DOUGLAS TIMBER OPERATORS MONTHLY NEWSLETTER
Transcription
DOUGLAS TIMBER OPERATORS MONTHLY NEWSLETTER
DOUGLAS TIMBER OPERATORS MONTHLY NEWSLETTER July, 2012 DTO BOARD OF DIRECTORS SEAN SMITH Starfire Lumber Co. President PAUL BECK Southern Oregon Log Scaling & Grading Bureau Secretary/Treasurer JOHN BLODGETT Douglas County Forest Products STEVE CARTER Northwest Hardwoods MONTE CLOUGH Weyerhaeuser RON DOAN Cow Creek Govt. Offices JIM DUDLEY Roseburg Forest Products DON HARDWICK Swanson Group MIKE KELLER Keller Lumber Co. DALE ROBERTS Lone Rock Timber Co. SCOTT STARKEY Menasha/Campbell TIM VREDENBURG Coquille Indian Tribe CAROL WHIPPLE Rocking C Ranch Director Emeritus EXECUTIVE STAFF BOB RAGON Executive Director AUDREY BARNES Executive Assistant For more information, call (541) 672-0757 FOREST ROADS CASE While the U.S. Supreme Court's latest term was dominated by decisions on health care and immigration, it also included a tremendous ruling for the timber industry. In issuing an order granting certiorari in the Forest Roads case, the Supreme Court agreed to review the infamous Ninth Circuit Court of Appeals decision that forest roads used for timber harvest on federal, state, and private lands are "point sources" of pollution, requiring a National Pollutant Discharge Elimination System (NPDES) permit under the federal Clean Water Act (CWA) for stormwater runoff. In a typical session, less than two percent of all requests are granted review by the Supreme Court. Matters became more complex when Solicitor General Donald Verrilli advised against review, despite Verrilli's unequivocal position in his own brief that the Ninth Circuit ruling was "wrongly decided" and had erred in not accepting the Environmental Protection Agency's (EPA) interpretations of its own regulations. In granting cert, the Supreme Court identified two critical questions: (1) Whether a citizen may bypass judicial review of a National Pollution Discharge Elimination System permitting rule under 33 U.S.C. § 1369, and may instead challenge the validity of the rule in a citizen suit to enforce the Clean Water Act; and (2) whether the Ninth Circuit erred when it held that stormwater from logging roads is industrial stormwater under the rules of the CWA and the Environmental Protection Agency, even though EPA has determined that it is not industrial stormwater. These are excellent questions for industry to challenge head on. Numerous amici ("friend of the court") briefs are likely to be filed by 1 both sides in August. On our side, many other industries will be concerned about a precedent that stormwater runoff from any road could require an NPDES permit. Although a schedule has not been set, parties expect that briefing could be completed as early as August, with oral arguments likely set for late November or early December. A decision could be seen as early as February, 2013, but more likely in late June, 2013. A congressional prohibition on EPA requiring permits for forest roads will expire on September 30, 2012, leaving the Ninth Circuit's decision in place. However, from the Supreme Court's view, if action was enforced under the decision, it would quickly be stayed in court. Congressional action might also temporarily extend the prohibition. Left hanging is the status of the Notice of Intent (N01) initiated by the EPA to "expeditiously" propose and complete revisions to its stormwater regulations to specify that discharges from logging roads are not industrial activities, and therefore not (Continued on page 8) (Forest INSIDE THIS ISSUE Page 1 Page 2 Page 3 Page 4 Page 4 Page 4 Page 5 Page 6 Page 7 Page 7 Page 8 Page 9 Page 9 Forest Roads Case Letter from Eric Riley (PUR) Challenge to Oregon Air Quality Program Henri Bisson Article Triangle Lake “Acosta” Case (2 articles) Conservationists Rise to Administration Side on Owl Timber Industry Report Spotted Owl Critical Habitat Comments Suit Filed on Murrelet Take Thomas Maness Western Governors Letter to Congress National Forest System Rework TIMBER TOPICS 2 TIMBER TOPICS DTO Calendar of Events August 9, 2012 Roseburg Breakfast Meeting 7:00 a.m. @ Elmer’s Speaker: Larry Cooper Oregon Department of Fish & Wildlife August 17, 2012 Coos Bay Breakfast Meeting 7:00 a.m. @ The Red Lion Speakers: TBA August 23, 2012 Roseburg Breakfast Meeting 7:00 a.m. @ Elmer’s Speaker: Norm Smith Ford Family Foundation Program: Big Transitions at the Ford Family Foundation September 13, 2012 Roseburg Breakfast Meeting 7:00 a.m. @ Elmer’s Speaker: Dave Loomis JMURF Program: Rock-ED — Douglas County’s Outdoor Education Center! September 17, 2012 Coos Bay Breakfast Meeting 7:00 a.m. @ The Red Lion Speakers: David Koch, CEO Port of Coos Bay Speaker: Port Update With New CEO CHALLENGE TO OREGON AIR QUALITY PROGRAM A plaintiff activist group known as the Pacific Environmental Advocacy Center (PEAC), operating out of Lewis & Clark Law School, filed suit in late February challenging EPA's