BMFPR issues
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1. Issue
1.1. supporting information
a) sub-sect of supporting information
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1. The BMFPR does not represent my “desired condition” for how I gather natural resources from the Blue Mountains currently, how I access those resources, or how future generations of my family will access those resources.
2. This plan as written, and all proposed alternatives other than Alternative A are restricted motorized access alternatives that do not meet mine, or the majority of the local resident needs or desires.
3. The “Designated Route” language found throughout all alternatives needs to be stricken from the document as it serves no purpose to address the needs or desires of the people of Eastern Oregon and has a negative impact on the resiliency of the communities of Eastern Oregon.
4. The plan in its current form is confusing, unclear as to final objectives, other than a desire to close the majority of the forest to motorized use, and needs to be condensed into a more understandable format that the common man or woman can understand.
5. The BMFPR is unclear as to what I am commenting on, one forest plan revision or 3, possibly 4 individual forest plan revisions at the same time.
5.1. “For the purposes of commenting on the draft forest plans, the three forest plans have been consolidated into one document. For the most part the plans for each national forest have the same plan components, where there are differences these distinctions are identified.”
5.2. Pg 1 Proposed Plan
6. The BMFPR does not clearly define what “restoration threshold” is attempting to be reached.
6.1. Pg 1 Proposed Plan
6.2. http://www.landfire.gov/NationalProductDescriptions20.php
6.3. It is not realistic that to plan a forest plan to “pre Euro-American settlement” when 100,000 plus people in habit the area, and 3.5 million live within a day’s drive.
7. The BMFPR states it plans for the “future needs.”
7.1. Pg 1 Proposed Plan
7.2. The BMFPR supplies no survey data of what the “needs” of future generations are, what type, quantities, quality or resources are need, nor does it state where this type of need was generated from.
8. “The National Environmental Policy Act (NEPA) of 1969 requires that all major Federal actions significantly affecting the human environment be analyzed, and the consequences to the quality of the human environment from proposed management actions are to be considered.”
8.1. Pg 2 Proposed Plan
8.2. The BMFPR show’s a heavy analysis of ecological/environmental concerns and how human interaction affects nature both flora and fauna, as well as “cultural resources” sites.
8.3. The primary objective of NEPA is to protect the “human environment” and to analyze federal actions on human beings not the effects of human beings on the environment.
8.4. There is no analysis of specific effects on rural communities from a financial stand point, no analysis of effects on local governments’ ability to protect their resident’s safety and welfare.
9. Effects on local residents and communities should be the primary decision making criteria of which alternative ultimately will be selected, the below “Decision Criteria” show what criteria will be used to select the final alternative.
9.1. Pg 4 Proposed Plan
10. None of the Proposed Plan alternatives meet the “desired condition” of the local residents of Eastern Oregon.
10.1. Pg 2 Proposed Plan
11. Social and economic expectations does not reflect the affect local resident’s expectations, but is only a general statement about conflict.
11.1. Pg 15 Proposed Plan
11.2. Social and Economic expectations of local residents revolves around more than “recreational” use of our public lands and this plan does not clearly define nor recognize the social and economic needs of the local residents.
12. The BMFPR references motorized and non-motorized use conflicts.
12.1. Pg 15 Proposed Plan
12.2. These claims are not supported by the 2009 Travel Use Study. In all categories the USFS exceeded their management objective and in all by one category exceeded 80% satisfaction with the forest and in several were 90 to 100% satisfied.
13. The BMFPR references an increase of invasive weeds caused by roads.
13.1. Pg 16 Proposed Plan
13.2. Roads do not “spread weeds” they may be a corridor to weeds spreading, but are not a “cause” of weeding spreading and removal for roads, or eliminating motorized access will not eliminate roads spreading weeds.
13.3. The plan fails to recognize in any substantial manner the lack of active weed management on the 3 national forest, or the general lack of on the ground treatment to address the growing problem.
13.4. The plan fails to recognize the key components that wildlife, waterways and wind patterns play in the spread of noxious weeds, or does it call for the removal of wildlife, streams or the wind from our national forest, as it does removal of motorized access from public lands.
