Help Protect Oregon's Public State Forests
11/3/97
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RELAYED TEXT STARTS HERE:
Headline: Help Protect Oregon's Public State Forests
Source: National Wildlife Federation
Date: 11/3/97
Dear Friend,
It is time for us to take charge of managing Oregon*s public state forests! You
can make a difference for imperiled fish and wildlife! If you believe that
Oregon*s state forests are a treasure and should not be massively
logged, then join NWF in its effort to protect over 600,000 acres slated for
increased logging beginning next year.
You will be a key player in the making of history. The Oregon Department of
Forestry (ODF), the state agency which oversees state public forests, plans to
issue a Habitat Conservation Plan (HCP) to balance survival of fish and
wildlife against the economic desires of the surrounding counties and ODF
itself (ODF is funded primarily by timber revenue). ODF is trying to make an
honest and good faith attempt to balance the competing uses. However, ODF has
a serious conflict of interest in writing an acceptable plan, because its
desire for money through timber revenue can easily shift this balance in favor
of logging over all other uses.
Only public outcry can ensure that logging does not predominate throughout our
public state forests. ODF will hold a series of public meetings in November
and early December to hear from you about its future strategy to increase
logging on state forest land. The evening you sacrifice to participate in one
of these meetings will make a significant difference for fish and wildlife that
live in the forests. These species include spotted owls, marbled murrelets,
and the six species of salmon (including coho, chum, and steelhead). Please
look at the enclosed schedule for the date and location of the meeting nearest
you.
The following materials will give you information that you may need to make an
informed and articulate contribution towards protecting fish and wildlife in
our state forests.
Please contact Sybil Ackerman, National Wildlife Federation, 503-230-0421,
Ackerman@NWF.org, with any questions
about the upcoming meetings.
Sincerely,
Sybil Ackerman
Habitat Conservation Plan Program Coordinator, Pacific Northwest
National Wildlife Federation
Framing the issue: commonly asked questions
Q. What is a Habitat Conservation Plan (HCP)?
The Endangered Species Act (ESA) allows non-federal landowners to write a plan
called a Habitat Conservation Plan (HCP) that essentially gives the landowner
permission to destroy threatened and endangered fish and wildlife
species and habitat in the course of lawful economic activities. Roughly 400
HCPs covering millions of acres of habitat have either been approved or are
being developed by the Clinton Administration. Many conservationists and
scientists have raised serious questions about the potential adverse impacts
these plans will have on species recovery.
ODF is creating an HCP because it is planning to log marbled murrelet and
spotted owl habitat as part of its plan to increase logging on 615,000 acres of
the state*s public forests. ODF*s HCP is entitled the Western Oregon State
Forest HCP (WOST HCP), and will cover approximately 75 species, including the
spotted owl, marbled murrelet, and six species of salmon such as the coho and
steelhead on 615,000 acres of state forest land in Oregon.
Under the *no surprises policy* created by the Clinton Administration, ODF is
allowed to create an HCP that will essentially exempt it from any further
obligations for fish and wildlife for 50-100 years. ODF therefore has
a strong incentive to create an HCP.
Q. What is the location and history of the public state forests covered by the
HCP?
The 615,000 acres of public state forests at issue include the Tillamook State
Forest, the Clatsop State Forest, the Santiam State Forest, and some smaller
parcels in southwestern Oregon. The Tillamook and Clatsop State Forests
comprise over 500,000 acres of the total HCP, and are located only forty
minutes from Portland. These ecological and recreational jewels form one of the
largest tracts of temperate rainforest in the lower 48 states.
Fifty years ago, much of these forests were private lands and were logged.
Beginning in 1933, these lands were subjected to a series of devastating forest
fires as a result of poor logging practices and hot dry weather.
After the fires, the degraded land was turned over to the people of Oregon to
replant. ODF is the state agency that manages the lands. Today, the mixture
of young and older forests are an important sanctuary for fish, wildlife, and
recreation.
