Response to Oregon State Department of Forestry on the Western Oregon Forest Habitat Conservation Plan

31 July 1998

Ms. Jane Hope, Planning Specialist
Oregon Department of Forestry
2600 State Street
Salem, OR 97301

Dear Ms. Hope:

This letter contains comments from the Oregon Chapter of the American Fisheries Society (ORAFS) on the draft Western Oregon State Forests Habitat Conservation Plan (HCP) prepared by the Oregon Department of Forestry (ODF). ORAFS is a volunteer organization of professionals in fisheries and aquatic sciences. We have over 500 members in Oregon representing a diverse mix of scientists in federal, state, and tribal agencies, and in the private sector.

We recognize the large effort it took to produce the draft HCP and commend ODF for undertaking this plan. Although the information compiled for the draft HCP has the promise to provide the foundation for an aquatic conservation strategy, we found the HCP largely lacking in sufficient detail to adequately evaluate it as an aquatic conservation strategy. We feel the aquatic conservation strategy as presented is not sufficient to recover salmon habitat and salmon populations in the North Coast state forests. As such, we find the plan lacks crucial elements that would allow it to help anchor the regional recovery strategy for salmon as envisioned in the Oregon Plan. We strongly believe management of these state forests must have the recovery of salmon habitat and populations as a principal guiding goal and that these large blocks of public land be adequately recognized as critical pieces on the North Coast in the overall goal of regional efforts to recover salmon.

Although the HCP presented some basic conservation concepts, it provided little information on important elements of an aquatic conservation strategy such as watershed reserves, integrated management of whole watersheds, or specific restoration goals relative to fish populations or other aquatic species. The HCP identifies some general strategies but leaves it to undetermined watershed analyses and small-scale implementation plans for details. We believe an HCP should provide sufficient detail to guide implementation at several spatial scales, especially at a forest-wide scale.

We commend ODF for including an aquatic section in the HCP, elements of which recognize the importance of watersheds within state forest lands for the recovery of salmon. We also commend ODF for acknowledging the limited ability of engineered stream enhancement measures to restore stream functions, and for recognizing that enhancement measures should be viewed as short-term and a stopgap for restoring natural processes (pages IV-26 and VI-30). However, we caution that monitoring and evaluating these types of projects will require persistence and vigilance because the tendency of current restoration approaches is toward an active rather than a passive strategy.

We also strongly agree that measures contributing to stream habitat degradation need to be identified and eliminated as a requisite for successful restoration (page VI-29). We believe the HCP should emphasize that elimination of degrading factors is a high priority and that this needs to be accomplished before much money is spent on enhancement projects.

Our review of the draft HCP identified several areas of concern. Detailed comments on the HCP are included as a separate enclosure.

Conceptual Framework and Conservation Strategies

We are concerned the HCP lacks a conceptual framework that emphasizes the experimental nature of a large-scale conservation strategy. The HCP should present a strategy containing an experimental design approach as its guiding principle. The HCP should outline a more detailed conservation strategy including such important conservation principles as watershed reserves and connectivity between high quality habitats. An HCP for the North Coast state forests should be based on current watershed or ecosystem planning principles (Reeves and Sedell 1992; Noss and Cooperrider 1994; Spence et al. 1996). The HCP should draw on information provided in Spence et al. (1996) for planning, implementation, and monitoring, and on specific conservation strategies for the Tillamook and Clatsop forests proposed by Huntington and Frissell (1997). The ODF goals in the HCP seem narrow, although this plan is an improvement over other HCPs that we have reviewed (see Slocombe 1998 for discussion of broader goals such as biodiversity, ecological integrity, and sustainability).

Regional Context

Although the regional context of the North Coast state forests is discussed, we feel the HCP does not adequately recognize the importance of these state forest lands for recovering salmon populations in the North Coast, where federal land is limited and where private forest land has continued to be heavily harvested. The North Coast state forest should be an anchor for salmon recovery under the Oregon Plan by providing watershed refugia in high priority watersheds within the forests and by implementing a strategy that minimizes risks to watersheds and salmon populations. This strategy would also serve to help mitigate for current conditions on adjacent private lands and to greatly increase the effectiveness of measures implemented on surrounding private lands. In such a role, management of the state forests should be highly conservative with a primary goal being to minimize ecological risks.

