot return more than 4.4 percent on the investment, no matter<br />

which management prescription is used. Replanting lodgepole pine stands is especially uneconomical...<br />

<strong>Response</strong><br />

Your assessment of return on investment is correct. We also agree that planting lodgepole pine is<br />

uneconomical and most lodgepole pine sales on the Forest are planned for natural regeneration.<br />

Comment<br />

Sustained yield of large sawtimber should be managed into the future in the mixed conifer, pine-associated<br />

and ponderosa pine plant communities. The growth rates should not exceed 15 growth rings per inch<br />

to assure high quality wood and the diameters should range between 18 to 28 inches on general forest<br />

land.<br />

<strong>Response</strong><br />

Between the draft and the final, we tried to find out what local industry felt would be high quality wood.<br />

The final determination was trees that were larger than 20 inches in diameter and trees that have fast<br />

height growth so there is clear wood between the limb whorls.<br />

Comment<br />

The Winema National Forest, seems to have accepted the idea that an economy based on smaller<br />

diameter fast growing trees will be superior to one based on lower volumes of mature ponderosa pine.<br />

This assumption is questionable since mature ponderosa accounts for over 90% of the revenue received<br />

on Winema N.F. timber sales. The departure would result in less ponderosa pine being available in the<br />

future, and would result in a trade-off of quality lumber for cheap wood fiber from young fast growing<br />

trees. Mature large diameter ponderosa pine gives local mills a competitive edge in the wood products<br />

industry.<br />

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<strong>Response</strong><br />

Based on your comment and other comments received during the planning process, the Forest is<br />

planning to maintain a sustained even-flow of ponderosa pine volume.<br />

During the planning process we tried to determine what is considered a Ohigh valued" ponderosa pine.<br />

Industry representatives generally agreed that ponderosa pine trees; larger than 20 inches in diameter<br />

with rapid height growth was a high valued ponderosa pine. The uneven-aged management in ponderosa<br />

pine will produce trees larger than 20 inches so no additional work is planned to produce 'high valued'<br />

ponderosa pine.<br />

Comment<br />

While a variety of harvest methods are described and Timber Foresiwide Standards and Guidelines<br />

are presented in the PLRMP, no details are provided to describe what timber harvest cycles would be<br />

implemented or what particular method of timber harvest would be employed. Thus, cumulative impacts<br />

of any alternative in which 'timber management' is the dominant land use within the adjacent ecosystem<br />

and/or viewshed of the Park cannot be discemed.<br />

<strong>Response</strong><br />

Table 2-10 shows the timber management intensities for all acres in each alternative. To get more<br />

detail for a specific analysis area, a person would need to review the FORPLAN outputs. FORPLAN<br />

would show when the area is planned for entry and which timber management intensity is applied.<br />

The Forest Plan prescribes uneven-aged management for all the ponderosa pine working group and<br />

will be the preferred silvicultural system on the pine associated working groups. That change in silvicultural<br />

direction will reduce the visual impacts of timber management as seen from Crater Lake National Park<br />

because a continuous high Forest cover will be maintained.<br />

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Water<br />

Comment<br />

Marsh, which is mostly water, need to protect and consideration of transferring it of the adjacent Refuge<br />

considered.<br />

<strong>Response</strong><br />

An attempt was made in the late 1970's to transfer the Marsh to the Fish and Wildlife Service. At that<br />

time there was not enough interest at the upper levels to make the transfer. It would probably take<br />

Congressional action to make the transfer and someone to push for this action to take place.<br />

Comment<br />

The Winema National Forest has a huge inventory of springs and wet meadows that provide significant<br />

riparian habitat and water resources that need to be mentioned in the management area guidelines.<br />

<strong>Response</strong><br />

Management Area 8 Riparian standards and guidelines have been designed to protect all riparian<br />

areas including springs and wet meadows. Habitat values as well as hydrologic values are preserved.<br />

Comment<br />

Water Rights - The State of Oregon has established a Water Rights Board that records and establishes<br />

any water rights that the Forest may have for activities on Forest such as recreation, irrigation or domestic<br />

use. This may have a future impact on others and we may need to address how we will deal with this<br />

in the future.<br />

<strong>Response</strong><br />

The Forest is continually updating its water rights for new developments that require a water right.<br />

Existing water rights will be protected through participation in the Klamath Adjudication. Standards<br />

and Guidelines are designed to protect water uses.<br />

Comment<br />

Stream side management on the east side is different from the west side. Overland flow of water is not<br />

significant compared to the west side. It is our opinion that buffer strips for shade may make sense<br />

but have little value as a filtering mechanism for sedimentation. Please make appropriate adjustments<br />

in buffer strip widths.<br />

<strong>Response</strong><br />

Streams on the Forest vary from completely forested to meadow. Our standard is to manage at least<br />

100 feet on both sides of the stream for protection of all streamside values, including hydrologic, wildlife<br />

habitat, and fishery.<br />

Comment<br />

We generally support the management proposals in the draft plan. We do believe that careful selective<br />

logging in riparian areas can be accomplished and cannot only assist in correct riparian management<br />

but also can prevent waste of timber output on these very productive sites. Studies in Arizona and<br />

Central Oregon indicate that modern grazing management systems can improve quality and increase<br />

vegetation production better than elimination of grazing. We urge that such techniques be reviewed<br />

and installed.<br />

<strong>Response</strong><br />

MA8 Riparian has been revised to specify management allowed in riparian areas. Logging is permitted<br />

in certain riparian areas under careful management, but is normally restricted within 100 feet of streams.<br />

Standards and guidelines require that allotment management plans be revised to incorporate proper<br />

grazing systems to protect riparian values.<br />

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Comment<br />

The plan provides for some harvest restrictions in riparian areas. It is not clear how these restrictions<br />

relate to those imposed along rivers planned for scenic management. The plan should explain this<br />

relationship. In particular, the plan and final DEIS should analyze the effect of the dispersion standards<br />

for each of these management areas. If the scenic management constraints override the riparian area<br />

constraints, it is critical that the plan evaluate the effects on fish habitat and water quality of not applying<br />

the dispersion standards the first two decades.<br />

<strong>Response</strong><br />

No harvest is planned along scenic corridor of the Sycan River and within 100 feet of class I and If<br />

streams and within 50 feet of class IlIl streams. In most other riparian areas where timber harvest is<br />

allowed, uneven-aged management is prescribed and the dispersion standard does not apply. The<br />

exception is lodgepole pine where limited openings are allowed as described in management area 8<br />

riparian.<br />

Compliance with Oregon water quality standards is a Forest-wide standard and guideline described in<br />

Chapter 4 of the Plan that applies to all activities. Management Area 8 Riparian standards and guidelines<br />

apply to all riparian areas except those located within more restrictive management areas such as<br />

wilderness, research natural areas, special management area, bald eagle management area, etc.<br />

Comment<br />

In addition, the plan should identify the sensitivity of riparian areas by watershed to allow analysis of<br />

the effects of harvesting on soil productivity and water quality. The Tribe urges that no timber harvesting<br />

be allowed in riparian areas if it would result in any further degradation of water quality or fish habitat.<br />

<strong>Response</strong><br />

Timber harvest in riparian areas would not be allowed to further degrade water quality and fish habit.<br />

No harvest is allowed within 100 feet of class I and 11 streams and within 50 feet of class Ill streams.<br />

Sensitivity of riparian areas will be identified at the project level and Standards and Guidelines and<br />

Best Management Practices will be applied to protect those resource values. Results will be monitored<br />

to see if those values were protected. Restrictions are the same regardless of watershed. No watershed<br />

was determined to be sensitive.<br />

Comment<br />

Water quality standards. The Plan and DEIS need to include a clear, unambiguous statement that<br />

compliance with state water quality standards promulgated under the Clean Water Act is mandatory.<br />

The Plan and DEIS refer to compliance with and monitoring of BMP's as a means of achieving compliance<br />

with water quality standards. While compliance with BMP's is intended to result in compliance with<br />

water quality standards, it does not necessarily insure it. Compliance with BMP's will not substitute for<br />

compliance with water quality standards or excuse violations. See e.g., Northwestern Indian Cemetery<br />

Protective Association v. Peterson, 795 F.2d 688 (ithCir., 1986); ONRC v. United States Forest Service,<br />

F.2d _, (9th Cir. 1987) (D.C. Cv. No. CV-86-6504-BU). Moreover, the Tribe believes it imprudent<br />

to rely solely on Oregon Forest Practices Act standards which are designed for use on private lands<br />

where management objectives and uses are significantly different than on National Forest lands. Greater<br />

protection of riparian zones, particularly those in a degraded condition, is needed to achieve multiple-use<br />

objectives on National Forest Lands to maintain and enhance water quality, and to protect the Kiamath<br />

Tribe's treaty rights.<br />

<strong>Response</strong><br />

Appendix C of the FEIS has been added to discuss the Clean Water Act, Oregon Forest Practices Act,<br />

and Best Management Practices to protect water quality. The State of Oregon has determined that<br />

properly applied Forest Best Management Practices meet or exceed the requirements of the Clean<br />

Water Act.<br />

Monitoring of implementation and effectiveness of BMP's will ensure that water quality is maintained or<br />

improved. Forest-wide and management area standards and guidelines will protect multiple riparian<br />

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area values and define water quality standards that will be met. Those riparian areas in degraded condition<br />

will be rehabilitated. The monitoring program for water quality is described in Chapter 5 of the Plan.<br />

Comment<br />

The projected sedimentation levels are of concern for an additional reason: there is no stated relationship<br />

between sedimentation rates and projected turbidity increases in the streams. This information is<br />

necessary to insure compliance with turbidity standards and the nondegradation standard. OAR<br />

340-41-026.<br />

<strong>Response</strong><br />

Generally, sedimentation and turbidity go hand-in-hand, however the exact relationship is unknown.<br />

The sedimentation levels are expected to be rather low.<br />

Comment<br />

The DEIS and Plan should provide information on present and projected water quality in the remaining<br />

roadless areas. As timber harvesting and road construction proceed, the present high quality waters<br />

must be protected to comply with the state nondegradation standard. OAR 340-41-026. The Final EIS<br />

and Plan should specify how activities planned for these areas of high quality water will comply with<br />

the nondegradation standard. General references to implementation and monitoring of BMP's is<br />

inadequate. As stated previously, implementation of BMP's while commendable, will not substitute for<br />

compliance with water quality standards, nor excuse their violation. This applies to the nondegradation<br />

standard as well as the turbidity standard.<br />

<strong>Response</strong><br />

Discussion has been added to Chapter 4 and Appendix H of the Plan concerning how Best Management<br />

Practices will be implemented to protect water quality. BMP's will be identified during project level planning<br />

and will be implemented and monitored to ensure compliance with the non-degradation standard.<br />

Forest-wide and riparian area standards and guidelines will further protect water quality.<br />

Comment<br />

The DEIS includes little detail on the status of current water quality. There is some general discussion,<br />

but no organized summary is presented. A watershed inventory would be a logical place to present<br />

information documenting water quality conditions. It is difficult to evaluate effects on water quality which<br />

would result from implementation the various options without documentation on the current status.<br />

The text indicates that state and Forest Service monitoring has shown high water quality on the WNF.<br />

Of the 567 miles of streams on the WNF, how much has been monitored? What parameters were include<br />

in the surveys and during what times of the year?<br />

<strong>Response</strong><br />

Chapter 3 of the FEIS was revised to discuss water quality in more detail. Some water quality data has<br />

been collected on most class I and 11 streams on the Forest, specifically, temperature, turbidity, and<br />

dissolved oxygen. However, the number of samples at a given site is very limited in most cases, so the<br />

data must be used with caution. Most streams originating on the west part of the Forest have high<br />

quality. Daily maximum temperatures on many of the streams on the east part of the Forest frequently<br />

exceed 58 degrees F. during late summer. A summary of data collected by the Forest is available for<br />

review in the Forest Headquarters. Chapter 5 of the Plan describes the future water quality monitoring<br />

program for the Forest. Additional monitoring has been done on some of the streams by the State, the<br />

Klamath Tribe and other agencies.<br />

Comment<br />

How does the approximately 50,000 acres of riparian ecosystems referenced here relate to the 15,775<br />

management acreage on page IV-63 of the plan?<br />

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<strong>Response</strong><br />

MA8 Riparian has been expanded to include all streams, wet meadows, wet conifer, seeps, and springs,<br />

as well as strips of non-wetland along streams and wet meadows to provide protection of riparian<br />

values. This includes over 50,000 acres. Standard and guidelines for this area have been revised and<br />

enhanced.<br />

Comment<br />

From information provided, there is no guarantee that Oregon Water Quality Standards will be met. For<br />

instance, increases in sediment from grazing which adversely affect the fishery could constitute a violation<br />

of the anti-degradation part of Oregon's Water Quality Standards. These issues are not addressed in<br />

the DEIS in terms of Oregon's Water Quality Standards and anti-degradation.<br />

<strong>Response</strong><br />

The Forest will meet Oregon water quality standards through implementation of best management<br />

practices and standards and guidelines. Implementation and effectiveness will be monitored to determine<br />

whether the Forest is meeting Oregon's water quality standards.<br />

Comment<br />

Restriction of domestic livestock grazing, timber harvest, or road construction in areas adjacent to<br />

streams and wetlands is described as a mitigation measure. The FEIS/Plan should include an explanation<br />

of how these measures will be implemented (e.g. allotment plan and timer sale contract conditions).<br />

<strong>Response</strong><br />

Project level planning will implement standards and guidelines and will identify Best Management Practices<br />

to be implemented for protection of water quality and riparian area values. Standards and guidelines<br />

are found in Chapter 4 of the Plan. The procedure for implementing BMPs is explained in Appendix H<br />

of the Plan.<br />

Comment<br />

The cumulative effects on water quality are difficult to evaluate at the project level. It is usually more<br />

appropriate to study at the area analysis or plan level for sensitive watersheds.<br />

<strong>Response</strong><br />

None of the watersheds on the Forest are considered particularly sensitive as explained in Chapter 3<br />

of the FEIS. Cumulative effects are studied at area analysis and project level planning.<br />

Comment<br />

The instruments used to implement the State Water Quality Management Plan on lands administered<br />

by the Forest Service should be updated. It is our understanding that the Oregon Department of<br />

Environmental Quality is currently updating these instruments. It would be very desirable for the FEIS/Plan<br />

to include references to the updated instruments.<br />

<strong>Response</strong><br />

Forest Service Best Management Practices for compliance with the Clean water Act have been updated.<br />

The procedure for implementation and monitoring BMPs is described iin Appendix H of the Plan. The<br />

State of Oregon has determined that Forest Best Management Practices meet or exceed the requirements<br />

of the Clean Water Act. Monitoring of implementation and effectiveness of BMP's will ensure that water<br />

quality is maintained or improved. Management Area 8 standards and guidelines will protect multiple<br />

riparian area values. Those riparian areas in degraded condition will be rehabilitated. A monitoring<br />

program is described in Ch.V of the Plan.<br />

Comment<br />

The text incorrectly interprets the water quality standards when it states that they are met through<br />

application of best management practices. It is correct to state that best management practices aid in<br />

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compliance with water quality standards. The numerical limits of water quality standards as indicated<br />

on page IV-50 of the Plan would apply.<br />

<strong>Response</strong><br />

Implementation and monitoring of Best Management Practices is the mechanism the Forest will use to<br />

meet water quality standards. Implementation and effectiveness of BMP's will be monitored to ensure<br />

that standards are met. The procedure is further explained in Appendix H of the Plan.<br />

Comment<br />

Objectives for management of riparian areas, especially for water quality and fisheries needs to be<br />

done on a stream by stream basis at the Forest Plan level, not the project level. Plan implementation<br />

and compliance with water quality standards is then easier to manage and link to monitoring.<br />

<strong>Response</strong><br />

This will actually be done on an area by area basis as management activities are planned in an area.<br />

We have not collected all of the site specific data necessary to put all of the streams into the plan at<br />

the detail requested. This information will be collected during the next few years.<br />

Comment<br />

The development of a detailed water quality monitoring plan should be based on a list of current beneficial<br />

uses, present condition, and desired future condition for each stream or a watershed unit which is<br />

small enough to adequately protect the beneficial uses. The present condition and desired future condition<br />

can best be expressed in terms of the beneficial use (e.g., percent fish habitat capability that is discussed<br />

in the DEIS). The monitoring plan should include types of surveys, location of sampling, parameters to<br />

be monitored, indicator species, budget, procedures for using data or results in plan implementation,<br />

and availability of results to interested and affected groups. Enclosed is a copy of our monitoring guidance.<br />

Appendices A and 0 of the Final Nez Perce National Forest Plan, October 1987, includes a level of<br />

detail and approach to water quality and fishery monitoring which we believe will accomplish the stated<br />

objectives.<br />

<strong>Response</strong><br />

The water quality monitoring plan described in Chapter 5 of the plan addresses most of your concerns.<br />

Comment<br />

The draft plan does not identify drainage objectives or include a watershed resource inventory. A<br />

watershed resource inventory summarizes facts, recorded measurements, observations, and other<br />

evidence which can be used to determine management objectives for rivers and streams. Oregon's<br />

water quality standards and water quality management plans, for instance, were developed using<br />

inventory information. An inventory is a key element needed for effective resource management. The<br />

drainage objectives derived from the resource inventory then provide a means of implementing the<br />

plan.<br />

<strong>Response</strong><br />

Management objectives are to maintain State water quality standards in all drainages through application<br />

of BMP's, standards and guidelines, and monitoring. Data was not separated by watershed because<br />

there are no sensitive watersheds on the Forest. Watershed information has been included in Chapter<br />

3 of the FEIS.<br />

Comment<br />

Achievement of these drainage objectives, conservation practices, and improvement projects can only<br />

be evaluated by water quality monitoring and fishery habitat surveys. The Plan does not identify a<br />

water quality monitoring program, nor criteria for evaluating riparian areas (temperature, streambank<br />

erosion, etc.). Native trout habitat monitoring is mentioned, however, specific sites or sampling/survey<br />

frequencies are not identified. We would support the recommendation to establish a multiagency technical<br />

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work group in Oregon to address these concerns and to advise the USFS in developing a water quality<br />

monitoring program.<br />

<strong>Response</strong><br />

A water quality monitoring plan has been developed to ensure compliance with State water quality<br />

standards. Fishery habitat surveys have been initiated using methodology described in Stream Inventory<br />

Handbook, Region 6, July, 1989.<br />

Comment<br />

Plans for future monitoring on the WNF are not detailed and no explicit monitoring sites are identified.<br />

It is unclear, in the Plan, how the results of monitoring efforts will be displayed to resource managers<br />

in a way that will identify where modifications are needed to protect water quality. Without an effective<br />

monitoring program there is no assurance that adverse changes in the streams will be detected.<br />

<strong>Response</strong><br />

A monitoring program has been described in Chapter 5 of the Plan.<br />

Comment<br />

The standards and guidelines (page IV-50) indicates that numeric limits for temperature and turbidity<br />

will be achieved. However, the monitoring plan does not make provision for checking against this standard.<br />

<strong>Response</strong><br />

The monitoring plan now describes how water quality will be monitored against these standards.<br />

Comment<br />

The riparian area method of monitoring refers to an 'Activity Review.' This needs to be explained further<br />

as it appears to be very important.<br />

<strong>Response</strong><br />

An activity review is an inter-disciplinary team review of a management activity and is an example of<br />

one type of implementation monitoring. People knowledgeable in riparian management would be members<br />

of the team. They would assess whether implementation of the Standards and Guidelines concerning<br />

the riparian area was effective.<br />

Comment<br />

National Forest Water Quality Monitoring Recommendations<br />

<strong>Response</strong><br />

The monitoring plan can be found in Chapter 5 of the Plan.<br />

Comment<br />

We encourage the implementation of a strict monitoring system with firm dates for accomplishment of<br />

the plan and with Stop Action mandate on all activities that are found adversely impact water quality.<br />

<strong>Response</strong><br />

The monitoring plan can be found in Chapter 5 of the Plan.<br />

Comment<br />

We encourage the addition of qualified fisheries biologists to your staff with greater emphasis on riparian<br />

zone management.<br />

<strong>Response</strong><br />

The Forest is considering adding a fishery biologist to the staff, however no decision has been made.<br />

The Forest has relatively few miles of fish bearing stream, compared to many forests. The forest biologist<br />

and forest hydrologist will work together with the assistance of district biologists in the administration<br />

of the riparian and fishery resources on the forest.<br />

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Comment<br />

The time frame of 50 years to improve riparian ecosystems, water quality, and stream habitat capability<br />

from 30% to 80% is completely inadequate.<br />

<strong>Response</strong><br />

This has been revised in the goals and objectives statements.<br />

Comment<br />

The standards and guidelines for management area 8: Riparian management are less restrictive than<br />

the forestwide standards described in "managing riparian ecosystems for fish and wildlife ---' mentioned<br />

above.<br />

<strong>Response</strong><br />

Forestwide Standards and Guidelines apply to all management areas equally. Riparian management<br />

area standards and guidelines, to be applied in addition to the forest wide standards and guidelines,<br />

have been revised to be more specific and restrictive in protecting riparian area values.<br />

Comment<br />

Monitoring plans (Table V-1, p. V-1 0), for recovery of riparian areas simply to involve "District IDT review<br />

of EA's' are inadequate.<br />

<strong>Response</strong><br />

Monitoring plans have been revised to be more thorough.<br />

Comment<br />

IV-3 para. 2. Wildlife and fish program goals should include all riparian zones, not just 'key" (undefined)<br />

riparian areas, to be managed to maintain or improve fish and wildlife habitat and water quality.<br />

<strong>Response</strong><br />

Correct. All riparian zones will be managed according to Forest-wide and management area Standards<br />

and Guidelines to protect the riparian values for habitat and water quality.<br />

Comment<br />

The Plan should also provide standards for wastewater systems. We request that the following language<br />

be added to the forest-wide standards section beginning on page IV-36 of the proposed Plan: 'Sewage<br />

treatment and disposal facilities shall be approved by the Department of Environmental Quality or its<br />

contract agents and shall be in compliance with rules of the Environmental Quality Commission.'<br />

<strong>Response</strong><br />

A standard similar to the above proposed standard for wastewater systems has been added to the<br />

final plan under Forestwide Standards and Guidelines in Chapter 4 of the Plan.<br />

Comment<br />

To demonstrate consistency with the Clean Water Act, the Winema Final EIS should discuss how the<br />

alternatives will satisfy the requirements of the Forest Practices Act. Particular attention should be given<br />

to the newly adopted rules for riparian area management. The forest's standards and guidelines for<br />

riparian areas should reflect the full intent of the Forest Practices Act as well as demonstrating consistency<br />

with the approved rules.<br />

<strong>Response</strong><br />

Implementation and monitoring of Best Management Practices and standards and guidelines that apply<br />

to all the alternatives will meet or exceed the requirements of the Clean Water Act and Forest Practices<br />

Act, including riparian area management. Discussion has been added to Chapter 4 of the FEIS explaining<br />

how the requirements of the Clean Water Act will be met.<br />

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Comment<br />

Sediment Yields - (DEIS, page 11-95) Table 11-3A shows projected sediment rates by alternative providing<br />

a tons per acre index as a point of reference and comparison. Footnote 25 (page 11-95) states that this<br />

figure includes 2,800 tons/year of background sediment not related to management activities (emphasis<br />

added). At this rate the, background level would be about nine times the index level for the no action<br />

alternative (A). The document provides little information about how the estimates of erosion were obtained<br />

or the source of data for the 2800 tons/year background sediment rate.<br />

The Department of Forestry recommends that historic levels be used to provide a firm base from which<br />

to describe the level of sedimentation caused by additional logging and road construction activities.<br />

Further analysis, discussion and documentation is needed in the final EIS to provide credible estimates<br />

of off-site soil loss (sedimentation). Accurate sedimentation estimates are of great value to decision<br />

makers.<br />

The Winema should provide credible estimates of sedimentation to the public and describe the benefits<br />

and costs, if they are measurable, of the projected changes and discuss the margin or error of these<br />

sediment production estimates.<br />

<strong>Response</strong><br />

The sediment indices in Table 2-3A should be in tons per year, not tons per decade. The figures in<br />

the table include 2800 tons per year background sediment. All of the erodible acres on the Forest<br />

were put into an erosion and sediment delivery model (Anderson, 1969). The model took into consideration<br />

slope, soil erodibility, vegetation cover and recovery period from management treatments. Not surprisingly,<br />

highest sediment yields came from timber harvest on steep slopes. Sediment delivery is very low compared<br />

to other Forests because of relatively flat topography on the Forest and the low erosion hazard of<br />

most Forest soils.<br />

Comment<br />

The draft plan could further acknowledge the role of local Soil and Water Conservation Districts (SWCD's)<br />

in addressing and resolving local resource issues. The publicly elected directors of local SWCD's can<br />

be a key link to the community on such issues and provide additional expertise for assistance in forest<br />

management as related to private lands affected by that management.<br />

<strong>Response</strong><br />

The Forest is currently working with the Klamath Soil and Water Conservation District on projects such<br />

as the Williamson River Coordinated Resource Management Plan, where impressive riparian management<br />

benefits on Forest and private land have been achieved. A new standard and guideline has been added<br />

to ensure that the Forest will continue to work with SWCD's where mutual concern exists.<br />