Q. What does the ODF logging plan look like?
The WOST HCP is currently fluid and in a negotiation phase. However, there are
some definite areas that appear to be developing. ODF will use a new theory of
*structure based forest management* (SBM) to be the main thrust of the HCP.
Compliance with SBM will alleviate ODF from any future ESA obligations for most
of the 75 species covered by the WOST HCP. SBM is a habitat based approach
that is a fairly new theory and is based on a vague percentage-based scheme of
forest structure that attempts to replicate a natural ecosystem. In reality,
the theory as applied to state forest land may be problematic because, among
other things, it does not create substantial reserve areas, allows logging on
approximately 90% of the forest, does not commit to specific tree rotation
periods, does not carefully map the specific types of logging that will be done
in each part of the forest until after the plan is approved, and does not yet
have adequate adaptive management and monitoring regimes. Although the theory
behind SBM is a good one, because it attempts to replicate a natural forest
ecosystem, the reality of this plan leaves far too much up to ODF which already
has a conflict of interest because of their strong dependence on timber revenue
to survive.*
ODF will also establish specific management objectives for spotted owls,
marbled murrelets and salmon. For spotted owls and marbled murrelets, ODF will
designate cluster areas that require some kind of undefined *augmented*
protection. ODF has not yet released its plan for salmon but the preliminary
reports appear to be that ODF will not protect salmon as well as they are
protected on federal forests. For example, salmon habitat buffers
may only amount to a third of the protection offered on federal land.
Q. Why should I care about this issue when federal land already has provisions
for wildlife?
Federal land alone can not adequately protect imperiled fish and wildlife. A
recent GAO report noted that 73% of species listed by the Endangered Species
Act (ESA) have more than 60% of their habitat on non-federal land.
Forty-four listed vertebrates and thirty-two listed invertebrates depend
exclusively on non-federal land to survive.
The public state forests at issue is important habitat for the spotted owl and
the marbled murrelet. The Tillamook and Clatsop State Forests also house six
species of salmon including the coho, which depends almost exclusively on non-
federal land to survive. The Tillamook and Clatsop State Forests are also
surrounded primarily by private land, further augmenting the need to have
strong conservation measures at least equal to those on federal forests.
Q. What is the National Environmental Policy Act and how does it influence this
process?
The National Environmental Policy Act (NEPA) is a federal law that requires the
Fish and Wildlife Service (FWS) and the National Marine Fisheries Service
(NMFS) to consider a range of alternative actions when developing an
HCP. The FWS and NMFS must first determine whether the action may pose a
significant impact. If the action will not pose a significant impact then
there are minimal requirements under NEPA. However, if FWS and NMFS determine
that the proposed action may cause a significant impact, then they will
carefully consider the environmental impacts of a broad range of different
management strategies for the forests in a document called an Environmental
Impact Statement (EIS).
ODF wants FWS and NMFS to determine that the HCP will not pose a significant
impact, thereby obviating the need to undergo a careful analysis of a range of
strategies in an EIS. There is a strong argument that an HCP of this
magnitude, covering so many species for such a long period of time, may pose a
significant impact. FWS and NFS have not yet decided this issue.
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*Clarification-The general theory of Structure Based Management (SBM) is
included within a plan entitled the draft Long Range Northwest State Forest
Management Plan (FMP). The SBM concepts articulated in the FMP will be
incorporated into the Habitat Conservation Plan.
Sample letter to mail and read during oral testimony at the upcoming meetings
Sample letter and guide for oral testimony
John Engbring
Fish and Wildlife Service
510 Desmonde Dr SE, Ste 102
Lacey, WA 98503
Steve Landino
National Marine Fisheries Service
510 Desmonde Dr SE, Ste 103
Lacey, WA 98503
James Brown
Oregon Department of Forestry
2600 State Street
Salem, OR 97310
Dear John Engbring, Steve Landino, and James Brown:
Thank you for the opportunity to submit written and oral testimony regarding
the Western Oregon State Forest Habitat Conservation Plan (WOST HCP). It is
apparent that the Western Oregon Habitat Conservation Plan (WOST HCP) is
currently in its formative stage, there is much that still must be done to
achieve a workable plan. The HCP must encompass enforceable guidelines that
demonstrate a strict set of realistic goals geared to protect fish and
wildlife.