As mentioned in the HCP, much of the landscape in the planning area was disturbed recently by fire and (perhaps more importantly) by intensive salvage logging that occurred after the fires. The HCP should carefully estimate historical conditions in the region to assess the extent and frequency of natural disturbance. We believe that estimating the historical condition of landscapes, channels, and biota is critical to monitoring and to serve as reference conditions for recovery goals. Without an appropriate set of reference conditions it will not be possible to set recovery goals or to evaluate progress in achieving the goals (see Hughes 1995 and Thurow et al. 1997 for examples and applications).

As acknowledged in the HCP, recent assessments of freshwater habitat in the North Coast forests indicate freshwater productivity may be at a relatively low point (page II-28). In addition, analysis of coho habitat in the Tillamook Bay and Nehalem basins suggests that just 5% and 25% of the habitat, respectively, is of sufficient quality that coho salmon could replace themselves if the average marine survival observed during the past decade continued for an extended period of time (Nickelson 1998). The HCP should outline a comprehensive strategy with a goal of specifically increasing the quality of freshwater habitat that would address the sustainability of salmon runs in the watersheds of the state forests.

These issues illustrate that salmon recovery cannot be planned or evaluated by looking at just one point in their life history cycle. The role of the HCP should be to address the management of state forest lands while recognizing the conditions of adjacent lands as well as estuarine and ocean conditions. In this context, forest management on state lands would likely be more conservative than if the state lands were looked at in isolation.

Silvicultural Approach to Restoration

We believe the HCP should present a strategy that clearly recognizes the regional landscape is in early stages of ecological recovery and that many areas may not be ready for more disturbance. Despite the recent and widespread disturbance within state forests and the need for conservative approaches to forest management, the HCP stresses active silvicultural treatments throughout much of the state forests as the principal approach of its conservation strategy (pages I-2 and IV-3). While this approach may be appropriate in certain areas of the forest, we disagree that large-scale treatment over much of the forest is the most prudent or productive restoration strategy to increase the quality of freshwater habitat (particularly in the riparian zones of perennial and seasonal streams), or the best strategy for minimizing risks to watersheds or salmon populations.

The HCP seems to define recovery by the size of trees relative to timber production, rather than by the condition of the landscape in an ecological sense. Human intervention as a means of directing recovery of large watersheds is highly experimental and should be recognized as such in the HCP. As such, we do not know if the proposed silvicultural treatments will speed recovery, will be neutral, or will inhibit recovery. Yet throughout the plan, discussion of silvicultural treatment is presented as a certainty (e.g. on page IV-7; “a diverse forest landscape will be created…through active management”, “[stand] structures will be in a dynamic balance across the landscape”). Whether or not the treatments will actually result in projected stand structures is open to question, especially over a long time period. More importantly, even if a silvicultural treatment results in a certain stand structure, will these managed stands really emulate the ecological functions they strive to represent?

We recommend that the HCP incorporate a passive restoration approach (Kauffman et al. 1997) in large areas of the forest, primarily in areas designated for watershed reserves or some other conservation designation. Active restoration should be based on watershed assessments with the goal of directing streams and watersheds toward historic conditions (Roper et al. 1997).

Riparian Management and Water Quality

Riparian management in the HCP includes an extremely narrow no-cut buffer (25 feet) and protection standards that are much less than those proposed by NMFS for private forests or in place on federal forests. An ODF-sponsored study (Botkin et al. 1994) concluded current Oregon Forest Practices Act standards would impede recovery of degraded streams and riparian systems. The need for improved riparian protection has been expressed in several recent planning documents and analysis (FEMAT 1993; Spence et al. 1996; USFWS and NMFS 1996).

In addition, proposed silvicultural treatments in Riparian Management Areas (RMAs) will result in constructing or maintaining roads in or near riparian areas. Impacts from roads have been well-documented and include increased erosion and sedimentation in streams, changes in watershed hydrology, lost production area for development of riparian forests, increased isolation of riparian areas from upslope areas, etc.

We recommend that all riparian areas be managed for their recognized ecological values and contributions to the maintenance and recovery of stream habitat. As such, we suggest that these areas be removed completely from the timber base for the state forests. We further suggest that activities allowed in riparian areas be restricted to those that will clearly benefit the ecological values of the areas, and for which the benefits clearly outweigh the risks.

