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. People felt that they would no longer be able to access the land and enjoy its pristine state. (387-2, 2001-18, 3140-3) The following are examples of this group:Comment: 38-2: It takes into concern the natural habitat at the land but not the human factor..
Comment: 1035-6: What would be the effect on surrounding property owners?
Comment: 14-2: How about the personal effect on me and my family if I can't use that land anymore?
- Response: Additional effects analyses have been added to the FEIS especially those relating to social and economic impacts. Adjacent landowners and visitors who use lands acquired by Crown Pacific that lie within this interface area would continue to enjoy many of the amenities they currently enjoy. The feeling of open space and being in a natural surrounding or the ability to access forested lands for recreational or spiritual purposes would not be noticeably different within the interface zone. Changes in resource conditions readily visible to adjacent land owners would be similar to activities which might typically occur if the ownership did not change.
- A section on Scenic resources has also been added and discloses the impacts of the land exchange on specific areas frequented by the public. Once the land is exchanged, the existing landscape characteristic and scenic integrity level would reflect Crown Pacific current forest management philosophy, policy, and style. Conversely, the existing landscape characteristic and scenic integrity level would reflect the Forest Service current forest management philosophy, policy, and style which is less active and places more emphasis on scenic values.
- A survey of County records on property values did not indicate a significant difference in values of land adjacent to National Forest System lands. Property values were more influenced by acreage, number of bedrooms, bathrooms and square footage of living space. The County does not have a factor to increase property values for tax purposes if the property is adjacent to federal lands.
Comment: Cutting or thinning of timberlands causing fragmented scenic areas. (316-4)
- Response: A section on Scenic resources has been added to the FEIS and discloses the impacts of the land exchange on specific areas frequented by the public. Once the land is exchanged, the existing landscape characteristic and scenic integrity level would reflect Crown Pacific current forest management philosophy, policy, and style. Spiritual and social benefits from lands that contain late and old structural characteristics which may be harvested by Crown Pacific would be reduced over current conditions. Conversely, the existing landscape characteristic and scenic integrity level would reflect the Forest Service current forest management philosophy, policy, and style which is less active and places more emphasis on scenic values.
Economics Comment: Explanation is needed to explain why the proposed action would affect total payments by 1%. The payment to counties is vague does not disclose the pertinent information so the public and decision- maker is fully informed. (342-12)
- Response: Based on the total number of NFS acres in each county and the total payment provided to each county, the proposed action would affect the total payments to counties by less than 1%. For example in Lake County, the total payment in FY 96 was $1,341,879 and the total number of NFS acres was 1, 030,101. Based on the total payment and total number of acres, Lake County received an average of $1.30 per acre of NFS land. As a result of the proposed action, the number of acres in Lake County would decrease by 484. The total payment to Lake County, based on FY 96 payments, would be reduced by approximately $629 (484 acres x $1.30).
Comment: My concern is the loss of property taxes on the Crown Pacific land that will be exchanged for National Forest land. (111-2)
- Response: Counties receive payments in lieu of taxes when timber harvest takes place on National Forest System lands. Therefore the amount that counties receive from federal lands is dependent on the volume of timber sold, the selling price and restoration work necessary for mitigations of the activities.
Comment: If the public land traded to Crown Pacific is logged and then developed, or sold to a developer, then Crown Pacific ends up with no tax liability, ..development requires water, roads, schools, more taxes and a layer of government. (111-3)
- Response: Crown Pacific pays annual ad valorem taxes (taxes in lieu of property taxes) and pays harvest taxes when logging takes place. County zoning and land use laws require developers to address impacts to roads, water and other public systems when developing subdivisions.