I will now list some key provisions that should be included as you continue to
negotiate terms:
The National Environmental Policy Act
It is imperative that the National Marine Fisheries Service (NMFS) and the Fish
and Wildlife Service (FWS) write an Environmental Impact Statement (EIS) for
the WOST HCP. The project to increase logging in 615,000 acres of selected
state forests will impact approximately 75 species including substantial
marbled murrelet critical habitat, spotted owl sites, six species of salmon,
including the coho, chum and steelhead. It is critical that a full and
accurate range of alternatives is considered before any logging increases take
place on the land.
Structure Based Management
While I hail ODF*s attempt to replicate a natural functioning ecosystem, I am
concerned that this process will not be a *win win* situation for fish and
wildlife. This plan is too vague to offer assurance that it will adequately
and fully protect 75 species for the 50 year duration of the WOST HCP. The
draft long range plan is problematic because, among other things, it will allow
logging on approximately 90% of the selected forests, leave no reserves, set no
specific rotation periods for tree stands beyond those in limited riparian
areas, allow for limited to no road decommissioning, continue large scale
spraying, and offer a funding source that is almost completely dependent on
logging to survive.
Conservation of Public Land
State forests are public lands. The WOST HCP must reflect the public*s desire
that essential fish and wildlife habitat will never be logged for commercial
purposes, so as to preserve the recreational and biological values
of the forest.
Citizen Participation
I welcome the opportunity to comment on the HCP and I am encouraged that you
are currently developing a schedule for regular meetings with key stakeholders
to provide input into plan and that you will design a process for
sharing drafts as soon as they are developed. I also hope that you will infuse
into the HCP a opportunities for the public to monitor and effectively guide
the implementation of the HCP after its approval.
Unlisted Species/ No Surprises
Unlisted species should only be included in the WOST HCP if there is credible
scientific evidence that they will directly benefit from the plan. The current
mechanism of structure-based-management provides no such assurance.
Credible Adaptive Management
The WOST HCP must identify specific adaptive management regimes for every
species it intends to cover. Further, the WOST HCP should remain flexible over
time to allow for the incorporation of future research that discovers improved
management techniques for fish and wildlife covered by the plan.
Consistency with Recovery
The WOST HCP must be part of an overall strategy for recovering species covered
by the plan. The following are two specific conservation proposals that
should be incorporated into the WOST HCP:
a) Sensitive salmon stocks must be restored through a network of reserves
throughout the forest.
b)Essential spotted owl and marbled murrelet habitat must be completely removed
from the timber base.
Cumulative Effects
The WOST HCP must be analyzed in conjunction with the underlying strategy of
management on the surrounding land. Further, ODF must also consider the impact
of the WOST HCP on concurrent land use plans for the affected and
neighboring areas.
Funding
A stable and long term funding source must exist to implement the WOST HCP.
This funding source must not depend exclusively on continued logging as a
primary source of revenue.
Thank you for allowing me the opportunity to comment on the WOST HCP and
surrounding plans. I look forward to working with you again soon.
Sincerely,
You
(Put your name and address)
CC:
Governor John Kitzhaber
State Capitol
Salem, OR 97310
Dr. David Gilbert
Chair, Oregon Board of Forestry
1410 L Avenue
La Grande, OR 97850
**Remember- During the meetings, ODF will sound as if they are already working
in the direction of protecting the forest. Do not let this stop you from
offering oral and/or written testimony explaining that you care about
the strong conservation measures. It is necessary for ODF, NMFS, and FWS to
receive public input from people who care about strong protections while they
are developing their plan.