Comment<br />

Water resources are not identified as an issue and are not very thoroughly discussed in the DEIS and<br />

the LRMP. Yet the Klamath River Basin is one of the most heavily used in the state from a water resources<br />

standpoint. We believe the treatment of water resources needs to be improved in the FEIS and LRMP.<br />

The most important issue is water yield and seasonal distribution.<br />

The DEIS indicates that water yield will not change in all decades among all of the alternatives. There<br />

are no data or studies to support this conclusion. Even though total yield may not change, the literature<br />

suggests that timber harvest can affect the timing and rate of run-off. The Water Resources Department<br />

is particularly concerned that the proposed large lodgepole pine harvest may allow snow to melt faster<br />

and accelerate discharge or later groundwater recharge and discharge. These potential impacts need<br />

to be analyzed in the EIS.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3 covering your concerns. To our knowledge, no<br />

scientific studies have been done to establish these relationships on local conditions. Our conclusions<br />

are based upon watershed studies done elsewhere in the western U.S. and on professional judgement.<br />

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Comment<br />

The riparian management area focuses discussion on wildlife habitat concerns. These objectives may<br />

be sufficient to assure the integrity of riparian communities, but specific goals directed to maintaining<br />

or preferably improving hydrologic conditions should be included. The goal should be to maintain or<br />

improve habitat and hydrologic conditions to retain diversity and provide for the continued production<br />

of riparian resources.<br />

<strong>Response</strong><br />

Correct. The management area goals and objectives have been revised to cover this concern and<br />

standards and guidelines have been included to protect hydrologic values.<br />

Comment<br />

It would help us considerably in our analysis if information on water yield and discharge and timber<br />

harvest activity were broken out by major watersheds on the Forest: the Williamson, Sycan, Sprague<br />

and Wood Rivers. This type of presentation would assist us in evaluating the cumulative impacts of<br />

other management activities in these watersheds.<br />

<strong>Response</strong><br />

Harvest activity was not broken out by watersheds because no sensitive watersheds have been identified<br />

and because much of the water from the forest flows underground and may not reflect any measurable<br />

change from timber harvest. A generalized watershed map was included in Chapter 3 of the FEIS.<br />

Water yield data has been included in Chapter 3 to show average water yields from several important<br />

gaging stations that are reflective of major watersheds. It is the intention of the Forest to begin recording<br />

timber harvest activity and certain other data according to major watersheds, but currently this information<br />

is not available.<br />

Comment<br />

Riparian area management is a critical concern in semi-arid eastern Oregon, where the lands around<br />

streams, lakes and other wet areas are so important to water flow management, fisheries, and species<br />

diversity. Unless done carefully, land management activities in riparian areas can compact soils and<br />

remove needed vegetation, thus changing water flow rates and raising water temperatures. A full<br />

understanding of the affected resources is essential to ensure that riparian zones are not degraded<br />

through land management activities. Their importance is underscored by the many State agencies<br />

which expressed concerns over possible degradation of these areas including the Department of<br />

Agriculture, Department of Water Resources, DEQ, and ODFW.<br />

We found insufficient detail in the DEIS and LRMP on riparian zones and evaluation of their condition.<br />

We request that you provide us, if possible, (with a map of riparian zones by condition class, or at<br />

least a compilation of this information by subbasin, and more information on the allowable livestock<br />

use rate in these zones.)<br />

<strong>Response</strong><br />

Management Area 8 and Forest wide range standards and guidelines have been revised to strengthen<br />

the protection of riparian areas. Range utilization standards have been tightened to ensure that riparian<br />

values are maintained or improved. The standards take into account existing condition of the riparian<br />

area. Riparian condition class has not been summarized to the detail you request. A new riparian survey<br />

is scheduled for 1990-1992. Discussion of watershed and riparian areas needing rehabilitation has<br />

been included in chapter 3 of the FEIS.<br />

Comment<br />

Regarding water quality, DEQ's main concern is that the LRMP be consistent with Oregon's adopted<br />

Statewide Water Quality Management Plan for forest practices as required by the Clean Water Act.<br />

The DEIS and LRMP recognize goals of meeting water quality standards and protecting beneficial<br />

uses of water. However, these documents lack information needed to assess adequately the water<br />

quality effects of proposed activities on the Forest, including sediment production and management<br />

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controls in specific watersheds. Findings need to be made on the relationship between baseline water<br />

quality conditions and the effects of proposed Forest activities. In Oregon, the Forest Practices Act<br />

and administrative rules aid in meeting Clean Water Act requirements. These rules should be addressed<br />

in the DEIS. See DEQ comments for a more detailed discussion.<br />

<strong>Response</strong><br />

Information has been added to Appendix H of the Plan describing how the forest will comply with the<br />

Clean Water Act. Chapters II and IV of the FEIS discuss the anticipated effects of management on<br />

water and riparian resources.<br />

Comment<br />

Regarding water quality, the Department's concern is that the Plan be consistent with Oregon's adopted<br />

Statewide Water Quality Management Plan for forest practices as required by the Clean Water Act. It is<br />

important to ensure that the proposed activities of timber harvest, road construction, chemical handling<br />

and usage, sewage disposal, livestock grazing and other forest land activities comply with Oregon's<br />

Water Quality Standards and Guidelines and be monitored for their effectiveness in complying with<br />

these and protecting beneficial uses of the water. However, important information is lacking in the Plan<br />

and DEIS to adequately assess the water quality effects of the activities in a multiple use forest, including<br />

sediment production and management controls in specific watersheds. In addition, findings need to be<br />

made regarding the relationship between baseline water quality conditions and the effects of the planned<br />

forest activities.<br />

<strong>Response</strong><br />

See response to previous comment. The State of Oregon has determined that Forest Best Management<br />

Practices meet or exceed the requirements of the Clean Water Act. Monitoring of implementation and<br />

effectiveness of BMP's will ensure that water quality is maintained or improved. Management Area 8<br />

standards and guidelines will protect multiple riparian area values. Those riparian areas in degraded<br />

condition will be rehabilitated. The process for implementing BMP's is described in Appendix H of the<br />

Plan. Monitoring program is described in Chapter 5 of the Plan.<br />

Comment<br />

The draft Winema Forest Plan provides a goal for meeting state water quality standards. The Plan also<br />

provides standards and guidelines for water that will meet standards through application of Best<br />

Management Practices (BMP) at the project planning level. We believe these are compatible statements,<br />

both of which, if achieved will maintain or improve water quality in the forest. To strengthen these<br />

statements and avoid misinterpretation of goals, we suggest specific references to Oregon's water<br />

quality standards (OAR Chapter 340, Division 41) and Oregon's forest practice rules (OAR Chapter<br />

629, Division 24) be added to the water resources goal statements (p. IV-2, proposed Plan) and the<br />

statements in the forest-wide standards section beginning on page IV-36 of the proposed plan.<br />

<strong>Response</strong><br />

Oregon State water quality standards have been referenced in soil and water goal statements and in<br />

standards and guidelines. Appendix H of the Plan has been added to discuss the Clean Water Act,<br />

Oregon Forest Practices Act, and Best Management Practices to protect water quality.<br />

Comment<br />

If the proposed preferred plan alternative can maintain or improve water quality, then the DEQ could<br />

support the preferred alternative. However, the Plan has a basic flaw that concerns us. The Plan and<br />

DEIS, collectively, display a lack of concern for water quality. We agree that the amount of water leaving<br />

the forest via surface and groundwater may be relatively small. But, this by no means should suggest<br />

a reduced emphasis on water quality. For example, the statements on page S-29 for Management<br />

Area 14, Minimum Management, concerning water are inappropriate and contrary to policy stated in<br />

Oregon Revised Statute (OAR 468.710) regarding the need to provide for adequate water quality to<br />

protect beneficial uses of water. The statements on page S-29 lead the reader to believe that water<br />

quality is not important.<br />

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Furthermore, the DEIS (pgs. 111-59-60) suggests that native trout is the indicator of water quality. The<br />

DEIS mentions that these trout populations are depressed because of stream and riparian habitat<br />

abuse by a long history of grazing. These statements prompt the reader to see what the plan is going<br />

to do about these poor conditions. Much to our disappointment, the proposed Plan identifies only 1%<br />

of the damaged riparian areas in the forest receiving rehabilitation efforts each year (1,000 acres needing<br />

improvement, 10 acres per year rehabilitation). We request that the forest staff be more aggressive<br />

and obtain complete rehabilitation in the first decade of the Plan. In so doing, the staff would start the<br />

native trout and water quality on the path to recovery rather than giving the appearance of maintaining<br />

the status quo.<br />

<strong>Response</strong><br />

All lakes, streams, wetlands, and other riparian areas have been included in Management Area 8 --<br />

Riparian, unless otherwise protected by other management areas such as wilderness. Forest-wide and<br />

management area standards and guidelines have been strengthened for the protection of the water<br />

resource.<br />

Only a small portion of the class 1, 11, and 11 streams on the Forest have unstable banks, and these<br />

areas are receiving treatment (see Chapter 3 FEIS). Excessive water temperature is a major limiting<br />

factor for trout populations in some streams, particulary those streams that receive most of their flow<br />

from off the Forest. Temperature in Forest streams will be lowered by enhancing overhanging bank<br />

vegetation and improving channel characteristics through implementation of standards and guidelines<br />

for control of livestock grazing. Water flowing onto the Forest frequently has excessive temperature<br />

due to degraded riparian conditions on private land upstream from the Forest. The Forest is currently<br />

participating in Coordinated Resource Management Plans to improve riparian and watershed conditions<br />

on streams with multiple ownerships. By these means, degraded streams will be improved and streams<br />

currently in good condition will be maintained. However, the healing process is often slow, so complete<br />

recovery may take longer than one decade.<br />

Comment<br />

We also suggest that the sediment production figures displayed in Table 11-3A of the DEIS be broken<br />

down by watersheds so that a more accurate watershed-by-watershed portrayal of sediment production<br />

can be made. The way in which the sediment production figures are depicted are meaningless when<br />

trying to assess management strategy impacts in various watersheds.<br />

<strong>Response</strong><br />

The sediment production figures are meant to be a relative comparison of the alternatives. The sediment<br />

production rates are very low, reflecting the low erosion hazard of the Forest. Given the low rates, it<br />

was felt that portraying sediment production by watersheds would have little value.<br />

Comment<br />

The monitoring plan given in Table V-1 of the Plan does not address water quality, per se. One would<br />

assume that it is covered in the native trout habitat/monitoring question #8). We request a specified<br />

plan for water quality, in some detail, be added to the monitoring plan.<br />

The goal of a Monitoring program to protect the water resource should be to assess the changing<br />

water quality conditions, not assessment of BMP implementation. The BMPs are tools to achieve water<br />

goals and should be monitored for their effectiveness to achieve water quality protection. However,<br />

BMPs are not the end products. Good water quality is the end product and, therefore, should be the<br />

focus of monitoring.<br />

<strong>Response</strong><br />

Water quality monitoring plan is now described in Chapter 5 of the Plan. Water quality monitoring is<br />

not limited to implementation of BMP's. It includes monitoring of implementation, effectiveness, and<br />

validation (see BMP discussion in Appendix H of the Plan).<br />

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Comment<br />

Adequate and guaranteed funding of a monitoring program is necessary. The proposed plan displays<br />

costs for monitoring, but this does not ensure that the monitoring will actually take place. It is our position<br />

that plan implementation monitoring is not voluntary or optional, but mandatory. Our position is based<br />

on the monitoring requirements inherent in the national Forest Management Act (NFMA) which states,<br />

"(E) insure that timber will be harvested from National Forest System lands only where:<br />

(iii) protection is provided for streams, streambanks, shorelines, lakes, wetlands, and other bodies<br />

of water from detrimental changes in water temperatures, blockages of water courses, and deposits<br />

of sediment, where harvests are likely to seriously and adversely affect water conditions or fish<br />

habitats (Section 6, NFMA).<br />

<strong>Response</strong><br />

We agree. With adequate funding for implementation and monitoring of standards and guidelines and<br />

best management practices, the risk of damaging water and riparian resources is rather low. Without<br />

adequate funding the risk is high. The Forest will make every effort to secure adequate funding.<br />

Comment<br />

The Plan virtually ignores the groundwater component of the hydrologic cycle. The Plan and DEIS do<br />

recognize that 95% of the forest is a groundwater recharge area with thousands of acre feet of water<br />

surfacing down gradient, some of which is becoming stored in Klamath Lake (DEIS, pg. 111-5). With this<br />

magnitude of groundwater storage, the Plan should recognize the importance of groundwater protection<br />

and discuss the following points.<br />

1. Activities that affect groundwater quality will eventually affect surface water quality. Conversely, changes<br />

in surface water quality might be reflected in groundwater quality.<br />

2. Lakes with unique pristine water quality may need special groundwater protection requirements to<br />

prevent nutrient enrichment, particularly with regard to sewage disposal practices associated with<br />

intensive recreational use.<br />

3. All sewage disposal practices need to be in compliance with state requirements. Please state those<br />

requirements by reference in the Plan.<br />

4. Groundwater protection planning should be included in all chemical handling practices, in the forest.<br />

This would include, but not be limited to herbicides, pesticides, fertilizers, and degreasing solvents at<br />

maintenance shops.<br />

5. Activities and procedures that minimize erosion, and surface water runoff also will increase infiltration,<br />

allowing for more stable year round stream flow.<br />

<strong>Response</strong><br />

Information and Standards and Guidelines have been added to the FEIS and Forest Plan, for those<br />

items above.<br />

Comment<br />

The Forest needs to use the interagency standards for rating riparian ecosystems found in "Managing<br />

Riparian Ecosystems for Fish and Wildlife in Eastern Oregon and Eastern Washington' (1979). The<br />

DEIS disclosed no inventory information using the above standards. These standards were adopted<br />

by Region Six in 1979 for use in evaluating riparian ecosystems and as input to the planning process.<br />

<strong>Response</strong><br />

The standards in the stated report were used in formulating our Standards and Guidelines. The report<br />

was listed in the reference section. Our Standards and Guidelines will equal or exceed the standards.<br />

Comment<br />

ODFW recommends as a Forest-wide standard no programmed timber harvest in riparian areas of<br />

Class 1, 11, Ill, and IV streams, nor in wet and moist lodgepole pine sites subject to regeneration problems.<br />

ODFW recommends no grazing be permitted in riparian areas in less than "good' condition.<br />

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<strong>Response</strong><br />

There will be no programmed timber harvest within 100 feet of class I and 11 streams and within 50 feet<br />

of class Ill streams. With standards and guidelines and best management practices, programmed<br />

timber harvest can be permitted on the remaining riparian while still protecting or enhancing riparian<br />

values and water quality. Standards and guidelines for grazing will maintain or enhance riparian values<br />

since they are more restrictive when condition is less than good.<br />

Comment<br />

The goal for riparian habitat management should be at least 80 percent of potential. ODFW recommends<br />

the Forest implement protective measures necessary to achieve functional recovery of 80 percent of<br />

potential fish and wildlife habitat characteristics within 10 years; ecological recovery of native plant<br />

communities should be reached in 20 years. This recommendation is consistent with the Forest goal<br />

of maintenance or recovery of riparian values and Forest Service Manual (FSM) 2526 policy to give<br />

preferential consideration to riparian-dependent resources over nonriparian-dependent resources.<br />

<strong>Response</strong><br />

It is not clear what is meant by 80% potential. It could mean climax or could mean the condition before<br />

white settlers; there is no sure measuring point. Ecological recovery is an objective that could be achieved,<br />

but would most likely take much longer than 20 years. The goal stated in Chapter 4 of the Plan, "maintain<br />

and/or enhance structure and function of wetland ecosystems ... to maintain ecological integrity," will<br />

in all probability achieve the same objective.<br />

Comment<br />

The DEIS did not describe the condition of springs, seeps, and associated riparian vegetation. Most<br />

such water sources on grazing allotments have been degraded and the potential exists for disease<br />

transmission between livestock, wildlife, and man. Region Six range improvement handbooks describe<br />

the protective measures needed for springs and seeps.<br />

<strong>Response</strong><br />

Riparian management area 8 has been expanded to include springs and seeps and standards and<br />

guidelines have been added to ensure their protection.<br />

Comment<br />

P.111-7.<br />

(Paragraph 1) What is the cause for the temperature and dissolved oxygen problems in the Sprague<br />

River during the late summer months? (DEIS 111-7-1) What causes the turbidity problems to the tributary<br />

intermittent streams flowing into the Sprague River? (DEIS 111-7-2).<br />

<strong>Response</strong><br />

Water coming onto the Forest has been impacted by intensive agricultural use up stream from the<br />

Forest (channelization, overgrazing, removal of streambank vegetation, irrigation, etc.). This has caused<br />

the high temperature and low dissolved oxygen problem.<br />

Intermittent streams flowing from Forest land south of the Sprague River will have some elevated turbidity<br />

levels during spring run-off. This area does not have a pumice and ash soil mantle and consequently<br />

can have rapid run-off that picks up some sediment on both private and Forest Service lands. Copperfield<br />

Draw has been identified as a high priority area for rehabilitation.<br />

Comment<br />

P.111-8.<br />

(Paragraph 2). What is the current condition of riparian habitats on the Forest? (DEIS 111-8-1).<br />

(Paragraph 5). What is the problem with the three areas that need watershed improvement work? (DEIS<br />

111-8-2).<br />

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<strong>Response</strong><br />

Additional information has been added to Chapter 3 concerning current condition of riparian habitats.<br />

Three of the areas with watershed problems (Telephone Draw, Bull Pasture, and Copperfield Draw) are<br />

associated with livestock and past logging and roading activities. One area (Great Meadow) involves a<br />

drainage ditch cut into a tufted hair grass meadow to drain the meadow for a landing strip.<br />

Comment<br />

P.IV-5.<br />

(Paragraph 1). Soil productivity and water quality will be protected in all alternatives... The sediment<br />

outputs displayed in Table 11-3A indicate the degree of protection varies significantly among the<br />

alternatives. Most alternatives show a significant increase in sediment yield from decade one to decade<br />

five.<br />

<strong>Response</strong><br />

Sediment outputs do vary by alternatives, but the total magnitude in each alternative is very low. Higher<br />

output are associated with more logging on steep ground. Implementation and monitoring of standards<br />

and guidelines and BMP's will ensure that sedimentation will remain low.<br />

Comment<br />

P.IV42.<br />

Paragraph 2). The Forest states "...less than 5 percent of the total streambanks on the Forest are in<br />

degraded conditions." When was the inventory for the level of degraded conditions conducted and<br />

what were the criteria used to judge conditions? (DEIS IV-44).<br />

<strong>Response</strong><br />

F<br />

The inventory was made in 1979 and 1980. A standard Regional process was used which considered<br />

vegetation, rock content, slope gradient and other factors.<br />

Comment<br />

D-17.<br />

2.a Define sufficient amount.'<br />

<strong>Response</strong><br />

OSufficient Amount! will vary somewhat depending upon the riparian community present. This will be<br />

determined during project level planning.<br />

Comment<br />

D-17.<br />

2.b. Change to read *... along at least 80 percent of a stream's length within the project area.'<br />

<strong>Response</strong><br />

Was changed to read a... in a stable condition along at least 85 percent of a stream's length in any<br />

given drainage.'<br />

Comment<br />

D-17.<br />

2.c. Add class Ill streams to line four.<br />

<strong>Response</strong><br />

Class IlIl streams have been added to standard and guideline.<br />

Comment<br />

D-17.<br />

3.a. Add class IlIl streams to line one.<br />

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<strong>Response</strong><br />

Class IlIl streams are protected under 3c.<br />

Comment<br />

D-17.<br />

3.c. Strike class III on line one and add class IlIl to lines three and five.<br />

<strong>Response</strong><br />

We feel that it should remain as stated.<br />

Comment<br />

PP IV-50.<br />

2.a. Define sufficient amounts."<br />

<strong>Response</strong><br />

oSufficient amountN will vary somewhat depending upon the riparian community present. This will be<br />

determined during project level planning.<br />

Comment<br />

PP IV-50<br />

2.c. Class Ill needs to be included in this paragraph.<br />

<strong>Response</strong><br />

Class Ill streams was added to this paragraph.<br />

Comment<br />

Wildlife and Fish Program Goals, IV-3: Paragraph 2 which states, To maintain or enhance the unique<br />

and valuable...or improve water quality," also should include water quantity.<br />

<strong>Response</strong><br />

That is stated as a Soil and Water (Watershed Management) goal.<br />

Comment<br />

Resource Outputs and Activities, Table IV-1, IV-9: The table indicates that water yield will remain constant<br />

at 700,000 acre feet annually from decade one through decade five. On the surface this analysis seems<br />

questionable considering that 87,000 acres of lodgepole pine will be harvested during the first decade,<br />

primarily from the upper Williamson River drainage (chemult RD).<br />

<strong>Response</strong><br />

An explanation has been added to the Water section of Chapter 3 FEIS.<br />

Comment<br />

The Department is concerned with the effect the proposed large lodgepole pine harvest will have on<br />

surface water discharge. Removing the canopy cover over such a large area may allow snow to melt<br />

faster and accelerate discharge or alter ground water recharge and discharge. The potential effects of<br />

large-scale lodgepole pine harvest on downstream water uses need to be examined in both the LRMP<br />

and DEIS.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3 to address your concerns.<br />

Comment<br />

Soil and Water Program, Monitoring the Effects of Forest Plan Implementation, IV-1 8: This section fails<br />

to include a water quantity monitoring program. There is no mention of monitoring for water quantity<br />

changes which might result from implementation of the forest plan. Table V-1 does not break out the<br />

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frequency of monitoring to meet provisions of the LRMP or the costs associated with monitoring water<br />

supply. Riparian monitoring is expected to be undertaken through the Interdisciplinary Team review of<br />

each environmental assessment. In addition, neither Table B-i or B-2 includes budgets for monitoring<br />

the effects of management decisions on water supply.<br />

<strong>Response</strong><br />

We will not have a water quantity monitoring program because we do not believe there will be a significant<br />

change in runoff and because flow is adequately measured by U.S.G.S. monitoring stations. This is<br />

explained in Chapter 3 of the FEIS. The monitoring plan for water and riparian quality has been expanded.<br />

Comment<br />

There is no specific guideline addressing water quantity. The Department suggests including a<br />

standard/guideline stating management activities, such as timber harvest, will not accelerate the timing<br />

or rate of seasonal runoff. These activities may produce some temporary acceleration of runoff, but<br />

runoff will not be affected over a period of more than two runoff seasons.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3. Standards and guidelines limit intensity and spacing<br />

of harvest if it will negatively affect hydrologic conditions.<br />

Comment<br />

1. Riparian area management objectives (LRMP, IV-50) for a management unit should explicitly include,<br />

in addition to the 1 00-foot minimum management zone on either side of a stream, sufficient upland<br />

transition zone required to meet all the riparian standards.<br />

<strong>Response</strong><br />

The standards include 100 feet from a streams plus the farthest reaches of riparian vegetation as a<br />

minimum, and would include additional area if needed.<br />

Comment<br />

2a. The term sufficientw should be replaced with a minimum quantifiable standard for maintenance of<br />

ground cover. Require that a percentage of ground cover by area (for example, 80 percent per square<br />

meter) or percentage of ground cover by management unit (80 percent of the unit) be maintained to<br />

stabilize soil movement and prevent erosion in the two major soil types. This would not be conceptually<br />

different than the guideline which requires stable streambanks along 80 percent of the streams on the<br />

Forest.<br />

<strong>Response</strong><br />

Refer to the Effective Ground Cover Table (4-12) in the soils section of the Forest-wide standards and<br />

guidelines, Chapter 4 of the Plan. "Sufficient Amount" will vary somewhat depending upon the riparian<br />

community present. This will be determined during project level planning.<br />

Comment<br />

2c. This guideline calls for development of specific quantitative criteria on a stream-by-stream basis.<br />

For planning purposes, maximum and minimum parameters would prove useful for establishing the<br />

acceptable range of management options for woody debris and structural habitat for fish.<br />

<strong>Response</strong><br />

Specific recommendations will be made during project level planning.<br />

Comment<br />

3b. This standard states that an increase of no more than 10 percent in natural stream turbidities will<br />

be allowed, and that temporary changes will be allowed but must be 'minimal' and adequately monitored.<br />

A temporary variance allowing no more than a specific percentage (for example, 35 percent) for a<br />

period of hours, days or weeks would be more useful than the term "minimal.' This would establish an<br />

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upper limit which would make monitoring changes in, and environmental effects of, turbidity more<br />

meaningful.<br />

<strong>Response</strong><br />

This would depend on the stream system and the timing. We believe this Oregon water quality standard<br />

is acceptable.<br />

Comment<br />

5. Amend the wetlands and floodplains standard to include maintenance of wetlands and floodplains<br />

to store and route ground and surface water, including floodwaters.<br />

<strong>Response</strong><br />

Standards and guidelines have been amended accordingly.<br />

Comment<br />

In conjunction with the Forest's ongoing discussions with the Klamath Tribe and the Oregon Department<br />

of Fish and Wildlife on development of minimum streamflows, a standard addressing streamflow volumes<br />

might be useful. One suggestion might be to include a standard which maintains or increases stream<br />

pool volumes during low streamflow conditions.<br />

<strong>Response</strong><br />

A statement has been added in Standards and Guidelines, that the Forest will conform with any minimum<br />

stream flow established and maintain or increase stream pool volumes during low stream flow conditions.<br />

