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18-8

The pertinent Oregon Forest Practice Rule is Oregon Administrative Regulations (OAR) 629-24-203, which involves protection of waterways and open water. The regulation provides that, for aerial applications of 2,4,5-T and silvex only, a 200-foot unsprayed area shall be left between Class I streams and spray application. For other herbicides, the minimum buffer shall be "one swath" in width for aerial applications. Since BLM has discontinued use of both 2,4,5-T and silvex, the BLM buffer widths listed on page 1-15 of the DES appear to be consistent with State requirements. A statement that BLM forest management practices meet or exceed objectives of the statewide water quality management plan has been added to Section 1.5.2.1, State Government, and the Memorandum of Agreement with the State has been further explained.

18-9 Multiple use analysis in the MFP process has resulted in a recommendation of an average 100-foot buffer zone which would provide adequate shade to maintain water temperatures, reasonably maintain the riparian habitat for wildlife and not appreciably diminish the visual setting for recreationists.

18-10 A reference that Bureau minimum standards meet or exceed state rules is included in Section 1.5.2.1 (under State Government). The BLM and USFS, acting jointly, have entered into a Memorandum of Understanding with the State Forester in this regard.

18-11 The economic impacts on the commercial fishing industry are a function of the specific impacts on the habitat of commercial fish species. Since the specific impacts on habitat could not be quantified, neither could the economic impacts. Overall, however, the effects on habitat are expected to be insignificant. The fish habitat on public lands in the JKSYUs can be linked to the generation of a relatively small amount of personal income from commercial fishing (approximately $22,000 annually).

18-12 See response to comment 2-2. There is potential impact from sediment if homeowners downstream from a logging sale withdraw surface water from streams for domestic use. Planned sales in areas of known sediment problems have been identified in Section 3.4.2.1. During site specific project planning, authorized water diversions are identified and the impacts of the project addressed in the Environmental Assessment (Section 1.5.3).

18-13 Table 1-3 shows the classifications from TPCC prior to consideration of
any multiple use conflicts. Conflicts and proposed tradeoffs for high
intensity lands only are explained in Table 1-6 and summarized in Table
1-5. The proposed sustained yield allowable cut was computed on the
resulting base of 258,597 acres as shown in Table 1-1.

Low intensity management lands (47,840 acres) are included in the 92,100
acres shown in Table 1-3 as commercial forest lands excluded from the
base. It is on 4,900 acres of these low intensity lands that a trial
harvest program is proposed to meet the objectives shown in Section
1.2.1.2.

Limited management lands (see Section 1.2.1.2) constitute the remainder of commercial forest land excluded from the base as shown in Table 1-3.

18-14 Detailed site specific TPCC data are available for review in the Medford District office.

18-15 The adjacent Rogue River and Siskiyou National Forests have been underplanting following the regeneration cut of a two-stage shelterwood system for 6 to 7 years with significant success. Limited Medford District experience during the past 3 years shows similar success. Analysis of these data is the basis for the proposed decision to underplant. Final harvest cut of the Shelterwood system would not take place until regeneration is established.

Steep, dry and unstable soil areas would be excluded through TPCC. Only
the higher site areas would be clearcut. It is these areas which have
demonstrated the capability to be successfully replanted after clearcut
harvest. See also response to comments 1-2 and 14-1.

The need for replanting and interplanting 12,200 acres of high intensity land and 1,200 acres of low intensity land is based on three factors: (1) Reforestation success is higher on high intensity lands. Research and experience also indicates a higher rate of success when reforestation efforts are completed promptly after harvest. (2) Any plantation can have areas which do not attain adequate stocking levels throughout and therefore require replanting or interplanting. (3) Some damage or mortality would occur during the shelterwood final harvest cut which constitutes a portion of the 13,400 acres.

18-16 See response to comment 12-4.

18-17 High intensity lands in the 1978 inventory are much more stringently defined and located in place than was the case in 1971 (see response to comment 1-2 for details).