approval of Oregon's 2011 air program, administered by the Department of Environmental Quality. PEAC asserts the program is not sufficiently stringent with regard to the operational permitting of hundreds of boilers, biomass, and small scale energy producers, and greenhouse gas regulation. Two critical components at risk for OFIC members include the loss of a facility's emissions "baseline," (unique to Oregon's program) through which years of accrued emissions reductions can be used as a credit against new modifications and expansions, and Oregon's "carbon neutrality" exemption from greenhouse gas permitting regulations for biomass energy production. Neither PEAC nor EPA informed affected parties, including the State of Oregon, of their legal challenge, and instead they have been secretly negotiating the future of Oregon's air program behind closed doors. There is serious risk that EPA and PEAC will reach a back room deal in the form of a consent agreement that could throw the Oregon air permitting program into chaos for the foreseeable future. Working in conjunction with Associated Oregon Industries, Northwest Pulp and Paper Associa-tion and others, OFIC manufacturers have strongly stepped to the plate and funded an effort to intervene in the case. Tom Wood with Stoel Rives has been engaged and is preparing to make a court filing no later than June 30. OFIC, June 25, 2012 OUR VALUED MEMBERS We would like to thank the following individuals and businesses for their valued partnership and continued membership with DTO! Herbert Lumber Company, Riddle HPS Electrical Apparatus Sales & Service, Roseburg DR Johnson Lumber Company, Riddle Keller Lumber Company, Roseburg Kruse Farms, Roseburg Claude McLean, Roseburg Mercy Medical Center, Roseburg Rich Mouser, Roseburg Nordic Veneer, Roseburg Pacific Power, Roseburg Peterson Machinery Co., Eugene Troy Reinhart, Bend 3 TIMBER TOPICS HENRI BISSON ARTICLE TRIANGLE LAKE I'm frustrated! Really frustrated!!! It has been 31/2 years since this Administration vacated the Western Oregon Plan Revisions that were completed at the very end of the Bush Administration. The decision to vacate the plans was done as a result of continuing threats of lawsuits and legal advice from the Justice Department, who would have had to defend the decisions. I have no quarrel with the Administration's right to change the plans. That is not the basis of my frustration. At the time of that decision, there were options available to speed up the process of replacing plans that the Administration felt could not be defended. One possible solution would have been to simply vacate the Record of Decision and go through a much shortened process based on use of the existing NEPA analysis to issue a new Record of Decision. It would have saved a lot of time, money and some of my personal frustration. Instead, the BLM is now embarking on a new planning effort for Western Oregon, 3 1/2 years later! Recent attendance at some of the scoping meetings has a number of our members concerned, because the O&C Act and forest harvest issues are specifically not being identified as issues to be considered in the plans. It's not a matter of raising very legitimate issues with the public regarding the management of other values of the O&C lands. It's the complete denial of the legal framework required by both the Federal Land Policy and Management Act and the O&C Act for management of these Nationally significant forest lands that concerns me. Public information related to this effort avoids any mention of the O&C Act. The O&C lands have a rich history of recreation use, significant biological and cultural values, and, a very significant economic value to local communities. How can we avoid discussion of use of these lands for the production of wood using the best science and technology available anywhere in the world? These are the most productive forest lands in the United States. Is it better to force timber production on other countries where technology and forest practices lead to wasting of huge forest areas and associated impacts? It just doesn't make any sense to me! PLF membership includes five former Oregon State Directors, former District and Area managers, planners and employees from many disciplines who spent the last 40 years in a seemingly endless stream of plan production for Western Oregon. There has been one battle after another to supplant sound decisions based on the best available science with decisions based on ideology. When is it going to stop? The exposure investigation at Triangle Lake continues down a slow and tortured path. Recent developments include new Pitchfork Rebellion-provided data that allegedly shows herbicides in area streams. They have also conducted air testing, although to what extent is uncertain. Additionally, it appears that the Oregon Health Authority is trying to resurrect the "Dr. Barr" urinalysis data that was presented to the Board of Forestry in 2011 