Comment<br />

Under alternative D, almost 102,000 acres of lodgepole pine will be converted (harvested) during the<br />

second decade alone. Coupled with the total potential acreage subject to even-aged management,<br />

clearcutting, and associated soil disturbance, the natural inference, although difficult to determine, is<br />

that the timber harvest contained in this alternative will have an impact on water resources. Yet Table<br />

S-2, DEIS page S-32, indicates water yield will not change in all decades among any of the alternatives.<br />

While total water yield may not change, the Water Resources Department is concerned with potential<br />

changes to the timing and rate of seasonal runoff. Literature suggests that forest practices can affect<br />

the timing and rate of runoff. This alternative, along with all the alternatives, fails to discuss the affect<br />

timber harvest practices may have on seasonal runoff patterns.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3, covering this concern.<br />

Comment<br />

Although the management strategies developed to meet wildlife habitat management objectives may<br />

be sufficient to ensure the integrity of riparian communities, specific goals which maintain or improve<br />

hydrologic conditions, in addition to habitat requirements, should be identified.<br />

<strong>Response</strong><br />

Standards and guidelines for hydrologic protection have been strengthened. Management strategies<br />

for wildlife are designed to also maintain or improve hydrologic conditions.<br />

Comment<br />

Riparian areas are highly productive, sensitive and geographically limited ecosystems. A variety of<br />

important resources, including wildlife, depend totally on riparian areas. The management goal for<br />

riparian areas should include provisions emphasizing maintenance or improvement of habitat and<br />

hydrologic conditions to retain diversity and provide for the continued production of riparian resources.<br />

The goal may restrict levels of management for nonriparian dependent resources to those activities<br />

that exhibit a high probability of benefitting riparian resources and produce few adverse effects.<br />

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Site-specific riparian management objectives should be developed for each riparian unit. Programmed<br />

timber harvest may not be suitable for specific riparian units.<br />

<strong>Response</strong><br />

Standards and guidelines for riparian management have been strengthened. The riparian management<br />

area [8] has been revised to include management intensities for specific types of riparian areas. Timber<br />

harvest is not programmed near class 1, 11, and Ill streams.<br />

Comment<br />

The Winema National Forest does not break out information by watershed or drainage area. Both the<br />

DEIS and LRMP could be improved with additional data on water resources.<br />

<strong>Response</strong><br />

Additional information has been added to Chapter 3 about watersheds. It was determined that watersheds<br />

were in relatively good condition and management would not benefit from breaking out information on<br />

a watershed or drainage area basis. However it is the intention of the Forest to begin summarizing<br />

data according to watershed.<br />

Comment<br />

The DEIS briefly describes forest hydrology in general terms, and lists the major streams and miles of<br />

class 1, 11 and Ill streams. It points out that forest streams respond differently to precipitation than do<br />

other northwest streams because of pumice and ash soils. The discussion suggests forest soils have<br />

a high infiltration rate and water is released gradually to discharge zones. However, the discussion<br />

fails to discuss stream density or document whether streams respond directly to precipitation.<br />

<strong>Response</strong><br />

Additional information has been added to Chapter 3 covering your concerns.<br />

Comment<br />

The DEIS states the Forest yields roughly 700,000 acre feet per year, 95 percent of which flows into<br />

Upper Kiamath Lake. Yield and discharge information is not broken out by watershed or drainage.<br />

Furthermore, there is no discussion of the effects of land treatment on discrete watersheds. Nor is an<br />

attempt made to examine in more than a cursory fashion the cumulative effects of land treatment on<br />

the water resources of the forest, and on downstream water users.<br />

<strong>Response</strong><br />

Information was not broken out by watershed because no watersheds were determined to be sensitive.<br />

However additional information was added to Chapter 3 of the FEIS concerning watersheds.<br />

Comment<br />

Discussion of the affected environment on page 111-8 of the DEIS points out that total flows from the<br />

Forest will remain essentially unchanged in the future, although there may be some minor changes of<br />

flows due to lodgepole pine mortality... None of these activities will significantly affect the availability of<br />

water.' This may be so, but these statements lack documentation for independent analysis of the effects<br />

on seasonal runoff patterns and total water yield of the large-scale lodgepole pine harvest envisioned<br />

by the plan.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3 covering your concerns. To our knowledge, no<br />

scientific studies have been done to establish these relationships on local conditions. Our conclusions<br />

are based upon watershed studies done elsewhere in the western U.S. and on professional judgement.<br />

Comment<br />

To its credit, the Forest states it is not manipulating vegetation for the purpose of increasing or altering<br />

stream flows. However, although the Forest indicates there may be incidental changes from timber<br />

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management activities, it does not provide any further discussion or analysis of what the effects might<br />

be. Again, further documentation or analysis would be useful for independent assessment of these<br />

assertions.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3 covering your concerns.<br />

Comment<br />

There is no information included in the DEIS describing watershed boundaries, watershed conditions,<br />

or the importance of Forest watersheds to downstream, off-Forest water users.<br />

Additional useful data needed are:<br />

a. Watersheds location, area, elevation, slope and aspect, estimated annual,<br />

flood and low flows, and condition (the DEIS mentions areas<br />

needing watershed improvement but includes no inventory of conditions.<br />

b. Forest map of watersheds<br />

c. Forest map indicating improvement areas<br />

d. Inclusion of Soil and Water Improvement Inventory<br />

<strong>Response</strong><br />

Necessary information has been added to Chapter 3 covering your concerns. Not all the requested<br />

information is available at this time.<br />

Comment<br />

Paragraph four, page B-1 9 of the Appendices, states that the Forest has classified streams based on<br />

Regional standards for streamflow and use characteristics. Including this information in an appendix<br />

would be useful for examining the interaction of land treatment practices on streamflow and water use.<br />

<strong>Response</strong><br />

Stream class definitions have been added to the Description of Management Area 8 Riparian in the<br />

Plan and to Chapter 3 of the FEIS.<br />

Comment<br />

The DEIS emphasizes the impacts of forest roads on wildlife, page 111-104, and does not discuss potential<br />

water quality or hydrologic impacts. Water quality impacts are alluded to in the discussion of affected<br />

environment for soil, water and air quality, page 111-4. Erosion, because of the type of soils occurring in<br />

the Forest, apparently is not a serious problem. Hydrologic impacts are not discussed.<br />

<strong>Response</strong><br />

Additional information concerning these relationships has been added to Chapters 2, 3, and 4 of the<br />

FEIS.<br />

Comment<br />

Effects of the alternatives on soils and water, page IV-4, fails to identify potential hydrologic impacts.<br />

The DEIS makes clear that soil-disturbing activities such as road building will be subject to the guidelines<br />

contained in Appendix D. Appendix D, page D-1 9, adequately sets standards to protect soils from<br />

disturbance and minimize erosion, but does not specifically set standards to protect hydrologic values.<br />

<strong>Response</strong><br />

Hydrologic values are protected by the revised Forest-wide and Management Area 8 - Riparian Standards<br />

and Guidelines.<br />

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Comment<br />

The Forest should discuss whether or not high road densities accelerate water runoff.<br />

<strong>Response</strong><br />

Additional information has been added in Chapter 3. High road densities are not accelerating water<br />

run-off on most of the Forest since most of the soils on the Forest are highly permeable (greater than<br />

20 inches per hour) and there is very little run-off water to be collected on roads. On approximately 20<br />

percent of the Forest the roads can accelerate water run-off, but these roads are mostly gravelled and<br />

properly drained.<br />

Comment<br />

The lack of timber resources and harvest information by watershed or drainage makes hydrologic<br />

analysis extremely difficult. At a minimum, data should be arrayed for the major watersheds of the<br />

Forest: the Williamson, Sycan, Sprague and Wood Rivers drainages. Further segregation of data at a<br />

finer scale for specially affected environments, such as the upper Williamson watershed, would be<br />

useful. A summary table of proposed harvest activities by watershed/drainage would make it easier to<br />

examine the potential impacts to a stream system, and whether dispersion constraints are being followed.<br />

<strong>Response</strong><br />

Additional information has been added to Chapter 3 about watersheds. It was determined that watersheds<br />

were in relatively good condition and management would not benefit from breaking out information on<br />

a watershed or drainage area basis. It is the intention of the Forest to begin summarizing certain information<br />

by watershed.<br />

Comment<br />

Further definition of dispersion constraints by watershed would be useful to assess hydrologic impacts<br />

of land treatment.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3 covering your concerns.<br />

Comment<br />

Plans to harvest insect-damaged lodgepole pine highlight the previous two points of the timber harvest<br />

comments. Volumes, acreages and reforestation figures and methods are listed for lodgepole pine,<br />

but location of proposed actions in relation to watersheds and drainages is missing. Table IV-13, page<br />

IV-36 of the DEIS, indicates that under the preferred alternative 139,200 acres of lodgepole pine will be<br />

harvested in the first two decades, 87,000 acres in the first 10 years. This information is broken down<br />

by ranger district in other sections of the documents. However, as significant as this action is, there is<br />

no way to determine potential water resource impacts because the information is not arrayed in suitable<br />

maps and accompanying tables and site-specific harvest plans.<br />

<strong>Response</strong><br />

Additional discussion has been added in Chapter 3. Refer to the watershed map that has been added<br />

to Chapter 3 of the FEIS. Most of the impact from lodgepole pine harvest will be on the Williamson<br />

River watershed.<br />

Comment<br />

Generally, data are presented in a consistent manner. Unfortunately, the structure of the documents<br />

consistently provides no succinct description of hydrologic data.<br />

<strong>Response</strong><br />

Little data about timber harvest and other activities has been collected and organized by watershed in<br />

the past. Due to the rather flat topography on the Forest, it is difficult for a person traveling on the<br />

ground to know when one watershed is left and another entered. Also, erosion, sedimentation, slumps<br />

and slides are relatively minor problems on this Forest. Consequently, watershed analysis has not<br />

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eceived the priority that it might otherwise have had. However, it is the intention of the Forest to begin<br />

to collect and organize certain data according by watershed. Additional flow data on the major rivers<br />

has been furnished in Chapter 3.<br />

Comment<br />

Riparian values are consistently dealt with through wildlife habitat issues and range activities. It appears<br />

that there is an opportunity to expand upon management objectives for riparian areas in order to provide<br />

water resources benefits.<br />

<strong>Response</strong><br />

Management objectives for wildlife and range activities are designed to protect or enhance the water<br />

resource values. However, standards and guidelines for protection of hydrologic values have been<br />

strengthened.<br />

Comment<br />

Under the Water, Soil and Air Forestwide Standards and Guidelines, on p. IV-50, insert a new #13 to<br />

read:<br />

13. Meet aquatic resource protection standards of Oregon's Removal-Fill Law (ORS 541.695).<br />

<strong>Response</strong><br />

This has been added to the Forest wide Standards and Guidelines.<br />

Comment<br />

The Winema Forest has not developed a management strategy for watersheds. ORC urges the Forest<br />

to develop such a strategy; this need is supported by a wealth of watershed and stream ecology research.<br />

The strategy should be applied to all watersheds, including terrestrial areas. It should allow no<br />

programmed timber harvest within 150 feet of riparian zones; extend the rotation of timber harvest in<br />

all terrestrial areas that influence water quality and flow regime, to no greater than 10% occurrence of<br />

trees in age-class 0-50 at any one time; prohibit exposure of mineral soil in excess of 5% in any area<br />

that contributes directly to a watershed; manage all potential wild and scenic rivers with a 1/4 mile no<br />

impact boundary on each side of the waterway.<br />

<strong>Response</strong><br />

Timber harvest is not programmed near class I and 11 streams. Activities are limited in and near all<br />

other riparian areas. Generally, uneven-aged management is prescribed in riparian areas, except<br />

lodgepole where other restrictions apply. Watershed, riparian, and wild and scenic values are protected<br />

by Forest-wide and Management area standards and guidelines.<br />

Comment<br />

Page A-4, number 10. Riparian habitat and wetlands should be added to the items of concern listed in<br />

number 10 in the final document.<br />

<strong>Response</strong><br />

These concerns were identified under Water on page A-4 item 14.<br />

Comment<br />

Page 111-7, para 1. Specific reasons and possible management solutions for the high water temperature<br />

and turbidity levels in the Sprague River should be provided in the final statement.<br />

<strong>Response</strong><br />

Discussion has been added to Chapter 3.<br />

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Wild and Scenic Rivers<br />

Comment<br />

If the Sycan River does not have or gain special designation at this time in history, it can never gain<br />

special designation as it now is forever in the flow of history. This river is probably the most sensitive<br />

water way ecosystem in Oregon. It is a very small ecosystem and a short river.<br />

<strong>Response</strong><br />

The Forest determined that the Sycan was eligible for inclusion in the National Wild and Scenic River<br />

System. The Omnibus Oregon Wild and Scenic Rivers Act of 1988 included most of the sycan river as<br />

a portion of the National System. See Appendix E of the FEIS for additional information.<br />

Comment<br />

Your analysis of Wild and Scenic Rivers does not reflect informed views on the Upper Williamson where<br />

rehabilitation now underway is expected to restore and support remarkably productive trout water, and<br />

on the Sprague which does have recreational potential as well as a good trout fishery. Both should be<br />

reexamined.<br />

<strong>Response</strong><br />

Concerning the Upper Williamson River: We agree that in the future after the restoration work is complete<br />

there is a potential to have a good trout fishery. Our evaluation of this river segment did not indicate<br />

that this condition exists today and therefore we found no outstandingly remarkable values. Please see<br />

Appendix E of the FEIS for additional details.<br />

Concerning the Sprague River: Our evaluation of the Sprague River revealed that the fish and recreation<br />

values of the river segment were about standard for a river in Central Oregon. We found no outstandingly<br />

remarkable values. Please see Appendix E of the FEIS for additional details.<br />

Comment<br />

The Sprague was determined to be ineligible due to absence of outstanding remarkable features. In<br />

contrast, the Oregon State Parks and Recreation Division believes that the Sprague has outstanding<br />

recreational values and should be considered for possible eligibility. We recommend that you discuss<br />

the Sprague with State Parks and reconsider your conclusion. In all rivers studies, you should ensure<br />

that all eligible rivers are examined in this assessment and fairly considered for the different designation<br />

categories.<br />

<strong>Response</strong><br />

In order for a river segment to be eligible for inclusion in the National Wild and Scenic River System it<br />

must be free flowing and contain one outstandingly remarkable value. We agree that the Sprague<br />

River down to the Chiloquin dam is free flowing. No information was submitted which would lead us to<br />

believe that we should change our findings concerning the lack of outstandingly remarkable values.<br />

Our analysis of the river is that the recreation values are about average for a river in central Oregon.<br />

See Appendix E of the FEIS for additional information.<br />

Comment<br />

The potential population status of the upper Williamson downstream from the Wickiup Springs area<br />

has been misinterpreted. We believe that the river down to about Irving Creek has the potential to<br />

produce trout comparably with the segment just below Wickiup Spring. The difference in forecast<br />

population level would result from angling mortality, those fish caught and removed from the population<br />

by anglers.<br />

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<strong>Response</strong><br />

We agree that the fisheries values in the Wickiup Spring area are significant but this value can only be<br />

attributed to a very small area around the spring on private land. From the spring to Irving Creek the<br />

fisheries values are about average for a river in central Oregon. We agree that this section has the<br />

potential for higher concentrations of fish because of the habitat work currently under way on the river,<br />

but those values do not exist today.<br />

Comment<br />

Basic eligibility information for some of the river segments addressed were not presented in the DEIS<br />

appendix. This includes segment mileage, land ownership and current Forest management prescriptions.<br />

<strong>Response</strong><br />

Segment mileage and land ownership have been added in the FEIS Appendix E for the Lower Williamson<br />

River. This was not done for the rivers that do not qualify for inclusion in the System. The current Forest<br />

management prescriptions are detailed in Alternative A and NC in Chapter 11 of the DEIS and FEIS.<br />

Additional information on ownership and current and probable use of land has been added to the<br />

suitability section in Appendix E and Chapter III and IV of the FEIS.<br />

Comment<br />

The Winema Forest erred in its eligibility analysis of the Upper Williamson River. From 0.5 miles upstream<br />

of Wickiup Spring to Irving Creek the Williamson satisfies the two requirements for eligibility set forth<br />

by the Act: the river is free-flowing and possesses one or more outstandingly remarkable values. The<br />

fact that the highest population of native rainbow and brook trout in the state exists preferentially in<br />

the vicinity of the spring does not disqualify the river downstream. ORC urges the Forest to reassess<br />

for eligibility the Upper Williamson, using requirements set forth in the Act and Handbook. Poor habitat<br />

conditions are the result of inadequate resource management; Wild and Scenic designation would<br />

compliment the current habitat enhancement work. We also recommend adding recreation and scenic<br />

to the list of outstandingly remarkable values. We recommend a scenic classification.<br />

<strong>Response</strong><br />

We agree that the river segment is free-flowing but do not agree that the river offers outstandingly<br />

remarkable scenic and recreation values. We find the scenic and recreation values to be about average<br />

for a river in central Oregon.<br />

We agree that the fisheries values in the Wickiup Spring area are significant but this value can only be<br />

attributed to a very small area around the spring on private property. From the spring to Irving Creek<br />

the fisheries values are about average for a river in central Oregon. This is due in part because of<br />

habitat conditions and also because the fish populations tend to migrate to the Wickiup Spring area<br />

and cooler water as the water down stream warms.<br />

Our studies do not support eligibility of the upper Williamson River as a candidate to the National Wild<br />

and Scenic river system (see Appendix E).<br />

Comment<br />

Standard progression for a Wild and Scenic River assessment, as outlined in the Act and detailed in<br />

the Handbook is to start with eligibility, then classify the river into appropriate segments, then proceed<br />

to suitability. The DEIS assessment of the Lower Williamson shows the river was first classified into<br />

segments, then assigned outstandingly remarkable values.<br />

<strong>Response</strong><br />

A Wild and Scenic River study is not conducted in a clear step by step process. In fact, the eligibility<br />

and classification process tend to be interrelated and occur at about the same time. We have modified<br />

the text of the study to clarify the study process.<br />

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Comment<br />

The same problems with methodology outlined above apply to the Sprague River assessment. Page<br />

E-1 6 in the DEIS the river is freeflowing, yet goes on to say the private lands are impacted by dikes<br />

and irrigation facilities. The implication is that these impacts disqualify the entire river, including the<br />

portions on Forest lands. The finding of ineligibility for the Sprague is incorrect and a new study should<br />

be completed.<br />

<strong>Response</strong><br />

We have modified the text to clearly state that the reason for the finding of ineligibility is that no<br />

outstandingly remarkable value was found on private or public land. We agree that the impacted private<br />

land would not necessarily disqualify the river from inclusion in the national system.<br />

Comment<br />

We could find no indication of a suitability study in the DEIS. The introduction in Appendix E explains<br />

the suitability process, but that is the only reference. Without documentation of this portion of the study<br />

ORC has no means of commenting on the recommendations in any of the Forest's alternatives. Eligibility,<br />

classification and suitability should be assessed for all rivers, per the Act and Handbook, and the results<br />

presented in a study report. ORC cannot recommend simply adding this information to the Final Plan.<br />

Without reassessing the rivers and presenting the results for comment, the public has no way of influencing<br />

this portion of Forest planning.<br />

<strong>Response</strong><br />

As pointed out on page E-3 of Appendix E of the DEIS, several factors must be considered including<br />

public, state or local government interest. The method we selected to determine *interest' was through<br />

public participation on the DEIS. We have rewritten suitability section to reflect public input. Other factors<br />

of suitability are displayed in Chapter 4 of the FEIS.<br />

Comment<br />

The two rivers given consideration as potential wild and scenic rivers in the Winema Draft Plan were<br />

each identified through the NRI; no mention is made of attempts to identify other potential candidates.<br />

<strong>Response</strong><br />

Please see the first paragraph under RIVER SEGMENT ANALYSIS in Appendix E of the DEIS. This<br />

paragraph identifies the Upper Williamson River above the Klamath Forest National Wildlife Refuge and<br />

the Lower Williamson River below Chiloquin as being added to the study process. These two Segments<br />

were not identified in the Nationwide Rivers Inventory.<br />

Comment<br />

The Winema Draft Forest Plan/DEIS Fails To Provide Adequate Interim Protection For Eligible River<br />

Segments. The standards contained in Management Area 5 (Wild and Scenic Rivers) are inadequate<br />

for the protection of eligible wild and scenic river candidates. While the intent of the standards may be<br />

to protect eligible rivers in their present condition, they do not provide specific protections mandated<br />

through the USDAIUSDI Interagency Guidelines and the Forest Service Handbook, Chapter 8.<br />

<strong>Response</strong><br />

The standards and guidelines for Management Area 5 have been revised to conform with Chapter 8 of<br />

the Forest Service Handbook. Please see Chapter 4 of the Forest Plan for the revised standards and<br />

guidelines.<br />

Comment<br />

The Draft Plan fails to contain any detailed description of the management scenic river protection. The<br />

Final Plan should contain specific standards which adequately protect eligible river segments according<br />

to their classification. These standards should be consistent with the above mentioned USDA/USDI<br />

Guidelines, and the Forest Service Handbook, Chapter 8. All river segments found eligible should be<br />

placed within this management zone pending full suitability determinations.<br />

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<strong>Response</strong><br />

Alternative E was the Preferred Alternative in the DEIS and therefore was displayed in the Draft Forest<br />

Plan. The Draft Plan only displayed Management Area standards and guidelines which pertained to<br />

the allocation of Alternative E. Because of congressional action which declared the Sycan River a part<br />

of the National System, the Final Forest Plan now contains standards and guidelines to protect the<br />

Sycan under a Scenic Classification. Segment two of the Lower Williamson River was found eligible for<br />

inclusion in the System (see Appendix E). This segment is not being recommended for inclusion in the<br />

System under the new Preferred Alternative but will be managed to protect the scenic, recreational<br />

and scientific values of the area. See Chapter 4 of the Final Forest Plan for details.<br />

Comment<br />

The Planning Handbook directs that special management areas be defined along all rivers where<br />

evaluations are deferred into the future (Section 8.23). We recommend that the Final Plan and EIS<br />

designate such areas along the entire length of the Sprague, Sycan and Williamson Rivers, and that<br />

these rivers be managed as de facto Wild and Scenic Rivers until full evaluations are completed.<br />

<strong>Response</strong><br />

A complete study of the rivers was conducted as a part of the Forest Planning process. This study is<br />

contained in Appendix E of the FEIS.<br />

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Wildlife Habitat Management<br />

Comment<br />

To classify this National Forest as a National Wildlife Biological Preserve and National Critical habitat<br />

area, so as to save all life, including the peregrine falcon, bald eagle,, northern spotted owl, goshawk,<br />

marten, ferruginous hawk, Swainson's hawk, Klamath largescale sucker, short-nose sucker, western<br />

pond turtle, Lost River sucker, greater sandhill crane, wolverine, long-billed curlew, white-faced ibis,<br />

western spotted frog, bull trout, American white pelican, Townsend's big-eared bat and mountain lion.<br />

To establish then, this Winema National Forest as a permanent dedicated National Natural Wilderness<br />

Wildlife - Biological Preserve; with no surface - subsurface activities - developments.<br />

<strong>Response</strong><br />

To change the mission of the Forest to a "National Wildlife Biological Preserve and National Critical<br />

habitat area,m would require an act of Congress. This is considered by us to be outside our authority<br />

and inconsistent with the National Forest Management Act or the regulations regarding the National<br />

Forest Planning process.<br />

Comment<br />

Your current proposed plan only addresses mule deer for big game indicator species. It is my<br />

understanding that elk, bear and antelope are included under this indicator species.<br />

Each of these species require different habitat type for survival. So, how can we say that what is good<br />

for the deer is good for the bear, or the elk, or the antelope?<br />

<strong>Response</strong><br />

The Management Indicator Species Theory is explained in the DEIS on page 111-56, with species and<br />

habitat descriptions on following pages. The main commonality of mule deer, elk, antelope, bear and<br />

other species represented in this group is that early successional vegetation changes following Forest<br />

land disturbance, Timber Management or fire, generally provide their most desirable food sources.<br />

Mule deer use virtually all plant communities on the Forest. If habitat effectiveness is maintained to<br />

meet mule deer needs, viable populations of the other species will be maintained.<br />

Comment<br />

I am very concerned for wildlife. The sterile plantations won't feed a bear or deer, right?<br />

<strong>Response</strong><br />

Areas of land either harvested or burned can appear to be non-productive for wildlife. However, early<br />

plant successional vegetation changes following such activities can provide desirable forage conditions<br />

for wildlife, for approximately twenty years.<br />

Bear use all vegetative stages to varying degrees. Denser old forests provide habitat for hiding and<br />

denning. Food habitat surveys show a larger portion of the bears diet is plant life associated with openings,<br />

either natural or manmade.<br />

Comment<br />

Elk habitat requirements are not covered in the plan and are more stringent than deer.<br />

