Coast Range Association (CRA) submits powerful comments opposing the BLM’s Draft Environmental Impact Statement (DEIS) and Resource Management Plans (RMPs)



Abridged Comments Posted After Message




On August 21st, the CRA submitted powerful comments to the Bureau of Land Management (BLM) putting the agency on notice that draft plans for 2.4 million acres of forest in western Oregon are not legally adequate for the protection of streams, endangered species and portions of the forest providing for healthy watersheds. All federal forest planning unfolds under the National Environmental Policy Act (NEPA). Our comments explain how the agency’s planning process has failed key tests of NEPA adequacy.


The BLM’s Oregon planning effort is the first attempt to revise the Northwest Forest Plan (NWFP). The BLM’s DEIS flatly states they are leaving the NWFP. For twenty years powerful political forces have worked to overturn the NWFP and resume cutting of our last remaining native forests. The threat to native forests and the best remaining watersheds is led by Oregon’s timber industry and their political minions. Ground zero in the fight has been the 2.4 million acres of BLM forest in western Oregon.


The BLM’s 2008 attempt at new management plans went down in flames due to their failure to follow multiple federal laws. In 2014 the Forest Service announced they will begin planning for 19 national forests within the area of the Northwest Forest Plan. How the BLM’s newest planning process plays out will set the stage for Forest Service planning in 2016 and beyond.


As far back as 2001 political forces opposing the NWFP began targeting the Aquatic Conservation Strategy (ACS) portion of the NWFP. It was argued that “new science” warranted drastic changes to the ACS. The subtle, insider attack on the NWFP was accompanied by a larger Fox-News-like echo-chamber campaign created to fool the public into believing the NWFP “wasn’t working”. In truth, the NWFP wasn’t working for big timber and the counties who refuse to assess reasonable property taxes. Yet, what new science had to say about the ACS was not clear at the time.


In 2012 the CRA began to assemble the best aquatic science experts to clarify the science around the ACS. In 2013 we sponsored an Independent Science Review Panel to assess the NWFP ACS. Their science review concluded the ACS could and should be changed for stronger aquatic protections. In 2014 we published the report of the science panel (Frissell et al. 2014) and submitted the report to the BLM as official scoping comments. Today thanks to our work, the best available science has spoken and the message is clear – keep and improve the NWFP Aquatic Conservation Strategy.


Currently, Bob Hughes, former President of the American Fisheries Society, is working to submit the science panel’s report to a peer reviewed science journal. Over the past four months aquatic policy expert Rowan Baker and aquatic scientist Chris Frissell supported CRA’s effort to develop comments on the BLM’s new plans. Their input and
that of other experts went into our comments.


In June of this year I appealed to forest and watershed defenders to support our BLM comment work. Summaries of those comments follow. We sought to raise $10,000 in June for this vital work. To date we have raised $6,500. Our federal aquatics defense fund is exhausted. Please make a generous donation to keep the work going. No other conservation organization is as effective on aquatics as we are.  We can’t let the timber industry collapse the ACS and undermine the NWFP.


If you struggle, like I do, to make ends meet then make a $10 donation. If you are better off - then donate generously at your level of income. Everyone can give something. Here is the link to the CRA’s donation page:

A quick review of the CRA’s comments below will give you a sense of how important our work is for the defense of the last remaining native forests, watershed values and endangered native salmon. Please make a donation today to keep us working on the BLM planning process and upcoming Forest Service planning. The legacy of our public forests must be preserved for future generations.


Best wishes,


Chuck Willer

Executive Director

Coast Range Association




Abridged CRA Comments submitted to the BLM on August 21, 2015.



1.  The RMP DEIS does not take a “hard look” at the impacts of removing all relevant aquatic standards and guidelines linking riparian, key watershed, hydrologic, physical, chemical and biological processes and their management to the nine Aquatic Conservation Strategy (ACS) Objectives and other requirements of the Northwest Forest Plan (NWFP).
There are over one hundred standards and guidelines in the NWFP Record of Decision (ROD) applying to lands within the range of the northern spotted owl that reference and require compliance with the ACS and its Objectives. 