Although the HCP addresses water quality problems and issues in general, it demonstrates little awareness that many streams in these state forests fail to meet Department of Environmental Quality (DEQ) temperature and intergravel dissolved oxygen criteria for salmonids, nor does it recognize that fine sediment levels exceed those preferred by salmonids and amphibians. Continued timber harvest in riparian management areas will exacerbate temperature problems; continued use of clearcutting and other silvicultural treatments throughout the forests will continue to negatively affect the delivery of water and fine sediments to streams. Minimal riparian protections cannot buffer streams from extensive and intensive logging and roading across many watersheds.

The degree of riparian area protection relies on accurate classifications of streams. Definition of stream classes (permanent or seasonal; fish-bearing or not fish-bearing) is inexact and depends on specific sampling techniques and general climate patterns. Flows differ markedly depending on the catchment history and annual precipitation patterns. Climatologists have recently characterized precipitation patterns in our region as 20-year cycles, and have predicted that we are in transition from a 20-year trough to a period of above average precipitation. The precipitation pattern, summer temperatures, and catchment history (fire, logging, floodplain agriculture and urbanization) result in markedly different summer flows in streams. These flows in turn will determine whether or not a stream can support salmonid spawning and rearing.

Watershed Reserves

One important element in an aquatic conservation strategy should be the establishment of watershed reserves, at least on a temporary basis. Although the HCP acknowledges areas will be left to recover on their own, it provides no information on the number, size, location, diversity of features, or on the length of time that these areas will be left alone. Nor does the plan provide detail on the information that will be collected in these areas and applied in an adaptive management approach to the rest of the forest.

Monitoring and Implementation

Monitoring should be viewed as the data collection phase for answering ecological or management questions – it is not an end in itself. In order to answer landscape-scale questions monitoring must be strategically planned with careful attention to statistical design and the choice of meaningful indicators. The HCP lacks sufficient information on what water quality and quantity, physical habitat, and biological indicators will be used, how they will be monitored, or how monitoring will actually be used to change management of the state forests.

Because plans themselves are not management actions, implementation monitoring should not be of the plans but of the actions the plans propose to implement. Similarly, effects monitoring should not be only of indirect indicators of ecological effects; it must also monitor the desired final outcomes of concern. See Espinosa et al. (1997) for inadequacy of forest plans as indicators and see Spence et al. (1996) for examples of implementation and effects monitoring.

The HCP designates the district as the scale with which to decide monitoring needs, priorities, and implementation. Focus on district-level research, monitoring, and peer reviews is a recipe for weak and misleading results that could sabotage attempts at adaptive management and could jeopardize recovery strategies at the basin, ecoregion, and state levels. Looking only at local patterns can hide a multitude of detrimental impacts. For example, the clear and present danger of salmon extinction in the Pacific Northwest was brought into focus by the work of Nehlsen et al. (1991), who took a regionwide view of salmon status and trends.

If the HCP is to provide necessary conservation guidance to help implement the Oregon Plan for recovering salmon populations, then the HCP must have a broader perspective at the state and ecoregion scales. If monitoring data are to be applicable statewide, they must have common assessment questions, sampling designs, sampling protocols, and data reporting. Without this data collection and implementation could differ widely even on the forest-wide scale.

Thank you for the opportunity to review the HCP. We will be glad to provide additional input to future drafts.


Hal Weeks, President

for the Executive Committee

c. Paula Burgess, Roy Hemmingway, Kelly Moore, Governor’s office, State Capitol

Paul Brouha, AFS, Bethesda

Pete Bisson, President, Western Division, AFS

Garth Griffin, Protected Resources Division, Portland

Liz Gaar, Habitat Division, NMFS, Portland

Jeff Boechler, ODFW Habitat Conservation Division

Geoff Pampush, Oregon Trout

Ken Bierly – Governor’s Watershed Enhancement Board


Botkin, D., K. Cummins, T. Dunne, H. Regier, M. Sobel, and L. Talbot. 1994. Status and future of salmon of western Oregon and northern California. Report No. 8 (Draft). The Center for the Study of the Environment, Santa Barbara, California.

Espinosa, F. A., Jr., J.J. Rhodes, and D. A. McCullough. 1997. The failure of existing plans to protect salmon habitat in the Clearwater National Forest in Idaho. Journal of Environmental Management 49: 205-230.