<strong>Response</strong><br />

The Management Indicator Species Theory is explained in the DEIS on page 111-56, with species and<br />

habitat descriptions on following pages. The main commonality of mule deer, elk, antelope, bear and<br />

other species represented in this group is that early successional vegetation changes following Forest<br />

land disturbance, Timber Management or fire, generally provide their most desirable food sources.<br />

Mule deer use virtually all plant communities on the Forest. If habitat effectiveness is maintained to<br />

meet mule deer needs, viable populations of the other species will be maintained. Elk habitat management<br />

was not initially identified as a Forest Planning issue. Standards and guidelines for elk calving areas<br />

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are included. Additional study is needed to assess Elk habitat management needs in the general forest.<br />

This study will be completed prior to the next Planning cycle.<br />

Comment<br />

I am also very concerned over the rapid reductions in big game hiding and thermal cover. Mule deer<br />

populations are well below management objectives in the Klamath Falls and Sprague units and<br />

populations are declining further, buck ratios are declining, and fawn survival is declining. I believe<br />

that one of the causes for this is the decline in hiding (escape) cover, thermal cover, and the reduction<br />

of fawning habitat (riparian areas). The high levels of roading on many parts of the forest only compound<br />

these problems.<br />

<strong>Response</strong><br />

Mule deer populations can fluctuate greatly from year to year or a period of years due to many factors.<br />

They have the reproductive capability to recover to high population levels in a short period of time.<br />

Certainly the habitat factors you are concerned about are key in this issue. General standards and<br />

guidelines which will be implemented on the Forest to maintain habitat effectiveness for mule deer are<br />

described in Chapter 4 of the Forest Plan.<br />

Comment<br />

Another suggestion I wish to offer is: The feasibility of restocking the remote parts of the National Forests<br />

with nature's original game managers--the timber wolves and the cougars. They did it so well for thousands<br />

of years. Note: Have you ever read the study of the Isle Royale Wolves and Moose of Lake Superior?<br />

<strong>Response</strong><br />

Under a long standing agreement the Oregon Department of Fish and Wildlife (ODFW) is responsible<br />

for regulation and control of animals and the Forest Service is responsible for managing habitat. The<br />

ODFW in their Non-game Wildlife Management Plan published in 1986 provide the following statements<br />

regarding wolves in Oregon. "While the wolf was a major component of Oregon's fauna, there are no<br />

plans to re-introduce it. It is not felt Oregon has sufficient wolf habitat of adequate size that is free from<br />

potential livestock damage problems to make wolf re-introductions feasible. This is based on the large<br />

expanse of territory required by each wolf pack and the fact several packs would be needed to provide<br />

a viable population.' Cougar are managed as game animals in Oregon by the ODFW. The 1987 Cougar<br />

Management Plan prepared by ODFW indicates medium population levels of cougar occupy the general<br />

area of the State encompassing the Winema National Forest. This indicates the habitat is occupied<br />

and introduction not necessary.<br />

Yes, we are familiar with the studies mentioned.<br />

Comment<br />

Experts say that somewhere between one third and one half of deer and elk range land should remain<br />

in cover.<br />

<strong>Response</strong><br />

The standards and guidelines listed in Chapter 4 of the Forest Plan are designed to maintain habitat<br />

effectiveness for deer were developed from a review of literature and contact with recognized experts<br />

on the subject.<br />

Comment<br />

In the interest of preserving the richness of our forests and providing habitat for such species as the<br />

white-headed woodpecker, at least 10% of each timber type in Winema should be preserved as true<br />

old growth stands.<br />

<strong>Response</strong><br />

The Forest Service is required to manage fish and wildlife habitat in such a way as to maintain viable<br />

populations of existing and desirable introduced species of wildlife. This will be achieved through allocation<br />

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of special habitat areas in some cases and in the implementation of Forestwide standards and guidelines<br />

for wildlife.<br />

Based on the planning direction for indicator species and management requirements for wildlife, the<br />

species used as indicators for these ecosystems will provide for the needs of white-headed woodpeckers<br />

and black-backed woodpeckers. The white headed woodpecker would be covered by management for<br />

pileated woodpeckers and goshawks. It's habitat will also be maintained through the standards and<br />

guidelines for cavity nesters (snags and wildlife trees) which is a management requirement discussed<br />

in Chapter 4 of the Forest Plan. We have set aside about 10% of the Forest for preservation of old-growth.<br />

Comment<br />

Include the white headed woodpecker and the black backed woodpecker for indicators of old growth<br />

ponderosa and lodgepole pine.<br />

<strong>Response</strong><br />

The Forest Service is required to manage fish and wildlife habitat in such a way as to maintain viable<br />

populations of existing and desirable introduced species of wildlife. This will be achieved through allocation<br />

of special habitat areas in some cases and in the implementation of Forestwide standards and guidelines<br />

for wildlife.<br />

Based on the planning direction for indicator species and management requirements for wildlife, the<br />

habitat retained for species used as indicators for these ecosystems will provide for the needs of<br />

white-headed woodpeckers and black-backed woodpeckers. The white headed woodpecker would be<br />

covered by management for pileated woodpeckers and goshawks. It's habitat will also be maintained<br />

through the standards and guidelines for cavity nesters (snags and wildlife trees) which is a management<br />

requirement discussed in Chapter 4 of the Forest Plan.<br />

Comment<br />

The plan, if implemented, would not provide sufficient cover for the elk herd currently in the Winema.<br />

<strong>Response</strong><br />

The main commonality of mule deer, elk, antelope, bear and other species represented in this group is<br />

that early successional vegetation changes following Forest and disturbance, timber harvest or fire,<br />

generally provide their most desirable food sources. Mule deer use virtually all plant communities on<br />

the Forest. If habitat effectiveness is maintained to meet mule deer needs, viable populations of the<br />

other species will be maintained.<br />

Comment<br />

I see nothing for managing antelope.<br />

<strong>Response</strong><br />

The main commonality of mule deer, elk, antelope, bear and other species represented in this group is<br />

that early successional vegetation changes following Forest and disturbance, timber harvest or fire,<br />

generally provide their most desirable food sources. Mule deer use virtually all plant communities on<br />

the Forest. If habitat effectiveness is maintained to meet mule deer needs, viable populations of the<br />

other species will be maintained.<br />

Comment<br />

With respect to stands of aspen, I believe we should protect the stands and manages them. Since<br />

aspen is so valuable for food and cover, the plan should include management of all aspen stands.<br />

Aspen stands, (in addition to being a source of autumn splendor), are highly valuable as wildlife habitat.<br />

The Forest has not addressed aspen in particular and hardwoods in general. ODFW recommends<br />

baseline data covering pure and mixed aspen stands and hardwood components be provided. Aspen<br />

regeneration is valued for big game browse and the stands also provide valuable habitat for nongame<br />

such as the Williamson's sapsucker. Livestock use of aspen sites often prevents stand regeneration.<br />

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ODFW recommends all pure aspen stands be managed to ensure that the intrinsic values of this unique<br />

habitat are restored and/or protected. All mixed aspen stands should be retained and managed so<br />

habitat and fauna diversity is maintained.<br />

<strong>Response</strong><br />

The Forest contains very few stands of pure aspen, unlike many of the Forests in Central Oregon. Our<br />

planning mapping system does not contain any stands of pure aspen so no allocation can be made at<br />

the Forest Planning level. Treating aspen to increase regeneration will be considered during project<br />

specific environmental analysis.<br />

We agree that aspen are highly valuable as wildlife habitat. On the Winema Forest, aspen occur primarily<br />

as inclusions with other tree species, usually in moist sites, rather than in pure stands. The stand size<br />

is usually not large enough to be mapped separately in normal timber stand or vegetative mapping<br />

processes. It should, however, be recognized in individual project level planning and implementation.<br />

Comment<br />

The plan should address protection criteria for snags and downed timber as habitat for non-game<br />

species of wildlife.<br />

<strong>Response</strong><br />

Regional planning guidelines for incorporating management requirements (MR) established that habitat<br />

requirements for the primary cavity excavators, as a group, be addressed. The Winema habitat situation<br />

is discussed Chapter 3 of the FEIS. General Forest Standards and guidelines for providing this type of<br />

habitat are found in Chapter 4 of the Forest Plan.<br />

Comment<br />

The Williamson River above the Klamath Marsh is in need of extensive rehabilitation due to bank erosion,<br />

a lack of thermal cover and instream cover. At present an effort is underway to accomplish some of<br />

this work. I believe this reach of the river could provide an excellent wild trout fishery. To this end, I<br />

would like to see a long range plan developed in conjunction with the Oregon Department of Fish and<br />

Wildlife to provide a solution to the high water temperatures in the summer, bank erosion and instream<br />

cover for trout.<br />

<strong>Response</strong><br />

The Winema National Forest is a part of a group made up of private land owners, public agencies,<br />

Klamath Tribe and the local fly casters club, working through the Klamath County Conservation District<br />

on a Coordinated Resource Management Plan for the Upper Williamson River. This is a long term plan<br />

to improve water quality and the fishing by stablizing bank erosion, improving bank and instream water<br />

temperatures. Agencies and groups working within this group are the Soil Conservation Service, Extension<br />

Service, Winema National Forest, Oregon Department of Fish and Wildlife, the Klamath Tribe, and the<br />

Klamath County Flycasters. Numerous private landowners are also cooperating in this effort. Various<br />

sources of funds for the work are being sought. Work is progressing within the plan area.<br />

Comment<br />

Would like to see larger areas with log and snag residues. Such areas are alive with fauna and flora,<br />

including bushes and plants. (I lived on a farm which had several acres of land without large trees but<br />

which had all the smaller stuff.) Riparian areas, too should be generously endowed with wide stream<br />

side protected borders.<br />

<strong>Response</strong><br />

More emphasis is being placed on leaving log and snag residues. Much less is being piled and burned.<br />

There are Standards and Guidelines requiring a certain amount of logs to be left for flora and fauna.<br />

Standards and Guidelines also require protection of streamside borders. Some woody debris will be<br />

left for instream fauna. We have added protection for riparian areas (see Management Area 8, Chapter<br />

4 of the Forest Plan).<br />

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Comment<br />

This letter is to comment on your Preferred Alternative Plan, which, in my opinion, leaves very little<br />

alternatives for the wildlife we are obligated by law and by morality, to protect. Overgrazing of livestock<br />

on our public lands should cease.<br />

<strong>Response</strong><br />

The Preferred Alternative meets management requirements necessary to maintain viable populations<br />

for all wildlife species.<br />

Comment<br />

Adequate protection of deer and elk habitat should be included. This would mean that at least 40% of<br />

big game range should remain in cover and that 10% or more of each timber type would be preserved<br />

as true old growth stands for wildlife habitat.<br />

<strong>Response</strong><br />

General standards and guidelines which will be implemented on the Forest to maintain or improve<br />

habitat suitability for mule deer are described in Chapter 4 of the Forest Plan. Cover is only one of the<br />

factors considered. Alternative J, FEIS Preferred Alternative, proposes to retain approximately 10% of<br />

each major timber type in old growth to provide for wildlife habitat, ecological diversity, and aesthetics.<br />

Comment<br />

Why is there no consideration for bringing fisheries habitat up to full biological potential?<br />

<strong>Response</strong><br />

The overall goal is to bring fisheries up to as near to full biological potential as possible. More surveys<br />

may be necessary to adequately establish what that potential may be. Biologists feel that 80% of potential<br />

is what can be achieved before unknown or uncontrollable factors in the natural system come into<br />

play. Also, beyond a certain point in achieving potential the cost of investment would far outweigh the<br />

gains made by habitat enhancement.<br />

Comment<br />

I also feel that not enough old growth timber is being preserved for the long-term; the Forest Service<br />

should protect at least several thousand additional acres of those magnificent old stands of ponderosa<br />

pine for which the upper Klamath Basin was once famous.<br />

<strong>Response</strong><br />

FEIS Table 2-14, gives the acres of old growth available by decade by alternative. About 59,000 acres<br />

will be managed specifically as old growth. A wide range of acres were allocated and analyzed in the<br />

Alternatives.<br />

Comment<br />

I think that existing Wilderness areas should be inventoried and included in set asides for single purposes,<br />

such as elk winter range, spotted owl habitat, botanical areas, old growth stands, etc., and thereby<br />

increase the percent of the forest that is available for Multiple Use Management.<br />

<strong>Response</strong><br />

We recognize and account for the various habitats that occur within the wilderness. They are<br />

representatives of high elevation ecosystems. Spotted owl and elk winter ranges in general occur in<br />

lower elevation ecosystems. A key to maintaining viable wildlife populations is providing habitat dispersal<br />

which provides for genetic exchange within species groups.<br />

Comment<br />

Elk habitat requirements are not covered in the preferred plan. These animals require taller cover and<br />

fewer roads. Both deer and elk forage needs regeneration. The plan does not include management for<br />

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elk habitat. You should include sufficient habitat in your management prescriptions to assure a healthy<br />

elk population.<br />

<strong>Response</strong><br />

We do not have adequate knowledge of elk numbers or their habitat relationships on the Forest at this<br />

time to develop specific direction for them. The ODFW does not have firm objectives yet for elk<br />

management in the area. Some intensive surveys and coordinated planning must be done in the future<br />

to analyze the situation. This will be completed prior to the next planning period. The standards and<br />

guidelines proposed for mule deer will provide some habitat for elk.<br />

Comment<br />

The white-headed woodpecker and black-backed woodpecker should be designated indicator species<br />

for Ponderosa pine and Lodgepole pine forests, respectively.<br />

<strong>Response</strong><br />

Based on the planning direction for indicator species and management requirements for wildlife, the<br />

species used as indicators for these ecosystems will provide for the needs of white-headed woodpeckers<br />

and black-backed woodpeckers.<br />

Comment<br />

Aspen groves are delicate areas which are in need of protection by the management plan from both<br />

logging and grazing. These special areas of critical habitat for many species.<br />

<strong>Response</strong><br />

We agree that aspen are highly valuable as wildlife habitat. On the Winema Forest, aspen occur primarily<br />

as inclusions with other tree species, usually in moist sites, rather that in pure stands. The stand size<br />

is usually not large enough to be mapped separately in normal timber stand or vegetative mapping<br />

processes. It should, however, be recognized in individual project level planning and implementation.<br />

Comment<br />

Undisturbed forest land is vital to population of deer and elk, as well as cavity-nesters inhabiting dead<br />

and down logs.<br />

<strong>Response</strong><br />

The Forest Service is required to manage fish and wildlife habitat in such a way as to maintain viable<br />

populations of existing and desirable introduced species of wildlife. This will be achieved through allocation<br />

of special habitat areas in some cases and in the implementation of Forestwide standards and guidelines<br />

for wildlife, see Chapter 4 of the Forest Plan.<br />

Comment<br />

We strongly support your proposal that over 140,000 acres of former Reservation lands, principally<br />

Ponderosa pine forest lands, receive uneven-aged timber management. We agree with your assessment<br />

that this silvicultural practice is more compatible with wildlife values.<br />

<strong>Response</strong><br />

We did not make an assessment indicating uneven-aged timber management is compatible with wildlife<br />

values. It may be true for some species and the opposite for others.<br />

Comment<br />

Wildlife Habitat. Provide necessary forage and winter and summer range for large game animals and<br />

sufficient habitat for a diverse blend of other equally important non-game wildlife as well as provide for<br />

plant diversity. Tree farms do not meet this goal.<br />

<strong>Response</strong><br />

The Forest Service is required to manage fish and wildlife habitat in such a way as to maintain viable<br />

populations of existing and desirable introduced species of wildlife. This will be achieved through allocation<br />

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of special habitat areas in some cases and in the implementation of Forestwide standards and guidelines<br />

for wildlife, see Chapter 4 of the Forest Plan.<br />

Comment<br />

Roadlessness? Wildlife in general gravitate to roadless areas -- protecting wildlife, increasing wild game<br />

herds, increasing habitat for shy raptors -- all goes hand in hand with roadless areas. Let's make more<br />

roadless areas.<br />

<strong>Response</strong><br />

Roadlessness in itself does not equate to large numbers or increases in wildlife. The key to producing<br />

optimum numbers of any wildlife species is through provision of adequate basic habitat needs; food,<br />

water and cover to support the projected populations. Man induced harassment of wildlife due to roading<br />

can be controlled through gating, obliteration or general area closures. The standards and guidelines<br />

listed in Chapter 4 of the Plan are designed to provide habitat for viable populations of wildlife.<br />

Comment<br />

The northern spotted owl, northern goshawk, and the three-towed woodpecker show a downward<br />

trend of numbers in all alternatives. What is the answer?<br />

<strong>Response</strong><br />

Chapter 4 of the FEIS discussed the relationship of the alternatives on these species. Mitigation measures<br />

discussed in Chapter 4 of the FEIS provide the methodology for maintaining viable populations of all<br />

wildlife species.<br />

Comment<br />

It is important that the riparian zones along all the streams and tributaries, not just the wild and scenic<br />

river drainage, be afforded protection. Mature and large dead trees, standing and down, need to be<br />

present in these zones so that there will be a future supply of large woody debris for these streams.<br />

Recent studies in the Northwest indicate that this large woody debris is very important for the well<br />

being and productivity of the streams. Many other plants, insects, birds and animals including big<br />

game need a forested riparian zone for their home at least part of their lives. The zone needs to be<br />

150 to 200 feet on each side of the Class I & II streams and lakes and meadows, that wide totally along<br />

Class Ill streams and at least 50 feet of either side of the Class IV headwater streams.<br />

<strong>Response</strong><br />

The standards and guidelines for Management Area 8 (Chapter 4 of the Forest Plan) addresses these<br />

concerns.<br />

Comment<br />

Marsh, which is mostly water, need to protect and consideration of transferring it to the adjacent Refuge<br />

considered.<br />

<strong>Response</strong><br />

An attempt was made in the late 1970's to transfer the Marsh to the Fish and Wildlife Service. At that<br />

time there was not enough interest at the upper levels to make the transfer. It would take Congressional<br />

action to make the transfer.<br />

Comment<br />

The so called Preferred Alternative of the Winema Forest plan is completely unacceptable. It allows<br />

for too little roadless areas and does not adequately provide for the protection of wildlife.<br />

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<strong>Response</strong><br />

The Forest Plan provides a modified approach to these concerns.<br />

Comment<br />

Deer seem to be increasing, but they are staying closer to farmland and are even in town. Do we need<br />

more range for food supply?<br />

<strong>Response</strong><br />

Many species of wildlife, deer included, are very opportunistic in filling artificially created habitat niches<br />

around farms or towns. Usually these areas have historic deer use patterns and the upeople use' has<br />

encroached over the area often resulting in a change of animals normal movement patterns.<br />

Comment<br />

A better plan is needed to support wildlife habitat so that certain bird species do not become endangered.<br />

<strong>Response</strong><br />

The mission of wildlife and fish programs as discussed in Chapter 4 of the Plan, requires that viable<br />

populations of all wildlife species will be maintained. These population levels are designed to recover<br />

species currently listed as threatened or endangered and keep other species from being listed.<br />

Comment<br />

The species that was omitted from the DEIS that the Oregon Natural Heritage Data Base tracks on the<br />

Winema National Forest is the Great Gray Owl. The Data Base lists 17 occurrences of Great Gray Owls<br />

on the Winema. The species is included in lists of species of concern in the Forest Plan (p. IV-42),<br />

implying that the species is indeed in need of monitoring. The Great Gray Owl is an important species<br />

in the East Cascades managed forest systems as it is almost wholly dependent upon lodgepole pine<br />

forests. Given the emphasis of the Forest Plan with regards to greatly accelerated harvests of beetle<br />

killed lodgepole pine, upwards of 50% of the stands to be harvested in the next decade, the Great<br />

Gray Owl is deserving of concern. For these reasons the Nature Conservancy is recommending that<br />

the Forest include the owl as a sensitive species on the Forest and that the owl population be closely<br />

monitored. The owl has all the characteristics of a Management Indicator Species for lodgepole pine<br />

forests and should receive the consideration that is afforded other indicator species, especially with<br />

the planned harvests projected for lodgepole pine.<br />

<strong>Response</strong><br />

The Great Gray Owl is not on the Region 6 Sensitive species list, which is the parent document for the<br />

plan list. We have the Natural Heritage Data Base, most of which we coordinated in gathering.<br />

Comment<br />

Non-forested communities are not specifically addressed in Chapter IV of the DEIS with regards to the<br />

effects of the alternatives on vegetation diversity but certain areas such as cliffs, talus slopes, and<br />

caves are mentioned in the mitigation section (p. IV-3) as being protected. Of particular concern, however,<br />

are the extensive wet and dry meadows that occur on Forest. In the Forest Plan under the Standards<br />

and Guidelines section, natural openings are mentioned with reference to adjacent timber sales (created<br />

openings.) Instead of allowing created openings to occur directly adjacent to the meadows, as the<br />

Standards call for (Plan, IV-46), we recommend instead that a sufficient buffer (100-200') be provided<br />

around these sites so as to avoid changes in the microclimate of these areas (i.e., shading) and to<br />

lessen the invasion of weedy species into the meadows. When natural meadows are included in sale<br />

areas the surrounding management of the landscape can result in loss of part or all of the meadow<br />

habitat. This occurs as a result of timber removal from the site, soil compaction, draining of small wet<br />

meadows and ponds, and tree planting in meadow fringes. To avoid these disturbances natural openings<br />

or meadows should be included under the category of unique wildlife habitats and afforded the same<br />

protection they are given in the Forest Plan (p. IV-41).<br />

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<strong>Response</strong><br />

Additional standards and guidelines have been developed which provide for the protection of wet and<br />

moist meadows. These areas are now included in Management Area 8.<br />

Comment<br />

Old growth stands need to be at least 300 acres to avoid edge effects that diminish the actual effective<br />

habitat of the site. The small wildlife habitat sites are most evident in the eastern portion of the Forest.<br />

<strong>Response</strong><br />

The size of old growth stands needed for various species are discussed in Appendix J of the DEIS<br />

which is now a part of the planning records. Some species (e.g., bald eagle and Goshawk) require<br />

smaller areas and some (e.g., pileated woodpecker) require larger areas.<br />

Comment<br />

Population levels for one of the indicator species, the goshawk, appears to fall below MMR population<br />

requirements due to the extensive departure cutting of lodgepole pine called for in the preferred alternative.<br />

In decades 3 and 4 the projected population level of goshawks falls below 87 pairs (DEIS. IV-46). This<br />

is unacceptable and the rationalization for the low levels that there is habitat for the species adjacent<br />

to the National Forest is not founded and cannot be relied upon. In truth the private timber lands have<br />

been extensively cut and are not managed for wildlife species. Also it is realized that the National Forests<br />

will need to take the lead role in maintaining habitat for the State's wildlife. Therefore, the preferred<br />

alternative must be adjusted to meet the legal MMR requirements for this species, which probably<br />

means slowing the planned harvest of lodgepole pine on the Forest.<br />

<strong>Response</strong><br />

Appendix J of the DEIS is a Sensitivity Analysis of Management Requirements dealing with your concern.<br />

Comment<br />

Standards prescribing the amount of snags and downed woody materials are inadequate in the proposed<br />

plan. You should maintain at least 60% of potential dependent species in timber management areas<br />

and 100% in other areas.<br />

<strong>Response</strong><br />

Page IV-40 of the draft plan referred to the forest policy, which does contain the levels you state. The<br />

Forest Plan includes a revised approach that, more ralistically, achieves the 40% level with a combination<br />

of individual trees and snag patches.<br />

Comment<br />

Do we really need to disturb the home range of a pair of spotted owls in Aspen?<br />

<strong>Response</strong><br />

The Plan will provide spotted owl habitat based on The Record Of Decision by the Chief of the Forest<br />

Service on the Final Supplement to The Environmental Impact Statement on Spotted Owl guidelines.<br />

Comment<br />

All know, suitable eagle habitat should be managed as such. The area should not, as proposed, be<br />

reduced by 50%.<br />

<strong>Response</strong><br />

No comment necessary.<br />

Comment<br />

And, all 23 known spotted owl territories should be protected from logging, not just the 9 owl territories<br />

proposed (on only 12,000 acres).<br />

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<strong>Response</strong><br />

The Plan will provide spotted owl habitat based on The Record Of Decision by the Chief of the Forest<br />

Service on the Final Supplement to The Environmental Impact Statement on Spotted Owl guidelines.<br />

Comment<br />

Planting fish at the headwaters, I think, is a waste of time and money. The only people who benefit are<br />

a few owners of cabins down creek, who think they were planted for them alone and only come up<br />

creek on days that fish are planted and make 5 or 6 trips a day at high rates of speed so they can get<br />

all they can.<br />

<strong>Response</strong><br />

The Oregon Department of Fish and Wildlife is the responsible agency for stocking fish.<br />

Comment<br />

I would like to see the area made into a game preserve of some kind. We have beaver, martin, mink,<br />

wolverine, mountain lion, all the native animals in this small area.<br />

<strong>Response</strong><br />

The standards and guidelines in Chapter 4 of the Forest Plan are designed to maintain viable populations<br />

of all species.<br />

Comment<br />

I'd like to see you clearcut 1 or 2 acres every 5 square miles and plant it with alfalfa or sweet clover for<br />

the deer and other wildlife. And a little bitterbrush and mountain mahogany would be helpful too, I<br />

think. I'd like to see more raptor nesting and perch sites like the one on Lake Ewana<br />