2.  The RMP DEIS fails to accurately describe the No-Action alternative and the full range of protections that the ACS and its standards currently provide in contrast to all action alternatives that remove protections. The No-Action alternative is the only alternative that offers adequate science-based guidance and required Standards to promote maintenance of stream and watershed conditions where they are currently functional, and to promote restoration where they are not.


3. The RMP DEIS does not present the complete array of resource concerns and issues that comprise the Affected Environment. Dispensing with the Affected Environment section for a complex and controversial EIS allows BLM to avoid taking a hard look at degraded landscape conditions, and move quickly into modeling an arbitrary set of select issues.  This flaw is exacerbated by inadequate scoping and inattentive or biased consideration of public scoping comment for determining significant issues “affecting” the human environment. 


4. The RMP DEIS fails to take a hard look and disclose to the public the connected structure and overarching requirements of the NWFP Record of Decision (ROD). Such a hard look must address the ACS objectives, components, and Riparian Reserve Standards which overwrite and enhance provisions of all current RMPs.


5.  Because of items 1-4 above, the RMP DEIS fails two key tests of NEPA adequacy: correctly identifying the No Action alternative and meaningfully evaluating the impacts of each of the action alternatives when compared to those of the no-action alternative (the NWFP).  The selection and comparative weighing of the impacts of alternatives is at the very heart of NEPA.


6. BLM often either claims “no significant impact” or states broadly that impacts cannot be determined at the scale deemed relevant by BLM to the decision scope. But given the scale at which timber harvest and road management will be implemented under proposed plans, and the dramatic departure from existing conservation requirements, it is only possible to assert no significant impact if relevant issues are skirted.




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7.  Regional Administrators of the primary federal agencies involved in the NWFP have not disclosed to the public that the BLM has been found to be cutting numerous corners in implementing the ACS Objectives and protective ACS-related Standards over the past twenty years. The impacts of not fully implementing the ACS provisions in the NWFP have not been addressed in the DEIS. Past and, in many cases, ongoing adverse impacts need to be analyzed along with current impacts of the BLM's misinterpreting and partially following the relevant Standards in the ACS. The failure of the DEIS to account for the BLM’s history of inadequate NWFP ACS implementation results in failing the third major litmus test of an EIS which is an accurate assessment of the NEPA environmental baseline (properly framed: what actually happens now and continues to happen into the future under the no-action scenario). The baseline is an essential starting point to do valid cumulative impacts analysis, which is another critical NEPA requirement.  As such, BLM’s cumulative impacts analysis also fails the litmus test of a “hard look” under NEPA.


8.  The DEIS inadequately addresses current observable climate trends and the potential for further climate change impacts requiring greater aquatic and riparian protections when evaluating impacts of the alternatives, including no-action, both currently and moving forward over time.


9.  The RMP DEIS portrays existing and planned thinning in riparian reserves as having few limits. Yet, commercial timber harvest within RR boundaries is generally prohibited under the no action alternative on West Side forests.  The BLM and USFS are not allowed to count timber volume taken from RRs toward meeting “timber targets” as part of their “programmed” timber outputs.  Said another way, any such volume has to have an ecological not an economic justification. Recent best available science increasingly suggests thinning in Riparian Reserves has multiple effects contrary to ACS objectives.


10.   RMP DEIS ignores a recent, comprehensive scientific review of the ACS (Frissell et al. 2014). The ACS alone, while a significant improvement over past aquatic systems management, is insufficient to avoid lasting and irretrievable damage to fisheries and aquatic ecosystems.  A recent science synthesis supports the conclusion that the ACS needs to be strengthened to remain a viable, conservation strategy in light of newer scientific evidence. New science regarding climate change, cumulative impacts of timber harvest, thinning, extensive ground disturbance, riparian vegetation removal, and road related impacts on adjacent, non-federal lands were all considered.  The entire report (Frissell et. al 2014) is included in these comments as Appendix 5.