FEMAT (Forest Ecosystem Management Assessment Team). 1993. Forest ecosystem management: an ecological, economic, and social assessment. U.S. Government Printing Office 1993-793-071. U.S.Department of Agriculture, Forest Service; U. S. Department of the Interior, Fish and Wildlife Service, Bureau of Land Management, and National Park Service; U. S. Department of Commerce, National Marine Fisheries Service; and U.S. Environmental Protection Agency. Washington, D.C.

Hughes, R.M. 1995. Defining acceptable biological status by comparing with reference conditions. Pages 31-47 in W.S. Davis & T.P. Simon, editors. Biological Assessment and Criteria: Tools for Water Resource Planning and Decision Making. Lewis Publishers, Boca Raton, FL.

Huntington, C.W., and C.A. Frissell. 1997. Aquatic conservation and salmon recovery in the north coast basin of Oregon: a crucial role for the Tillamook and Clatsop state forests. Report prepared for Oregon Trout, Portland.

Kauffman, J.B., R.L. Beschta, N. Otting, and D. Lytjen. 1997. An ecological perspective of riparian and stream restoration in the western United States. Fisheries 22(5):12-24.

Nehlsen, W., J.E. Williams & J. A. Lichatowich, 1991. Pacific salmon at the crossroads: stocks at risk from California, Oregon, Idaho, and Washington. Fisheries 16(2): 4-21.

Nickelson, T.E. 1998. A habitat-based assessment of coho salmon production potential and spawner escapement needs for Oregon coastal streams. Oregon Department of Fish and Wildlife, Information Reports (Fish) 98-4, Portland.

Noss, R.F., and A.Y. Cooperrider. 1994. Saving Nature’s legacy: protecting and restoring biodiversity. Island Press, Washington, D.C.

Reeves, G.H., and J.R. Sedell. 1992. An ecosystem approach to the conservation and management of freshwater habitat for anadromous salmonids in the Pacific Northwest. Proceedings of the 57th North American Wildlife and Natural Resources Conference: 408-415.

Roper, B.B., J.J. Dose, and J.E. Williams. 1997. Stream restoration: is fisheries biology enough? Fisheries 22(5):6-11.

Slocombe, D.S. 1998. Defining goals and criteria for ecosystem-based management. Environmental Management 22: 483-493.

Spence, B.C., G.A. Lomnicky, R.M. Hughes, and R.P. Novitzki. 1996. An ecosystem approach to salmonid conservation. National Marine Fisheries Service. Portland, OR.

Thurow, R.F., D.C. Lee, and B.E. Rieman. 1997. Distribution and status of seven native salmonids in the interior Columbia River basin and portions of the Klamath River and Great Basins. North American Journal of Fisheries Management 17: 1094-1110.

USFWS and NMFS (U.S. Fish and Wildlife Service and National Marine Fisheries Service). 1996. Environmental assessment for the proposed issuance of a multiple species incidental take permit: Willamette timberland, Weyerhaeuser Company, Benton, Douglas, Lane, and Linn counties, Oregon. Prepared by Beak Consultants, Inc. Prepared for U.S. Fish and Wildlife Service and National Marine Fisheries Service, Olympia, WA.


The following comments are compiled from individual reviewers and are cross-referenced by the page number of the Habitat Conservation Plan (HCP).

I-21. Figure I-2 would be much more informative if it reflected the past 75-100 years instead of just the past 30 of timber harvest.

IV-2. The historical percentages of old growth in Western Oregon range from 35 to 80%. How are these numbers influenced by the definition of old growth and its location (such as western slopes of Coast Range)? What is the current percentage of old growth in the habitat conservation planning area, on the North Coast, and in the Oregon coastal region as a whole, and how does this compare to the historic percentage and distribution?

IV-27. How are changes in base and peak flows influenced by season and ecoregion?

V-3. How are properly functioning aquatic and riparian systems defined?

V-6 and Table VII-6. What was the frequency and extent of periodic natural disturbances? How do these compare with current natural and anthropogenic disturbances? How do human land uses affect natural disturbances?

V-8 & VI-8. The percentages in Table V-1, VI-1 do not sum to 100%. Shouldn’t they? If not why not?

V-9. A major value of down wood is in soil regeneration, especially of soil carbon, and its role in water retention.

VI-3 & VI-41. Soil type and character should also be included in a watershed assessment. Soils must be managed properly for a forest to be managed properly. Employees should be trained about high-risk soils.