Comment: The economic costs to the public for the proposed action (p.99) far exceed the benefits. Lands slated for exchange are those that are among the most valuable for recreation, which involves natural beauty. ..which the natural environmental systems have become the main basis for the entire economic development of Oregon. This is the foundation for the new economy. It is sustainable and promotes wildlife and CO2 absorption. The DEIS cites none of the literature which documents how timber economies produce slow growth and high unemployment. (251-4)
- Response: The Responsible Officials need to weigh a variety of factors when deciding which alternative to select. They also need to weigh the long-term benefits against the short-term costs and considering all factors including recreation. In a consolidated ownership pattern, the length of the external and internal boundaries are less and costs for posting and maintaining boundaries are less. Overall, property boundaries requiring survey, posting, and maintenance would be reduced by approximately 320 miles. The three National Forests would share approximately 170 miles of joint boundary with Crown Pacific. This reduction in boundaries would result in long-term savings to the government from reduced costs for boundary maintenance of approximately $9,900 (33 miles per year x $300 maintenance cost per mile) per year. New costs associated with establishing and posting new land boundaries would be approximately $14,400 (based on approximately 4 miles of new exterior boundary, surveyed and posted at $3600 per mile).
Comment: Crown Pacific would intensively manage the lands which will have an impact on the deer and elk population. In time, with a decrease in this populations, the economy, by the lack of hunters coming into our small communities during the hunting season, will be adversely affected. (252-2)
- Response: As discussed in the Social/Economics section of the FEIS, the small rural communities are likely to incur the greatest direct social and economic effects of the land exchange. However, the environmental analysis does not predict a measurable adverse affect on deer or elk populations, nor a reduction in the hunter access as a result of the land exchange, so there is unlikely to be a predictable or demonstrable cause and effect relationship between the amount of hunters in the local communities and the land exchange.
Comment: Crown Pacific economic impact on the region and individual communities is greatly underrated. They create many jobs directly, indirectly through contractors and services needed. This project is good for the economy of this area. (262-1, 267-2)
- Response: Klamath and Lake County economies have been fueled by more traditional markets in agriculture, lumber, and wood products. Employment in trade, services, and government provides a degree of stability to these primary markets. Commensurate with these county economic projections, employment within the Gilchrist-Crescent Community (Klamath County) is influenced by Crown Pacific. Crown Pacific estimates that 300 jobs are provided from the Gilchrist mill and surrounding Crown Pacific lands. However, only 40% of Crown Pacific's raw material is supplied by it's own land. The proposed exchange lands constitute less than 1% of Crown Pacific's land base in Oregon. The proposed action, as disclosed in Chapter 3 of the FEIS, would have no distinct effect on the regional or local economy.
Comment: The impact upon La Pine area alone amounts to double digit millions of dollars. They plan to donate land to La Pine Senior Center and La Pine Park & Recreation District. (267-3)
- Response: This comment is in support of the land exchange and the commentor feels there will be significant gain to the public by the land exchange. The FEIS attempted to disclose the economic impacts of the land exchange in the Economic and Social Environment Section of the FEIS. There would be no direct change to the current social and economic conditions and trends of the region described in the affected environment section. Based on the relatively small amount of lands involved in the proposed trade when compared to either the total land base of the landowners or the counties, it is unlikely that changes in the social and economic conditions of such a vast and diverse region could reasonably be traced to the activities which would take place within these lands, regardless of ownership.
Comment: The DEIS states that "private timberlands have a more stable timber supply than public lands". This is simply not true. (342-16, 350- 9, 370-1, 376-11, 1067-6)
Comment: The amenities on federal lands strongly influence the locational decisions of households and firms and shapes the overall structure and strength of the local economy. The Forest Service has failed to examine proposed actions in the light of this new economic reality. (1067-8)
Comment: Deschutes County's non-timber sectors made up the ground lost by the shrinking timber sector and still had enough strength to yield whopping increases in the overall economy. This economic transformation- a long-run trend, not a short-run cycle- is easily the most important fact to report about the "economic and social environment" and yet the DEIS doesn't mention it. (1067- 5)
Comment: The DEIS fails even to mention, let alone account for the significance to its evaluation of such key long-term trends as the declining role of the timber industry, the increasing importance of amenities in the locational decisions of workers, households and firms, and the continuing integration of nonmetropolitan and metropolitan areas. (1067-7)
Comment: The Forest Service cannot (and does not) fully describe the environmental and economic consequences of the proposed exchange unless it shows how the exchange will affect the private sectors of the local economy- including the real estate market- that are linked to the recreational opportunities on federal lands. (1067-4)
Comment: The DEIS on page 99 states, "The exchange could provide favorable effects on the local economy." Nothing could be farther from the truth, it will probably have a long term negative effect on the local economy. Losing 3,500 acres of old growth ponderosa pine with its associated wildlife habitat, and recreation opportunities will impact tourism. (1068-13)
- Response: The Social and Economic Section of the FEIS has been rewritten to more fully describe the social and economic values of the proposed exchange lands. See Chapter 3 of the FEIS.