11.  RMP DEIS “management objectives”, which apply to all newly revised RMPs, are significantly weaker than the nine Aquatic Conservation Strategy Objectives (See Appendix 3).  No analysis is offered in the DEIS to fully explain how the new management objectives and direction would lead to an adequate protection of aquatic and riparian-dependent resources, or how those management objectives are to be achieved (other than assumed sufficiency of BMPs).  In comparison, the ACS Objectives in the No Action alternative are to be achieved specifically by following the Riparian and Key Watershed Standards and Guidelines of the NWFP which link directly back to the ACS Objectives as well as to the statement
(the statement is in NWFP ROD, Appendix C, hence part of the No Action S&Gs themselves) preceding each of the ACS Objectives that “Lands… will be managed to…[meet the objectives]” and the related S&G requiring managers to support their findings of project level ACS consistency using watershed analysis.  The BLM DEIS has not fully analyzed the impacts of these changes in Management Objectives on streams, waterbodies and fisheries. This should be done in the Final EIS.


Key CRA Finding:  There is no scientific basis or justification for the changes in management objectives and direction from those already contained and well justified in the NWFP/ACS (No Action alternative).  BLM must provide an explicit scientific basis for the changes in management objectives and management direction in the FEIS.


12. All key functions provided by the Riparian Reserves are not analyzed and the existing Sandards and Guidelines for riparian reserves are made less protective with fewer physical, hydrologic and biotic functions mentioned.  This shift toward less holistic treatment of the full suite of functions of RRs needs to be fully analyzed in the FEIS. The BLM DEIS limits its analysis of the numerous functions provided currently by Riparian Reserves to only those BLM chooses to model (principally shade, sediment, peak flows, and large wood).  In doing so, the BLM uses highly questionable assumptions (and in many cases, misinterprets their own cited sources) regarding hydrologic and physical processes and system responses.  A comparison of functions and processes to be examined is in Appendix 3.

13.  Inadequate range of alternatives.  No alternative that would increase RR widths from the current, default delineation of 1-2 site potential tree heights or 100' minimum depending on stream and waterbody type.  There is an inadequate range of alternatives in the DEIS largely as a result of inadequate scoping of issues, and the DEIS limited Purpose and Need statement. (See comment 14 below). The BLM says increased riparian reserves are not needed because the current ACS is doing the job. The BLM cites the interagency Aquatic and Riparian Effectiveness Monitoring Program (AREMP) program saying “Riparian Reserves are improving watershed conditions (Lanigan et al. 2012)”  (DEIS Alternatives, p. 80). That’s like an EMT stabilizing an accident victim at the scene of an accident and declaring “No need for improved medical techniques!” Even worse, the BLM then scraps 60% of the Riparian Reserves in its preferred plan. At this point the BLM has is admitting that the purpose and need in the DEIS is too narrow to allow for science based conservation of wildlife populations (See comment 14, below)


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14.  The BLM has established a Purpose and Need statement that is not based on a full evaluation of existing and foreseeable resource needs and conditions. The “Purpose and Need” statement in the DEIS is biased toward timber outputs, ignores the current ecological status and conservation importance of BLM lands and will perpetuate management failure if it does not consider climate impacts and projections as a contributor to current and future impacts to streams, fish, aquatic systems and water quality.


The Purpose and Need statement misrepresents the current status and trend of BLM lands within the larger landscape that, generally, are dominated by industrial forest owners whose management regime follows financial objectives mandating intense disturbance through short harvest times. Such interspersed private landscapes are depauperate of many forest and aquatic values. The FEIS must correct the above DEIS shortcoming and assess interspersed private landscapes at multiple ecological scales to establish watershed baselines.