VI-4. It is critically important to define what timely recovery is. Recovery is most often taken as an improving trend, even if barely perceptible, even if it would take 200 years to reach an endpoint, or even if only based on management assumptions that are not well or frequently monitored. It is also important that more than riparian areas be managed so as to bring about stream and fish recovery. Recovery will only be achieved when the entire watershed is effectively managed to prevent and reverse stream degradation.

Too much emphasis is placed on the riparian area providing sediment routing and storage functions. Nothing is said about sediment delivery functions. Large woody debris (LWD) management has its role in sediment routing and storage, but the processes that accentuate sediment delivery to the channel are inadequately discussed. Watershed alterations can result in major changes to the hydrologic regime and consequently the sediment input and transport functions.

VI-6. The objective is to maintain water quality conditions to support ecological processes important to fish and wildlife production. All the significant ecological processes are not known with any certainty and can not be itemized. Although the idea of ecological processes may provide a useful abstract concept about what sort of system is desired, more concrete standards need to be applied.

A strategy is to focus on standards for turbidity, water temperature, and forest chemicals. Sediment-related standards will be addressed by application of Best Management Practices (BMP). Sediment routing and storage processes will be maintained. The plan should identify a substrate standard for fine sediment as an objective. A turbidity standard alone will not suffice. Relying on BMPs essentially means that there will be no adaptive management–i.e. there will be no instream condition that would result in changing a BMP, even if all pools filled with sediment or spawning gravels became choked with fines. This management scenario calls into question whether the intended objective of ecosystem processes is anything other than rhetoric. If channel substrate becomes inundated with fine sediments due to inadequate BMPs applied to the watershed, it is doubtful whether a strategy to maintain sediment routing processes can either be understood or translated into an adaptive management procedure.

Define proper road management and best management practices of forests. How will a disconnection of road drainages from stream networks be achieved? Where will water and sediment collected from the road system be routed?

VI-7. The HCP sets stand management targets for watersheds, but will apply these targets only to 3rd or 4th order stream drainages and only where state ownership exceeds 30%. Yet the HCP represents this as “basin level” management. It is not responsible stewardship of natural resources when the state controls as much as 25% of the land base in a watershed but chooses to let down on its part of watershed management by resorting to a weak set of management prescriptions. True basin level management applies to whole watersheds, regardless of the size of subbasins or ownership. In reality, management targets may have to be more conservative in subbasins where the state does not own as much of the land in order to compensate for conditions on adjacent lands.

VI-7 and VI-8. Despite the acknowledgement of the importance of old forest stands in its basin stand management plan, only 50% of the basin’s stands need to be “old” and old is defined as meeting any of three conditions: understory (11 in. dbh), layered (18 in. dbh), and OFS (24 in. dbh). This could simply mean that future forestry will involve overstory removal, followed by understory removal on a 60-year rotation. This is not new forestry. The fastest rate of harvest applied to tree farms is approximately a 40-year rotation.

VI-9. Functions and processes are mentioned that would somehow be used to massage the width of the Riparian Management Area (RMA). However, the list of processes, methodology for their description and interpretation, and relationship to management are not described, nor is an explanation of why trees would be important in some RMAs but not in others. The plan needs to be much clearer in what it is actually trying to achieve. For example, if cold water temperature is the goal, the plan needs to explain how riparian tree harvest on any perennial or intermittent stream would contribute to this goal. The plan should also explain why inner gorge areas would be more sensitive than floodplains, thus requiring expansion of the RMA. Why is the floodplain zone not included as a key term or a key management area that would require the width of the RMA to be expanded to fully encompass it?

VI-12 – VI-16. How protective are the classification definitions for aquatic amphibians and benthic macroinvertebrates, which serve as prey for salmonids? The 6% gradient cutoff for non-fish bearing streams is not adequately supported in the plan. This standard will eliminate the majority of headwater streams from protection. Although this may be the intent, such a standard will not fully protect fish or maintain or improve their habitat, key objectives of the HCP. Is fish presence in streams to be determined in winter? Classification of streams as fish-bearing/non-fish-bearing is notoriously flawed. It is limited by monitoring efforts and is also biased by currently depressed fish populations in general.