but never provided to the state for verification and authenticity prior to launching the exposure investigation. This data allegedly shows background levels of atrazine and 2,4-D in many participants that "spiked" after aerial application of those herbicides in the general vicinity. Rumors of OHA interest in proposing legislation to "strengthen" the FPA with respect to notification of pesticide application (actual time, date and location) and detailed post-spray records continue to circulate. OFIC, June 25, 2012 “ACOSTA” CASE On June 20, OFIC filed a formal reply to the U.S. District Court in support of its motion to intervene in the Northwest Environmental Advocates v. EPA suit challenging water quality protection rules regulating activities on private forestland under the Oregon Forest Practices Act. The reply was in response to both the plaintiffs' and defendants' opposition to OFIC's earlier motion to intervene, and refutes, among other issues, the claim that only Oregon Administrative Rules that implement the FPA, and not the FPA itself, is the subject of the challenge. EPA and NWEA's insistence that approval or disapproval of the rules will not implicate the FPA, rather than acknowledging such action constitutes, at minimum, an advisory opinion on the adequacy of Oregon's existing mechanisms for regulating nonpoint forest practices altogether, should weigh heavily in favor of OFIC's motion to intervene. However, counsel is not optimistic about achieving intervener status, based not on merit but on timing. OFIC, June 25, 2012 “ACOSTA” CASE (UPDATE) In a disappointing but not surprising move, Judge Acosta denied the collective motions of OFIC, Small Woodlands and Farm Bureau to intervene in Northwest Environmental Advocates v. EPA. The court concluded the motions to intervene were untimely, and it was also "unpersuaded that interveners have a significant protectable interest" in the litigation. Both the EPA and NWEA argued at length that the Forest Practices Act (FPA) and other nonpoint source statutes and regulations are not at issue in the case — just the Department of Environmental Quality rules that cross-reference the FPA. If nothing else, the motions to intervene have succeeded in forcing the EPA and NWEA to try to characterize the scope of the court's decision on the nonpoint issues much more narrowly. The Public Lands MONITOR, Summer 2012 OFIC, July 9, 2012 4 TIMBER TOPICS CONSERVATIONISTS RISE TO ADMINISTRATION SIDE ON OWL Article from Public Lands News, Volume 37, Number 14, July 13, 2012 Not to be outdone by a wave of criticism from western Republicans and the timber industry, conservationists made a pitch last week for the designation of extensive critical owl habitat in the Pacific Northwest. In a July 2 letter to President Obama more than 50 conservation and environmental groups effectively endorsed a Fish and Wildlife Service (FWS) proposal to protect as much as 14 million acres for the Northern Spotted Owl. FWS would designate the 14 million acres as critical habitat under the Endangered Species Act. “We commend the agency’s use of modeling to identify the proposed acreage which we believe represents the best available science,” said the conservationists, led by the American Bird Conservancy and the Sierra Club. Further, the groups said two decades of protectionist policies for the owl, the Marbled Murrelet and Pacific salmon appear to be effective. “Studies show that the Northwest Forest Plan is working as intended to retain mature and old forests, and that the highly fragmented forest ecosystem is growing back into the large blocks of mature forest habitat needed to maintain water quality and recover threatened species, . . .” the groups said. As always, the conservationist plea contrasts sharply with the opinions of western Republicans, as symbolized by the statement of House Natural Resources Committee Chairman Doc Hastings (R-Wash.) at a hearing he held May 21 in the State of Washington. “The Obama administration’s proposed Northwest recovery plan would increase burdensome regulations, cost thousands of jobs, and place more public land off limits, all while failing to address the Spotted Owl’s top predator – the Barred Owl,” he said. The American Forest Resource Council (AFRC) seconds Hastings’s motion. “Nearly two decades after first setting aside millions of acres for spotted owl ‘reserves’ at the expense of rural communities and jobs, forest health and other forest-dependent species, (FWS) is poised to triple down with a flawed proposal even more devoid of reality,” said Tom Partin, president of AFRC. He laid the spotted owl’s problems on the barred owl, not timber sales. “A lack of habitat is not a limiting factor for the spotted owl,” he said. “Unfortunately, it appears that agency ineptitude in confronting the threats posed by the barred owl and deteriorating forest health conditions on our federal lands and the resulting catastrophic wildfires