242 



DRAFT 



Miscellaneous Natural Sediment Losses in Undisturbed Forests (tons per acre f)er 

 year)* 



Lowest Range 



PNW Average Range 



Three Alsea Watersheds Average 



Castle Creek, N. California 



N. Calif. Coast Marine Soils 



0.003-0.031 



0.23-0.55 



0.49 



1.46 



3.13 



Reproduced from the OFIC report; no verification of original data accuracy* 



Chemical Use. Agriculture and Forestry (pages 93. 164 and 174): 



The information presented in the table on page 93 is misleading, and does not appear to 

 be reflective of the actual total use of chemicals by the forest industry. As noted by 

 footnote "(b)" of the table, the chemical use attributed to "forestry" only includes 

 chemicals applied by the U.S. Forest Service on National Forest lands and is, 

 therefore, a vast underestimate of the total use of chemicals by the forest industry. The 

 estimates for agricultural chemical use are extracted from an EPA report which 

 presumably estimates total agricultural use within the entire nation. The authors of the 

 original report from which this data is extracted (Norris et al. 1991) specifically note 

 that: "these figures underestimate the total use of pesticides in forestry because they do 

 not include pesticides applied by other U.S. agencies or by state or private forest 

 management groups. " The "ratio comparison" prepared by the authors of the OFIC 

 report is not valid since it is based on incomplete data, and should not be included 

 within the report. 



Several other statements in this section of the report are also questionable: 



"These ratios [referring to the previously discussed table] could be 

 applied to the land use acres for agriculture (5.3 million acres crops, 

 22. 7 million acres range) versus timberland (21.9 million acres). 



Application of the chemical use ratio estimates to the agricultural and forest land 

 acreages would result in an inaccurate estimate of relative chemical use. 



"[Pesticide] application is often by aerial spray, except a large portion 

 of herbicide is now hand sprayed . . . " (emphasis added) 



This statement is not substantiated by any literature citations, and is contrary to current 

 forest management trends. The authors may be referring to U.S. Forest Service 

 pesticide use being restricted to hand spray applications due to a nationwide ban on 

 aerial application of these chemicals (Norris et al. 1991). Attributing this trend to all 

 forest lands is not indicative of current land management practices. 



A-36 