<strong>Response</strong><br />

No comment necessary.<br />

Comment<br />

I bemoan the loss of Grey Owl habitat from logging the thickets under Fuego Mountain on the Sycan,<br />

and the Bald Eagle nest that is endangered from a lodgepole sale.<br />

<strong>Response</strong><br />

No comment necessary.<br />

Comment<br />

We get the false impression that our world is going to support us indefinitely. The Amazon Rain Forests,<br />

the elephant, the rhino, the condor, the Great Gray Owl--how long can we push and shove, in the<br />

name of economics--before it's too late? We are forcing our wildlife into those *visual corridors the<br />

Alternative E-Plus plan talks about. Isn't that a little like putting them in a zoo? I can point out several<br />

such corridors, those narrow strips of trees left to buffer the destruction behind them, caused by logging<br />

operations. There's a half-mile strip south and north of Williamson River Road at the 18-22 mile markers.<br />

Another is the northwestern ridge-top above the old Bray Mill on the Sprague River Highway and on<br />

the Whitehouse Road, north of Williamson River Road by the Lone Pine junction, the area is marked<br />

for complete clearcut--no visual corridors allotted. (How many other such places exist?) But these corridors<br />

themselves are already marked for clearcutting, with the marks away from the road where people might<br />

see them. I don't understand this!<br />

<strong>Response</strong><br />

Visual corridors, are managed for scenic purposes in a predominantly mature forest condition overtime,<br />

with a balance of age classes from young to old. Wildlife may use these areas for forage or cover, and<br />

the public may benefit by viewing wildlife from the roads. However, it is not intended that wildlife be<br />

limited to these areas. It is known that many species utilize the early successional stages of vegetative<br />

growth that returns when harvesting of trees occurs.<br />

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In marking timber sale units, tags and marks are generally placed on the side of trees that face away<br />

from the road in scenic areas to reduce evidence of management activity, which is an objective for<br />

managing for scenic quality. It is not intended that we 'hide' management activities from you, but maintain<br />

a natural appearing forest as long as possible for your viewing pleasure.<br />

Comment<br />

We have serious doubts about the data and knowledge concerning wildlife habitat needs. The method<br />

used to develop minimum management requirements is flawed from a National Environmental Policy<br />

Act process point of view.<br />

<strong>Response</strong><br />

The process is discussed in detail in Appendix J of the DEIS, which is now part of the planning records.<br />

Comment<br />

We agree that roosting habitat is important for species like the Bald Eagle. We also have seen numerous<br />

studies that show the Bald Eagle is very adaptable to changes in its habitat as long as it has an adequate<br />

food supply and protected roosting areas. We support growing some stands at wide spacing to develop<br />

quality roosting habitat. Unless studies prove this is not possible, we do not support the setting aside<br />

of suitable timberland for roosting habitat. We do support avoiding harvest in roosting ares until the<br />

necessary research is completed. But removal of the lands from all harvest should only be done when<br />

it is determined adequate roosting habitat cannot be provided by careful management of second growth<br />

forests.<br />

<strong>Response</strong><br />

You misinterpreted the direction regarding timber harvest. To maintain these areas may require a<br />

considerable amount of stand manipulation, including timber harvest. Such timber harvest will be done<br />

as directed to meet habitat goals, not as a part of the regular programmed timber harvest. See the<br />

standards and guidelines for Management Area 9. (Chapter 4 of the Forest Plan)<br />

Comment<br />

How do wildlife populations react to even-aged versus uneven-aged management. We suspect<br />

uneven-aged management will provide a significant improvement in available wildlife habitat.<br />

<strong>Response</strong><br />

Some species will react favorably to oneven-aged management, others will not.<br />

Comment<br />

Once areas are harvested, roads should be put to bed to minimize human harassment of wildlife of all<br />

forms. This impact alone may be far greater than the change in habitat caused by timber harvesting.<br />

<strong>Response</strong><br />

Your statement is valid. There are other reasons also for putting roads to bed. Chapter 4 of the Forest<br />

Plan contains statndards and guidelines dealing with this concern.<br />

Comment<br />

The bald eagle protection activities should be included as part of the old growth MMR requirements as<br />

no harvest is allowed within a 30-acre area around each nest site. Our experience has shown that<br />

carefully timed selective harvest is not detrimental and we suggest this option be explored with wildlife<br />

biologists.<br />

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<strong>Response</strong><br />

Management Area 9 address the requirements for the bald eagle.<br />

Comment<br />

The LRMP states that these old growth areas represent a 'minimum management requirement...for<br />

northern 3-toed woodpecker and pine martin habitat.' The proposed standards and guidelines for old<br />

growth areas further state that *developed recreation is not compatible with the goals of this management<br />

area." However, neither the LRMP nor DEIS explain how the proposed old growth areas on Pelican<br />

Butte are expected to co-exist with a winter sports area if they are incompatible.<br />

The City urges the Forest Service to not designate old growth areas inside the proposed winter sports<br />

area; and to address the issue of other surrounding old growth areas; compatibility with the winter<br />

sports area in the final LRMP and EIS. Guidance is needed as to how these different designations can<br />

be implemented in a complementary fashion, including possible mitigation measures.<br />

Additionally, the old growth management guidelines for each indicator bird species states that 'disturbing<br />

human activities: will be discouraged or minimized within 1/4 mile of active nest sites. Presumably, this<br />

would apply if an active nest is identified at the perimeter of an old growth management area, such<br />

that the 1/4 mile protection zone would extend a 1/4 mile outside the old growth management area.<br />

Depending on where old growth management areas are designated in the final LRMP, a winter sports<br />

area access road might have to be placed in an old growth management area. The LRMP does not<br />

state whether it is possible to build a road in such an area, and, if so, what design constraints might<br />

apply. As with the bald eagle habitat areas, road closure during specific periods is included within the<br />

management standards for old growth, and the standards also include the reference to 'transportation<br />

and utility corridors' that are to be 'avoided.'<br />

Both of these standards seem incompatible with the placement of an access road. Whether or not this<br />

is the intent of the Forest Service, the City recommends that these standards be clarified to provide<br />

guidance on the construction and use of a road through old growth management areas.<br />

<strong>Response</strong><br />

The proposed winter sports area is included within a semiprimative recreation area until further studies<br />

which specifically address the developed recreation proposals, are completed.<br />

Comment<br />

The LRMP also states that is a bald eagle pair 'chooses to establish a new nest in an area already<br />

receiving human use, the human activities occurring at that time should be evaluated for continuance."<br />

Discussions with Winema staff indicate that if an eagle pair choose to relocate next to what is called a<br />

'high hazard' area, such as an existing road, human activities will not be curtailed. The final LRMP and<br />

EIS should include discussion to this effect.<br />

<strong>Response</strong><br />

The statement as written, follows the Bald Eagle Management guidelines for Oregon and Washington<br />

and processes included in the Pacific States Bald Eagle Recovery Plan and has been through formal<br />

Section 7 consultation. Any changes in practice may require further consultation on a case by case<br />

basis.<br />

Comment<br />

The LRMP further states that bald eagle habitat management areas may include 'recovery' nest sites<br />

that contain suitable nesting habitat. Neither the LRMP nor DEIS indicate whether the bald eagle habitat<br />

area designated on the east side of Pelican Butte contain any recovery nest sites. Winema staff have<br />

informed the City that they do not, and the City therefore, asks that this be stated as such in the final<br />

LRMP and EIS.<br />

<strong>Response</strong><br />

It is felt that biologically the Bald Eagle nesting habitat on the East side of Pelican Butte is occupied to<br />

capacity. None of the recovery sites for additional nests were placed in this area. However, the overall<br />

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management strategy for that area will maintain adequate stand structure for recovery nesting, should<br />

a catastrophic event destroy one of the existing sites.<br />

Comment<br />

The City urges the Forest Service to reopen a brief public comment period for the Winema LRMP and<br />

DEIS when the final Regional habitat management standards become available, so that their impact on<br />

the LRMP can be definitely assessed, particularly in regard to winter sports area planning on Pelican<br />

Butte.<br />

<strong>Response</strong><br />

A site-specific EIS is being developed to address the issue.<br />

Comment<br />

The minimum management requirements (MMRS) set forth in the Winema draft forest plan do not<br />

comply with the requirements of the National Forest Management Act (NFMA), National Environmental<br />

Policy Act, or the Administrative Procedures Act (APA). NFMA requires public participation and<br />

interdisciplinary analysis. In addition, the MMRS were not subject to the rule-making procedures required<br />

by the APA. The consequence of the Forest Service's failure to comply with proper procedure is the<br />

artificial narrowing of the range of alternatives and resource outputs. SOTIA recommends that the Forest<br />

Service not use MMRS in the forest plan and EIS until public participation and rule-making for MMRS<br />

is completed as required by NFMA and NEPA.<br />

The Forest Service devoted an entire environmental impact statement to developing MMR requirements<br />

for the spotted. MMR levels for species other than the spotted owl have not been developed as the<br />

result of an integrated scientific process, with public involvement at each step of the development<br />

process.<br />

<strong>Response</strong><br />

The National Forest Management Act (NFMA) set legal guidelines for management of the National<br />

Forests. The guidelines were interpreted by the Secretary of Agriculture, in cooperation with a Committee<br />

of Scientists and with public and professional involvement, to develop regulations. Direction from the<br />

Chief of the Forest Service and Region 6 resulted in MR's which reflect the requirements of the laws<br />

and regulations in NFMA. The MR direction ensures that minimum legal requirements are applied to all<br />

alternatives in Forest plans consistently across all National Forests. MR's exist for dispersal of created<br />

openings, water quality, riparian and wildlife habitat as required by NFMA.<br />

The MR's were shown to have an insignificant effect on this Forest as discussed in Appendix J of the<br />

FEIS.<br />

Comment<br />

The DEIS violates these regulations by not considering a reasonable range of alternatives for indicator<br />

species. The alternatives considered in the DEIS would maintain indicator species significantly above<br />

the MMR levels necessary to ensure continued viability of the species. This is inconsistent with multiple<br />

use management of the Forest. For example, the MMR level for spotted owls on the Winema National<br />

Forest is nine pairs. All of the alternatives provide at least twice the MMR level of spotted owls (DEIS p.<br />

IV-45). Thus, it can hardly be said that the spotted owl population on the Forest is distributed between<br />

the maximum resource potential and the minimum resource potential within the alternatives considered<br />

for implementation on the Winema National Forest.<br />

<strong>Response</strong><br />

Alternatives vary between providing for MR levels only to levels well above MRs for all species. Regarding<br />

spotted owl: the nine pair of owl for which the Forest will manage is part of a network developed throughout<br />

Oregon, Washington and northern California Distributional networks were developed for the Forest for<br />

woodpeckers and goshawk. These were overlapped as much as possible on the owl network to avoid<br />

overallocation.<br />

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Comment<br />

No nesting or population surveys exist for pileated woodpeckers on the Winema National Forest. Thus,<br />

it is improper for the Winema to use the pileated woodpecker as an indicator species. An indicator<br />

species is a species whose health is an indicator of the health of other species who use the same<br />

habitat. Since the Winema has no idea how many pileated woodpeckers exist on the Forest, the<br />

populations of this species cannot be used to indicate anything.<br />

<strong>Response</strong><br />

The responsibility of the Forest is to provide habitat in quantity and distribution that will support viable<br />

populations. The pileated woodpecker is a reasonable indicator of the requirements of primary cavity<br />

nesters requiring large trees and characteristics of old growth for nesting, and small dead trees for<br />

feeding. The provision of adequate habitat does not necessarily mean that that habitat will be occupied,<br />

however, the potential for the species exists.<br />

Comment<br />

The Winema did not examine the alternative of using management techniques to provide healthy<br />

populations of these animals without the need for such extremely costly measures. For example, the<br />

use of nest boxes and artificial nesting substrates should have been examined as a means to increase<br />

the population of these animals in areas designated as general forest.<br />

<strong>Response</strong><br />

The Forest is obligated to provide habitat for viable populations of vertebrate species. This is interpreted<br />

to mean natural habitat or Forest habitat, not artificial structures. Artificial structures may be used to<br />

enhance populations, we agree. However, reliance on artificial structures sets the stage for drastic<br />

population declines if not maintained at the artificially high levels with a great deal of investment. Also,<br />

many of the species represented by indicator species have not had demonstrated reproductive success<br />

using artificial structures.<br />

Comment<br />

The failure to examine alternatives which employ intensive wildlife management techniques to increase<br />

the populations of wildlife in areas otherwise suitable for timber harvest violates 36 CFR 219.19(a)<br />

which requires that each alternative establish objectives for the maintenance and improvement of habitat<br />

for indicator species to the degree consistent with overall multiple use objectives of the alternative."<br />

<strong>Response</strong><br />

The Forest is obligated to provide habitat for viable populations of vertebrate species. This is interpreted<br />

to mean natural habitat or Forest habitat, not artificial structures. Artificial structures may be used to<br />

enhance populations, we agree. However, reliance on artificial structures sets the stage for drastic<br />

population declines if not maintained at the artificially high levels with a great deal of investment. Also,<br />

many of the species represented by indicator species have not had demonstrated reproductive success<br />

using artificial structures.<br />

Comment<br />

In its current form, the monitoring program for indicator species would only detect changes that would<br />

result in action being taken to reduce the flow of timber from the Forest. This is because the threshold<br />

of concern for the indicator species relates only to a decline in populations and not increases. If plan<br />

revision only occurs when a decline in these values takes place, then the only decision that can be<br />

made will be to increase protection of indicator species at the expense of timber production.<br />

<strong>Response</strong><br />

Monitoring of indicator species as revised in the Forest Plan includes monitoring the implementation of<br />

standards and guidelines, and the effectiveness of those guidelines. This may include monitoring use<br />

of habitat areas by the species in question. The monitoring plan also calls for validation of many of the<br />

assumptions that have gone into the plan. Validation is, generally, research-oriented and will be most<br />

dependent upon adequate funding.<br />

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Comment<br />

In summary, we have found no documentable reason in the scientific literature to assume that a<br />

well-designed timber management program would adversely affect the Winema's big game populations,<br />

especially in view of the fact that the Forest's current deer population uses winter range off the Forest.<br />

We believe that an alternative that emphasizes forage production, direct habitat improvement projects<br />

and road management to reduce disturbance by humans would largely mitigate any adverse effects<br />

resulting from timber harvest activities and changes in cover availability. Greater reliance on uneven-aged<br />

management would further mitigate any adverse impacts associated with increased emphasis on timber<br />

production.<br />

<strong>Response</strong><br />

An interagency technical advisory committee consisting of biologists from several agencies including<br />

the Klamath Tribe reviewed literature and developed a habitat suitability model which addresses forage,<br />

cover, water, and livestock competition. The concepts of the model were used to derive an index of<br />

habitat suitability for each alternative.<br />

Comment<br />

The coalition supports any measures needed to ensure the survival of all of Oregon's wildlife species.<br />

Nevertheless, given: (1) the scientific uncertainty currently surrounding the questions of which wildlife<br />

species truly depend on old growth for their continued survival and how much old growth is needed to<br />

meet their minimum requirements; (2) the acreage of old growth permanently protected in the Forest's<br />

designated wilderness and other classified areas; and (3) the urgent need to maintain an adequate<br />

timber sale program on the Forest, we question the need to restrict timber management activities on<br />

extensive acreages of nonwilderness old-growth stands.<br />

Congress has already permanently set aside more than 87,000 acres of forested lands on the Winema<br />

in three designated Wilderness Areas that will never be logged (DEIS Table 111-5). Barring natural disasters,<br />

these lands will provide a vast reservoir of old-growth timber to meet wildlife objectives. The draft forest<br />

plan would permanently protect an additional 40,500 acres of old-growth stands outside of wilderness<br />

areas to meet the needs of old-growth dependent wildlife species (DEIS Table 11-2). This old-growth<br />

acreage would include approximately 10,000 acres more than needed to meet the MMR requirements<br />

for the spotted owl (DEIS Appendix B-1 71). The DEIS does not describe the impact on timber production<br />

potential; however, it is probably significant. The volume and PNV tradeoffs resulting from the MMR<br />

requirements and any additional old growth allocations should be clearly disclosed in the FEIS.<br />

<strong>Response</strong><br />

The volume and PNV trade-offs of the MR's were found to be insignificant as discussed in Appendix J<br />

of the FEIS. Trade-offs of additional old-growth allocations are discussed in the contexts of alternatives<br />

which vary widely in this regard.<br />

Comment<br />

We disagree with the Forest's MMR development process and seriously question the need to permanently<br />

set aside any productive forested lands at all to provide habitat for so-called mold-growth dependent'<br />

wildlife. Other eastside national forests have stated in their draft planning documents that 'there is no<br />

wildlife species that has been identified as requiring solely old-growth forest, although some species<br />

require conditions that are best represented in old-growth stands." (Wallowa Whitman DEIS 111-28,<br />

emphasis added).<br />

<strong>Response</strong><br />

The MR's were found to have an insignificant effect on this Forest (FEIS, Appendix J).<br />

Comment<br />

The procedure used to develop MMR's is crucial since the MMR's are imposed as minimum standards<br />

which must be met by all alternatives. If MMR's are unnecessarily restrictive, they could significantly<br />

limit the decision space available to line officers and involve significant and unnecessary opportunity<br />

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costs. Our analysis indicates that the Forest's MMR constraints decreased the first-decade ASQ by<br />

about 5 to 6 million board feet per year (Appendix A). The sensitivity analysis included in Appendix J<br />

of the DEIS is a step in the right direction, but still incomplete and not legally acceptable in our opinion<br />

(Appendix B).<br />

First, the development of MMR's must take place through an interdisciplinary process, including public<br />

participation. The Winema's MMR's were developed in secret, without public participation. The Winema<br />

also ignored the direction of the regulation which it cites as a basis for MMR's, which requires that<br />

management objectives shall be considered in determining what management practices may be<br />

performed in MMR areas (36 CFR 219.27(e)).<br />

<strong>Response</strong><br />

The development of MRs was an interdisciplinary process. Public participation was encouraged in<br />

review of the Forest Plan and EIS. Management objectives were considered in determining what practices<br />

can be performed in MR areas. The areas addressing MRs for wildlife species, specifically old growth<br />

areas, are allocated to MA 7: Old growth Ecosystems which has a specific objective as stated in Chapter<br />

4, Forest Plan.<br />

Comment<br />

Second, the Forest should have, but did not, examine alternative ways to achieve the MMR objectives<br />

in the most cost-efficient manner, not just the effects of alternative levels of protection. A hypothetical<br />

example could involve use of nesting boxes for pileated woodpeckers as an alternative to taking old-growth<br />

stands out of the suitable land base.<br />

<strong>Response</strong><br />

Since the effects of the MR's were found to be insignificant on this Forest (FEIS, Appendix J), it is not<br />

necessary to examine alternative approaches.<br />

Comment<br />

Need to address road closure on F.S. Road #3456. Road goes through bald eagle habitat management<br />

area and if Pelican Butte is developed as a ski area, this road would be closed during the ski season.<br />

<strong>Response</strong><br />

A site-specific EIS is being developed to address resource issues regarding the application by the City<br />

of Klamath Falls to build a ski resort on Pelican Butte.<br />

Comment<br />

In our Mixed Conifer Plan Association, we should consider uneven-aged management due to major<br />

frost problems. Plan does not address retention of thermal cover.<br />

<strong>Response</strong><br />

Standards and guidelines in Management Area 10 require retention of thermal cover for big game on<br />

winter range. We have proposed very little uneven-aged management in the mixed-conifer (Klamath<br />

District) working group due to continuing problems with root rot.<br />

Comment<br />

Trees and other plants that provide cover, should receive as much priority as forage plants when<br />

considering planting and seeding for habitat improvement. Mountain Mahogany is a very important<br />

specie that should be planted/seeded and protected when ever reasonable and possible. This specie<br />

is not reproducing naturally at a fast enough rate, is difficult to reproduce artificially and yet is vital to<br />

big game. We suggest the Forest Service research methods to bring this plant back to a more vital<br />

condition on the winter range.<br />

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<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

In regard to grazing on winter range we ask that livestock be rotated off critical winter range to insure<br />

that any fall green up of forage is reserved for wildlife. We are not compelled to offer a date for that<br />

removal as it may change each year but would normally occur in July.<br />

<strong>Response</strong><br />

Forest-wide standards and guidelines for range management provide forage for the plant first, then for<br />

wildlife, then for livestock. Allotment management plans and annual operating plans are the appropriate<br />

tool to determine seasonal removal of livestock for wildlife purposes.<br />

Comment<br />

A forage/cover ratio of 60/40 is generally considered optimum for mule deer if road dispersion is minimum<br />

and cover is 100% effective a ratio of 70/30 will satisfy deer needs. That ratio may not provide enough<br />

cover to offer the deer escapement ODF&W would prefer during hunting season. We suggest summer<br />

range cover be managed to provide 40% cover in areas capable of producing that ration. Areas that<br />

are incapable of producing 40% cover should be retained in as close as is reasonable to the maximum<br />

cover they will produce.<br />

<strong>Response</strong><br />

Forest-wide standards and guidelines that apply to summer range require 30 percent of area as cover<br />

unless special circumstances such as catastrophic insect damage occur, then 15 percent cover is<br />

acceptable only if removal below 30 percent will show long-term benefits for deer.<br />

Comment<br />

We understand ODF&W manages populations through hunting regulations and tag availability. They<br />

too are concerned about mule deer populations, they feel the Forests projected population is 30%<br />

under their planned population. We feel a much more positive approach to your planning would be: a)<br />

establish habitat improvement criteria; b) in conference with ODF&W establish what positive affect that<br />

will have on surplus animals left after hunting season; and c) plan for that increasing population in the<br />

final LRMP.<br />

<strong>Response</strong><br />

Currently mule deer populations are lower than ODFW management objectives in all but the Fort Rock<br />

and Silver Lake units. The standards and guidelines in the Forest Plan provide guidance to maintain or<br />

improve habitat.<br />

The Forest offers hunting season recommendations annually to ODFW in conference.<br />

Projections of deer populations based on habitat suitability indices indicate an increase over time for<br />

most alternatives. Refer to Chapter 4, FEIS for further information.<br />

Comment<br />

OHA has several concerns and some major disagreement with the LRMP in regard to elk. Some of this<br />

may be due to the fact the DEIS and LRMP are already outdated regarding the elk on the Forest.<br />

Please be aware that many comments we have made in regard to mule deer also apply to elk, we ask<br />

you to regard them in that light.<br />

As you are aware elk populations on the Forest are growing rapidly and will likely continue to expand.<br />

OHA supports the increasing population growth. If ODF&W plans to allow the elk number to increase,<br />

and we understand they do, the Forest Service must address elk habitat management practices with a<br />

higher priority. Even if they don't suggest a higher base population, more improved habitat will mean<br />

additional surplus animals available for harvest, which we also support.<br />

As yet the elk have not been in competition with mule deer, nor have they caused what we feel have<br />

been significant damage to private agricultural lands. Until these potential problems occur there is no<br />

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logical reason not to allow elk numbers to increase, they likely will anyway. When and if we get into<br />

these problems they can and should be addressed at that time.<br />

<strong>Response</strong><br />

The Forest is participating in funding a cooperative interagency elk study east of Highway 97. The<br />

Forest will provide for the protection of elk calving areas where they are identified. Management of<br />

calving areas includes seasonal road closures. An elk management plan will be developed upon<br />

completion of the study.<br />

Comment<br />

Therefore, we ask the Forest Service to proceed with the following:<br />

1. Obtain elk habitat management research date and use it in relation to the elk population on the<br />

entire forest, including the areas east of Highway 97.<br />

2. Give elk habitat where it exists or is needed on the Forest the same consideration as mule deer<br />

habitat, cover requirements are essentially the same with some efficiency differences such as height.<br />

3. Administer a road closure program in critical elk habitat areas, open roads are dramatically detrimental<br />

to habitat effectiveness to elk when in excess of 1.5 miles of open road per square mile.<br />

4. Consider grazing and riparian area management in regard to elk as well as other wildlife.<br />

5. Develop in cooperation with ODF&W a long term elk habitat management plan that addresses the<br />

expanding elk population, particularly on the east side of Highway 97.<br />

<strong>Response</strong><br />

The Forest is participating in funding a cooperative interagency elk study east of Highway 97. The<br />

Forest will provide for the protection of elk calving areas where they are identified. Management of<br />

calving areas includes seasonal road closures. An elk management plan will be developed upon<br />

completion of the study.<br />

Comment<br />

Antelope - there is a hunting demand for antelope on the Forest and it is true that habitat is somewhat<br />

limited. There has been little, if any habitat improvement directed toward antelope on the part of the<br />

Forest. Some mule deer habitat improvement projects may have been of benefit to antelope. OHA<br />

feels the Forest needs to commit a higher priority in habitat improvement to these animals. Study of<br />

research currently available should point out improvements that can be made. We would certainly<br />

support such effort and if it would also benefit mule deer that is so much the better.<br />

<strong>Response</strong><br />

Mule deer are identified as a key issue species for ODFW and the Klamath Tribe. The particular issue<br />

regarding the Tribe is subsistence hunting rights. Habitat improvements for mule deer, particularly<br />

road closures and water developments, will also benefit antelope.<br />

Comment<br />

Planned projects should involve ODF&W cooperation.<br />

<strong>Response</strong><br />

ODFW is involved with planned projects either directly or through the environmental analysis process.<br />