The DEIS is premised on an incorrect statement of existing legal requirements, placing the O&C Lands Act of 1937 legally above all other environmental laws – particularly the Clean Water Act and the Endangered Species Act. Such a hierarchy is incorrect and severely limits the development of alternatives that address many pervasive pre-existing and evolving “problems” critical to identify (for ex., through adequate NEPA scoping) and examine in detail:  ESA listings since 1994-5, Clean Water Act 303(d) listed waterbodies and actual and projected climate impacts for this region which include, among other things, decreased summer low flows, increased nighttime and summer stream temperatures, reduced connectivity of streams and wetlands during longer and more intense periods of drought, and loss of snowpack leading to altered hydrologic regimes (not only in current rain-on-snow zones, as BLM asserts (see comment 16, below).


The above flaw also applies to the missing “Affected Environment” section of the DEIS, which, as stated earlier, is how BLM skirts an assessment of on the ground conditions and evolving landscape dynamics related to terrestrial and aquatic conditions.


15.  “New ESA listings” in some chapters of the DEIS are relegated to the future but in fact there have been new species listings since 1994-5.


16.  Biased and incomplete hydrologic modeling and analysis using a hydrologic model the BLM states that “Less than 2 percent of the decision area would be susceptible to peak flow increases over time under any alternative. The No Action alternative and Alternatives A and D would result in slight decreases and Alternatives B and C would result in slight increases in the number of sub-watersheds susceptible to peak flow increases.” (Chapter 3, Hydrology, page 286).


Focusing only on peak flows appears to be based on assumptions that are not scientifically supportable. In fact, many species depend on sufficient flows in late spring and summer, natural pattern and timing of higher flows for attraction and spawning, consistent base flows to maintain habitat extent, or a natural pattern of surface water distribution.  These species require sufficient summer low flows, base flows, and relatively natural temporal and spatial patterns of flows – patterns to which their life histories and movements are often uniquely adapted. (See Appendix 4).


The BLM fails to mention impacts to summer low flows which, combined with increases in drought conditions due to current and projected climate change, is a significant oversight. The BLM must address the impacts of all alternatives on low flows not just peaks. The drying of streams in summer means shallower water leading to both loss of overall habitat extent and to warmer stream temperatures. BLM’s methods of analysis are biased to ensure analyses incapable of detecting environmental and resources responses of BLM’s proposed actions.


The BLM neglects to fully analyze hydrologic and other impacts to intermittent streams which are a large proportion of the total stream miles in many watersheds.  The BLM also fails to fully examine the hydrologic impacts that occur due to ongoing, generally poor identification of intermittent streams. 

What do the findings of Watershed Analyses conducted by BLM tell us about potential responses of watersheds, aquatic ecosystems and riparian sources to the changes proposed by BLM in alternatives of this DEIS? A review of BLM watershed analyses throughout the region (Please see Pacific Rivers Council 2008 comments on BLM WOPR DEIS, and summarized and cited in Frissell et al. 2014) would demonstrate that RR widths have quite often been reduced without basis particularly for intermittent streams and non-fish streams. Whole categories of environmental impact are not addressed or disclosed in this DEIS and need to be fully analyzed in the FEIS (See Frissell et al. 2014).


17.  Outdated and biased LWD analysis. The Large Woody Debris (LWD) Recruitment analysis relies on 2008
modeling and is inconsistent with best available science and with the actual condition of riparian stands, particularly in coastal streams and tributaries in central to northern Oregon. An interagency panel (Spies et al 2013) reviewed current models for LWD delivery to streams within wetter forests, and determined that thinning reduces LWD pieces and volumes entering streams for up to 90+ years. Why aren’t the findings of Spies et al. 2013 considered in the DEIS?  Instead, both many of the technical assumptions underpinning the analyses and the findings of this DEIS that alternatives will not differ in large wood recruitment and delivery to streams appear to be in unexamined and in acute conflict with the findings of the Spies et al. panel (and with much of the literature that panel relied on).