Management based on Properly Functioning Condition (PFC) is basically a stream gestalt method whereby if it looks fairly nice to a stream technician it passes the test. PFC is weak on application of standards. Reference to other managed streams that are judged to be properly functioning is not a useful guide to the true potential of the stream in its restored state.

“A portion of the waters will be managed for conditions associated with mature forests…based on the assumption that these seral conditions support a majority of the functions and processes of properly functioning aquatic habitats. The remaining waters will be managed in a manner that supports the maintenance or restoration of identified aquatic functions and processes.” It is not clear how a riparian area can be managed to support maintenance or restoration when only 50% of the watershed after a 50-year period will be in states where the trees are >11 in. dbh. It may take no more that 20-25 years to produce such a seral state. Supporting maintenance appears to mean simply not causing the stream to become further degraded. This management philosophy does not acknowledge the fish production potential of a watershed based on historic conditions and recovery potential.

Requiring only some stream reaches to provide cool water is not sufficient when attempting to address violations of water temperature standards. Managing fish or amphibians on the basis of thermal refuges is not an ecosystem approach. Incremental increases in riparian shading might provide a slight improvement in the thermal regime for the stream but protecting only portions of perennial streams and none of the seasonal high energy transport streams will not result in attainment of water temperature goals. Streams with seasonal flows may tend to appear dry in general by July 15 (per definition on page VI-12). However, even when flows in such streams are very low, seepage exposed to intense radiation can become heated and streambed heating will transfer heat to subsurface flows. These sources of heating contribute warm water to fish-bearing tributaries. In addition, seasonal flows vary from year to year. A stream that is dry on average by July 15 one year may still be flowing by August 15 the next year. Summer flow in July and August represent one of the more critical periods of the year for anadromous fish rearing conditions. These are the very months in which all sources of heated water should be controlled. Knowledge of long-term mean flow characteristics for July 15 is likely very limited for most streams. These guidelines are not erring on the side of fish; rather they place anadromous fish at continued risk.

Tables VI-2 and VI-3 (pages VI-17 – 26). All riparian zones should be managed for mature forest conditions. These conditions should encompass the recognized ecological values of riparian areas and their contributions to the maintenance and recovery of stream habitat. The interim management standards for Type F stream RMAs are virtually identical in basins having basin level stand conditions below target level as in basins where stand conditions are above target levels. The only difference is that if the basin level stand condition is below target level, 20 or more conifer trees and snags per acre need to be retained in the outer RMA rather than 10. No minimum size is specified on snags. In fact it appears that the leave trees in the outer RMA could all be small snags.

Partial cutting is allowed along fish bearing streams in the inner RMA zone as long as the density is not below Stand Density Index (SDI) 30. SDI 22 was defined as 120 ft2 basal area but the standard was not defined. It is stated that desired mature forest condition is the target for the inner RMA and that this equates to a basal area of 220 ft2/acre. It is not clear how partial cutting or how allowing up to 10% of the stand to be knocked down in the attempt to harvest the outer RMA will achieve mature forest conditions. Further, the 10% of the stand that would be knocked down is not even added to the amount of the partial harvest. It is simply not feasible to expect progress in cooling stream water when so much latitude is given to harvest in the inner RMA. The plan does not even state that clearcutting is prohibited so long as the mature forest conditions has not been reached. With all the allowance being made for conducting partial harvest and managing for relatively young (and short) conifers, it hardly seems worth the effort to mention the value of retaining greater amounts of the outer RMA to increase shade cover and improve the microclimatic effects of cooling the air temperatures near ground level in the riparian zone. Although the tables indicate that 80-100 year old conifers equate to 40-45 trees per acre (TPA) of 32 in. dbh, this is merely a conversion factor. There is no indication that the “mature forest condition” would be, in reality, significantly greater than 11 in. dbh (the minimum diameter expected). After all, management to the minimum is all that is required.

VI-26. Table V-3 should be Table VI-3.

VI-29. “Given the relatively young age of many stands in the plan area, waiting thirty to fifty years for the restoration of long-term processes, such as large wood recruitment, may pose a higher risk to the survival of depressed populations than the risk associated with active habitat restoration efforts”. If the condition of the stands in the plan area is as young as indicated, the most logical action is to allow no harvest in the streambank and inner RMA zones at a minimum. To express concern about the very young age of existing stands in watersheds of the plan area as a way to justify conducting active instream restoration is a disingenuous concern for fish. Real concern for fish would be expressed in riparian management standards by not allowing harvest within 100 feet of streams at a minimum.

