The draft simply asserts that the

"net effects [of these two methods] on stand establishment,

if further information showed SIMIX to be a valid
here would still be difficulties in relying on its
n of an allowable cut. On page 1-21 it is stated
iter model determines the largest allowable cut
forty decade projection period. "Age class
est stands, annual wood growth, wood volume
rtain treatments are also determined for each
"This means that in order for the projected
occur, foresters must locate every area of

every condition and age class used in the program, and actually
carry out the proposed treatment on those specific lands according
to schedule.

Owing to the fact that there may not be an in-place
inventory of forest resources, the probability of being able to
Without
carry out the program in this detail is very small.
allowances for failure to do all the thinning and fertilizing
d in the program in complete detail, the allowable cut

12-9 |

-9

to the Management Framework Plan and to various other documents
and procedures underlying the draft timber management plan but
none are explained in sufficient detail to allow meaningful
public participation as required by NEPA. The proposed plan
itself is described in generalities and does not give complete
information as to specific actions that will be taken, the
locations for implementing these actions, or the sequence of

events.

The FES must make clear how the lands were inventoried,
how allowable cut was calculated, how benefits of intensive
management were qualified, and so on. The draft is woefully
lacking in all these respects. The public cannot effectively
comment upon such a document but is expected, it seems, to accept
it on faith.

II.

The Draft's Discussion of Mitigation Measures Is Wholly
Inadequate

Chapter 4, "Mitigation Measures Not Included in the Proposed
Action," consists of this sentence:

"With present technology, impacts identified
in Chapter 3 are not mitigatable beyond
those levels included in the proposal and
described in Section 1.3 as project design
features."

This is to say that there are no possible mitigation measures
that could be taken that have not been taken as "project design
This is patently absurd.

features."

The discussion of a wide range of mitigation measures is
ial for compliance with NEPA. Baldly asserting that the
11 the mitigation possible hardly meets

12-16

DES that wherever commercial forest

cut base.
public lands, it has been routinely included in t..

In light of BLM's restrictive interpretation of the
O&C Act as a near total restraint on management of O&C lands
for anything but timber, the opportunity to use so-called high
intensity management lands on non-O&C lands for purposes other
than timber should be carefully examined as a means of counter-
balancing the primary-use management of O&C lands.
silent on this point.
The DES is

The final three alternatives that are offered, Alternatives

12-17 3, 4, and 5, are all unrealistic as each would violate the

policies of sustained yield and even flow which govern BLM's

states that "[t]he Josephine and the

Jal

the first [units] to which the new policy [of temp
increases] will be applied.' "New Timber Policy Announced by
Andrus," BLM News Clips, July, 1979, p. 3.

We feel it is essential to point out that FLPMA (43 U.S.c.

SS 1701 et seq.) and the O&C Lands Act (43 U.S.C. §§ 1181a et seq.)

9-27

-12

told at page 3-38: "It is possible that impacts on fish and other aquatic life could be significantly harmful in some local

DES

sites in a worst case situation. Lacking site specific
information, these local instances are impossible to predict."
Essentially the same dodge is taken in discussing otters.
P. 3-41.
How can the DES on the proposed plan be said to have
considered adequately the impacts of that plan when, by its own
admission, not enough information has been collected to identify
what impacts will occur or where? To answer that these impacts
will be dealt with in environmental assessments later is not
a proper response. It is this proposed timber plan which sets
a certain cut for a certain number of acres which will lead to
these adverse impacts. They must be fully examined before a
decision is made on the final plan, not put off to later site
assessments which will not attract public attention and which
may be useless once an overall plan is approved. The site-
specific adverse impacts identified at that time may well be iden-
tified as insignificant or, at any rate, unavoidable since the
already approved plan mandates harvest of the site.

Finally, the impacts section fails to look at the cumulative
effects of BLM's proposed actions in the JKSYU with those of
private landowners and other government agencies operating in
the same area or at the cumulative effects of BLM's various
proposed actions considered together. As to the first, for
example, the DES should examine the effects of its proposed
action on air quality (through burning) and water quality

12-13

12-14

-13

(through sedimentation) in light of similar effects from

neighboring actions by others. The draft should also pull
together the impacts on various forest values of all proposed
activities to present a picture of the overall impact of the
proposed action on the JKSYU. Assessment of cumulative impacts

is essential to rational decision making as to the form the
overall plan should take.

IV.

The DES Fails to Consider an Adequate Range of Feasible
Alternatives

The draft is faulty in that three of the five alternatives
examined are not feasible and in that it does not examine several
important options which should be considered. The discussion
of alternatives would also be made much more relevant to the
reviewer if the various impacts of each alternative were explicitly
compared to those for the proposed action (to which these are
alternative) in addition to the present situation.

Alternatives 1 and 2 are feasible, for they both present
approaches compatible with the legal requirements upon BLM to
manage for sustained yield. However, they appear somewhat
unlikely to be chosen by BLM over the proposed action because
they result in smaller yields than it does.

We believe the BLM should examine alternatives which would
12-15 produce substantially the same cut as the proposed action but
1/
which would use different management activities. For example,

1/ We are, of course, assuming in this statement a proposed
action in which the cut is properly set at a true sustained
yield level. For our doubts as to whether this is the case with
the current proposed action, see Part I, above.

12-15

12-16

-14

an alternative more likely to be accepted than Alternative 1

would be one which, like 1, dispensed with broad-scale use of
herbicides, but used site-specific labor intensive and other
methods to control competing vegetation where appropriate.
Such an approach might result in an equivalent yield to the
proposed action while eliminating the harmful impacts of herb-
icides and supporting the local economy.