14. The BMFPR states that roads render wildlife areas unusable.
14.1. Pg 16 Proposed Plan
14.2. In 1912 Elk were in such short supply from overhunting that a reintroduction campaign was initiated in Wallowa County to assist in bring herds back to sustainable population, from 1912 through the 1970’s miles or roads increased exponentially on the landscape as did the populations of Elk and Mule Deer in the region.
14.3. There is not proven scientific study that shows that “roads render wildlife areas unusable.”
14.4. The Ladd Marsh Wildlife Area between La Grande Oregon and Union Oregon is completely surrounded by roads, those being Interstate 84, Highway 203 and Foothill Rd., all high traffic roads and Ladd Marsh is considered one of the gems of the Oregon Department of Fish and Wildlife’s “Wildlife Management Areas.”
15. The BMFPR uses “assumptions and potential effects” to make social decisions that affect basic human rights to engage in traditional cultural uses.
15.1. Climate Change Discussion Pg 19 Proposed Plan
15.2. No authority has been given to make those decisions for individuals.
15.3. “models and assumptions” are heavily used instead of “best available science” from all areas of land use and instead heavily rely one-sided science that is known to be flawed and highly subjective.
16. The BMFPR uses does not define “Key Watersheds.” Well enough in Lameman’s terms for the general public to truly understand their location, what management criteria will be put into place, or how additional management restrictions will affect their day to day use of those areas.
16.1. Pg 22 Proposed Plan
16.2. The vagueness of the BMFPR does not allow for the general public to fully understand what target goals are being agreed to, and how those goals will affect their use of public lands.
17. The BMFPR states “Native fish species have access to historically occupied aquatic habitats and connectivity between habitats allows for the interaction of local populations.”
17.1. Pg 29 Proposed Plan
17.2. While this altruistically improves habitat for fish species, does not fully examine the effect on the “human environment” that NEPA requires the USFS to manage for.
17.3. The purpose of a Forest Management Plan is to manage for the human component and use of public lands.
17.4. No full assessment is found of how improving connectivity between habitats will directly and disproportionally effect local residents or lesser economic means from gathering supplemental foods and heat for their families.
18. The use of the term “anthropogenic” should not be found in this document or all human interaction in the National Forest should be removed
18.1. Pg 29/30 Proposed Plan
18.2. The term Anthropogenic is a term used to describe negative human impacts on the environment.
19. The BMFPR does not spell out what the “Regional Foresters sensitive species” are, where the authority is delegated from to make such designations, what regulatory authority that designation carries, or what corrective actions are authorized to affect change on designated species under this authority.
19.1. Pg 30 Proposed Plan
19.2. Under the Endangered Species Act federal agencies are granted certain authorities to protect species, however no such authorities are spelled out in the BMFPR for the Regional Forester.
19.3. No assessment is found of decision criteria is given as to how those special designations would affect the human environment of the local residents or visitors to the Blue Mountains.
20. The BMFPR describes human activity as a strictly negative activity in the “disturbance processes” of the proposed plan.
20.1. Pg 32/33 Proposed Plan
20.2. Human activity described only in a negative fashion garners a supporting position that people must be more heavily regulated.
20.3. This description does not reflect the current use of the Blue Mountains, nor does the description reflect the local communities desire to have an open access forest.
21. OHV use is being targeted as negatively affecting “the soils”.
21.1. Pg 43 Proposed Plan
21.2. The BMFPR does not specifically document how OHV is negatively affecting “the soil.”
21.3. A very small percentage of the actual soils of the Blue Mountains is directly affected by any motorized use, and of that a considerable less area is “negatively impacted by motorized use.
21.4. Erosion is not a “soil quality” issue, and as such should not be discussed as a “negative” factor in this plan revision, as it is a natural process.
22. The BMFPR does not adequately describe soil erosions rates and sediment depositions or what the management objective is.
