BLM’S RESOURCE MANAGEMENT PLAN FOR WESTERN OREGON

Cooperating Agencies Advisory Group Meeting

February 19, 2015 Eugene, Oregon

ACTION WHO BY WHEN

Provide AOCC statement and graphics to CAAG DSC With Session

summary

Provide ESA Consultation timeline to CAAG Project Team ASAP

Internal discussion regarding CAAG input process,

needs, and information share

Project Team ASAP

Provide agency/government’s desired outcomes to

DS Consulting

CAAG Members March 19th

Create ‘desired outcomes’ document to help guide

future CAAG conversations

DSC Late March

Share the ‘Preferred Alternative’ with CAAG once

identified

BLM When identified

Schedule CAAG outreach ‘dry run’ DSC Late March

Schedule CAAG working group meetings for

continued conversation on outcomes

DSC Late March/

early April

CAAG members present for all of part of the meeting: Dayne Barron (BLM DM – Medford),

Patty Burke (BLM DM – Coos Bay), ELynn Burkett (BLM DM – Lakeview), Chris Cadwell

(AOCC), Ray Davis (USFS), Tim Freeman (Douglas County Commissioner), Abbie Jossie

(BLM-Roseburg), Mike Kennedy (Siletz Tribe), Rod Krahmer (ODFW), Kim Kratz (NOAA),

Teresa Kubo (US EPA), Van Manning (AOCC), Jim Muck (NOAA), Josh Seeds (OR DEQ),

Kathy Stangl (BLM DM- Eugene), Jim Thrailkill (USFWS), Peter Wakeland (Coquille Tribe)

CAAG members on the phone for all of part of the meeting: Annabelle Jaramillo (Benton

County Commissioner), Rocky McVay (AOCC), Doug Robertson (AOCC ED)

BLM Staff present for all or part of the meeting: Mark Brown (BLM -State Office), Richard

Hardt (BLM-State Office), Megan Harper (BLM-Coos Bay), Mike Haske (BLM-State Office),

Trish Hogervorst (BLM-Salem), Carolina Hooper (BLM – Salem), David Howell (BLM –

Salem), Sarah Levy (BLM- State Office), Panchita Paulete (BLM –Eugene), Cheyne Rossbach

(BLM – Roseburg), Carolyn Sands (BLM-Salem), Heather Ulrich (BLM -Eugene), Jody Weil

(BLM – State Office), Jim Wittington (BLM – Medford)

Facilitation Team: Facilitator: Donna Silverberg; Facilitation Support: Robin Gumpert & Emily

Plummer, DS Consulting

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Meeting Summary

The following summary is provided to help the group remember the issues discussed and any

actions or next steps to be taken. Notes are drafted by the DS Consulting Facilitation Team.

Welcome and Introductory Business

The Facilitator, Donna Silverberg, welcomed CAAG to the meeting. Donna reminded the

members of the CAAG that BLM State Director, Jerry Perez asked them to think about the

outcomes they are seeking, and this would be the focus of today’s discussion. The purpose of

today’s meeting on outcomes was to help CAAG members formulate their ideas for public

comment on the draft EIS, to help BLM hear what matters most to its Cooperating Agency

partners, and to understand the outcomes that are most important to the Cooperating Agencies

which will help to inform the BLM’s movement toward a proposed alternative. She emphasized

that today is just the beginning of the discussion on outcomes. People would be working in small

groups to explore ideas and begin to tease out where there are agreements, areas for potential

agreement if given more time to work together, and disagreements that can’t be overcome.

Donna also reminded the CAAG that it is an advisory group to BLM. Within the group,

negotiations and consensus seeking discussions will occur. However, Donna reminded the group

that BLM’s State Director has the sole decision making authority. She shared a handout of

“Consensus vs. Consultation” describing the similarities and key differences between these two

processes. This Cooperating Agency Advisory Group process is a consultation with the BLM—

the group is consulting with BLM staff and may eventually make a group, consensus-based

recommendation to the BLM State Director who will take that recommendation, and many

others, into account when he makes decisions about the RMP/EIS..

Donna asked the group if they had any changes or additions to the draft Facilitator’s Summary

from the January 7th

and 8th

CAAG meeting; no edits were noted and the draft summary was

approved by consensus. The summary will be posted to the DS Consulting website

(www.dsconsult.co/page28.cfm).