will seal the fate of the spotted owl.” Here are the three legs of the Obama administration owl policy: Critical habitat: The March 8 rule proposed by FWS says the agency would begin analyzing almost 14 million acres as possible critical habitat for the owl. New habitat designation for the owl is needed because a federal judge in September 2010 threw out a Bush administration plan. The Bush administration had tried to reduce protected habitat from 6.9 million acres to 5.3 million acres. The comment period on the proposed habitat revision ended July 6. Timber sales: BLM on March 9 said it would revise six resource management plans to help the spotted owl and other threatened species, provide clean water and produce timber sales. The comment period on BLM’s proposed approach to revising plans ended June 6. Separately, the Forest Service said it intends to increase national sales from 2.4 billion board feet in fiscal 2011 to 3 billion board feet in fiscal 2014. And BLM, operating on O&C lands in western Oregon, has planned 150 timber sales over the next two ears with a target sale of 197 million board feet. Barred owls: The FWS published March 8 a draft EIS that analyzes seven alternatives for experimental removal of barred owls from spotted owl habitat. Some of those alternatives may be controversial because animal rights groups object to killing the birds. The comment period ended June 6. Public Lands News, July 13, 2012 5 TIMBER TOPICS TIMBER INDUSTRY REPORT by Rick Sohn July28, 2012 Too good to be true? This 2005-looking homebuilding boomlet is taking shape in July, 2012 at River Run, in Spokane, WA. These houses are all sold. Four-year trends of lumber, logs, housing, and mortgage statistics are shown below. Prices in Dollars per Thousand Board Feet_______ Southern Oregon Studs ¹ Southern Oregon Logs² July‘12 June’1 May‘1 Apr’12 June‘1 June’1 June‘0 $302 $315 $547 $328 $568 $265 $579 $245 $545 $235 $520 $185 $185 Not avail. ___ Thousands of Housing Units_________ 760 585 711 747 615 536 755 601 784 723 633 587 3 US Private Housing Starts US Private Building Permits3 ____Months of Inventory of Unsold Homes_______ Portland OR Unsold Home inventory4 30-year Fixed Rate Mortgage5 3.9 4.2 4.7 6.0 7.3 __________ Percentage interest rate____ 3.55 3.68 3.80 3.91 4.51 4.74 8.2 _ 5.42 Interpretation. A picture is worth a thousand words. The recovery is back…… in a few select places. In fact there are 6 homes in a row under construction on this River Run street overlooking the Spokane River (only one of these shown is now lived in). Apparently once the first of these view lots sold a price was established. The others sold quickly and all began construction about the same time. Still, a good sign!!!! This month’s statistics verify this picture of optimism. The mortgage rate is continuing to drive intense interest among those who can qualify, while lower unsold home inventories are pushing construction – more in some parts of the country than others. Overall, housing starts and building permits continue to strengthen. Either starts or permits have posted a new high every month since January, 2012. Even better news for wood products manufacturers is that the price for studs has been more than half the price of logs for the last two months. This balance in favor of the mills has not happened since the first half of 2010. Even though prices for studs are down $10 in July, the key will be the log prices, which tend to weaken in the summer. According to Janet Johnston of Prudential Real Estate, “Agents (in Roseburg, Oregon) are reporting that they are busy and…I have been very busy…my listings ARE getting shown, so I’m optimistic that we are going to get more properties sold this year. Can you believe the (interest rates)?...... Amazing!!! ….Potential Buyers…shouldn’t continue to ‘sit on the fence’ as the rates are going to start going back up, as soon as the market increases in activity…they are going to be disappointed that they missed these great rates AND the ‘bargains’ that are out (there)…. these days.” (Continued on page 8) 6 TIMBER TOPICS SPOTTED OWL CRITICAL HABITAT COMMENTS On July 6, AFRC submitted extensive comments on the US Fish & Wildlife Service’s (FWS) Northern Spotted Owl Draft Critical Habitat and Environmental Impact Statement and Economic Assessment to expand designation of spotted owl critical habitat from 5,312,300 acres to 13,962,449 acres. Our conclusion is that the proposal fails to meet the requirements of section 3(5)(A) of the ESA and accompanying regulations. The Draft Environmental Assessment fails to disclose the true environmental consequences of the proposal and is based on the faulty processes of the previous two documents. The Draft Economic Analysis fails to meet the requirements of section 4(b)(2) of the ESA and accompanying regulations and misrepresents the current situation (baseline) therefore grossly underestimating the economic consequences of the