22.1. Pg 43 Proposed Plan
22.2. Surface erosion rates and sediment deposition are within the natural range of variability for each biophysical setting.” Is this using the “landfire” model? Which vegetative type do you compute the erosion rates and sediment for, post historic fire, climax community or mid-serial, after a natural event (disease, microburst, etc).
23. The BMFPR does not correctly reflect the “primary designated beneficial use of water” and does not meet its intended objective of managing for the human environment.
23.1. Pg 44 Proposed Plan
23.2. “Existing Condition: The primary designated beneficial use of water on National Forest System lands in the Blue Mountains is for cold-water fish habitat.” This designation of the “existing condition”
23.3. The people of Eastern Oregon do not utilize the water of the Blue Mountains primarily for Cold-Water Fish habitat. The primary uses of the waters coming from the Blue Mountains are municipal water, irrigation, power generation, and recreation.
23.4. The waters coming from the Blue Mountains are first and for most for the people of Eastern Oregon, and as such should be managed as such. Any calling for water prior to human use is not acceptable and should not be found in a landscape document such as this.
24. The BMFPR creates a hostile and confrontational stance between human use and “historical ecological conditions” that leads public employees with only one recourse for action and that is to remove humans from the ecology to reach historic conditions.
24.1. Pg 44 Proposed Plan
24.2. “Issues of landscape fragmentation and patch connectivity are a concern in conservation biology (Forman and Godron 1986) – statement of opinion, not of scientific fact. Hann et al. (1998) found that when land use, ecosystem health, and species diversity are out of balance with inherent disturbance processes and biophysical capabilities, the landscape ecosystem tends toward unbalance. Hemstrom et al. (2001) concluded that past types and levels of human use have caused extensive changes and have run counter to the historical ecological conditions.”
24.3. The Forest Plan is hostile towards human use, and attempts to manage towards a “historical ecological condition” where human population densities were substantially lower.
25. The BMFPR claims decreases in large snags are attributed to “roaded areas”
25.1. Pg 48 Proposed Plan
25.2. The BMFPR currently identifies “roaded areas” as being an issue for decreased snag densities. The plan fails to give current snag densities across the entire forest.
26. The BMFPR Social Well-being memorializes nature’s well-being over the Social Well-being of local communities and residents and leaves out subsistence use of the forest as a side note instead of the cornerstone of local communities and residents lives.
26.1. Pg 50 Proposed Plan
26.2. The BMFPR currently identifies Social Well-being as “A diverse and complex set of values that contribute to one’s social well-being can be tied to natural resources-related work, including restoration, ranching, and recreation”
26.3. It fails to articulate the importance of subsistence use as a primary driver in our communities ability to Socially well off.
26.4. “These values may include viewing or hunting wildlife, being able to do natural resource-related work, knowing that restoration efforts are supporting fish populations, and being part of an environment where human traditions and cultures can be maintained.”
26.5. quoted from pg 2 – “The National Environmental Policy Act (NEPA) of 1969 requires that all major Federal actions significantly affecting the human environment be analyzed, and the consequences to the quality of the human environment from proposed management actions are to be considered.”
27. The BMFPR does not supply a full enough break of areas found in each scenic class.
27.1. Pg 52 Proposed Plan
27.2. The BMFPR currently does not delineate all areas found in each scenic class so that the public can comment on the appropriateness of the designated scenic class.
28. The BMFPR identifies throughout the document but namely on Pg 54 of the Proposed Plan that reducing road densities is a preferable option and a desired condition of the local residents, which is not the case.
28.1. Pg 54 of the Proposed Plan
28.2. The BMFPR currently identifies 80% of the users frequently use motor vehicles to access the national forest.
28.3. The plan assumes a higher disproportionate use of adult aged people 18 years and older, while minimizing youth usage.
28.4. The surveys are heavily weighted against reflecting the totality of users that engage in a motorized means to utilize the forest, either as an operator of a motorized vehicle or passenger.
29. The BMFPR identifies insufficient funding as a reason road densities need reduced, or road segments need to be decommissioned or obliterated.