A. Introduction
A 60-day comment period was provided for interested and affected publics, including appropriate local, State, and Federal governments and agencies. This period lasted from November 14, 1997 until January 9, 1998. During this period, the Forest Service received a broad range of comments from many sectors of the public. As discussed in the Record of Decision (ROD), comments were incorporated into the decision by the responsible officials. Some comments resulted in additional analysis, such as more study of the recreational use in the Tumalo area. Comments also resulted in modifications to the Proposed Action Alternative, as described in the ROD. Ultimately, the responsible officials weighed the comments in the context of the benefits of meeting the project purpose and need.
Approximately 1,040 separate pieces of mail were received during the comment period. Comments were categorized into general categories, and as necessary, placed into subcategories. The bulk of the comments focused on the following specific areas:
- Social: Many people who commented and attended public meetings were concerned that the DEIS did not take into consideration the human element impacted by the land exchange. They felt that social and economic impacts were not fully addressed and that effects to adjacent property owners were not taken into consideration. Concerns were raised about the importance of maintaining a "green belt" of public lands between existing blocks of private lands in order to prevent future development and to provide area residents with open space adjacent to development. Many people expressed concerns about what the proposed land exchange would do to their property value. Other comments raised concerns about the indirect effect the land exchange would have on their quality of life. These commenters were primarily adjacent or nearby landowners, who regularly recreate or otherwise use the national forest lands closest to their properties. Most of the commenters in this category stated they had purchased their property primarily because of its location next to National Forest Systems, or in some cases BLM, lands. Many comments conveyed the property owner's sense that when they purchased land next to NFS lands, their expectation was these lands have and would remain "the same" as the current condition for as long as they owned the land, particularly the vegetative and recreational access conditions.
- Future Management: Besides what people feel is a threat to their relative privacy, isolation, and personal enjoyment of the National Forest lands, they are also concerned that the conditions will change so drastically under Crown Pacific management as to diminish or eliminate their personal satisfaction with their own property. Some expressed the concern that logging operations would commence nearby when Crown Pacific logs the acquired lands, and that they would be affected both directly from the removal of the natural setting surrounding their home, and indirectly from the dust, noise, and increased log truck traffic associated with harvest activities. Some commenters also felt that Crown Pacific is a desirable neighbor, that they contribute to the local economy and their forested lands also provide amenities to their quality of life. Concerns were also raised about potential residential development within these newly acquired Crown Pacific lands.
- Public Interest: People who wrote comments of support cited the land exchange as being in the general public interest, that it resulted in the acquisition of wetlands, especially in the Tumalo Canyon area, and that the consolidation of lands for wildlife management would be desirable. However, many people raised questions about the public interest served with regard to the area near Tumalo because of its recreational value. They suggested that the lands surrounding subdivisions be removed from the land exchange proposal. Commenters who raised this concern included but were not limited to those who own land adjacent to exchange parcels (Ponderosa Pines and other subdivsions). Many commenters in this category could not see how the exchange was in the public's best interest.
- Access: There were substantial numbers of comments from the Ponderosa Pines subdivision landowners concerning their fear that Crown Pacific, after gaining ownership of the proposed lands, would limit, restrict, or affect their existing use of the lands in question. They were concerned that fences would be built and cited the example of existing Crown Pacific lands that were fenced along Masten Road. They were also concerned that their opportunities for recreational activities such as walking, hiking, horseback riding, bird watching, ATV riding and others would be curtailed, reduced or eliminated by the new ownership of lands by Crown Pacific. Numerous residents of the Tumalo area commented on their concern about transferring land from the NFS to CP. Their belief is that CP would limit their access to recreate on lands. They believe that the Tumalo area offers a unique situation close to a residential area for a variety of recreation activities such as hiking, biking, walking, horseback riding, etc. A few commenters stated that their feeling was that the exchange would result in no change to the opportunities for recreation on Crown Pacific lands. They stated that recreation and access is already occurring on Crown Pacific lands, including the Tumalo area, and that people may not be aware of when they were on federal lands or on private timber company lands.
- Wildlife: Concerns were raised that the exchange will have an impact on wildlife habitat, including mule deer and elk, especially winter range and migration corridors.
- Late and Old Structure (LOS): The bulk of these comments expressed a desire to retain large trees in the public ownership, and so requesting a change in the proposal to keep areas of LOS under Forest Service management
- NEPA: Concerns were raised about having enough information to make a decision, especially in the areas of recreational use and LOS. Concerns were also raised about the range of alternatives pursued during the analysis, as well as the public involvement/notification methods that were used during the planning effort.
- Appraisal: Comments raised concerns about the lack of disclosure of values used in the appraisal. Commenters felt it was difficult for reviewers to gauge public interest when the appraisal information was not made public. Questions also arose over how non-commodity values where accounted for in the appraisal, and whether they had been given adequate weight to avoid "giving lands away."
Other categories of comments were the following:
- Cultural Resources (in particular, sites near Pot Hole Spring),
- Fire Protection (especially near Ponderosa Pines subdivision),
- Forest Health,
- History of the Exchange,
- Lands,
- Noxious Weeds,
- Recreation,
- Riparian,
- Sensitive Plants,
- Sisters 16-acre parcel,
- Timber,
- Water Quality.
Of the 1,040 pieces of mail that offered comment on the proposal, more than half of the respondents (550) voiced their concerns on form letters, pre-printed postcards, a newspaper clip-out coupon, a survey form, and a petition. Of the 2,457 comments counted, 1,150 were offered on one of the as the mass-produced comments forms. The rest of the respondents (about 500) offered about 1,300 separate comments. Although all comments received review, substantive comment received the focus during this comment analysis. Therefore, comments received repeatedly on a postcard or other mass-produced input method have been considered once in their respective categories. For instance, 75 postcard comments expressed concern with future residential development potential on the lands that would be conveyed to Crown Pacific through this exchange. This comment has received a response, located in the "Future Management" category, under the "Development" subcategory.
A few comment letters were received after the end of the comment period. Although not required to consider these comments, the planning team reviewed them and responded to those comments that had not already been given a response. This review found a case where the Oregon Dept. of Fish and Wildlife raised a question about white headed woodpecker viability that had not been previously raised, and so the team elected to respond to this comment. Upon review of other comments that came after the comment period ended, no additional responses were necessary.
B. Comments and Responses
As part of the comment analysis, each piece of correspondence was logged in with a reference number. As comments were identified within each piece of correspondence, a second number was assigned. For example, comment number 100-2 represents the second comment taken from letter number 100. These numbers have been used throughout the comment analysis to assure each comment receives a response.
Once a comment was identified, it was placed into a category (and subcategory as appropriate). Generally, responses were developed to answer questions or provide references to analysis contained in the DEIS, FEIS, or other documentation. Comments may have been answered singly or in groups, with the aim being to provide as specific a response as possible, while avoiding a large amount of duplication of responses.
This Appendix offers a large sample of comments in order to provide an accurate flavor of the input received. However, this document does not provide a complete list of comments. The project file includes a list of comment letters, as well as a list of comments and the categories into which they have been placed. These lists are available upon request.
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