Section VII-throughout. Habitat monitoring should be recognized as a merely an index of what the habitat is doing; it is not a surrogate for direct measure of the species of concern. Monitoring can be fraught with assumptions, therefore habitats may be perceived as adequate, yet owls and murrelets may still decline because some the measured habitat was not a true reflection of habitat quality or a critical habitat component was not monitored. If the concern is with species, then species must be directly monitored.

Section VII and IX-throughout. We are concerned with leaving monitoring needs, priorities and implementation to districts and basing them on district and basin needs. If the Oregon Plan is to succeed we must also have a broader perspective at the state and ecoregion scales. If monitoring data are to be applied statewide, they must have common assessment questions, sampling designs, sampling protocols, and data reporting. Otherwise the data will not be compatible for large-scale assessments, and implementation will likewise suffer (see Spence et al. 1996 for suggestions).

VII-2 & VII-13. Normal system variability is not a response to human use. The variability of natural and human use systems should be compared. How will variability from various sources be established? Current research has found this to be a nontrivial issue deserving considerable attention.

VII-3. Development, maintenance and enhancement of actively managed systems should be compared with those in natural systems.

Assumptions underlie management effects and actions; does this mean that these will not be monitored or only monitored by universities? A monitoring plan should evaluate the underlying assumptions as well as management actions and their effects.

VII-4 and 5. Peer reviews by district employees and Salem staff are insufficient. The critical component of peer reviewers is that they be independent and not biased by employment, payments, or perspectives of those being reviewed.

VII-5. All monitoring should be statistically valid. Monitoring is simply the data collection phase of research. Because research questions differ, so do monitoring designs and indicators. The distinction between research and monitoring outlined here, though common, is trivial. Research should be conducted to evaluate management and cause-effect relationships; monitoring is needed to collect data for both.

VII-9. The levels listed are indistinct. There is a mix of time (annual), space (area), and activities (program, plans). Where do the districts fit in each?

VII-11. The interaction of various spatial and temporal levels of planning, monitoring, adaptive management, and use of watershed assessments appears to be very confused in the Aquatic and Riparian Strategies. It would seem that watershed assessments should have a more central role in setting basin-wide, long-term plans. Its use in annual operations and site-specific levels seems to be beyond its capability or below its true value.

VII-13. “when an action’s effects are overlaid on the natural variability of the system, data is [sic] often difficult to evaluate.” These comments imply an intention to highlight difficulties in differentiating effects of management against the background of natural events. This is always a challenge and can necessitate significant effort in monitoring to reveal the actual effects of management. Relative to water temperature monitoring, there are numerous streams in the Plan area that do not meet state water temperature standards. Nowhere does the monitoring plan indicate that compliance with state standards will be a monitoring priority. In fact, water temperature is a medium priority question (page VII-35). The monitoring Table VII-5 does not really indicate what will be done. It merely lists some potential questions that might interest district personnel. With the monitoring plan so amorphous, it is questionable how rapid the response would be to negative trends that may be present. Unless some very specific questions relative to the effects of management on stream temperature can be listed, one wonders what approach temperature monitoring will take. Half-hearted attempts to monitor temperature dynamics will certainly confound response to management with natural variation. The effect of riparian harvest on stream heating is so clearly understood from innumerable research studies that it becomes hard to comprehend how canopy removal can be sanctioned at the same time that monitoring is being conducted to hopefully show that effects were minimal or limited in scope spatially. A decision is needed about the objective of water temperature monitoring at such a small budget and site-specific scale: is it to challenge all of what is known about physics of stream heating from extensive research studies; is it to decide if intensive individual projects will be intensively analyzed; is it to determine if gains are being made in usable habitat at the basin scale; or it is to determine if state standards are being met in any given reach?

VII-14. Will salmon reports be submitted to NMFS or the Independent Multidisciplinary Science Team of the Oregon Plan? We recommend that these entities be included and consulted.

VIII-3. It is a common fallacy that USGS hydrologic units represent basins or watersheds. They don’t and this is one reason they were named units (see Omernik and Bailey 1997) for clarification.

Omernik, J. M., and R. G. Bailey. 1997. Distinguishing between watersheds and ecoregions. Journal of the American Water Resources Association 33: 935-949.