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Therefore we urge you to adopt Alternative 3-A as an immediate
response to meeting need. Studies and experimentation currently
underway should help us all to meet future needs based on the
next ten years experience.

Thank you for your consideration.

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1.) With timberland withdrawals taking place all around us as a result of congressional wilderness designations and RARE II studies; it is discouraging, to day the least, to see BLM plan further land base reductions on this unit. We urge, in the strongest possible terms, the rapid development of the experimental program on the so-called "low intensity management lands" and a most attentive review of the Mason, Bruce and Girard studies relative to land withdrawals which may not be justified under the TPCC process on which they were based.

2.) Industry is so severely impacted now that in testimony on RARE II for Senator Hatfield on July 6th, a local small mill operator (Ron Webb of Webco Lumber) stated that his company is currently hauling logs 250 miles to process. That single example appears to us to indicate that industry has, and is making enormous efforts to maintain their timber handling capabilities in a very unstable setting.

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Executive Department

INTERGOVERNMENTAL RELATIONS DIVISION

ROOM 306, STATE LIBRARY BLDG., SALEM, OREGON 97310

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Thank you for submitting your draft Environmental Impact Statement for State of Oregon review and comment.

Your draft was referred to the appropriate state agencies. The Division-State Lands and Fish and Wildlife offered the enclosed comments which should be addressed in preparation of your final Environmental Impact Statement.

We will expect to receive copies of the final statements as required by Council of Environmental Quality Guidelines.

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If you cannot respond by the above return date, please review date. call to arrange an extension at least one week prior to the

ENVIRONMENTAL IMPACT REVIEW

DRAFT STATEMENT

This project has no significant environmental impact.
The environmental impact is adequately described.

We suggest that the following points be considered in the
preparation of a Final Environmental Impact Statement.

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If you cannot respond by the above return date, please call to arrange an extension at least one week prior to the review date

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We suggest that the following points be considered in the preparation of a Final Environmental Impact Statement.

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The proposed timber management plan discussed in the Draft Environmental Impact Statement (DEIS) appears to be generally acceptable. However , Our field biologists in the area are concerned about some aspects of the statement that could impact fish and wildlife.

The DEIS indicates that with the worst case analysis (page 8-6), a total of 12,945 tons of sediment could be deposited in the streams of the Jackson and Klamath Sustained Yield Units (JKSYUS). The statement recognized that this material could be detrimental to an individual stream, but would be insignificant to the JKSYUs as a whole. We contend that the 20-1 cumulative effect of this sediment could have a significant negative impact on the streams of the entire area.

Approximately 375 miles of new road construction is planned during the 10-year period. Additionally, an estimated 100 miles of road will be reconstructed during the same period. This construction/reconstruction activity could result in higher than anticipated sediment deposition in associated streams. This concern may be especially applicable to areas like the West Fork Evans Creek, which has a history of sedimentation problems. Road construction in these unusually vulnerable areas should be minimized and special logging techniques employed to prevent any additional sediment problems.

The statement should address road closures, particularly on deer and elk winter ranges. Roads within this critical habitat will increase public 20-2 access often resulting in unnecessary harassment of wintering animals. Roads constructed in winter range areas should be eliminated or physically blocked following harvest operations.

The DEIS specifically identifies timber sales that could potentially increase stream sediment loads. Important fishery waters could be negatively impacted by the presence of additional silt. These sales should be reevaluated, modified or eliminated for the protection of the instream habitat.

A significant portion of the JKSYUS is planned for two-stage shelterwood cutting. The standards applied to the size and shape of a clearcut should also apply to this harvest method. Large shelterwood cuts could have the 20-3 same negative impacts on wildlife as a large clearcut. The width of the shelterwood cut should not exceed one-fourth mile. The harvest area boundary should attempt to follow natural contours. The creation of large openings should be avoided, especially on big game winter ranges.

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