Mark Brown shared that BLM is still on track to release the Draft RMP/EIS in April 2015. The

release will begin the official 90-day public comment period. Mark provided the CAAG with a

draft process and timeline update, noting that it is a draft document and subject to change. He

pointed out the aggressive timeline, and highlighted the document’s focus on the timing for

CAAG involvement. If CAAG members notice missing pieces or have recommendations, please

provide feedback to Mark. The CAAG Members had the following process questions and

comments:

Q: Where is BLM expecting ESA Consultation to occur in the timeline? o A: We’ve drafted an integrated NEPA/ESA Consultation timeline and will share

it with CAAG.

Q: Will there be discussion in the Draft RMP/EIS regarding how the Northwest Forest Plan fits into the alternatives?

o A: There will be a very specific statement explaining that this RMP replaces the Northwest Forest Plan as it relates to BLM. The two plans do not fit together as

they have two distinct Purpose and Needs.

Q: What is the timeline for Jerry Perez’ identification of the Preferred Alternative? o A: Jerry is currently in conversations with the Washington Office regarding the

identification of the Preferred Alternative; however, at this point it has not been

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identified. Also, Mark reminded that, at the November and December CAAG

meetings, BLM spoke to the limitations of identifying of a Preferred Alternative

and asked CAAG to weigh in on the identification. There was not a lot of

feedback received, and thus a “CAAG preference” was not shared with the

Washington Office. If CAAG members have strong feelings that have not been

voiced, BLM wants to hear, however, the decision is about to be made. Mike

Haske, Deputy State Director of Natural Resources, reiterated that the

identification of the Preferred Alternative is a requirement of the planning

process, and not where BLM will end up. BLM wants to focus conversations on

what the Proposed Alternative will look like; today’s meeting will start that

process.

Q: When the Preferred Alternative is identified will BLM share it with the CAAG? o A: Yes, BLM will commit to sharing the Preferred Alternative with CAAG.

Q: Will BLM submit for consultation on the Preferred Alternative? o A: The Preferred Alternative will not be submitted for Section 7 consultation.

BLM will submit the Proposed RMP for consultation via a Biological

Assessment. The resulting Biological Opinion will be for the Proposed RMP.

Q: Will consultation be conducted prior to the Record of Decision (ROD)? o A: Yes, that is the goal.

Q: Does the Biological Opinion need to be signed before the Governor’s Review? o A: No, however, the Biological Opinion will need to be signed before the ROD is

signed.

Q: Is there an official closing date for agency input on the Draft RMP/EIS? o A: The official comment period is expected to close at the end of July. However,

the more we can front load CAAG conversations/feedback the better. BLM does

not want to wait to get all of the input at the end of July, as it will make it more

difficult to stick to the tight timeline.

Comment: NOAA is very interested in a successful ROD, which is dependent on getting the Proposed RMP completed and through consultation. This is a big

undertaking, in a short timeframe and will require that all are diligent.

o Mark echoed the thought, noting that it is absolutely necessary to get CAAG input quickly. This cannot be a multiple month process; BLM needs to understand

CAAG’s thinking as soon as possible. He noted that the final will begin to be

drafted as soon as the 90-day comment period is complete. He further explained

that this CAAG meeting is about getting feedback on areas of agreement,

potential agreement and disagreement. He noted that this conversation is added to

by all previous conversations at CAAG and BLM wants to get focused on desired

outcomes.

Outreach Update

Sarah Levy, Project PAO, provided an update on the RMP outreach effort. She noted that the

CAAG Outreach Team has met twice with BLM and provided valuable input about design and

timing. Sarah gave CAAG a draft public outreach schedule, which includes both open houses

and issue specific meetings.

The open house forum is BLM’s attempt to get away from ‘BLM talking heads’ and is designed

for smaller, more personal conversations focused on what individuals want to talk and learn

about. The format will consist of information stations/tables, interactive maps, videos, with

subject experts (from the Districts) available to answer questions and direct people to additional

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information. District Managers will serve as session Ambassadors. These will be self-directed

learning opportunities for members of the public. BLM is currently planning to have an open

house in each District.

The issue specific meetings will be a series of high profile issue-based workshops oriented to

members of the public who are more familiar with the subject matter. The focus of these

sessions will be to have productive conversations aimed at soliciting high quality comments,

with a focus on the outcomes specific to those issues. BLM does not want these sessions to be

about debating the analysis or results. Instead, they would provide an opportunity to get people

contributing to a proposed action. The following issue meetings will be held:

o Social-economics workshops: Roseburg and Portland, week of June 8th o Forest management and related topics, including ESA species and fire resiliency:

Medford and Salem, week of June 15th

o Riparian/Aquatics: Eugene, weeks of June 8th or 15th o Recreation: Medford, Roseburg, Eugene, Salem, month of June

BLM will also have a special Elected Officials meeting; Rocky McVay (AOCC) will help

organize the session. Rocky suggested being fluid on the date of the session depending on who

is available. Mark explained that due to recent political events at the State level, BLM is

temporarily holding off on organizing this session, which Rocky felt was okay.

