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To [email protected]
05/09/2011 06:19 PM
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Subject Pilot Project Scoping Comments
Dear Ms. Kelleher,
Thank you for accepting these comments on the Medford BLM pilot
project. The pilot is a demonstration of the restoration principles of
Drs. Johnson and Franklin. They rely on the protection of older
forests and legacy trees, while thinning dense forest stands. I
support these concepts, but I do have some concerns with the direction
of the BLM in the pilot project.
The BLM should not build any new roads that have adverse impacts on
forest structure, wildlife habitat or watershed values. Roads
generally impact habitat and watersheds, spread noxious weeds, and are
known to increase the proliferation of off road vehicles in the
Applegate Valley.
Please also maintain habitat for wildlife species and explain how
these restoration principles would help with the long-term recovery of
the northern spotted owl and the salmon populations. While there are
areas that are set aside for the owl in the project area, please
explain how these will be treated in the future. The removal of larger
trees (larger than 20 inches) should be highlighted and the public
should be informed how these trees are contributing to the restoration
objectives.
The use of the stewardship contracting authority should be
demonstrated in this project, along with innovative, low-impact
logging techniques. Traditional logging methods cause too much damage
to the soil and the residual forest structures. Along with the use of
local crews, stewardship contracting could help preference the use of
low impact equipment that helps prevent excessive soil disturbance and
enables the BLM to better achieved the restoration objectives of the
project.
Please include a systems of third-party or public monitoring to create
transparency and ensure that the processes that are implemented to
guidelines in the pilot project, and also create measures that ensure
equity for all parties resident within the Medford district with
regard to notification, release of information, transparency of
process, and honesty in description of the affected environment and
predicted effects.
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