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DRAFT 



Regulations and Practice ^ rpages 95 and 169): 



The authors cite several provisions of the Oregon Forest Practices Act incorrectly: 



'Buffers. . . were. ..maintained on state Class I streams to protect soils and 

 provide 75 percent of shade. ' 



'. ..and streamside vegetation were to be in near natural condition. ..and 

 provide for 75 percent pQU operation shade cover. ' (emphasis added) 



'The 75 percent stream shade rule was retained with the addition of a 50 

 percent overstory canopy rule. . . Trees mav be cu t in the RMA. if the 

 actual riparian zone meets the 75 percent s tream shade and 50 percent 

 oversiorv canopy rules . ' (emphasis added) 



'The 75 percent post operation shading rule was retained and a 50 

 percent canopy rule was added. . . Trees could be cut in the RMA if the 75 

 percent post operation stream shading and 50 percent canopy 

 requirements were met. Otherwise, timber in the RMA was protected to 

 meet the shade and canopy rules. ' (emphasis added) 



These rules are improperly interpreted and do not reflect the current management 

 restrictions placed on timber harvest activities within Oregon riparian management 

 areas (RMA). The correct language of these rules is as follows: 



OAR 629-24-546 (3) (a) Maintain an average of 75 percent of the preoperation shade 

 over the aquatic area along Class I waters. 



OAR 629-24-546 (3) (b) Retain at least 50 percent of the preoperation tree canopy in 

 the riparian area along Class I waters. 



Timber harvest activities are currently allowed to reduce existing shade and overstory 

 vegetation to 75 percent and 50 percent, respectively, of preoperation conditions. 

 These regulations are not currently based upon postoperation conditions as the report 

 states. The authors also imply that timber harvest activities are restricted if 

 preoperation conditions are less than 75 percent shaded and 50 percent overstory 

 canopy closure: these restrictions are not a current requirement of the Oregon Forest 

 Practices Act. For example, recent monitoring conducted by the Oregon Department 

 of Forestry indicates that, on the average, shading on streams within the ODF 

 Northwest Region was reduced from 83 percent preoperation levels to 61 percent 

 following logging (ODF, Water Temperature document from technical workshops 

 related to SB 11 25). 



This section should be rewritten to reflect the actual legal requirements of the Oregon 

 Forest Practices Act. 



A-37 