Comment: Ponderosa Pines community has a big tax base and that should not be ignored. (386-1)
- Response: As discussed in Chapter 3 of the Final EIS, the proposed exchange of lands would have an immeasurable effect on the assessed values of property.
Comment: Who is going to police Crown Pacific on the amount of timber harvested for tax purposes? (388-9, 389-9)
- Response: All timber harvested from private land must be reported to the Oregon Department of Revenue at the time timber harvest and severance taxes are paid voluntarily. The Department of Revenue has unlimited authority to audit the landowner's records of removal, including the volumes for which logging contractors and haulers were paid to remove, volumes used in manufacturing facilities and volumes sold to others.
Comment: I am deeply distressed that these issues (recreation, old growth, socio-economic) have been overlooked by the Deschutes National Forest who knows full well that tourism, recreation and quality of life in Deschutes County provide the #1 source of revenue. (420-2)
- Response: These concerns have not been overlooked, but were addressed in less detail in the DEIS. Old growth has been addressed as Late and Old Structure (LOS) stands and was considered a key issue, additional analysis is also presented on the impacts to wildlife species associated with LOS habitat. Analysis of the issues which you referred to (recreation, old growth, socio- economic, etc.) is presented in the DEIS, with augmented information presented in the FEIS. In addition, a section under the Economic and Social Environment discloses the impacts to local and regional economies. Impacts socially are also disclosed. Crown Pacific's land management policy states that they will allow public recreation on their lands while reserving the right to close access if damage is incurred from public use, therefore it is expected that recreation opportunities would not change.
Firewood Comment: In the 1990 Deschutes LRMP it talks about providing for personal use firewood. In the Crescent R.D. area personal use firewood is vital to the community and also to the Willamette Valley people that come to the area for their firewood. At the December public meeting in Gilchrist, the Crown representative stated that Crown Pacific wanted all the dead lodgepole they can get for chips and that people could pick up limbs for their firewood. The National Forest is for multiple users and firewood gathering is another use of the forest. (252-4, 1033-1)
- Response: The Deschutes, Winema, and Fremont National Forests will continue to offer firewood before, during, and after the proposed exchange in accordance with the Forest Plans. The amount of firewood available is unlikely to change significantly, based on the amount of lands proposed for trade. The location of public firewood gathering areas change periodically regardless of the land exchange, as supplies fluctuate with public demand, mortality rates of the forest, and resource needs. Crescent area residents will likely have to travel farther to gather firewood.
Greenbelts Many commentors expressed their concern about the importance of maintaining a " green belt" of public lands between existing blocks of private lands in order to prevent future development and provide area residents with open space adjacent to development. Examples have been cited of where cities or counties have had to repurchase lands they sold or traded to developers in order to maintain this desirable open space. Many people see National Forest System lands involved in the exchange as fulfilling this important function. The following are examples of comments received:
Comment: 360-1: In light of the phenomenal growth that Bend has experienced: 48% from 1990 to 1997, it is imperative to retain green belts and recreational areas for both the current and future generations.
Comment: 105-2: ..public land buffer area lying between the present built up area and Crown Pacific land is essential. Public access to Forest Service land and protection from urban development would be accomplished.
