Comments on the WOP
I have submitted my comments regarding the Bureau of Land Management’s (BLM) Draft Environmental Impact Statement for the revision of the resource management plans of the western Oregon BLM Districts. You may also do the same by visiting the BLM WOP Revision site [here]. You have until Jan 11 to submit comments.
Here are mine:
I. Do away with Site Potential Tree Height
Site Potential Tree Height is pseudo-scientific fraud. It does not exist. There is no such phenomenon. The concept cannot be measured. It is not a metric.
The BLM might as well use 400 frog hops, or 37.4 watermelon seed spits.
SPTH was made up out of thin air during the secret, invitation-only, public-excluded meetings following the Clinton Timber Summit of 1993. SPTH appears nowhere in forestry or forest science literature prior to those meetings.
SPTH had never been measured or correlated to riparian conditions, because the concept did not exist. SPTH had never even been thought of, let alone studied. And it hasn’t been studied since, either. There are still zero scientific reports of studies on SPTH. None, zip, nada. It’s not science. It sounds like science, but it most assuredly is not.
Implementation of the NWFP caused confusion at the USFS and BLM local levels. No one knew how far two SPTH’s was, since the concept had not been, nor could it be, measured. Big numbers were dreamed up, for political correctness purposes, and lines drawn on the maps. As a result, 85 percent of Federal forest was set aside in “riparian zones”. In effect, most Federal forest in the Pacific Northwest has been dedicated to catastrophic fire, based on an out-and-out scientific fraud.
SPTH is voodoo forestry. SPTH is destroying forests. It’s a fake concept, it cannot be measured, and yet it is used as the most important yardstick in forest planning in Oregon, Washington, and California.
Bogus frauds make for improper and unworkable guidelines. It is time to bury this bogosity.
II. Do away with “shade” restrictions
Like SPTH, shade cannot be measured with any degree of accuracy. In fact, “shade” cannot be defined, or else is subject to a dozen different definitions.
No study ever in history has found that sunlight warms streams, or that shade prevents that warming. That’s because the alleged phenomenon DOESN’T EXIST. Water reflects sunlight. Steams are warmed (or cooled) by ambient air temperatures. Stream flow rate is also a statistically significant factor. But “shade,” no matter how it’s “measured,” has never been found to have a statistically significant effect on stream temps, despite “valiant” attempts by those who have tried to find the effect.
Bogus frauds make for improper and unworkable guidelines. It is time to bury this bogosity.
III. Do away with riparian buffers
Riparian buffers, such as those proposed, are killing forests and poisoning streams. Massive build-up of fuels in regulatory riparian zones lead to catastrophic megafires that denude entire watersheds, cause excessive post-fire erosion and sediment smothering of salmon spawning gravels, increase stream turbidity, alter stream pH’s, reduce dissolved oxygen, coat the gills of fingerlings, and fertilize algae, all of which lead to even more fishery problems in the future.
At recent Senate hearings top forests scientists agreed that aggressive active forest management is desperately needed now to remove excess fuels and restore forest ecological functions, in order to prevent further destruction of Oregon’s old-growth forests. See Testimonies to the US Senate Energy & Natural Resources Subcommittee on Public Lands and Forests: To receive testimony regarding forest restoration and hazardous fuels reduction efforts in the forests of Oregon and Washington (Hearing Room SD-366), Thursday, December 13, 2007 [here].
Note in particular the testimonies of K Norman Johnson - University Distinguished Professor, Oregon State University, and Jerry F. Franklin - Professor of Ecosystems Sciences, College of Forest Resources, University of Washington, and of Michael E. Dubrasich - Executive Director of the Western Institute for the Study of the Environment.
Forest restoration is not just for ridgetops. The forest fire crisis is a landscape-scale problem and requires landscape-scale solutions. That means forest restoration treatments should be carried out right up to the edge of streams.
To protect riparian zones and their aquatic habitat we must tend them, not abandon them to catastrophic fires. Creating huge regulatory riparian buffers where forest restoration is excluded is not the environmentally beneficial option.
Forests: Tend Them or Lose Them
That goes for so-called riparian zones, too.