LWD recruitment to riparian and stream habitat will be reduced by at least the following actions, compared to wood recruitment that can be expected from management under current NW Forest (when they are faithfully executed):

I. Halving of the RR boundaries in most cases (an exception perhaps is Alternative D for certain stream types).

II.   Removal of the inner gorge from RR definitions for all action alternatives.

III. Inadequate protection for potentially unstable (landslide prone) slopes that can deliver LWD episodically.

IV.  Inadequate protection and concern for the “channel migration” zone in RR definitions for all action alternatives.



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18. The DEIS lacks a synoptic or overall look at either cumulative watershed impacts or climate impacts.  Cumulative impacts of current management on adjacent non-federal lands, as well as reasonably foreseeable future actions of private, state, and all federal actors are not fully examined. Cumulative effects are defined by regulation (40 CFR Section 1508.7) under the National Environmental Policy Act as:

Reasonably foreseeable impacts of extensive thinning, clearcutting, road construction, post-fire salvage, etc., are not given the “hard look” that NEPA requires. Furthermore, ongoing climate impacts to streams, fish and riparian- and aquatic-dependent resources are not evaluated as part of cumulative impacts. The DEIS must contain a synthetic cumulative impacts and climate impacts analysis. These two lines of evidence must be integrated, using “best available scientific information” on climate projections as well as updated baseline and cumulative impacts of past, present and future management actions. This circles back to the primary defect of the RMP DEIS which is an inadequate portrayal of the current ecological state of affairs. This biased assessment of the status quo also results in a biased Purpose and Need statement, which, in turn, results in an inadequate range of alternatives (see Comments 13 and 14)


19.   Riparian Reserves vs. “managed” large block reserves – a manufactured controversy.

See Appendix 1 for an explanation of how BLM inaccurately portrays RR vs. LSR provisions of Non Action, and hence the current protections on the landscape. It seems unfortunately apparent that the BLM chose to pit fish biologists and owl biologists against one another, rather than seeking a conservation plan that structures BLM actions to benefit both resource sets. The No-Action alternative already provides a carefully measured balance between later successional forest development in LSRs and adequate stream and listed fish protection via the ACS.  If the balance is compromised, as it will be under any of the several Action alternatives, the end result will undermine the upcoming USFS plan revisions process. 

20.  No Environmentally Preferred Alternative. The BLM must create a new action alternative (the “environmentally preferred” alternative) that does not compromise either the ACS or late successional forests – it will resemble the no action alternative, but with improvements to the ACS, as well as improvements in the spatial arrangement and connectivity of later seral forests, to allow for species migrations in light of observed and projected climate changes.



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21. The 2015 DEIS/RMP incorporates by reference the 2008 FEIS and cites pages in 2008 FEIS as a substitute for doing 2015 updated analysis.  Analysis and data from USDI/BLM 2008 is at least 8 years old.  For example DEIS: 221 states: "The 2008 RMP/EIS analyzed potential large wood and small functional wood contribution to streams considering the effects of forest management and stand growth over time in portions of the landscape capable of delivering wood to streams. That analysis is incorporated here by reference (USDI BLM 2008,pp. 779-797)." We assert that any and all comments submitted to BLM during the failed 2008 WOPR process are valid for the purpose of demonstrating flawed analysis in USDI BLM 2008 which is repeatedly referenced to support conclusions in the 2015 DEIS/RMP. 



22.  BLM inappropriately used the Aquatic Resource Evaluation Monitoring Program (AREMP) 20 Year Report conclusions. The DEIS states that “[m]monitoring results conclude that the ecological condition of approximately two-thirds of the watersheds in the Northwest Forest Plan area have improved in condition in the past two decades.”  (DEIS, page 233). AREMP results can only make broad, coarse scale inferences about the general condition of watersheds (HUCs) or basins where there is > 25% federal ownership. Watersheds primarily at the boundaries of federal ownership and/or where BLM checkerboard lands coexist with mostly non-federal land would be underrepresented or simply not represented by the AREMP monitoring data.  In any event it is questionable whether AREMP results, which are FS land-base-centric, apply to all BLM land ownerships within the planning area.  Moreover, as all BLM action alternatives remove ACS protections and therefore the BLM cannot claim that any improving trends in watershed conditions, even if real, will continue as the improving trend depends on full ACS implementation moving forward.


