233 



DRAFT 



Page 66, 2.1.10. Flood Control and Navigation 



The following statement is unsubstantiated and misleading: 



"There are 22 major estuaries in Oregon, plus 1 7 minor estuaries:. . . All 

 estuaries were especially critical for native pink and chum salmon, which 

 mostly have disappeared,... " 



There is no evidence that pink salmon were ever native to Oregon estuaries. Chum 

 salmon populations were found primarily in north coastal estuaries with smaller 

 populations occurring in some central and southern estuaries. Only sixteen estuaries in 

 Oregon (including the Columbia River) are believed to have historically contained 

 populations of chum salmon (Chilcote et al. 1992). 



Section 2.2. Land Use 



Page 70, 2.2.1. General 



The authors do not report that the majority of road mileage in Oregon is for the 

 purpose of forest management. Therefore, the negative effects of roads cannot be 

 separated from the other negative effects of logging. 



The following passage is contradictory and the second sentence is unsubstantiated 

 because the citation is not listed in the References. 



'Fine sediments are detrimental to spawning gravel habitats and many 

 millions of salmon and steelhead eggs and alevins have been smothered 

 and subsequently died. However, salmon and steelhead are resilient, 

 and the sediment spawning area impact is not always dramatic (Iwamoto 

 etal.,1978) 



Other citations in this section not listed in the References include: Sidle et al. (1988), 

 Bjomn (1969, 1970), Bjomn et al. (1974), Stober et al. (1982), Duyck (1987), 

 Froehlich (1970), Saltzman (1977), and Burwell (1970). 



Roads rpaees 73-75 and 177-179): 



The report generally appears to be an accurate assessment of the impacts of roads on 

 salmonid habitat, and the relationship of this activity as a factor contributing to the 

 decline of these fish. This section does not identify land management activities 

 responsible for a majority of the road construction affecting salmonid habitat, however. 

 The relative responsibility for road construction may be obtained from a table in this 

 section (page 73) which identifies that 70 percent of Oregon road miles are attributed to 

 an "other" category comprised primarily of forest management roads. In addition, a 

 majority of the literature citations substantiating the impacts of roads were extracted 

 from studies concerning the affects of forest roads. The Department believes that this 



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