Comment: 3146-4: Our communities are defined by public greenspaces - this transfer of land to private entities will increase urban sprawl and development.
Comment: 2001-17: How does the land exchange prevent urban growth when it can be sold for urban uses as has been indicated?
Comment: 293-4: Please discount the comments you receive asking that the USFS to provide a buffer between rural land owners and commercial forest land. This is not a proper use of Federal Lands.
- Response: Maintaining open space free of development within a localized urban or rural setting is more appropriately the responsibilities of the local or State governments which regulate private land development than that of the Forest Service, who's mission is to manage large tracts of forest land for the national public benefit. The mission of the Forest Service is not to prevent urban growth. From a national perspective, lands immediately adjacent to private development - especially where public land becomes an inholding to privately owned residential development - requires a higher per acre cost to manage and protect than other lands. These costs are reflected by a need for more administration of those lands in response to private landowner concerns and often reflect a higher percentage of trespass incidents than interior forest lands. Fire suppression costs and values at risk from wildfire spreading from these lands are elevated as well. The more isolated parcels become from the larger blocks of forest, the less effectively the block of land can be managed as a public forest or as wildlife habitat.
Property Value Many commentors expressed concerns about what the proposed land exchange would do to their property value. The following are example comments.
Comment: 27-1: Most of us probably made our initial decision to buy our property because we were surrounded by Forest Service land. In fact most real estates ads mention this fact.
Comment: 133-3: Property values would fall.
Comment: 163-1: Reduction of property values: Our retirement savings is invested in our home here in Ponderosa Pines and being on a fixed income, it would be impossible to relocate.
Comment: 320-1: When I purchased my property which borders on Forest Service land, believe me that if Crown Pacific gets the property my property will devaluate considerably.
Comment: 337-1: Is this going to mean the property will be of less value or stricter rules and regulations governing the property? Could you explain as to what this land exchange means? Will we have to pay higher taxes?
Comment: 430-7: We estimate a loss in value if the land is exchanged of 16 - 17%. This will affect not only the property owner, but the Realtor's resale commissions, and most important, the County of Deschutes tax base.
- Response: Adjacent property owners are concerned that once Forest Service lands are transferred to Crown Pacific their property values will be negatively affected. Residents of Ponderosa Estates through their joint letter stated that on average the values would decrease in their subdivision by 17%. Comments from those in the Tumalo area were less than specific as to how much they felt their property values would decline but stated in general terms that their property values would be negatively affected. Several commenters related lack of access to lands once in Forest Service ownership would also affect adjacent property values negatively.
Based upon discussions with the Deschutes County Assessor, there is no direct relationship in assessed property valuation between properties immediately adjacent to Forest Service lands and others non-adjacent properties of like size and value. The are many other factors that are considered when reaching current assessed values following the schedules used by the County Assessors Office. These schedules take into consideration such things as lot size, dwelling size, number of bedrooms, bathrooms, decking, landscaping etc. and also use comparable sales in the same area to determined the assessed value. Over time market values will influence assessed through the inclusion of comparable sales into the schedule formula.
- hus it is very difficult to determine if property values will decline in any given area adjacent to Forest Service lands upon the completion of the proposed land exchange. Property value is only determined at point-of-sale and thus its value in the marketplace is based on what a buyer is willing to pay to a willing seller. Thus any assertions of property value declines as the result of the proposed land exchange are speculative and cannot be determined.
Quality of Life Many commentors raised concerns about the indirect effect the land exchange would have on their quality of life. These commentors were primarily adjacent or nearby landowners, who regularly recreate or otherwise use the national forest lands closest to their properties. Most of the commentors stated they had purchased their property primarily because of its location next t 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.
Besides what they 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 commentors 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.
