88 



prescribe that every acre of forest has the same prescribed conditions. That is not natural 

 nor desirable however, the ROD for The Presidents Forest Plan requires it. 



The solution is to require general management plans over the landscape and on a larger 

 scale and for longer periods of time for each forest alIo\«-ing discretion for existing diverse 

 conditions, thus steering clear of prescriptive, regulatory administrative rules, that do not 

 match the conditions and many times are based on incorrect assumptions. 



The Adaptive Management Area (ANlA) should be the creative experimental area where 

 new forcstrj- techniques are tried, however, the AMA's arc bound by the same 

 administrative minutia of prescriptions and layers of screens and administrative review as 

 the matrix, the LSRS and other areas . Under the guidelines the manager must still 

 address the concerns of elk thermal cover, big game winter range, visuals, archeologjcal 

 sites, ephemeral streams, wildlife connectivity corridors and sensitive plants that are 

 neither threatened nor endangered and the list goes on and on. As an example, the Squaw- 

 Elllot timber sale in the Applegate, where the stand has been identified as a high fire 

 hazard and risk. Under guidelines in both the Rogue LRMP and the NW Forest Plan, 

 there arc all the concerns mentioucd above. The archeological site is a mining ditch and 

 the visual is a lake and the streams run a little water when it rains but have no annual 

 deposition and scour. ^Vhen you screen for all these values, and require helicopter logging 

 as specified by the local hydrologist, even though immediate and cost effective treatment is 

 desirable because of high fire hazard, the sale is not practical with this burden placed on it. 

 Even in the AMA we cannot accomplish a common sense goal of reducing fire hazard, 

 because of regulation and cost escalation. ( The constraints assume that any disturbance 

 will damage the environment when we have scientific evidence and history that show us the 

 natural system in the forest is created by natural disturbances and catastrophic events 

 which humans have altered in the last 10,000 years.) There is not enough flexibility built 

 into the ROD to experiment making assumptions that are different. Recognizing nuances 

 and differences is the basis for creatr\'c problem solving in science and all other endeavon. 

 The restrictions add up to an equation that guarantees failure. To their credit, the agency 

 managers and personnel try to meet ever more burdensome regulation, but the task cannot 

 be successful as now prescribed. 



