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provide for the production of commodities for sustaining local economies while avoid- 

 ing elaborate transition strategies. I am concerned about the notion of mitigating 

 impacts through assistance programs. 



My level of concern was raised after I became a award of a social and economic 

 policy analysis prepared by Dr. Robert Lee at the Institute for Resources in Society 

 (Robert G. Lee. 1995 Potential Social and Economic Contributions of Small Wood- 

 producing Businesses in the Spotted Owl Region: A Policy Analysis. University of 

 Washington, Seattle, WA). The study analyzed the potential for small businesses to 

 revitalize rural communities whose economies were adversely affected by reduction 

 in wood processing of federal lands within the Clinton Northwest Forest Plant 

 (FEMAT) region. Among the conclusions were: (1) family-wage jobs in the wood 

 products industry have been replaced by sub-family wage jobs largely in the service 

 sector, (2) tourism is unlikely to help very many of the affected counties compensate 

 for the loss in wood products jobs and income, (3) secondary manufacturing may pro- 

 vide some help to a few of the most heavily challenged counties, but will tend to 

 concentrate near urban areas in proximity to transportation nodes and markets, (4) 

 restoration work, along with associated retraining for new occupations, will do very 

 little to substitute for loss of wood product jobs and income, and (5) small wood 

 products businesses engaged in primary manufacturing provide the best opportuni- 

 ties for challenged counties to develop a stable and sustainable economic base. 

 These early lessons from FEMAT should compel the ICBEMP to proceed cautiously 

 when proposing policies that impact resource supplies and the communities depend- 

 ent on them. It is clear to me that the reductions in federal timber supply proposed 

 by the ICBEMP need to be reevaluated and avoided until the expected outcomes of 

 social and economic mitigation and transition strategies are know with certainty. 



CUMULATIVE IMPACTS 



One of the contributors to the current timber sales gridlock is difficulties in con- 

 ducting cumulative impact analyses as part of NEPA compliance on individual sales. 

 These analyses need background material at the regional and watershed level to as- 

 sess potential cumulative effects. It is hoped that the ICBEMP will provide that ma- 

 terial in the DEIS's, the Scientific Evaluation of the Alternatives, and/or the Sci- 

 entific Assessment. The project managers need to assess whether the documents 

 will satisfy future NEPA requirements. Without sufficient background material the 

 gridlock will likely continue. 



BROAD SCALE MODELING ANALYSES 



We have conducted several studies to evaluate the ability of broad-scale ICBEMP 

 forest inventory and GIS data to provide an assessment of forest conditions appro- 

 priate for setting forest ecosystem restoration activity levels and for directing ac- 

 tions where forest treatments are most needed. We conducted several exercises in 

 which we compared data generated by the project, which to my knowledge has not 

 been statistically validated, to a more detailed independent data set based on sat- 

 ellite imagery that was acquired from the Forest Service. The ICBEMP data set has 

 limitations when applied spatially to finer scales of management such as those used 

 at the National Forest or BLM district level, or those needed for amending forest 

 and land management plans. Additionally, we have revealed concerns about the ac- 

 curacy of the ICBEMP broad-scale forest inventory data, particularly its representa- 

 tion of forest tree diameters and volumes, forest structural stages, species composi- 

 tions, and the portrayal of forest health. 



In comparing results from the two sets of data, conflicts between (1) forest man- 

 agement information derived from broad-scale assessment data and (2) inferred 

 management needs and priorities from higher resolution and more accurate fine- 

 scale inventory analysis were revealed. It appears that there is a disconnect be- 

 tween the ICBEMP's broad-scale forest ecosystem assessment and the fine-scale 

 data needs of local managers for planning and implementing ecosystem manage- 

 ment strategies. Fine-scale assessments similar to the ones described in our studies 

 will be needed to refocus future management direction subsequent to the ICBEMP. 

 A process for resolving these conflicts is needed for seamless implementation of eco- 

 system management strategies at all scales. Furthermore, it is unclear how the 

 ICBEMP will use its Scientific Assessment to identify forest health hazards and 

 risks as they relate to wildfire, insects, and disease potential, and that are ex- 

 pressed by forest vegetation conditions. 



I hope these comments are helpful to you in your review of the ICBEMP. Thank 

 you for this opportunity. 



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