Comment: The reason we bought property in Ponderosa Pines is because it was surrounded by Forest Service land. If they rape, pillage and burn this piece of land like they've done in past practice our quality of life will drop. (56- 2)
- Response: Crown Pacific has indicated their willingness to work with adjacent landowners to address their issues of access and vegetation conditions by providing in writing to maintain an urban interface zone within which modified management will occur. This proposal (Appendix F) ensures that fences will not be erected, nor will emergency and other access notably change, except perhaps through improvement. It agrees to maintain a certain large tree component in the stands within the interface zone. Landowners desires to maintain vegetative conditions as they currently exist are not likely to be met. However, it should be recognized that these expectations may not necessarily be met under current ownership, either. Currently, much of the land adjacent to rural residential lands is available for harvest under the Forest Plans. Lands within the Deschutes National Forest are reviewed and evaluated on a rotating basis to determine if desired future conditions projected by the Forest Plan are being met. Proposed treatment plans for this area have been deferred for some time because of the pending land exchange. Many of the expected consequences of timber harvest such as noise, dust, logging traffic, and the visual appearance of a post-harvest area would be similar regardless of the ownership.
- A primary difference is the amount of public involvement that would be involved in the location and amount of timber harvested from a particular area. For all federal actions, that would require further consideration of public comment and, under current laws and regulations, an opportunity for landowners to appeal and litigate the decision. For forest lands under private ownership, there is no requirement for consideration of public opinion, and no opportunity to litigate if activities are conducted in accordance with the State Forest Practices Act. Another difference is the agreement that Crown Pacific has initiated with private landowners. Adjacent landowners are unlikely to get an agreement with the Forest Service to maintain a modified management area for their benefit if it does not provide a greater public benefit, or is not already prescribed by the Forest Plan. Currently, no such prescriptions exist in the Forest Plans. The Forest Service has partnered with adjacent landowners to achieve desired vegetative conditions within the forest, and, in general, tries to minimize the impacts of harvest activities to adjacent landowners. Crown Pacific has shown its interest in developing the same relationships with adjacent landowners by proposing the Ponderosa Pines Management Area and have in the past worked with landowners when marking timber.
- In the absence of a catastrophic stand-replacing event such as a wildfire or insect epidemic on the proposed exchange lands, the amount and distribution of " old growth" trees is likely to be less under Crown Pacific ownership than under Forest Service management. Eastside Interim Forest Service (Eastside Screens) management within the exchange lands requires comparison of the amount of trees over 21" in a given watershed with an estimated "historic" range before any trees at or above that size are harvested. The Eastside DEIS (Interior Columbia Basin Ecosystem Management Project (ICBEMP) proposes continued emphasis on protection of this stand component to varying degrees across the Columbia Basin.
- Crown Pacific raises trees for the primary purpose of harvest and to provide the greatest economic return to the land owner. Thus, it is reasonable to assume that, as market conditions and management goals dictate, those trees which are over 21" are likely to be harvested. Some old growth components may be sustained as they contribute to long term site productivity, provide for threatened and endangered species, or meet Crown Pacific's long term management goals, but the amount and location is not reliably predictable.
- This expected reduction of old trees is an identified irretrievable commitment of resources identified in the EIS. It is one of the trade-offs which were considered in the Forest Supervisor's decision (see ROD).
Scenic/Personal Comment : People would not be able to enjoy the natural forest - humans would suffer from growth that is going to be cut down. (3123-3) Thinning of timberlands would cause fragmented scenic areas. (1054-3)
- Response: Crown Pacific has a record of actively managing its forested lands with more emphasis on timber production than the Forest Service. Once the land is exchanged, the existing landscape characteristic and scenic integrity level would reflect Crown Pacific current forest management philosophy, policy, and style. Crown Pacific's active management practices focus on uneven-aged management and utilization of dead and down timber to reduce fire hazard, especially near urban interface areas. Crown Pacific's management activities will lead to more open forest stands.
- Conversely, the existing landscape characteristic and scenic integrity level would reflect the Forest Service current forest management philosophy, policy, and style which is less active and places more emphasis on scenic values. Current National Forest System lands adjacent to subdivisions are presently being managed intensively in places to reduce the risk of catastrophic fire, this includes reducing the amount of trees per acre and slash and brush on the ground.
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