Sarah shared that the outreach plan remains a draft and is subject to change, if needed. If anyone

has thoughts or feedback, please contact Sarah directly. BLM also extended an

invitation/request to CAAG members to join BLM at the outreach sessions.

Sarah also reported that BLM is putting together short outreach issue videos to be shown at the

open houses and via social media outlets. Annabelle Jaramillo (Benton County) will be a star in

the timber/revenue video, Teresa Kubo (EPA) the star of the Riparian video, Brendan White

(USFWS) will be the star of the wildlife video, Harry Dalgaard (Travel Oregon) will be the star

of the recreation video, and Chad Davis (ODF) will be the star of the climate change video.

BLM is still working to get someone from the Association of O & C Counties to star in the

timber video. BLM also is working with the tribes to develop a tribal video.

Similar to previous outreach efforts, BLM would like to get CAAG feedback via a ‘dry run’

session. In the past, the ‘dry run’ has been a valuable opportunity to get feedback to BLM on the

materials they have developed. It was suggested that the dry run should be held when BLM has

outreach materials very close to being finalized. This will likely be in late March.

Q: Why is there only one riparian session and four recreation sessions?

A: It is in part due to the fact that the demand for recreation has been incredibly high with

past outreach efforts and there is a lot of ground to cover with recreation. Riparian is an

important topic and BLM thought that one central location would be enough to draw the

interested parties they have heard from through past outreach efforts. Sarah further

explained that a lot of the locations were chosen based on BLM’s understanding of local

interests, if CAAG members have feedback on the location, number of meetings, etc.,

please let the Project Team know.

AOCC Oral Comment on the RMP Scope

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At the request of the Association of Oregon and California Counties, Chris Cadwell, spoke on

behalf of the Association, sharing their longstanding concerns about what they see as a limited

scope of alternatives. Chris explained that the AOCC has sent letters to BLM Director, Neil

Kornze and State Director, Jerry Perez (as requested by AOCC, both letters were passed along to

the CAAG via email from DS Consulting on 2/2/15). One letter details datasets that AOCC

requested be made available to CAAG, as well as additional analysis that the AOCC would like

to see as a part of the RMP process. The second letter focuses on AOCC’s interest in expanding

the range of alternatives. Chris provided explanation as to why the AOCC feels that the range of

alternatives is limited. His full statement and supplemental diagrams are attached.

BLM Deputy State Director of Natural Resources, Mike Haske, thanked Chris for his

explanation and shared that BLM is preparing written response to the letters sent to Director

Kornze and State Director Perez.

BLM Project Manager, Mark Brown also thanked Chris and ensured that BLM wants all

cooperators to know that this is a forum to express thoughts, concerns and ideas. He noted that

BLM’s intent is to reach out to the AOCC in a one-on-one meeting. He also noted that the

CAAG Memorandum of Understanding has a clause stating that BLM will recognize and

acknowledge when there is a significant disagreement with any CAAG members and will

provide a summary of the disagreement in the Draft RMP/EIS. BLM has asked the neutral

facilitator, DS Consulting, to prepare that statement and will share it with AOCC before it is

incorporated into the draft. This will be provided as a professional courtesy and will not be an

opportunity for editing.

Mike Haske added that BLM takes cooperator comments seriously, and reminded the group that

the Purpose and Need was not created and approved quickly; it went through a lot of internal

review both locally and in Washington DC. He also noted that there will be a significant data

release with the draft RMP/EIS that will allow those interested to dive deeper into the details.

Chris closed by noting that the AOCC would like to support this effort and recognizes that

conservation needs are a high priority. However, AOCC’s main concern is that there has not

been a full exploration of the range of possible alternatives.

RMP Analysis and CAAG Input on Potential Outcomes The Facilitator divided the group into three small groups for discussion around desired outcomes.

Each group was made up of representatives from federal, state, tribal and county cooperators.

Based on the issues presented at the January session, they were asked to identify: the issues of

importance to each cooperating agency; desired outcomes; areas of agreement; areas of possible

agreement with some refinement; and areas of clear disagreement.