Another alternative which must be examined is one which
truly provides for the multiple use of the twelve percent
of the JKSYU lands which are not O&C Lands. Regardless of
what the law requires of management of O&C lands, regular
public domain lands within the JKSYU must be managed for multiple
uses under FLPMA. See 43 U.S.C. 1701 (a) (7).

Yet it appears from the text and a map included with the
DES that wherever commercial forest land is present on non-O&C
public lands, it has been routinely included in the allowable
cut base. In light of BLM's restrictive interpretation of the
O&C Act as a near total restraint on management of O&C lands
for anything but timber, the opportunity to use so-called high
intensity management lands on non-O&C lands for purposes other
than timber should be carefully examined as a means of counter-
balancing the primary-use management of O&C lands. The DES is
silent on this point.

The final three alternatives that are offered, Alternatives
12-17 3, 4, and 5, are all unrealistic as each would violate the
policies of sustained yield and even flow which govern BLM's

12-17

-15

management of its timber lands. Alternative 5 is even more
clearly unrealistic as it is the very management system (the
present situation) which is discredited by the DES. While one
such alternative of the sort represented by these three might
be useful for comparison's sake, it is not sound analysis to
pose as a majority of the proffered alternatives ones which cannot
and should not be implemented. The DES should present several
more reasonable and practicable alternatives in place of these
illegal and unsound proposals.

V.

The Final Plan Cannot Legally Increase the Allowable Cut
above a Level That Can Be Sustained

The DES gives no indication (as it could not, having been
prepared before the fact) of the BLM's reaction to the announce-
ment of Alfred Kahn on June 11, 1979, that the Administration
desires temporary departures from sustained yield levels of
timber harvest on all federal timber lands to combat inflation
We fear that this announcement will cause
in housing costs.
harvests to be conducted on the JKSYU and other BLM sustained
yield units far larger than can be sustained over time.

Indeed,

a short article in the most recent BLM News Clips specifically
states that "[t]he Josephine and the Jackson-Klamath will be
the first [units] to which the new policy [of temporary annual
increases] will be applied." "New Timber Policy Announced by
Andrus," BLM News Clips, July, 1979, p. 3.

We feel it is essential to point out that FLPMA (43 U.S.C.
SS 1701 et seq.) and the O&C Lands Act (43 U.S.C. SS 1181a et seq.)

-16

both mandate harvest of timber on a sustained yield basis.
Unlike the National Forest Management Act (16 U.S.C. SS 1600
et seq.) which governs the Forest Service's setting of harvest
levels from the National Forest System, neither FLPMA nor the
O&C Act allow departures from sustained yield levels of harvest
for any reason. Under the dictates of these laws, any harvest
proposed in the JKSYU FES must be sustainable indefinitely.

VI.

Conclusion

The Jackson-Klamath Sustained Yield Units Draft Environ-
mental Statement is inadequate for a variety of reasons. It
fails to give adequate information to enable the reviewer to
assess the validity of the actions it proposes or even to know
what, precisely, the timber management plan is and how it relates
to an equally ill-defined management framework plan. Discussion
of mitigation measures is so brief as to be almost nonexistent.
Impacts of the proposed action are neither as clear nor as
thorough as NEPA requires. Finally, the discussion of alterna-
tives is focused too much upon alternatives which are not
feasible and too little upon realistic alternatives to the
management assumptions of the proposed action. NRDC strongly
urges BLM to correct these critical deficiencies in its prepar-
ation of the final statement.

Response to comments in Letter 12

12-1 The methodology incorporated in the various inventories is much too
lengthy and detailed to be included in an environmental statement. A
complete description of inventory procedures used, along with an explan-
ation of how their reliability is measured, is available in the Oregon
State or District offices in western Oregon.

Of the three types of timber inventory employed in development of the
proposal (see Sections 1.2.1, 1.2.2 and 1.2.3), only the reinventory,
which utilized measured plots, can be statistically analyzed for relia-
bility. Section 1.2.3 has been expanded to show that the sample is
within 7 percent of true mean volume at one standard deviation.

See response to comment 1-3

While the trial harvest program proposed for the JKSYUs may involve
some treatments and approaches duplicated in the Josephine SYU, an
additional variety of experimental opportunities are provided in the
Jackson and Klamath SYUS. Taken together, the three SYUS should provide
examples of areas exhibiting most southwest Oregon timber management
problems for research under the FIR program discussed in Section 1.4.2.
See also response to comment 1-2.

The following summary is provided to explain how increases in allowable
cut which result from various intensive management practices, as shown
in Table 1-7, were derived.

A BLM young-growth management committee was formed for the JKSYUs in
July 1977. After analyzing technically feasible management practices,
the committee made economic feasibility studies of these practices.

Yield projections for those practices having a benefit/cost ratio
exceeding 1:1, when assuming full benefit of allowable cut effect,
were then derived using the USFS Douglas-fir Interim Tables (D.F.I.T.)
Stand Simulator Program (Bruce et al. 1977). This program incorporates
the lastest available research information regarding yields attributable
to the various intensive management practices.

The committee then developed managed stand yield tables. Management
practices considered in preparing the yield tables were precommer-
cial thinning, commercial thinning and fertilization.

Further discussion of impacts to non-target vegetation has been added to
the text in Section 3.5.1.4.

At

Potential benefits from nitrogen-fixing species is recognized.
present, definitive data on optimum densities, in relation to conifers,
magnitude of benefits, etc., for species found in the JKSYUs are not
available, but studies are in progress. At such time as data are
available which identify favorable relationships, full consideration
will be given to the use of nurse crops in forest management programs.