23.  In the past, the BLM has repeatedly deviated from the explicit requirements and essential components of its plans. In particular, the BLM never faithfully implemented many interrelated aspects of the ACS Standards and Guidelines. In all the action alternatives, these features are removed, thus formalizing BLM’s current inadequate aquatic and riparian management regime. The action alternatives essentially institutionalize current BLM management in violation of NWFP Standards, Guidelines and overall provisions of the NWFP Record of Decision.


24.  The best available science indicates that individual watersheds may vary in their conditions, capability and functions. The no-action alternative is the only alternative in the DEIS that includes watershed analysis and is the only one that can address individual watershed conditions, capability and functions. The BLM has repeatedly ignored its own watershed analysis findings when proceeding with timber sale and road management projects. The no action alternative, if executed with fidelity to rule, is the only alternative that would potentially incorporate and respond to the wealth of science based information contained in watershed analysis documents that is needed to meet all relevant ecological conditions specified in the ACS Objectives. 


25.  Overreliance on “Best management Practices” (BMPs). Chapter 3, Appendix “I” of the BLM DEIS is devoted to roughly 36 pages of BMPs.  BMPs are a form of mitigation for damages, not protection. Furthermore, the BLM DEIS’s extensive list of mitigation measures is evidence that the risks from cumulative mitigation failure are potentially very large. Rashin et al. (2006) evaluated similar timber harvest BMPs in Washington State and determined that the effectiveness of BMPs declined as a function of distance from streams. In their study, two of the primary operational factors influencing BMP effectiveness were the proximity of ground disturbing activities to streams and the presence or absence of designated stream buffers.


26.  The BLM has chosen to bypass or avoid independent peer review of the scientific information contained in the DEIS. All models and scientific assessments contained in the DEIS should undergo independent scientific peer review to identify and remedy flaws in BLM’s use of science - particularly in the design and parameterization or models and interpretation of results.


27.  ACECs – Areas of Critical Environmental Concern. Concurrent with the comment period for this DEIS, the BLM is seeking comments and recommendations from the public on “Areas of Critical Environmental Concern” (ACECs). This construct is a regressive (non holistic) approach to limiting environmental protections to small geographic areas. BLM plan options remove science-based protections across large landscapes such that the ACECs appear reasonable. However, by not analyzing the net loss of ecological protections the BLM is being disingenuous to the public. NEPA requires a hard look at impacts, accurate comparison of alternatives, and full disclosure to the public of any impacts to the human environment. The DEIS fails on all counts. Limited delineation of ACECs is not helpful or responsible.


28. Timber Harvest Practices. The DEIS fails to disclose in a side by side comparison table the range of mandated clear-cut acres in each alternative and sub-alternative. For example, while the No Action NW Forest Plan allows clear cutting, it does not mandate a prescribed amount to cut as is the case for each action alternative.


The DEIS:79 states “The BLM has eliminated from detailed analysis the continuation of the current practices as an action alternative, because it would not be a reasonable alternative, in that it would not provide for a sustained yield of timber over the long term.” We disagree with the logic of this statement. First, the DEIS is biased because it fails to cite compelling data from (USDI 2012) and data through 2014 that BLM has been selling the majority of its timber volume since 2000 by way of thinning.

In fact, the issue of timber harvest is not one of sustainability but of annual volume, timber sale net revenue and log type harvested. Any number of thinning harvest regimes could support a huge annual output of timber from 2.4 million acres. The BLM’s actual goal is an absolute volume of a certain type of saw log harvested in a certain way. Oregon’s political leaders have been clear what their demands on the BLM are: Larger saw timber (30” to 40” dbh) highly desired by Oregon’s mills and harvested by way of clearcutting to maximize net revenue distributions to county governments. All of which is a statement of political economy – the real driver behind BLM Purpose and Need for new plans.