Douglas County Commissioner, Tim Freeman, commented that the optics of listing ‘socio-

economics’ at the bottom of the handout list provided gives the impression that the issue is not a

top priority for BLM. He noted that socio-economic issues are top priority for many of his

constituents. Kim Kratz, NOAA, reassured Tim that community resiliency and economic

wellbeing is part of NOAA’s mission and, as a part of the Department of Commerce, it is

considered a priority along with species conservation needs. Donna Silverberg, Facilitator,

thanked Tim for the observation.

Mark Brown kicked off the discussion by putting CAAG’s discussion in the larger context: He

noted that the Draft RMP/EIS is scheduled to be released in April 2015. This is the point where

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the conversation shifts from what the BLM could do into what the BLM should do. Mark

stressed that today’s discussion is not a decision making effort; instead, it is an opportunity for

cooperators to give BLM feedback on the outcomes they would like to see result from what

BLM does. He stressed that there will be more opportunities for CAAG to provide input to

BLM, as well as opportunities for the broader public to provide input. All comments now and

from the 90-day public comment period will weigh into BLMs final decisions.

Richard Hardt, IDT Lead, clarified the types of outcome statements that will be useful to BLMs

ID Team at this point in the planning process. He noted that at the last CAAG meeting BLM

provided broad overview of the outputs from the Effects Analysis. The outcomes of the analysis

are the side boards for today’s discussion; it would be most useful if CAAG input is based on

what the BLM analysis has shown; BLM’s decision rationale needs to be based on the BLM

analysis, not something new at this point. The outcomes that cooperators identify should reflect

the outcomes available in the range of the alternatives and the boundaries of what the effects

analysis has shown. For example, Richard urged the cooperators not to suggest ‘12’ if the range

of alternatives shows ‘1 to 10’.

Richard urged the CAAG to be as specific as possible regarding desired outcomes. At this point,

BLM does not want the cooperator’s to focus on the alternatives, or even components of the

alternatives. Instead, they want to know what outcomes cooperators want to see so that the IDT

can creatively put together options to get to that outcome, thus providing more decision space for

the decision makers. He added that understanding the interest, or the WHY, behind the outcome

desired is incredibly helpful and adds flexibility to finding ways to meet multiple interests.

CAAG members had the following questions and comments:

Q: Can you help illustrate the distinction between outputs and outcomes? o A: Yes, you can say that timber volume is important. But it is really the revenue,

jobs, and economic wellbeing of the counties that is most important. Try to focus

on the effects and what specific effects you want to see.

Q: The purpose of the CAAG is to bring a variety of agencies with different missions and responsibilities together to work through those differences. However, there are

subsequent consultation processes that will further impact the range of options. In this

exercise should we be incorporating future impacts to the potential range of outcomes?

o A: For the purpose of this conversation, we would like you to be more focused on providing feedback on the effects that your agency would like to see. Impacts of

consultation are more process and policy questions that might come into play in

future conversations.

Q: It may be difficult, as an agency, to provide the level of specificity desired because the agencies are looking for the functions necessary to meet their interests, for example, the

conservation of listed fish species. Some functions of the analysis do not show a

significant difference in the outcomes.

o A: NMFS is a cooperating agency as a subject expert, not specifically because they have a role in Section 7 Consultation; NMFS knows more than anyone else

on how to conserve and recover fish. If you see differences in the outcomes that

are meaningful, or you think all of the outcomes provide the same benefit, BLM

wants to know. These conversations are not binding, it is information gathering.

After discussion, the large group reconvened and reported out from small groups. The following

points are a bulleted summary of what was reported out by the small groups. It was noted that

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there was not complete agreement within the groups; also, representatives reported out on the

issues discussed, not solely areas of agreement.

Socio-economic: the wellbeing and sustainability of the counties is important. o Coquille Tribe and AOCC want outcomes that yield economic sustainability.

This RMP effort affects the stability of these communities – specifically timber

jobs in the south.

o Provide maximum revenues to counties. o Socio-economic outcomes should also support species and recreation

opportunities.

o Manage fire and resources in a way that promotes livability and jobs.

Tribal: Reduce negative impacts on tribes and tribal management approaches.

Wilderness lands/wild and scenic designation: concerns around precluding timber harvest on O&C lands. There could be conditioned sustained yield in these corridors.

Recreation: Recreation is generally good; however, BLM needs to look at the travel management plan when considering opening and closing roads: e.g. where is travel

management environmentally appropriate?

Cultural Resources: BLM’s range is comprehensive; there is good protection of cultural resources.