Comment<br />

In heavy and unharvested lodgepole pine mortality areas where significant amount of dead trees have<br />

fallen, opening trails with equipment may be necessary to allow wildlife the opportunity to use these<br />

areas and reduce the threat of wildfire spread. Wood cutters may be able to accomplish similar end<br />

results if areas for down tree removal is designated on the ground. This practice may be especially<br />

important in riparian areas.<br />

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<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

Mule Deer habitat improvement projects that also benefit antelope should be high on the list of mule<br />

deer project priorities. Projects that would enhance use of other potential winter range areas should<br />

also be considered.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

Recent scientific investigation indicates managed stands, especially under uneven-aged management,<br />

will provide many of the components used by old growth dependent species. We accept the proposed<br />

29,000 acres of old growth protection on a temporary basis but request objective scientific monitoring<br />

be carried out to assess the impacts of timber production on these species. In this way the amount of<br />

old growth acreage permanently protected could be adjusted up or down as determined necessary.<br />

There is sufficient old growth to delay this decision for twenty years.<br />

<strong>Response</strong><br />

There is much conflicting information and opinion regarding old growth. The Forest is taking the<br />

conservative stance of old growth retention until other methods of management are proven to assure<br />

viability of old growth dependent species. Much study is being conducted regarding old growth<br />

characteristics, ecological significance, and fragmentation at this time.<br />

Comment<br />

I cannot believe that a ski resort in a place inhabited by elk is compatible. Those desiring the development<br />

do not seem to care whether they displace, disturb or destroy the habitat of the elk.<br />

<strong>Response</strong><br />

The potential impacts of a ski resort on Pelican Butte will be evaluated in a separate NEPA process.<br />

Comment<br />

More emphasis needs to be put selecting and improving wildlife intermediate habitat zones. This would<br />

help take some of the pressure off the limited winter habitat we have left. Everything that can be done<br />

to protect our winter habitat, must be done.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

Finally, it is important that you provide the public an opportunity to comment on the development of<br />

MMR's. Too much of the MMR process was carried out in secret and did not meet the requirements of<br />

NEPA. Viable populations should be protected, but we the people should have some say in what a<br />

Viable populations is and how much is protected at what cost.<br />

<strong>Response</strong><br />

The effects of the MR's were insignificant on this Forest (see FEIS, Appendix J).<br />

Comment<br />

Why can't we come up with data for small game & fish harvest levels on Table 11-5?<br />

<strong>Response</strong><br />

Small game and fish harvest is not reported by the hunter and fisherman. Estimates of take are not<br />

made on the Forest level. Estimates made from estimates would not be reasonably reliable.<br />

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Comment<br />

From a wildlife perspective, development of the Pelican Butte Ski area is inappropriate, given the high<br />

wildlife values of the old growth bald eagle habitat. NO MENTION is made of the wildlife (or aesthetic)<br />

consequences associated with building the resort. Retention of Sky Lakes B (and other roadless areas)<br />

in an unroaded condition will be more and more critical to maintaining viable wildlife populations as<br />

other ares of the forest are subjected to intensive timber management.<br />

<strong>Response</strong><br />

A site-specific EIS is being developed which will determine the effect of the City of Klamath Falls proposed<br />

ski area on Pelican Butte.<br />

Comment<br />

The assumption that only winter range conditions affect deer numbers may be short-sighted: increased<br />

harvest and road densities will very likely result in decreased effectiveness of summer habitat, which<br />

could in turn lead to declines in population levels.<br />

<strong>Response</strong><br />

Estimates of deer numbers in the FEIS are now based on a habitat suitability index which considers<br />

forage, cover, roads, water, and livestock competition. The estimates indicate improving condition over<br />

time for many alternatives with resulting increase in potential population.<br />

Comment<br />

Where is management unit 8? What % of existing riparian areas is 15,775 acres? How are we going to<br />

double fish populations while we increase harvest 25%?<br />

<strong>Response</strong><br />

The description of MA 8 is included in both the FEIS and the Forest Plan. The acres allocated to this<br />

management area have been increased in the FEIS Preferred Alternative. The 16,000 acres referred to<br />

are approximately 27 percent of the total.<br />

The 16,000 acres are the riparian areas associated with fish-bearing streams. The other acres are<br />

associated with wet forest, wet meadows, etc. that have very little influence on fish populations.<br />

Management of these areas is primarily for other wildlife needs, such as mule deer fawning. Improvement<br />

of streamside riparian areas along with instream habitat enhancement should increase fish population<br />

potential.<br />

Comment<br />

How can we maintain viable populations of wildlife with 95% of the tentatively suitable lands managed<br />

for timber? Will we be able to meet manual direction or NFMA law at this level of management?<br />

<strong>Response</strong><br />

Timber management can occur at many intensities. Provision for viable populations restricts management<br />

on the lands allocated for timber. The Forest-wide standards and guidelines regarding viable populations<br />

of species applies to all Forest lands.<br />

Comment<br />

Clarify mule deer management: does Nearly successional stage' mean plantations? If so, we should<br />

state that clearly. 'Improvement' of deer habitat by harvest activity is not a fact, but an opinion, and if it<br />

has some merit, it also has an upper limit. This is a misleading and arguable statement that ODFW will<br />

certainly contest. Cover needs are totally ignored. 'Wildlife' forage - this should read 'mule deer forage.,<br />

Further, the act of removing the forest canopy from a piece of land does not guarantee that the area<br />

will then automatically provide quality forage for deer.<br />

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<strong>Response</strong><br />

Early successional stage includes plantations. Successional stage is defined in the Glossary in the<br />

Forest Plan. Cover needs of deer are provided in the standards and guidelines. Forage is available for<br />

all wildlife, not just mule deer.<br />

Comment<br />

Is the old growth acreage calculated at the minimum? If so, why? Managing at the rock bottom minimum<br />

is biologically unsound and does not meet the mission of Caring for the Land. We should be managing<br />

enough acres to provide for viable populations, not minimum viable populations - managing for the<br />

minimum gives us no room to cope with unforeseen problems such as fire or blowdown.<br />

<strong>Response</strong><br />

Acres in old growth management vary by alternative. Alternative C manages at levels sufficient to maintain<br />

viable populations. Other alternatives provide old growth for viable populations plus ecosystem diversity<br />

plus aesthetic preservation.<br />

Comment<br />

The Plan does not clearly state that of the 24% of the Forest that would remain in old growth by Decade<br />

5, almost 1/2 is located in high elevation wilderness areas that receive little wildlife use, particularly by<br />

management indicator species. This is a misleading way of presenting the levels of old growth<br />

management.<br />

<strong>Response</strong><br />

Chapter 2 of the FEIS contains a table which indicates acres of old growth inside and outside of wilderness<br />

areas.<br />

Comment<br />

Why are we managing only 32% of our riparian areas? We should be working to maintain/enhance all<br />

of this critical resource. Again, how can we more than double trout production while ignoring > 60% of<br />

our riparian habitat?<br />

<strong>Response</strong><br />

The description of MA 8 is included in both the FEIS and the Forest Plan. The acres allocated to this<br />

management area have been increased in the FEIS Preferred Alternative. The 16,000 acres referred to<br />

are approximately 27 percent of the total.<br />

The 16,000 acres are the riparian areas associated with fish-bearing streams. The other acres are<br />

associated with wet forest, wet meadows, etc. that have very little influence on fish populations.<br />

Management of these areas is primarily for other wildlife needs, such as mule deer fawning. Improvement<br />

of streamside riparian areas along with instream habitat enhancement should increase fish population<br />

potential.<br />

Comment<br />

How can we 'maintain or enhance' snag habitat if we are to manage at 60% of biological potential?<br />

We are already deficient in snag habitat under existing conditions.<br />

<strong>Response</strong><br />

The objective level for snag habitat management is now 40% of potential. The Forest will manage no<br />

less that that objective. To achieve that objective may require enhancing areas that are deficient in<br />

snags by creating snags from live trees.<br />

Comment<br />

How will 'most' riparian areas be managed with emphasis on wildlife values? Need more detail. Does<br />

'most' include more than the 16,000 acres in Management Area 8?<br />

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<strong>Response</strong><br />

The description of MA 8 is included in both the FEIS and the Forest Plan. The acres allocated to this<br />

management area have been increased in the FEIS Preferred Alternative. The 16,000 acres referred to<br />

are approximately 27 percent of the total.<br />

The 16,000 acres are the riparian areas associated with fish-bearing streams. The other acres are<br />

associated with wet forest, wet meadows, etc. that have very little influence on fish populations.<br />

Management of these areas is primarily for other wildlife needs, such as mule deer fawning. Improvement<br />

of streamside riparian areas along with instream habitat enhancement should increase fish population<br />

potential.<br />

Comment<br />

What are current (1988) acres of existing old growth? Are we operating on out-dated figures? This<br />

could be critical in the case of old-growth associated wildlife species.<br />

Definition of old growth is inadequate and inconsistent with Regional definition.<br />

Given the extensive changes in available habitat that would result from this alternative and the inadequate<br />

acreages established for the MMRs, the numbers of pairs projected seems overly optimistic. Population<br />

levels projected for goshawks in the 3rd and 4th decade are UNACCEPTABLE in that they violate both<br />

Regional minimum guidelines and NFMA.<br />

<strong>Response</strong><br />

The current acres of old growth are discussed in Chapter III of the FEIS. An inventory of old growth<br />

will have been completed but not analyzed by October 1990. Acres of old growth by alternative are<br />

displayed in the FEIS, Chapter 2.<br />

Currently, the Forest is using the Regional definition of old growth. These definitions are found on<br />

pages 3-40 through 3-41 of the Regional Guide.<br />

These definitions are under review and may be changed or clarified so we elected to keep the standard<br />

definitions in the plan at this time until a final decision is made on the definitions.<br />

Comment<br />

(Notes, #21) Martens are frequently observed at lower elevations within the commercial forest zone on<br />

Chemult District. Please cite references for assumption of 1 individual/1000 ac.<br />

<strong>Response</strong><br />

The references and process pertaining to marten are in the process records file at the Forest Supervisor's<br />

office.<br />

Comment<br />

(Notes, #23) Nest tree dbh stated for pileated woodpecker is too small: also, trees this small will not<br />

stand very long.<br />

<strong>Response</strong><br />

The minimum nest tree size for pileated woodpecker is 20 inch d.b.h. Reference 'Wildlife habitats in<br />

managed forests, Thomas et al 1979.'<br />

Comment<br />

(Notes, #25) Misleading statement: mule deer may often be associated with early to mid-successional<br />

plant communities, but to say "dependent! is an overstatement and very arguable. Deer numbers are<br />

not linearly related to forage production. How does the model predict amount and quality of forage<br />

produced on different sites?<br />

<strong>Response</strong><br />

The Forest has revised mule deer population projections based on concepts in Interagency Technical<br />

Advisory Committee Mule Deer Model. The relationship between the habitat suitability index developed<br />

using the concepts and population is assumed to be linear for lack of any other defined relationship<br />

between HSI and population. Forage amount is projected based on level identifiers in the FORPLAN<br />

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model. These include ponderosa pine, pine associated, mixed conifer, meadows, rock, water, and<br />

others. These have average assigned forage values which vary over time and by treatment. Forage<br />

quality is not addressed.<br />

Comment<br />

(Notes, #26) Unclear as to what 'birds seem to partition themselves as to size of territory' means.<br />

<strong>Response</strong><br />

Birds tend to group by size of territory. This is because of the type of forage or the type of nesting<br />

substrate they require. Example: red-winged blackbirds and yellow-headed blackbirds tend to have<br />

similar territory sizes and could be found in similar areas.<br />

Comment<br />

(Notes, #27) Would like to see data to support 60 ac. as an adequate size for goshawk nesting, especially<br />

since minimum numbers of goshawks would not be maintained under this alternative.<br />

Poor sentence structure: *old growth allocations IS.'<br />

Method for calculating pairs is seriously inaccurate if it only addresses foraging habitat.<br />

<strong>Response</strong><br />

References supporting territory or home range sizes is within process documents at the Forest<br />

Supervisor's office.<br />

Comment<br />

(last paragraph) Plantations do not necessarily provide optimal, or even adequate foraging habitat,<br />

particularly as they begin to fill in. This paragraph ignores the need bty elk for both hiding and thermal<br />

cover.<br />

<strong>Response</strong><br />

As plantations mature they become cover. Until they become cover, they are assumed to provide some<br />

forage, usually more that the original forested stand. The use of the concepts of the Interagency Tech.<br />

Adv. Com. Mule Deer model recognizes that even mature forest stands provide forage.<br />

Comment<br />

If riparian habitats and water quality are already good, how do we propose to double trout populations?<br />

Factors limiting trout production in these streams may not yet have been determined.<br />

<strong>Response</strong><br />

Potential production was based on ODFW and Forest Biologist estimates. Riparian habitat and water<br />

quality are not the only factors that influence fish populations. Instream cover, above stream cover,<br />

and substrate are also factors that have influence. Improvements such as woody material placement,<br />

spawning gravel placement, increasing pools, planting vegetation for above stream cover will increase<br />

the potential population.<br />

Comment<br />

(Par. 3) What silvicultural systems will be used to maintain eagle habitat? Has control of competing<br />

vegetation been analyzed to determine any possible detrimental effects to eagles or their prey base?<br />

<strong>Response</strong><br />

All silvicultural systems are available to achieve the objectives of maintaining or improving eagle habitat.<br />

Thinning to leave pine and douglas fir is the primary method currently used. This is a removal of competing<br />

vegetation which allow the remaining trees to grow to a larger diameter.<br />

Comment<br />

Changes in habitat quality also need to be accurately measured. If habitats such as old growth are so<br />

important, why are we planning to reduce this resource by more than half on low elevation lands?<br />

K - 283

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<strong>Response</strong><br />

The Forest is attempting to achieve a balance of resources, providing for timber harvest while providing<br />

old growth habitat values.<br />

Comment<br />

Still no mention of potential loss of eagle or spotted owl habitat if Pelican Butte is developed.<br />

<strong>Response</strong><br />

A site-specific EIS is being developed by the City of Kiamath Falls that will address these issues.<br />

Comment<br />

Too many loopholes here, what is the purpose of this statement?<br />

Two hard snags/ac is minimal, 1 O is too small for a pileated woodpecker (minimum dbh for the smaller<br />

three-toed is 120).<br />

Be more specific about what constitutes disturbance.<br />

Assumptions on nest activity need to be re-thought: renesting may still occur for some species after<br />

June 1, and just because we are not able to detect activity from the ground, we should not assume<br />

the nest is inactive unless we closely monitor.<br />

Who is responsible for monitoring?<br />

<strong>Response</strong><br />

Pileated nest trees are minimally 20 inches d.b.h. Pileated will feed in trees 10 inches or greater.<br />

The responsibility for monitoring ultimately rests on the appropriate line officer of the Forest. These<br />

would be the Forest Supervisor and District Rangers. The person that would actually do the monitoring<br />

is the appropriate resource specialist (see Chapter 5 of the Forest Plan).<br />

Comment<br />

Does this mean the Winema will manage at only 20% of biological potential? Statement is unclear and<br />

inconsistent with the 60% level stated on 111-7.<br />

<strong>Response</strong><br />

The minimum management requirement to maintain viable populations is 20 percent. The Pacific<br />

Northwest Region has as policy to manage for no less than 40 percent. Alternative J, FEIS Preferred<br />

Alternative manages general forest at the 40% level.<br />

Comment<br />

To iffy-8shouldn leaves lots of loopholes.<br />

Only addresses cover/forage ratio, this is inadequate: need to address distribution and quality as well.<br />

Measuring ratios on Forest-wide basis could leave large areas totally devoid of cover.<br />

What does 'will be avoided' include? Again, too vague.<br />

Roads are not the only factor here: clearcuts remove cover needed for safe travel. Saying roads MAY<br />

be closed is inadequate, too vague.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

We are particularly concerned with the continued logging of old growth ponderosa pine forests. Few<br />

such areas of high quality remain, and retention of old growth ponderosa pine should be a high priority.<br />

This is especially crucial in that the WNF has failed to identify an old growth indicator species or MMR<br />

standards for ponderosa pine old growth forests. How will you assess and monitor the effects of the<br />

major reductions of such habitat proposed in the PA? While few species are entirely dependent on<br />

this habitat, many, such as the White-headed Woodpecker, are close associates and could serve as<br />

effective indicator species.<br />

K - 284

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<strong>Response</strong><br />

True, there is not a good indicator species for old growth ponderosa pine. The Forest has attempted<br />

to remedy this by providing additional old growth in ponderosa pine for ecosystem diversity and aesthetic<br />

reasons as well as for wildlife. This is incorporated into Alternative J: FEIS Preferred Alternative.<br />

Comment<br />

In several cases, an adequate range of appropriate indicator species has not been selected. One of<br />

these cases is that of indicators of riparian/wetland community types. Thee are a number of ecologically<br />

and structurally distinct classes of riparian/wetland vegetation, and each of these should have a valid<br />

indicator species. Riparian ecosystems are extremely diverse, extremely complex, and extremely important<br />

to the maintenance of a host of both plant and animal species. Avian and small mammal diversity<br />

reach their maximum values in riparian communities. While the designation of the Trout and Bald Eagles<br />

to represent general riparian and old growth/mature hardwood riparian are good choices in themselves,<br />

they do not represent the full range of riparian community types.<br />

<strong>Response</strong><br />

Riparian ecosystems are indeed diverse. Much analysis at the Forest and Regional level determined<br />

that there are no appropriate individual riparian indicator species that would be better than trout. Trout<br />

is used as the riparian indicator because the effect on trout can be quickly and readily determined.<br />

Also, riparian areas are defined in a general sense in the Forest Plan, so a general indicator is appropriate.<br />

Finer resolution of riparian communities will require more detailed inventory.<br />

Comment<br />

Inadequate Management Guidelines for Old Growth Indicators - Management guidelines for the Spotted<br />

Owl are particularly poor and will not be sufficient to maintain viable populations of this species on the<br />

WNF. Catastrophic reductions in habitat and nesting pairs predicted by the PA, when combined with<br />

the totally inadequate SOHA size guidelines and the untested and entirely experimental proposal to<br />

progressively cut the timber within the SOHAs themselves, combine, in our view, to spell out a program<br />

that is little more than a blueprint for the extirpation of the Spotted Owl from the Forest. The Spotted<br />

Owl S&Gs are quite simply not adequate to maintain these pairs over the long run. They are too small,<br />

there are not enough of them, and the old growth in them should be dedicated, not cut in some long-shot,<br />

conjectural shell game!<br />

<strong>Response</strong><br />

The Forest will manage spotted owl in accordance with the SEIS. The designated SOHAs are part of a<br />

network across Oregon, Washington and northern California. There has been recent analysis which<br />

indicates that this may be insufficient for owl viability, however that is outside the scope of the plan at<br />

this time. If changes are made in the network, or research indicates other management approaches<br />

are required, and these changes are approved by the Region in terms of appropriate for the network,<br />

the Forest will amend the Forest Plan and FEIS.<br />

Comment<br />

Yellow Rail - This extremely rare species in Oregon is known to occur as a nesting species on Upper<br />

Klamath Lake and may well occur on or near the Marsh roadless area. Despite the fact that this species<br />

is listed as Endangered by the Oregon Natural Heritage Data Base (1987), it is not even mentioned in<br />

the WNF's draft documents! We request that you add this species to the list of Endangered taxa on<br />

the Forest and immediately institute a management program and census to identify any populations<br />

found in the National Forest marshlands on Upper Klamath Lake. Full protection, including the prohibition<br />

of motorboats, should be instituted in and near any occupied or suitable habitat.<br />

<strong>Response</strong><br />

The yellow rail is now listed in the R6 Sensitive Species Ust for the Forest. Prohibition of motorboats<br />

falls in the jurisdiction of the State Marine Board except where specific federal legislation prohibits their<br />

use (such as Wilderness).<br />

K - 285

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Comment<br />

In summary, NFMA requires the FS to take all necessary measures to assure maintenance of viable<br />

populations of declining species, such as the Yellow Rail, Great Grey Owl, Bull Trout, and Purple Martin.<br />

The PA is clearly inadequate in this regard.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

We believe that a minimum of 10% of each timber type should be preserved as true old growth. Old<br />

growth provides habitat and cover for big game and for species dependent on old growth. Even flows<br />

of clear water are also found in streams flowing from old growth stands.<br />

<strong>Response</strong><br />

Old growth is allocated at varying levels by alternative. Alternative J, FEIS Preferred Alternative allocates<br />

old growth at nearly ten percent of each timber type.<br />

Comment<br />

The indicator species approach to assessing wildlife viability in relation to specific habitats is a theoretical<br />

model of questionable validity. According to an evaluation by Dr. Larry L. Irwin (NACASI Technical<br />

Bulletin No. 522, April 1987) the concept as applied by the Forest Service, including the Winema is<br />

probably in error.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

The indicator species concept represents a poor surrogate for inadequate knowledge of the basic<br />

ecological requirements of the species which may find optimal living conditions in climax forests. The<br />

three MMR indicator species of concern in this report (spotted owl, pine marten and pileated woodpecker)<br />

are presumed to need old growth (it has been shown the components within old growth are the key<br />

items). This implies that old growth is presumed to be limiting to all species which prefer old growth,<br />

and that alterations procedure declines in the associated species. Neither implication has strong research<br />

support. Rosenburg and Raphael (1986) found only 5 of 46 bird species to be negatively affected by<br />

forest fragmentation in northern California, including the spotted owl, pileated woodpecker, sharpshin,<br />

ruffed grouse, and winter wren. It is highly unlikely that trends in populations of the three indicator<br />

species as affected by management reflect similar trends in other species.'<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

PWP is a common, adaptable species whose abundance in numerous habitats that differ greatly from<br />

snag-riddled old growth forest belies the Forest Service habitat model and strongly indicate that the<br />

subject rather describes the ideal, preferred environment when the species inhabits eastern Oregon<br />

conifer forests.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

At the very least the DEIS should disclose acres by age class for the forest's major plan communities<br />

listed on page 111-18. Identification of additional management indicator species for riparian, wet meadow,<br />

dense second-growth conifer and high elevation stream habitats would also be an improvement.<br />

K - 286

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<strong>Response</strong><br />

Appendix J of the DEIS summarizes the indicator species selection process.<br />

Comment<br />

The minimum management requirements for the Northern Three-toed woodpecker (Picoides tridactyles)<br />

appear inappropriate for species viability. I also do not believe there is biological evidence that this<br />

species represents a habitat niche for elevation below 5,000 feet in south-central Oregon.<br />

<strong>Response</strong><br />

Acres retained for three-toed woodpecker habitat as part of the woodpecker group are distributed<br />

across both high and low elevations in a grid pattern that will provide for other species.<br />

Comment<br />

Personal observations and some research suggest that the Northern Three-toed nests only above<br />

5,000 feet in this area. There is also reason for concern regarding the habitat acreage per pair of 75<br />

acres. Research conducted by the U.S. Forest Service (Raphael and White, 1984) indicates a larger<br />

area, almost twice that provided, is required. Unpublished information from an area on the Deschutes<br />

National Forest found home ranges over 400 acres.<br />

<strong>Response</strong><br />

Acres retained for three-toed woodpecker habitat as part of the woodpecker group are distributed<br />

across both high and low elevations in a grid pattern that will provide for other species.<br />

The Forest is constrained to operate under the Regional Guides.<br />

Comment<br />

It seems that an appropriate species should represent the lodgepole plant communities below 5,000<br />

feet. The Blackbacked woodpecker (Picoides arcticus) might be appropriate, however, this needs to<br />

be further evaluated for true representation. This would require changes in size of habitat and spacing<br />

between MMR areas.<br />

<strong>Response</strong><br />

Acres retained for three-toed woodpecker habitat as part of the woodpecker group are distributed<br />

across both high and low elevations in a grid pattern that will provide for other species.<br />

Comment<br />

The forage table on page 11-144 of the DEIS states the number of pounds per acre of forage produced<br />

in each working group. Projections for the volume to be produced in Decade 5 are also provided. The<br />

Tribe believes the asserted volumes ar significantly over-estimated. Also, the type of forage produced<br />

is not identified. Does the term include only forbs and grasses, or are shrubs also included? If shrubs<br />

are included, which species and in what volume? The DEIS should define this and describe and quantify<br />

the activities proposed to increase forage production to the stated decade 5 levels, as well as justifying<br />

the stated present levels.<br />

<strong>Response</strong><br />

Shrubs are included as a browse component. Bitterbrush was used as the primary browse species.<br />

Comment<br />

The plan assumes current demand for fish and wildlife equals current annual harvest. Plan p. 11-8. This<br />

is a wildly inaccurate statement with respect to tribal demand, and probably with respect to general<br />

public demand. The plan should attempt to accurately reflect demand for fish and wildlife.<br />

K - 287

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<strong>Response</strong><br />

Recreation demand has been reevaluated. Refer to the discussion of Recreation in Chapter 3, FEIS.<br />