The DEIS is flawed because it failed to provide analysis of how much longer BLM can continue timber sales using thinning. Is it five years or ten years or fifty years? This analysis would appear to be an overriding consideration for a NEPA analysis in this EIS/RMP process. NEPA analysis is needed to properly inform the public and decision makers about the potential role of thinning to provide timber volume in the short term and long term (100 years).



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29. The RMP/DEIS violates the NEPA, ESA, FLPMA and CWA because it:
1) fails to provide spatially explicit mapping of coho critical habitat;
2) fails to establish or report baseline stream quality data (e.g. stream temperature trend, stream shade, large instream wood, sediment, road densities,  nutrients, toxics) for specific critical habitat streams, BLM critical habitat stream reaches and watersheds;
3) fails to adequately identify numeric standards for stream temperature, stream shade, large instream wood, sediment and road densities;
4) fails to identify required and discretionary techniques to achieve measurable progress towards quantitative standards for important habitat criteria including but not limited to stream shade, stream temperature, large instream wood, and sediment; 
5) fails to identify a time table for meeting or making measurable progress towards achieving quantitative standards; and
6) fails to coordinate with ODFW and ODEQ to develop a schedule for monitoring physical and biological parameters in Coho critical habitat to demonstrate trend from existing baselines.


29.1 Critical Habitat of ESA Listed Fishes. The RMP/DEIS failed to map the linear extent of critical habitat for federally listed fishes (DEIS 288) and more importantly failed to include an action alternative with a 2 site tree width (each side of stream) for the protection and enhancement of critical habitat designated for  threatened and endangered salmonid fish species. This means that critical stream habitat for salmonid fishes would have a 2 tree width while other streams with unlisted fishes could have lesser protection. 


The National Marine Fisheries Service identifies several benefits of critical habitat (64FR24050):


The National Marine Fisheries Service (NMFS) discusses “Adjacent Riparian Zones” in the designation of critical habitat for SONCC coho 86FR24053-55. The NMFS states that “On Federal lands within the range of the northern spotted owl, Federal agencies should continue to rely on the Aquatic Conservation Strategy of the NFP to guide their consultations with NMFS.” (64FR24055) Previous section 7 consultation has found the Northwest Forest Plan two tree width riparian reserve (each side) adequate for protecting listed species on federal lands. These facts support the continuation of a 2 site tree width riparian reserve for critical salmonid habitat. 

We provide additional science based analysis to support two tree riparian reserves for critical stream habitat.


Channel Migration and Conservation of Lateral or “Off-channel” Critical Habitat

The RMP/DEIS 219-230 asserts that there is no difference in effects between a one-tree-height riparian buffer width (action alternatives) and a two-tree-height riparian buffer width (no action alternative) for shade and large wood recruitment for salmonids. This narrow analysis of two parameters utterly and inexplicably fails to consider all attributes of critical habitat and the dynamic nature of streams over the 100 year period of modeling. The fundamental assumption of the DEIS modeling conclusions, that streams will remain within the middle of the riparian buffer, is known to be false. The modeling conclusions that there is no difference between a one-tree-height and two-tree-height tree riparian reserve are not based on the best available science.  For example, the 64FR24053 states: “Streams and stream functioning are inextricably linked to adjacent riparian and upland (or upslope) areas.  Streams regularly submerge portions of the riparian zone via floods and channel migration, and portions of the riparian zone may contain off-channel rearing habitats used by juvenile salmonids, especially during periods of high flow.” (emphasis added).  

The 64FR:24061 states “Critical habitat consists of the water, substrate, and adjacent riparian zone of estuarine and riverine reaches (including off-channel habitats)…”  (emphasis added).  Off channel habitats can be abandoned channels, beaver ponds, and overflow winter channels.  These critical habitats are often located more than 1 tree height from the summer low flow channel which will receive the “no cut” inner riparian buffer. More importantly these off-channel critical habitats will develop over time in unpredictable locations due to natural channel shifts over a 100 year period. The 1964 flood moved many stream channels hundreds of feet (e.g. Sucker Creek trib to East Fork Illinois River). This magnitude of change is within the range of natural variability and can be expected in the future 100 years.