Climate Change: needs to be addressed, specifically in regards to hydrology, temperature and timber.

Invasive Species: need to have a ‘step down’ process – invasives need to be dealt with. o Use herbicides only for invasives and sudden oak death, not growth enhancement

and release.

Air quality: important as it relates to fire and fuels; air quality requirements limit how BLM can manage for fire and fuels. There needs to be a way to deal with fuels.

Fire and Fuels: The current management practices are good; we need to maximize the outcomes so salvage logging should be incorporated.

o Clarify where management should take place. o Manage fire to mimic natural fire regimes: structure, intensity and frequency.

Also, silviculture practices should support natural fire regimes.

o Design strategies to protect key habitat areas and link to restoration of key habitat areas.

Hydrology: implement best management practices; management practices should not impact the hydrological systems of streams.

Riparian/Aquatic/Fisheries: manage for large wood, sediment, temperature. o Preserve and manage within riparian areas. o Healthy fisheries are an important component to all. o Protect surface and drinking water.

Listed Terrestrial Species: agreement that protecting species is important, but BLM needs to keep the O&C Act in mind.

o BLM also needs to keep the Coquille Tribe in mind – what BLM does impacts Coquille as they will have to follow same management regime.

o Maximize benefits in reserves for species and allow harvest where possible/ active management.

Northern Spotted Owl: keep the species in the positive – no more loss. o Maximize harvest with minimum impact where possible, to increase harvest land

base and sustained yield in order to maximize socio-economic benefits.

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Timber Management: analyze the mosaic and look for win/wins – more analysis on what management is possible in the mosaic.

o Look at ecological functionality across the watersheds and in context of habitat. o Don’t use a one-size fits all approach – can have approach that maximizes harvest

and conservation benefits.

There was discussion regarding the CAAG input and what elevation of detail is helpful for the

IDT and what is helpful for State Director Jerry Perez. It was noted that this initial feedback

about desired outcomes will be helpful for policy oriented decisions that Jerry Perez will be

making. In regards to the type of input that the IDT would like to get from the CAAG, Richard

noted that it will be helpful to hear specific details as to what effects CAAG members like and

why. Richard gave the example of the effects on fisher habitat, noting that one alternative shows

a decline in habitat, whereas one shows an increase in habitat. Richard asked CAAG members to

think of their agency perspective: does fisher habitat matter to your agency? If so, how much

habitat would your agency like to see? Is the alternative with habitat decline okay, or does there

need to be increasing fisher habitat? Amongst the effects, what do you see that matters to your

agency? Richard stressed that this is not an exercise aimed at figuring out the solution; instead it

is to identify the interests and needs.

The group considered how best to facilitate CAAG input for the IDT. It was suggested that if

BLM were to provide more detail on the specific areas that they would like input, CAAG

members could answer those questions. It was also suggested that BLM provide the CAAG with

the actual effects analysis so that CAAG can provide more detailed input. The RMP Project

Team agreed to meet internally and discuss how to best move forward gathering CAAG input.

Additionally, it was noted that it may be more productive to get specific input via the CAAG

working groups.

ACTION: BLM will discuss internally regarding what they can provide CAAG in order to solicit the input that they want.

ACTION: DS Consulting will schedule the CAAG working groups in March/April. ACTION: CAAG members will consider their agency’s desired outcomes and reasoning

and provide input to DS Consulting by March 19th

. DS Consulting will create a

document to help guide future CAAG conversations. Reminder: please stay within the

boundaries of the Effects Analysis!

BLM said they greatly value partner input and appreciate the CAAG being willing to provide it.

Mike Haske affirmed that the conversation was incredibly valuable to help inform policy level

discussions. He noted that having an understanding of the cooperator’s values and interests will

help BLM weigh options. Mike noted that this is a difficult and complex conversation, and BLM

appreciates CAAG’s continued participation.

Next Steps

BLM is going to digest the information received during the session and get back to CAAG with

next steps. The CAAG working groups will be reconvened in March/April and the CAAG

outreach ‘dry-run’ will be scheduled for late March. It was suggested that the Westside Steering

Committee members should look at the content of the upcoming work group meetings and

consider attending.

BLM and Donna thanked CAAG for their continued engagement and with that the session was

adjourned.