Comment<br />

The DEIS projects the same increase in fish populations on the forest over time under all of the proposed<br />

alternatives. Table 11-7. This assertion strains credulity, given the differences in projected sedimentation<br />

rates. DEIS Table 11-3A. The final plan must fully explain the fish population projections and amend<br />

them to reflect the actual differences among the alternatives. The final plan projections should break<br />

down the forest by watershed and provide full disclosures of effects specific to the former reservation<br />

lands. The Tribe retains fishing rights on these lands. The DEIS must disclose the effects of the plan<br />

on the Tribe, and the Forest Service must protect the rights from infringement.<br />

<strong>Response</strong><br />

All fish-bearing streams are protected by standards and guidelines. Increases in potential populations<br />

will be through continued long-term improvement of the streamside vegetation condition and through<br />

habitat improvement. The estimated numbers is based on habitat potential which increase is the same<br />

for all alterntives.<br />

Comment<br />

The plan does not provide an indicator species for snags in Ponderosa pine communities. The Tribe<br />

suggests the use of the white-headed woodpecker. Minimum habitat requirements would require 100<br />

acres area on a grid within the Ponderosa stands with no less than 45 snags in the area. In addition,<br />

at least 200 replacement trees would be necessary. Old growth habitat will not substitute, as the snag<br />

level is not high enough.<br />

<strong>Response</strong><br />

The Forest is constrained by the Regional Guide.<br />

The Preferred Alternative proposes retaining ponderosa pine old growth for ecosystem diversity and<br />

for aesthetic reasons. This old growth would provide for species that use ponderosa pine.<br />

Comment<br />

The Tribe suggests the use of the blue grouse (denigrates obscures) as an indicator species for the<br />

shrub component of the forest. Habitat areas of 50 acres at 5 mile spacing will provide minimum habitat.<br />

These areas must maintain structural diversity of shrubs, trees and herbaceous vegetation. The harvest<br />

projections should be amended to reflect this management requirement.<br />

<strong>Response</strong><br />

The Forest is constrained by the Regional Guide.<br />

Comment<br />

The Wildlife Forestwide Standards fail to provide a dispersion standard. This omission must be remedied.<br />

<strong>Response</strong><br />

Dispersion contraints are appropriate to even-aged management. Dispersal of units adequate for wildlife<br />

can be achieved through created opening constraints that apply forest wide. Uneven-aged management<br />

will not require dispersion constraints.<br />

Comment<br />

Numbers of catchable trout is used as an indicator of responsiveness of Plan alternatives. A better<br />

indicator for land management is quality of trout habitat (stream production capability).<br />

K - 288

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<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

Even though the acreage for the riparian management area varies among the alternatives, the DEIS/Plan<br />

does not provide a disaggregation by alternative. This should be included in Table 11-3A since page<br />

111-74 indicates that management of riparian areas directly affects the fish population.<br />

<strong>Response</strong><br />

Discussion of the riparian resource has been revised in all documents. The area was increased in<br />

Alternative J, FEIS Preferred Alternative, to include all riparian areas, not just areas associated with<br />

fish-bearing streams.<br />

Comment<br />

Table 1l-3A, Quantifiable Resource Outputs and Environmental Effects by Alternate, reports 12,000<br />

resident trout for all the alternatives and a 26% difference in tons/decade of sediment between alternative<br />

D and alternative I (page 11-95). Although not clearly described, page 111-60 seems to indicate a relationship<br />

between sediment and fish populations. This needs to be explained in the DEIS/Plan.<br />

<strong>Response</strong><br />

Sediment that gets to streams can affect fisheries. The levels of sediment projected as output are not<br />

considered enough to affect the fish resources. Over time other factors such as stream shade, instream<br />

cover and woody material would improve fish habitat and potentially provide for an increase in fish<br />

numbers.<br />

Comment<br />

Table 11-7 indicates a range of 1 to 47% of riparian areas in riparian management areas between<br />

alternatives. These differences need to be explained in terms of resident trout fishery and water quality.<br />

Is this a percentage of the 15,775 acre figure used on page IV-63 of the Plan?<br />

<strong>Response</strong><br />

Riparian habitat on the Winema National Forest includes wet meadows, wet lodgepole and other wet<br />

forested communties that have no effect on fish bearing streams. The 16,000 acres applies only to<br />

fish-bearing streams and is constant throughout the alternatives.<br />

Comment<br />

There are 167 miles of Class 1, 11, and Ill fish supporting streams on the WNF. What portions of these<br />

stream segments have been inventoried for fish habitat capability and riparian condition? What are th<br />

plans and schedule to fill in the data gaps?<br />

<strong>Response</strong><br />

Most fish-bearing streams were inventoried in 1979 using methods available at that time. Those methods<br />

did not identify habitat capability and riparian condition. The monitoring section of the Forest Plan<br />

indicates plans for inventory and monitoring of stream systems.<br />

Comment<br />

Stream aquatic habitat with a current resident fish habitat capability of 30% are listed as being in good<br />

condition. With an apparent potential of 80% habitat capability for these streams 'good condition' would<br />

seem to be an overly favorable description. This needs to be explained.<br />

<strong>Response</strong><br />

Good condition refers to low water temperature and stable streambanks. Production at 200 fish/mile is<br />

estimated as current which is good production. Instream habitat enhancement can increase production<br />

above these levels.<br />

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Comment<br />

The riparian area management standard and guideline (1.) is written more vaguely than the riparian<br />

MMR on page 11-14 of the DEIS. This standard and guideline should be rewritten.<br />

<strong>Response</strong><br />

Riparian standards and guidelines for MA 8 have been revised.<br />

Comment<br />

The standard and guideline for vegetation management (2.c.) is based on future development of woody<br />

debris criteria. How will this standard be applied before the data becomes available? What is the schedule<br />

for collecting this data?<br />

<strong>Response</strong><br />

The implementation and monitoring section of the Forest Plan indicates the schedule for data acquisition.<br />

Comment<br />

We encourage you to reclassify much of the riparian zones in your forest as areas of critical environmental<br />

concern and that they be managed separately from the general forest as distinct and unique.<br />

<strong>Response</strong><br />

Riparian areas are recognized as very important and are managed as a separate management area<br />

(MA 8).<br />

Comment<br />

Where historical abuses have occurred, we sanction compensating habitat restoration projects. However,<br />

we strongly favor protection above compensation.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

Both OSDF and ODFW believe insufficient information is provided in the DEIS to determine the current<br />

condition and proposed management direction for dead and down material. OSDF is particularly<br />

concerned about the effects of managing forest-wide snag potential at 20, 40, and 60 percent levels in<br />

terms of timber harvest levels, present net value and fire risk. By expanding your discussion of this<br />

issue, we may be able to identify a better alternative.<br />

<strong>Response</strong><br />

The Forest will manage snags at the 40 percent level consistent with Regional direction to accept this<br />

level as the minimum for management and consistent with neighboring Forests.<br />

Comment<br />

Both ODFW and OSDF had difficulty understanding your treatment of old growth. The total present<br />

acres of old growth are not stated in the DEIS and the definition of old growth is not the same as the<br />

one used in the Regional Guide. We do not understand the difference between 3 suitablew old growth<br />

and capable' old growth. We cannot make recommendations on old growth management until we<br />

have a better understanding of your terminology, its application and implications for management<br />

decisions.<br />

<strong>Response</strong><br />

The current acres of old growth are stated in Chapter 3 and in Chapter 4 of the FEIS. The definition is<br />

the same as used in the Regional Guide.<br />

K - 290

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Comment<br />

ODFW objects to management that creates an extensive area of even-aged stands across the Forest.<br />

Under even-aged timber management, structural and vegetation diversity would be greatly simplified<br />

and it may be difficult to maintain the desired amounts of dead and down woody habitats. A mix of<br />

even-aged and uneven-aged timber management across the Forest would provide diversity necessary<br />

for the variety of wildlife inhabiting the Forest.<br />

<strong>Response</strong><br />

The mix of even-aged and uneven-aged management varies by alternative. Alternative J, FEIS Preferred<br />

Alternative provides all ponderosa pine and half of the pine associated for uneven-aged management.<br />

Comment<br />

The Forest manages several habitat types for which no management indicator species have been<br />

selected. Therefore, there is no assurance that species dependent on those habitats will be maintained<br />

at viable population levels. For that reason, ODFW recommends the Forest adopt additional MIS as<br />

follows:<br />

1. The white-headed woodpecker as an indicator species for old-growth ponderosa pine. ODFW will<br />

assist the forest in determining habitat size.<br />

2. The yellow warbler as an indicator species for riparian habitat.<br />

3. The sandhill crane as an indicator species for wet meadow habitat.<br />

4. Small accipiters as indicator species for dense second growth coniferous habitat; and<br />

5. Bull Trout as an indicator species for high elevation trout stream habitat.<br />

ODFW also recommends the black-backed woodpecker be substituted for the northern three-toed<br />

woodpecker s the MIS for mature/old-growth lodgepole pine habitat. The black-backed is a better<br />

indicator of this habitat type. ODFW also recommends the habitat area be increased from 75 acres per<br />

site to 550 acres. (R. Goggins, 1987 unpublished).<br />

<strong>Response</strong><br />

The Forest is constrained to use the Regional Guide.<br />

Comment<br />

ODFW objects to departure alternatives because forest wildlife resources would be rapidly diminished<br />

by accelerated modification or loss of habitat. Departure timber harvesting risks the evenflow of<br />

recreational and commercial opportunities associated with fish and wildlife. ODFW recognizes the<br />

insect-infested overmature lodgepole pine is a serious management dilemma facing forest managers.<br />

Recently (1986), the Forest and ODFW have agreed on lodgepole pine management strategies that<br />

provide minimal habitat safeguards.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

ODFW recommends the habitat area for pileated woodpecker be increased from 160 acres per site to<br />

495 acres. (K Mellan, 1987).<br />

<strong>Response</strong><br />

The Forest Plan allocates 300 acres of old growth for pileated nesting habitat and manages 300 adjacent<br />

acres for feeding areas.<br />

Comment<br />

ODFW habitat protection criteria requires a minimum of 5-15 percent of each major plant community<br />

be dedicated old-growth stands; well-distributed by slope, aspect, and elevation throughout the Forest.<br />

The amount of existing old growth by plan community on the Forest cannot be determined with the<br />

data provided. ODFW recommends the final plan provide for dedicated old-growth habitats and managed<br />

K - 291

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old-growth stands located in a five to six mile grid pattern in the areas of sufficient size to meet habitat<br />

requirements of pileated and black-backed woodpeckers.<br />

<strong>Response</strong><br />

Alternative J, FEIS Preferred Alternative, provides approximately 10 percent of each timber type as old<br />

growth. Management requirements for indicator species for old growth provide a grid of old growth<br />

patches approximately 5 miles apart.<br />

Comment<br />

The Forest needs to provide more explicit information on wildlife in these categories, including more<br />

data on habitat requirements and habitat protection measures for sensitive species such as the northern<br />

spotted owl, great gray owl, and bull trout. See ODFW's comments for more detail. We agree with the<br />

Forest that special bald eagle management prescriptions should apply in the Marsh roadless area.<br />

<strong>Response</strong><br />

Information about species on the R6 Sensitive Species list is in Chapter 3 FEIS.<br />

Comment<br />

The "old growth' definition in the glossary is not the definition provided in the Regional Guide. If the<br />

amount of old growth under the Forest's definition does not concur with the amount that would exist<br />

under the Regional guide definition, the Forest should make corrections in the final EIS.<br />

<strong>Response</strong><br />

This has been corrected. The old growth acres in the FEIS reflect, as near as possible, the definition in<br />

the Regional Guide.<br />

Comment<br />

The Forest should indicate how many acres of dedicated old growth are 'suitable as opposed to capable,'<br />

as well as how many acres of dedicated stands have been thinned or have provided salvage.<br />

<strong>Response</strong><br />

It is not known at this time how many acres of old growth are suitable versus capable. The old growth<br />

acres identified in the FEIS and Plan are aggregations of age class and timber types from FORPLAN<br />

based on timber inventory. The aggregations were made to best fit the definition in the Regional Guide.<br />

Old growth acres have been allocated by alternative. The precise location of the stands that are allocated<br />

is not determined at this time, but will be determined as part of implementation. An inventory of existing<br />

old growth will be completed by October 1, 1990. Currently the old growth stands are selected on a<br />

site specific basis in project planning to most nearly approximate the location of the grid proposed in<br />

the Forest Plan.<br />

Comment<br />

The Forest has not provided detailed information on the condition of meadows. Where moist meadows<br />

are key livestock foraging areas, ODFW recommends grazing be tightly controlled in accordance with<br />

sound range management principles. There should be no forage allocated from wet meadows (Forest<br />

Service Handbook (FSH) 2209.21); because of soil problems on wet sites, most wet meadows are<br />

unsuitable for livestock use. The recommendations need to be Forest-wide standards, since all meadows<br />

are important wildlife foraging/nesting areas.<br />

<strong>Response</strong><br />

Detailed information is not available on the condition of meadows. The last range analysis was done in<br />

the 1970's on a few of the allotments on the Forest. Areas not in allotments have never had condition<br />

surveys conducted on them. Standards and guidelines for range vegetation management have been<br />

revised to include utilization standards. Allocation of forage on wet meadows is a process of allotment<br />

management planning after range analysis.<br />

K - 292

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Comment<br />

The Forest proposes to "manage' old growth lodgepole pine stands. The management prescription is<br />

acceptable to ODFW for 5-15 percent of the plant community; however, ODFW recommends that 5-15<br />

percent of the lodgepole plant community be retained in a dedicated prescription to ensure no old-growth<br />

values are precluded.<br />

<strong>Response</strong><br />

The Forest's approach to management of old growth environments is to identify suitable areas and to<br />

maintain their natural characteristics. This does not allow for the harvest of commerical timber from the<br />

area. This approach was adhered to in all alternatives presented in the DEIS except alternatives A and<br />

NC which were to reflect current plans.<br />

Comment<br />

The Forest must adhere to the lodgepole agreement (1986) to ensure dead and down tree habitat will<br />

be retained in lodgepole pine harvest areas.<br />

<strong>Response</strong><br />

Implementation of Forest-wide standards and guidelines and monitoring will provide for retention of<br />

dead and down habitat in all forested areas. Adequate numbers may be provide individually or in clumps<br />

as directed by safety considerations and may be met by creating snags where numbers are currently<br />

low.<br />

Comment<br />

ODFW recommends the Forest adopt a policy requiring monitoring of snags by 80 acre sampling units.<br />

This size would help maintain proper distribution of dead and down woody habitats across the Forest.<br />

<strong>Response</strong><br />

Monitoring of habitat for various species is provided for in Chapter 5 of the Forest Plan.<br />

Comment<br />

ODFW also recommends that the Forest provide adequate snags to meet 100 percent of potential<br />

population level in the 1,000 acre supplemental foraging area (1,000 acres) adjacent to dedicated<br />

stands of old growth. This should be adopted as a Forest-wide standard.<br />

<strong>Response</strong><br />

The Forest will provide 300 acres of old growth for nesting and 300 acres additional for feeding. The<br />

additional feeding area will meet approximately 100 percent potential population level for smaller cavity<br />

nesters but not for pileated woodpecker.<br />

Comment<br />

P.11-68.<br />

Management Area 8. The emphasis for this MA must include streamside and in-stream habitat conditions.<br />

ODFW recommends no programmed timber harvest in this management area. This direction would<br />

assure meeting the goal of protecting water quality, wetlands, floodplains, and wildlife resources.<br />

<strong>Response</strong><br />

MA 8 has been revised to include emphasis on all riparian areas, not just streamside areas. Alternative<br />

J, FEIS Preferred Alternative provides for no programmed harvest within 100 feet of a Class I or 11 stream<br />

and 50 feet of a Class Ill stream.<br />

Comment<br />

P.11-1 44.<br />

Table 11-7 Wildlife Forage. The Forest has planned for a departure in Alternative E by which most of the<br />

lodgepole pine sites would be harvested in the first two decades. With this in mind, how can the lodgepole<br />

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pine sites produce more forage in decade 5 than decade 1? (DEIS 11-144). ODFW is concerned that<br />

half or more of the alternatives offer no winter range or fawning area habitat management.<br />

<strong>Response</strong><br />

Forage output in FORPLAN varies by timber working group and treatment. Forage in decade 5 may be<br />

responding to harvest that is ocurring or to silvicultural practices such as thinning.<br />

Winter range and fawning habitat management varies to exhibit a range of management and the effects<br />

of management.<br />

Comment<br />

P.11-147.<br />

Common <strong>Response</strong> Factors. It is unreasonable to expect fish and deer populations to be the same for<br />

all alternatives. Variations in timber and especially grazing management intensities will significantly<br />

affect riparian habitat and fish populations.<br />

Winter range habitats off the Forest and hunting pressure are not the only limiting factors in herd population<br />

size. Studies have indicated that deer condition upon entering winter range is an important factor in<br />

deer survival and productivity' Management practices that affect food, cover, habitat effectiveness and<br />

winter range on the Forest vary by alternative and will have impacts on herd size and surplus animals<br />

available for harvest.<br />

<strong>Response</strong><br />

The Forest has developed a habitat suitability index based on concepts of the Interagency Technical<br />

Advisory Committee Mule Deer Model. From this index and based on fawn production, estimates of<br />

population have been derived for all alternatives. Factors considered in the model are cover, forage,<br />

roads, water availability, and livestock competition.<br />

Comment<br />

P.111-56. MIS<br />

What are current habitat conditions on the Forest for spotted owl, goshawk, pileated woodpecker, and<br />

marten? (DEIS 111-56-1). What is the current level of snags on the Forest? (DEIS 111-56-2). Why was no<br />

indicator species selected for riparian habitats? (DEIS 111-56-3). (See Recommendations).<br />

<strong>Response</strong><br />

The current conditions for spotted owl are discussed in Chapter 3. Old growth acres that could be<br />

used by the other species is discussed in Chapter 3. The current level of snags on the Forest is not<br />

known. Some areas have abundant snags, others are deficient. Snag levels are currently estimated on<br />

a project specific basis.<br />

Trout is the indicator for riparian habitat because it will best reflect changes in the riparian habitat<br />

adjacent to streams.<br />

Comment<br />

P.111-59. The Woodpecker Group<br />

The group consists of ten species, but only two are discussed. What are the other eight species and<br />

their habitat requirements? (DEIS 111-59-1).<br />

<strong>Response</strong><br />

The two species discussed are the indicators for the group. The other species are black-backed,<br />

white-headed, Lewis', hairy, downy, Williamson's sapsucker, yellow-bellied sapsucker, and common<br />

flicker. These species requirements for nesting and feeding are met by the requirements of the indicator<br />

species.<br />

Comment<br />

P.111-59.<br />

Marten. Marten are frequent users of lower elevation lodgepole pine and mixed-conifer sites where<br />

suitable habitat exists. What are the reasons for declining populations at lower elevations? (DEIS 111-59-2).<br />

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<strong>Response</strong><br />

The most probable reason would be decline in amount of habitat due to timber harvest and other<br />

human disturbance.<br />

Comment<br />

P.111-60.<br />

(Top of Page). The Dolly Varden trout is now officially referred to as the bull trout. The bull trout may<br />

be expired from some or all of its former habitat. This species is extremely sensitive to habitat degradation<br />

and needs special habitat considerations. The discussion needs to include recognition that shortnose<br />

and Lost River suckers are being considered for Federal listing.<br />

(Paragraph 3). Bank stability may be in fair to good condition but riparian and aquatic habitats are far<br />

from optimum.<br />

What has reduced the trout production on the Forest? (DEIS 111-60).<br />

<strong>Response</strong><br />

The name change to bull trout has been incorporated. The suckers are currently Federally classified<br />

as endangered species.<br />

Trout productivity on the Forest was reduced primarily by past grazing practices degrading streams<br />

and riparian areas. Grazing changes made around a decade ago have resulted in improvement in the<br />

riparian ecosystem and gains are expected to continue.<br />

Comment<br />

P.111-61.<br />

Table 111-1 7. Add the red-band trout to the list of fish found on the Forest.<br />

<strong>Response</strong><br />

The red-band trout has been added to the list of fish and is also on the R6 Sensitive Species list.<br />

Comment<br />

P.111-63.<br />

Table 111-1 8. The scientific name for the Lost River sucker has been changed to Deltistes luxatus. Add<br />

the bull trout to the sensitive species list.<br />

<strong>Response</strong><br />

These changes have been incorporated into the FEIS and Forest Plan.<br />

Comment<br />

P.111-66.<br />

Paragraph 2. Forage allocations in allotment plans should provide forage for big game at desired<br />

population levels. It is doubtful that 'high concentrations' of big game have or will significantly impact<br />

availability of forage for livestock.<br />

Grazing improvement projects are not necessarily positive for wildlife unless specific wildlife objectives<br />

are planned for and met. Forage development that favors grasses at the expense of cover and browse<br />

can have negative impacts on specific wildlife species.<br />

<strong>Response</strong><br />

Allotment management plans are the appropriate place to make site-specific allocations of forage.<br />

Range analysis will be conducted for each allotment and allotment management plans will be updated<br />

or revised to reflect current conditions on the ground and management direction in the Forest Plan.<br />

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Comment<br />

P.IV-16<br />

Below-cost Timber Sales. The potential short-term and long-term negative impacts of accelerated<br />

lodgepole pine harvest on big game and nongame habitat would exceed the possible impacts of debris<br />

built up resulting from dead lodgepole pine.<br />

<strong>Response</strong><br />

Perhaps in a very short-term sense this is true. However the high likelihood of high intensity fire that<br />

would result from the debris would have negative impacts that would probably outweigh harvest. Harvest<br />

of the dead lodgepole would have beneficial impacts to big game by permitting ease of travel and in<br />

many instances allowing more rapid regeneration of cover.<br />

Comment<br />

P.IV-37.<br />

(2nd Paragraph). -... experience future epidemics because no stocking level control...." The Forest needs<br />

to explore alternatives for managing lodgepole pine sites to promote more stable habitat conditions for<br />

wildlife.<br />

<strong>Response</strong><br />

The Forest has applied current knowledge of silvicultural practices to make the predictions.<br />

Comment<br />

P.IV.44.<br />

Old-Growth Habitat. The amount of old-growth habitat meeting Region Six definitions is not addressed.<br />

The Forest's term Nold-growth characteristics" needs to be defined.<br />

<strong>Response</strong><br />

The total acres of old growth meeting Regional Guide definition is addressing in Chapter 3, FEIS.<br />

Comment<br />

P.IV-48.<br />

Trout. What methods and standards were used to rate riparian and aquatic habitat conditions? (DEIS<br />

IV-48-1).<br />

If riparian and aquatic habitats are in good condition, why would it take 50 years to restore habitat<br />

capability for trout to 80 percent of potential? (DEIS IV-48;-2).<br />

<strong>Response</strong><br />

The rating of riparian condition is based on 1979 surveys and more recent ocular estimates. Fish habitat<br />

and stream condition are dynamic. It is not known what past conditions in relation to potential has<br />

been. It is assumed that 100 percent potential is "perfection' and that 80 percent is achievable using<br />

improvement and enhancement techniques. Regarding the time frame...vegetative condition takes a<br />

relatively long time to improve and the rate of improvement slows as it improves.<br />

Comment<br />

P.IV-49.<br />

(Top of Page). Where is the expenditure of K-V funds speeding the rate of stream recovery? (DEIS<br />

IV-49). The Forest should not discount the possibility of improving streams to greater than 80 percent<br />

of potential capability. The Forest should proceed to achieve optimum riparian/aquatic habitat conditions.<br />

A table of K-V expenditures for fish habitat improvements should be displayed in Chapter IlIl.<br />

<strong>Response</strong><br />

The 80 percent level is an upper level determined as feasible but does not preclude greater increases<br />

in capability. After a certain level, though, investment becomes greater than benefit.<br />

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A table of total anticipated expenditures which includes KV is in Chapter IV, Forest Plan.<br />

Comment<br />

P.IV-53.<br />

Developed Recreation. Development of a ski area on Pelican Butte would increase angling pressure<br />

on Francis Lake; which would exceed the current capacity for the lake. Increased pressure on the lake<br />

would require a more restrictive management strategy for the lake.<br />

<strong>Response</strong><br />

An EIS addressing the site specific effects of development of the ski area is being written.<br />

Comment<br />

P.IV-1 03.<br />

(Last Paragraph). As lodgepole pine firewood becomes less available, measures will need to be<br />

strengthened to protect dead and down woody material needed for dependent wildlife species.<br />

<strong>Response</strong><br />

Implementation of standards and guidelines regarding dead and down material will provide for dependent<br />

species at the 40% potential population level.<br />

Comment<br />

B-147.<br />

Table B-23. The maximum percentage in created openings for riparian zones should be zero. There<br />

should be no clearcuts or shelterwoods in the riparian zones. The riparian habitats on the Forest are<br />

very important to a large number of species and need to be maintained.<br />

<strong>Response</strong><br />

Protection of riparian areas and particularly streamside riparian area is addressed in Management<br />

Area 8. The standards and guidelines for this management area were significantly changed between<br />

draft and final.<br />

Comment<br />

D-7.<br />

5. The protection criteria to prevent human disturbance of active nests is supported by ODFW. What<br />

protection criteria will be used to protect the nest tree when there is no nesting pair? (App. D-5).<br />