29.2 Timber Harvest Activity: Sediment Impacts to Designated Critical Stream Habitat. The DEIS fails to take a hard look at the differences in potential logging sediment delivery to critical stream habitat from a 1 tree riparian reserve versus 2 tree riparian reserve. The 64FR24054 states:  “Human activities in the adjacent riparian zone, or in upslope areas, can harm stream function and can harm salmonids, both directly and indirectly, by interfering with the watershed functions described here. For example, timber harvest, road-building, grazing, cultivation, and other activities can increase sediment, destabilize banks, reduce organic litter and woody debris, increase water temperatures, simplify stream channels, and increase peak flows.”  (Emphasis added).

The DEIS failed to adequately consider that logging will occur on very steep slopes where shallow debris slides will penetrate and pass sediment  through the narrow uncut riparian reserve and logging related sediment will enter streams. The DEIS fails to disclose that new roads,  reconstructed roads, and temporary roads on steep slopes would be much less likely to deliver sediment to critical habitat streams when these roads are located 2 tree heights away from stream channels as is the current management policy with the ACS.  


29.3 Nutrient Impacts to Designated Critical Stream Habitat. Similarly, the DEIS fails to take a hard look at the differences in potential harmful nutrient enrichment to critical habitat streams from a 1 tree riparian reserve versus 2 tree riparian reserve. A 2 tree riparian reserve would far more effective in filtering out excess phosphorus and nitrogen.  (See Frissell et al. 2014:17) 


29.4 Benefits of Two-tree-height Riparian Reserves for Listed Terrestrial Species, Proposed for Listing Species, USFWS Species of Concern, and Beaver, a Keystone Species for Critical Habitat. Adoption of a two-tree-height riparian reserve width is supported, not contradicted, with the known ecological benefits to other listed species, proposed for listing species, USFWS species of concern and beaver. The DEIS/RMP failed to take a holistic multi-species perspective with proposed riparian reserve widths in action alternatives. The 64FR 24054 states: “[i]nterim riparian reserve recommendations in the FEMAT report were based on a systematic review of the available literature, primarily for forested habitats, concerning riparian processes as a function of distance from stream channels. The interim riparian reserves identified in the FEMAT report for fish-bearing streams on Federal forest lands are intended to (1) provide protection to salmonids, as well as riparian-dependent and associated species, through the protection of riparian processes that influence stream function, and (2) provide a high level of fish habitat and riparian protection until site-specific watershed and project analyses can be completed.  (Emphasis added). 



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Appendix 1: The BLM and the RMP DEIS currently uses the wrong land allocation hierarchy of standards and guidelines in the NWFP ROD.  Note:  This has been a tactic both FS and BLM have been using for years, allowing them to actively manage RR acreage within LSRs as if the other ACS related standards and guidelines for Riparian Reserves did not apply.  In reality RR S&Gs as well as LSR S&Gs apply.


Appendix 2. The BLM merges the “Affected Environment” section of a typical EIS out of existence which allows them to narrowly identify only those aspects of the environment that they want to analyze.

Appendix 3. Comparison of ACS Objectives (No Action) with Management Objectives (Action alternatives):


Appendix 4. Hydrologic Impacts was Adapted from an earlier unpublished and unwanted (scuttled by the agencies) hydrology whitepaper, with only the relevant (coastal basins) information included.


Appendix 5.  The CRA submitted the entire text of CONSERVATION OF AQUATICAND FISHERY RESOURCES IN THE PACIFIC NORTHWEST:  Implications of New Science for the Aquatic Conservation Strategy of the Northwest Forest Plan.

Frissell, Christopher A.

Baker, Rowan. J.

DellaSala, Dominick A.

Hughes, Robert M.

Karr, James R.

McCullough, Dale A.

Nawa, Richard. K.

Rhodes, Jon

Scurlock, Mary C.

Wissmar, Robert C.

FINAL REPORT - July 30, 2014 published by the Coast Range Association.