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* This summary is provided by the DS Consulting Facilitation Team; suggested edits are

welcome and can be sent to Emily Plummer at emily@dsconsult.co. *

Statement by AOCC – Range of Alternatives

February 19, 2015 CAAG

We all need to remember that the O&C lands are unique amongst the Federal lands. The Federal government does not pay taxes yet owns the majority of the land in the rural counties of western Oregon. They are unique because of the direction to manage the forest under the principles of sustained yield as a means to generate revenue for the 18 O&C counties. This is the foundation of why they were designated as O&C lands and distinguishes them from other Federal lands. The BLM’s Purpose & Need focused on a range of strategies based largely on terrestrial and aquatic objectives. The land base for sustained yield management resulted from what remained after all of these reserve designations were made. These “Reserve” based conservation strategies were informed by previous work that was likely to have good outcomes. From what has been shared to date, and as anticipated, the results for those objectives show a relative narrow range of positive outcomes that are in fine degrees. The design of the alternatives resulted in a very narrow range on the size of the lands allocated to sustained yield, which are similar to or smaller than the NWFP. The degree sustained yield management can simultaneously provide for conservation and economic objectives has not been rigorously explored and objectively evaluated by the BLM with this limited range of alternatives. When the “Reserve” label is assigned to the land base by definition it precludes sustained yield management and the opportunity for those lands to contribute to sustainable economic benefits for future generations. The same is not true when the “Sustained Yield” label is assigned to the land base. The use of extended rotations and retention has demonstrated that simultaneous achievement of sustainable timber production and habitat conditions are possible. In all of the Action Alternatives BLM has departed from long standing minimum harvest age of at or above culmination of mean annual increment (CMAI). The Alternative C sub alternative of no harvest of 80+ resulted in a harvest of 334 MMBF when earlier analysis based on CMAI indicated 96 MMBF. Is sustained yield management departing from CMAI and using optimization in the modeling tending towards a management style closer to private industrial lands? Has BLM fully explored longer sustained yield rotations on large land bases under these alternatives? – No. The Maxtent model assigns “Relative Habitat Suitability” based on concentration, structural stage, position on the landscape, and other factors. BLM has placed upfront “Reserves” for older more structurally complex forest based on simplistic broad brush age based criteria for the most part. This ignores the reality that it is more than age of an individual stand which indicates the degree it contributes biologically for owl conservation. The Planning Criteria stated the “alternatives would explore differing approaches to defining older and more structurally complex multi-layered conifer forest, by such criteria as stand age, structure, size, or landscape context.” The alternatives do not reflect exploring the relative landscape context in the need for establishing these reserves and precluding sustained yield.

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Other questions remain unanswered by this narrow range of Alternatives.

Could long rotations, with creating complex early seral conditions on a limited scale, be applied to younger and middle age portion of the large block reserves to create a range of habitat conditions? Does the entire large block need to go to older forest? Would not a mix of complexity and seral stages and structural complexity be beneficial for overall ecological diversity?

Can the existing older forest stand reserves be managed under a regime with legacy retention on a long rotation but still be managed on a Sustained Yield basis? The Alternatives reserve between 655-429,000 acres of older more structurally complex forest. Regeneration harvest levels under the NWFP and 2008 RMP ranged between 60-76,000 acres over a decade – a fraction of what is reserved. Older more structurally complex forest across the landscape will be increasing in the large blocks and riparian reserves. Are the additional reserves necessary or could timing of harvest and silviculture regimes achieve similar outcomes on a sustained yield basis? We don’t know by these Alternatives.

It appears uneven aged management areas were defined by various geographic determinations of “dry forest” loosely tied to a need to improve forest resiliency. To date we have not seen where there has been an assessment of the actual forest conditions to rank the level of need, and extent of the forest for resiliency treatments. Uneven aged management is an effective approach for improving resiliency but it comes at a cost of the sustainable harvest level. Is it not reasonable that a stand condition based needs approach should be evaluated as an alternative? How would this compare to predefined geographic condtions?

The BLM in the Purpose & Need did not identify revenue as an objective despite that it is foundational as why these lands were designated as O&C. The range of revenue outcomes for rural Oregon counties has a much wider range than most other outcomes and a direct effect on the rural communities and industries. At best it is 50% of historic payments and in most Alternatives 14-27%. AOCC has concern that the upfront decisions to limited range on the amount of land allocated to sustained yield has artificially limited the understanding what is possible by a fuller expression of the range of how sustained yield could be conducted, and the range of revenue outcomes. The planning process is a very unique opportunity which brings together the BLM professional expertise, the knowledge of the Cooperators, and data/models to build this understanding of how the BLM can simultaneously make significant contributions to both conservation and economic objectives. Evaluation of a broader range of sustained yield approaches, on a broader land base, is essential to the understanding of what is possible.

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