<strong>Response</strong><br />

The tree will be protected until it is determined that the tree is no longer used, but no seasonal restrictions<br />

will be in effect if there is no nesting activity.<br />

Comment<br />

D-9.<br />

6. What is the Forest's policy for cavity-dependent wildlife habitat management? (App. D-9).<br />

<strong>Response</strong><br />

The Forest's policy is to provide habitat to maintain viable populations of all vertebrate species.<br />

Implementation of standards and guidelines regarding dead and down material will provide for dependent<br />

species at the 40% potential- population level.<br />

Comment<br />

D-9.<br />

7.a Definitions for 'fawning cover and *hiding cover need to be provided. See recommendation for<br />

Big Game Habitats.<br />

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<strong>Response</strong><br />

See the Glossary for definitions provided.<br />

Comment<br />

D-9.<br />

Standards 8 and 9 are very good and supported by ODFW. For number 8, change April 1 to May 1<br />

and June 15 to July 15.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

D-1 0.<br />

14. Why has the Forest not referred to 'Wildlife Habitat Relationships of South Central Oregon?' (App.<br />

D-1 0).<br />

<strong>Response</strong><br />

The publication in question was not used. The reference in question contains much information but<br />

much is unusable. For example, species data by land type is no longer usable because the Forest no<br />

longer uses land type classification.<br />

Comment<br />

D-14.<br />

(Paragraph 1). The standard to harvest up to one-third of the perimeter of a natural opening is<br />

unacceptable. ODFW criteria is for no more than 10 percent of the perimeter to be open at any one<br />

time; this standard allows for more secure use of natural openings by wildlife.<br />

<strong>Response</strong><br />

No response necessary.<br />

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Comment<br />

D-67.<br />

Wildlife and Fish. 2. There were no native fish in lakes in the wilderness areas of the Forest.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

E-10.<br />

Fish (Sentence 2). Water temperature, not turbidity, is the more limiting habitat element along with a<br />

lack of cover.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

PP IV-3.<br />

Wildlife and Fish Program Goals. What are 'key riparian areas' and where are they? (PP IV-3). All riparian<br />

areas are important and should be managed for their intrinsic resource values.<br />

<strong>Response</strong><br />

'Key' riparian areas are those that have identified significance as relates to the major issues on the<br />

Forest. These are specifically fish habitat and mule deer fawning areas. The Forest recognizes the<br />

importance of all riparian areas by identifying all riparian areas in a separate management area in<br />

Alternative J, FEIS Preferred Alternative.<br />

Comment<br />

PP IV-5.<br />

(Paragraph 8). "Most riparian areas will be managed emphasizing wildlife habitat values." Page 111-7<br />

states only 32 percent of the riparian acres on the Forest would be allocated to MA 8 (Riparian<br />

Management). How would the remaining riparian areas be managed to emphasize wildlife habitat values?<br />

(PP IV-5-2).<br />

<strong>Response</strong><br />

Alternative J, FEIS Preferred Alternative, identifies all riparian areas except those that fall into allocations<br />

such as Wilderness which preclude direct management, as a separate Management Area.<br />

Comment<br />

PP IV-28.<br />

Wildlife and Fish Program. (Paragraph 3). This paragraph should state that some special habitats (e.g.,<br />

deer, trout, woodpeckers) will be managed at higher than minimum levels to allow for consumptive<br />

and nonconsumptive recreation use.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

PP IV-29.<br />

(Paragraph 1, Sentence 2). Wild trout' is more appropriate than 'native trout. Many streams have<br />

brook and brown trout that are not native but are self-perpetuating 'wild' populations.<br />

This is a statement of present condition and does not indicate what the Forest objective is for riparian<br />

and aquatic habitats. The Forest has identified improvement methods and areas where rehabilitation<br />

or improvements are needed but has not included a clear statement of intention.<br />

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<strong>Response</strong><br />

The goals for Management Area 8 are stated in Chapter 4 Forest Plan.<br />

Comment<br />

PP IV-117.<br />

A.2. Restrictions should be from November 1 to March 15.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

PP IV-117.<br />

C.2. This standard is an addition to the standards found in DEIS App. D-92. Firewood cutting in these<br />

areas wouild need close administration to ensure the habitat values for bald eagles are protected.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

ODFW habitat protection criteria require dead and down tree habitat be provided to maintain<br />

cavity-dependent species at a level of at least 60 percent of potential populations on timber management<br />

lands, and at 100 percent of potential populations on all other lands. Insufficient information was provided<br />

to determine the current condition and proposed management direction for dead and down woody<br />

habitats. There is no discussion of protection methods for dead and down woody habitats.<br />

<strong>Response</strong><br />

Dead and down tree habitat will be provided to maintain cavity-dependent species at a level of at least<br />

40 percent of potential populations on timber management lands. There are several protection methods<br />

available. These should be chosen depending upon the landscape, and the site-specific problems with<br />

protection.<br />

Comment<br />

Forest management activities have not protected dead and down tree habitat. Therefore, on Forest<br />

lands adjacent to where this has occurred, an equivalent number of forested acres should be maintained<br />

with sufficient habitat to meet the 100 percent level until replacement stands meeting the 60 percent<br />

potential population criteria have been developed.<br />

<strong>Response</strong><br />

The Forest objective is to provide 40 percent potential population level. Deferring harvest in adjacent<br />

stands until replacement stands have reached the objective level is one way to provide this. Creating<br />

snags from green live trees is another. The method of achieving the objective level is site specific and<br />

will be addressed in site-specific analysis.<br />

Comment<br />

PP IV-128.<br />

Monitoring. There is serious doubt existing biological staffing levels can carry out the monitoring plan.<br />

Sufficient biological personnel and seasonal help will be required to assure standards and guidelines<br />

for wildlife habitat are being followed. A key element is biological input at the planning level on all<br />

management activities. A minimum of one biologist in each ranger district, with permanent or seasonal<br />

support personnel, will be needed.<br />

<strong>Response</strong><br />

Staffing will be increased or decreased to reflect the implementation needs and the budget. As of July,<br />

1990, each Ranger District has one or more permanent full-time biologists.<br />

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Comment<br />

PP V-9.<br />

Suggested methods for monitoring need to be more specific. For example, the method listed for reserved<br />

old-growth areas is m10-year action plan, on-the-ground inspection.' How many sites will be looked at<br />

each year? what parameters will the inspection evaluate?<br />

For spotted owl habitats, the method is 'field review.' Again, how many sites and what parameters?<br />

These comments apply to all of the fish, wildlife, and water monitoring methods.<br />

<strong>Response</strong><br />

The monitoring plan has been revised between draft and final to be more specific.<br />

Comment<br />

PP V-15. Monitoring Questions.<br />

A fifth question needs to be added: 'f. Are fish and wildlife habitat improvement projects producing the<br />

estimated outputs?'<br />

<strong>Response</strong><br />

This concept has been included in the monitoring plan for all resources.<br />

Comment<br />

10. This guideline, page IV-40, should include quantitative standards for habitat maintenance or restoration<br />

of riparian ecosystems. The benchmark from which to gauge whether standards are being met might<br />

include a provision to maintain a specific percentage in excellent, good, fair, or poor condition. Or the<br />

guidelines might include a provision to improve to 'excellent' a specific number of miles or acres of<br />

riparian zone condition per year or decade.<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

Riparian areas are discussed almost exclusively in terms of wildlife, water quality, wetland and floodplain<br />

values. In most cases, management for these values would adequately address water quantity values<br />

such as stream channel stability. It appears as if the use of even-age timber harvest practices in riparian<br />

areas would be inappropriate to meet some fishery objectives such as trout habitat (tree shade<br />

requirements, water temperature).<br />

<strong>Response</strong><br />

The standards and guidelines for Soil and Water and for Management Area 8 have been revised and<br />

address fisheries as well as other resource values.<br />

Comment<br />

Management Area 8 - Riparian Management, 11-69, does not identify riparian locations other than that<br />

they are buffers along class 1, II, and IlIl streams. It is clear from the DEIS that the areas have been<br />

mapped for management purposes, and allowable sale quantities (ASQ) and acreage figures developed<br />

for them by ranger district. However, there is no indication of riparian area condition in the DEIS. Paragraph<br />

one, page IV-29 of the LRMP, states that riparian habitat and water quality are favorable in most of the<br />

fish-bearing streams. An inventory of the riparian condition of specific areas would be useful for<br />

corroboration of this statement.<br />

<strong>Response</strong><br />

In Alternative J, FEIS Preferred Alternative, riparian areas have been expanded to include riparian areas<br />

such as wet forest and wet meadows that are not just associated with streams. Riparian condition is<br />

based most recently on ocular estimates. The monitoring section identifies the need for riparian surveys.<br />

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Comment<br />

Need for Further Documentation and Analysis<br />

1. Data Uncertainty -The credibility of the plan could be increased significantly if the MMR's were submitted<br />

to peer review. That review would help assure that the most current data and a broad base of professional<br />

expertise are reflected in the plan.<br />

2. Alternative MMR Strategies - Only one set of MMR strategies is proposed in the plan and the sensitivity<br />

analysis provided in Appendix J only varies the intensity of that one set. Where alternative methods for<br />

achieving the same objectives are available, displaying them would be beneficial and possibly avoid<br />

later conflicts with NFMA and NEPA public disclosure requirements.<br />

3. Inconsistency Among National Forests - Based on the information provided in the forest plans published<br />

in Region 6 to date, it appears that similar national forests may be modeling their MMRs differently,<br />

thereby providing inconsistent levels of protection and inconsistently applied constraints on other<br />

resources. No published documentation supports these differences or explains how each forest's MMR<br />

package provides for the minimum level of protection, as required or suggested by NFMA. If alternatives<br />

are displayed, as recommended in number 2 above, this concern would be overcome.<br />

The need for and design of each MMR should be clearly explained in the forest plan. A display similar<br />

to the August 22, 1984 Wildlife MMR matrix produced by the Region should be included in the Final<br />

EIS. This now outdated matrix provided important data on the number of habitats being designated by<br />

each national forest for each indicator species, the acres of suitable land involved, and a measure of<br />

the effect of these allocations on timber management. Similar displays could be constructed for soil,<br />

water quality, and riparian MMRs.<br />

<strong>Response</strong><br />

Appendix J contains a discussion of Management Requirements.<br />

Comment<br />

In the Winema's planning process to date, the decisions and assumptions used in developing the<br />

MMRs were finalized and incorporated into all alternatives without the provision of any opportunity for<br />

full public review, as required by NEPA and NFMA. This action by the Forest Service makes the planning<br />

process vulnerable to legal challenges and prevents the agency from gaining the valuable input that<br />

the public and other resource professionals could have provided the Forest Service.<br />

<strong>Response</strong><br />

The National Forest Management Act (NFMA) set legal guidelines for management of the National<br />

Forests. The guidelines were interpreted by the Secretary of Agriculture, in cooperation with a Committee<br />

of Scientists and with public and professional involvement, to develop regulations. Direction from the<br />

Chief of the Forest Service and Region 6 resulted in MR's which reflect the requirements of the laws<br />

and regulations in NFMA. The MR direction ensures that minimum legal requirements are applied to all<br />

alternatives in Forest plans consistently across all National Forests. MR's exist for dispersal of created<br />

openings, water quality, riparian and wildlife habitat as required by NFMA.<br />

Comment<br />

The process for implementing MMRs must be opened up fully to public review. By doing so, the Forest<br />

Service may be able to develop new alternatives that are more responsive to public concerns.<br />

<strong>Response</strong><br />

The planning process, including MRs, is open for public review.<br />

Comment<br />

The effects of managing the forest-wide snag potential of all alternatives at 20, 40 and 60 percent level<br />

need to bed provided to display changes in timber harvest levels, present net value, and fire risk. If the<br />

high levels of snag retention were possible without significant reductions in timber harvest levels or<br />

significant increases in wildfire risk, the Department of Forestry would support managing snag habitat<br />

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at a higher level. The full costs of maintaining the higher levels of snag retention at 20, 40 and 60 percent<br />

levels should be included in the final EIS.<br />

<strong>Response</strong><br />

The trade-offs associated with various snag levels are similar to the trade-offs associated with most<br />

other alternative management scenarios. These are assessed in the context of the alternative comparison<br />

process wherein a variety of snag levels are provided. Individual costs of this consideration along with<br />

most other individual concerns are not separated.<br />

Comment<br />

Old Growth Habitat - (DEIS, page IV-44; App.) Information in the text is inadequate to describe the<br />

effects of each alternative on old growth management. Total present acres of old growth habitat are<br />

not provided in the DEIS. The text states '...currently 68 percent of the Forest is estimated to retain old<br />

growth characteristics [and] about 20 percent of the Forest will always retain old growth characteristics<br />

as wilderness and lands unsuited for timber production...." Since the forest is approximately 1.04 million<br />

acres in size, some 707,200 acres should be characterized as old growth and 141,400 acres in the<br />

second category as Wilderness and unsuitable lands. However, this information does not seem to<br />

compare with data in Table II-3A.<br />

<strong>Response</strong><br />

This information has been included and can be found in Chapter 2 and 4 of the FEIS.<br />

Comment<br />

The application of the glossary definition of an old growth stand (App. page GL-1 9) to the variety of<br />

descriptions of old growth used throughout the planning documents also adds to the confusion. Acres<br />

of old growth forest in an old growth condition are summarized in Table II-3A; however, mold growth<br />

forest communities' are discussed in management area 7,' forest with old growth characteristics' on<br />

page IV-44, and mold growth habitat' in Appendix page J-24. Do these terms all provide acres in old<br />

growth habitat? If so it seems that similarities should be reflected by the common definition. The basis<br />

for the range of acres described as old growth in the DEIS needs to be explained. If possible, extended<br />

totals in the tables showing old growth should be comparable to old growth habitat acreage in Table<br />

11-3A. The Department also recommends that the planning document include a table showing the amount<br />

of old growth timber that will continue to exist in each alternative during the first five decades projected<br />

by this plan.<br />

<strong>Response</strong><br />

Old growth can be defined in several ways depending upon the scale of the area, the purpose for the<br />

old growth, and the viewpoint of the definer. The definition used for deriving acres is from the Regional<br />

Guide. Chapter 2 (FEIS), also provides the total old growth remaining at the end of decades 1, 2, and<br />

5.<br />

Comment<br />

Another important comparison missing from the planning documents is a clear statement of the total<br />

number of acres of old growth needed (required by MMRs) for old growth preferring wildlife. According<br />

to Table J-2 (App.page J-24), this figure is about 20,909 acres.<br />

<strong>Response</strong><br />

The total old growth in additional to that in Wilderness, etc. needed for minimal viable populations of<br />

wildlife is about 21,000 acres.<br />

Comment<br />

The Winema conducted only a composite sensitivity analysis to the effect of varying individual MMRs<br />

remains unknown. Also, the Forest has displayed only the effect on present net value and allowable<br />

sale quantity of increasing or reducing the MMR constraints. There is no information on how these<br />

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different levels of protection would affect the target resources in the short and long term. A more<br />

comprehensive analysis should be provided in the final EIS.<br />

<strong>Response</strong><br />

Appendix J of the EIS addressed the effects of MRs. Altogether the MRs were determined to have less<br />

than 5% effect. This is an insignificant effect in the context of the inherent variability in natural systems<br />

and the abstractions of realilty necessary to model these systems. Individual MRs would have even<br />

smaller effects. Therefore, further analysis would be fruitless.<br />

Comment<br />

ORC supports priority management of native resident trout species. The Winema Forest is rich in<br />

outstanding wild salmonids and management should reflect this. Please establish additional management<br />

indicator species for high elevation trout streams: bull trout, for riparian habitat: yellow warbler, and for<br />

wetlands and meadows: sandhill crane.<br />

<strong>Response</strong><br />

See Appendix J of the DEIS for a discussion on indicator species.<br />

Comment<br />

Your plan provides for Northern Spotted Owl habitat as it should. Does it also recommend funding for<br />

ongoing studies of this elusive animal? I somehow missed this in the discussions on environmental<br />

consequences. Mentioned in the verbage were "currently evaluated factors which were beyond the<br />

scope of this analysis which, to me does indicate that some type of funding is underway.<br />

<strong>Response</strong><br />

One basic assumption is that whatever alternative is chosen, the funding levels are requested to do<br />

the job. However, funding is a congressional decision, which if history is any indicator, not always<br />

geared to identified field needs.<br />

Comment<br />

The plan evidently overvalues mule deer. Oregon Fish and Wildlife Department data indicate diminish<br />

sales and interest in mule deer statewide. Conversely, tag revenues and interest in elk has increased.<br />

The proposed plan ought to consider reductions in populations of mule deer and domestic livestock<br />

and manage for greater elk numbers. Additionally, effects of timber harvest on elk escape cover and<br />

winter foraging habitats should be evaluated.<br />

<strong>Response</strong><br />

Mule deer were identified through public process as a key issue species in this area. Elk are currently<br />

being studied through interagency cooperative funding. Until the dynamics of the elk in the area are<br />

known and recommendations can be made, the Forest will not manage specifically for elk habitat other<br />

than calving areas especially east of Highway 97.<br />

Comment<br />

A map of transition range should be prepared. We recommend that at least 50% thermal cover be<br />

provided on transition range, and that it be managed as for winter range with respect to road density.<br />

We recommend that fall greenup on transition range be reserved for wildlife.<br />

<strong>Response</strong><br />

The Forest will manage winter range and summer range. Many areas of the Forest do not have potential<br />

for 50% thermal cover. Road density is one of the factors considered in both winter range and summer<br />

range management.<br />

Comment<br />

Finally, we anticipate that managed stands and areas managed for visual quality, riparian values and<br />

big-game wildlife will provide many of the habitat components used by 'old growth dependent' wildlife<br />

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species, especially where uneven-aged management is emphasized. As noted above, we believe that<br />

opportunities exist to creatively manage the forest to maintain healthy wildlife populations without taking<br />

land entirely out timber production. The planning team should fully explore these kinds of opportunities<br />

and incorporate them into the final plan.<br />

<strong>Response</strong><br />

Stands managed for visual quality may provide some of the characteristics of old growth. However is<br />

many instances it may not provide for desired characteristics. Uneven-aged management in the classical<br />

sense has not been applied to the Forest. Thus, it is unknown what the effects on old growth<br />

characteristics, big game cover and forage, and other wildlife populations will be. It is projected that<br />

uneven-age management will leave a few large old trees but will not provide enough large trees to<br />

meet old growth stand characteristics required by many species. Stands in uneven-aged management<br />

will retain some minimal cover value for big game and may provide some short term forage. Alternative<br />

J, FEIS Preferred Alternative proposes all of the ponderosa pine and half of the pine associated timber<br />

types for uneven-aged management.<br />

Comment<br />

Actually, there doesn't seem to be any organized monitoring of the eagle population, despite repeated<br />

calls for review in KBEHMA. To cite a few:<br />

<strong>Response</strong><br />

Bald eagle populations are currently monitored by OSU Cooperative Extension Units in cooperation<br />

with Region 6. Biologists on the Winema also monitor use and activity of winter roosts and nest sites.<br />

Monitoring of bald eagle has been included in Chapter V Forest Plan.<br />

Comment<br />

This is unusually rich and diverse wildlife habitat found nowhere else on the forest. Here is an opportunity<br />

to preserve intact a complete elevational transect in a fairly pristine condition. Do we need lumber so<br />

badly that we are willing to sacrifice our very best wildlife habitat for those extra marginal acres?<br />

<strong>Response</strong><br />

Reviewer opinion. No response necessary.<br />

Comment<br />

We consider the need to get back to sound snag management throughout the forest to be a high<br />

priority. In addition to leaving snags, we would like to see assurances in this plan that you have a plan<br />

to protect snags. We fear that as the forest continues to dump large amounts of lodgepole on the<br />

fuelwood market, and as that resource begins to crash, snags will come under great pressure. Providing<br />

for near minimum amounts of snags as a policy, when portions of the forest are already deficient of<br />

snags, almost guarantees failure on this habitat front.<br />

<strong>Response</strong><br />

Implementation of Forest-wide Standards and Guidelines will provide snags at the 40 percent potential<br />

population level of woodpeckers in all timber types in the Forest.<br />

Comment<br />

The total acres of old growth existing on the Winema is not listed in the Draft Environmental Impact<br />

Statement. The definition of old growth is not the same as the one used in the Regional Guide. It is<br />

not clear what is meant by suitable old growth. It is difficult to comment on old growth management<br />

when we are not sure of what your definition of old growth is or how much old growth is available.<br />

<strong>Response</strong><br />

These acres are identified in Chapter 3, FEIS as is the definition of old growth. The definition used to<br />

derive the acres displayed is the Forest's closest approximation to the Regional Guide.<br />

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Comment<br />

Threatened and Endangered Species. Effects of the various alternatives on federally listed and proposed<br />

threatened and endangered species and their potential habitat, namely Bald Eagle, Peregrine Falcon,<br />

Shortnose Sucker and Lost River Sucker, have not been assessed in the DEIS.<br />

<strong>Response</strong><br />

The effects on these species have been addressed in Chapter 4, FEIS.<br />

Comment<br />

Minimum Management Requirements endoresed by the Forest do not coincide with management<br />

philosophy of maintaining Park wildlife populations in their natural abundance and distribution.<br />

<strong>Response</strong><br />

The National Park System and the National Forest System have different management mandates.<br />

Comment<br />

Timber Harvest. NPS is very concerned about the timber harvest levels of Alternative E and the impact<br />

this would have on the wildlife populations that inhabit the Park and surrounding Forest. For the area<br />

of Thielsen south to Sky Lakes, and east to Antelope Desert, Alternatives I or F would provide the<br />

lease disturbance to the Park ecosystem.<br />

<strong>Response</strong><br />

The National Park System and the National Forest System have different management mandates. The<br />

Forest mandate is to manage for multiple use, which use includes timber management and range<br />

vegetation management. The Forest Plan attempts to provide a balance in resource management.<br />

Comment<br />

Page 111-60, para. 3. The Forest states that the portion of the Williamson River under Forest management<br />

produces only 30 percent of its potential fishery production capability (this also includes sections of<br />

the Sycan and Sprague River fisheries). The final document should address what options, if any, the<br />

Forest will pursue to increase the productivity of these streams.<br />

<strong>Response</strong><br />

The Forest has as an objective to increase the capacity of fish production to 80 percent of potential.<br />

The specific methods are site-specific and must be dealt with in a site-specific manner which is outside<br />

the scope of this document. However, both the Forest Plan and FEIS discuss possible methods available.<br />

These are improvements in riparian vegetative condition and instream enhancement.<br />

Comment<br />

The DEIS-Chapter 3, should give additional consideration to anticipated conditions regarding the<br />

peregrine falcon. While occupation by this species is not currently noted on Forest lands, its status on<br />

Forest lands can be expected to change in the near future as a result of recovery activities within the<br />

region. Since a variety of Forest actions could adversely affect this listed species, annual inventories of<br />

potential and historic habitats are necessary to avoid possible adverse affects to this species and its<br />

recovery.<br />

<strong>Response</strong><br />

Consideration for the peregrine falcon is given in Chapter 3, FEIS; Chapter 4 Forest Plan.<br />

Comment<br />

DEIS 11-70, Management Area 9, Bald eagle: There is no mention as to whether or not potential habitats<br />

for bald eagle are designated for management as bald eagle habitat. Those areas identified by the<br />

Oregon Cooperative Wildlife Research Unit and Forest Service Region 6 as potential bald eagle territories<br />

should be included in Management Area 9 so that they can be given additional management<br />

consideration.<br />

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<strong>Response</strong><br />

Active nest sites and recovery nest sites have been identified in cooperation with other agencies. In<br />

addition to the particular sites, replacement habitat is identified for management to in the future provide<br />

habitat suitable for nest sites.<br />

Comment<br />

DEIS 11-84, Bald Eagle, Habitat and Historic Trend: References to the Bald Eagle Management Guide<br />

should be deleted. The Bald Eagle Management Guidelines do not reflect the current state-of-the-art<br />

measures for the management of bald eagles. The Pacific States Bald Eagle Recovery Plan has been<br />

finalized and should be utilized as the current reference document. The current strategy for bald eagle<br />

management emphasizes the development of site-current management plans.<br />

<strong>Response</strong><br />

The Pacific States Bald Eagle Recovery Plan is used as a reference document as well as more recent<br />

research data. The Recovery Plan directs the use of at that time current management guides.<br />

Comment<br />

Enclosed is the map referred to in our comments to the Winema DEIS and Proposed Plan. The map<br />

displays winter range and transition range for deer. This is a first effort at identifying deer transition<br />

range for the Winema. I suggest further refinement of the transition range boundaries by the Technical<br />

Advisory Committee (ODFW, Klamath Tribe, Winema N.F., and Fremont N.F.).<br />

<strong>Response</strong><br />

No response necessary.<br />

Comment<br />

ODFW is currently managing elk in south central Oregon that are increasing in numbers and expanding<br />

their range. Elk have been observed on almost all portions of the Winema National Forest. We will<br />

have better information on the distribution and needs of elk in south central Oregon when the proposed<br />

cooperative elk study is completed. At this time, however, ODFW considers all of the Winema National<br />

Forest as elk range.<br />

<strong>Response</strong><br />

No response necessary.<br />

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