proposal. AFRC employed the services of independent scientists from WEST, Inc. to conduct an analysis of the first of three computer simulation models the FWS used in designing their proposal. They concluded: “Based on the results in the Royle et al. (2012) and Torres et al. (2012) papers and the differences that we find between MaxEnt and maximum likelihood estimation applied to the U.S. Fish and Wildlife Service data from the Southern Western Cascades and Klamath East we believe that the results obtained from a MaxEnt analysis may be misleading for habitat modeling in general, and are unreliable with habitat modeling for northern spotted owls in particular. Also, as the U.S, Fish and Wildlife Service analysis used the output from MaxEnt for further analyses using the Zonation and Hexsim programs we believe that the results from these further analyses are also not reliable.” Dr. Larry Irwin of the National Council for Air and Stream Improvement also conducted a review based on his extensive research on spotted owl demography and habitat use. He concluded: “[T]here is a high degree of uncertainty that the combined models that underlie the proposed CH Rule accurately and reliably identified habitat that is essential for conservation throughout the range of the Northern Spotted Owl.” We believe the process used is incapable of determining what areas were “occupied at the time of listing” and/or are “essential for the conservation of the species” and should be completely redone using processes that will meet the requirements of sections 3(5)(A) and 4(b)(2) of the ESA. The final critical habitat designation is expected to be completed by November 15. /Ross Mickey AFRC, July 23, 2012 SUIT FILED ON MURRELET TAKE The Cascadia Wildlands Center has sued Oregon Governor John Kitzhaber, members of the Land Board and the Board of Forestry for violation of the ESA arguing that management of state forest lands results in a take of marbled murrelets. Plaintiffs asked the court to declare “that defendants’ management of, decision-making regarding, and timber sale programs for the Tillamook, Clatsop, and Elliott State Forests violate the Endangered Species Act.” In particular, plaintiffs want the court to rule that defendants are taking marbled murrelets by approving logging of habitat occupied by marbled murrelets; fragmenting occupied and suitable marbled murrelet habitat; creating Marbled Murrelet Management Areas that are insufficient to protect the birds and their habitat and are leading to habitat fragmentation; adopting and applying a “take avoidance” policy that fails to prevent take of marbled murrelets; and establishing logging levels and otherwise authorizing logging on the Tillamook, Clatsop, and Elliott State Forests that will result in take of marbled murrelets. Among plaintiffs’ request for relief is a court order requiring the state to obtain an incidental take permit through the adoption of the Habitat Conservation Plan (HCP). For the Elliott State Forest, the Land Board decided not to extend its existing HCP and instead adopted a take avoidance policy for management of forest lands. Under the Elliot’s revised 2011 forest management plan and take avoidance policy, the (Continued on page 8) 7 TIMBER TOPICS (Timber Industry Report — Continued from page 7) Data reports used with permission of: 1 Random Lengths. 2”x4”x8’ precision end trimmed hem-fir studs from southern Oregon mills. Price reported is Dollars per Thousand Board Feet generally for the second to last week of the month. One “board foot” of product measures 12 inches by 12 inches by one inch thick. 2 RISI, Log Lines. Douglas-fir #2 Sawmill Log Average Region 5 price. Current report is for the prior month. Dollars per Thousand Board Feet of logs are reported using standardized log measurements from the “Scribner log table.” 3 Dept. of Commerce, US Census Bureau. New Residential Housing Starts and New Residential Construction Permits, seasonally adjusted, annual rate. Current report is for the prior month. Recent reports are often revised in bold. Also, major revision made each May, reaching 2 1/2 yrs back. 4 Regional Multiple Listing Service RMLSTM data, courtesy of Janet Johnston, Prudential Real Estate Professionals Broker, Roseburg, OR. Inventory of Unsold Homes (Ratio of Active Listings to Closed Sales) in Portland Oregon, for most recent month available. 5 Freddie Mac. Primary Mortgage Market Survey. 30-year Fixed Rate Mortgages Since 1971, national averages. Updated weekly, current report is for the prior full month. Issue #5-6. © Copyright Rick Sohn, Umpqua Coquille LLC. For permission to reprint for nominal fee, Email [email protected] Roads, Continued from page 1) (Murrelett, Continued from page 7) subject to permits. In conjunction with this effort, the EPA hosted one of several proposed (but not confirmed) "listening sessions" in Seattle to evaluate water quality impacts of forest roads and existing BMP programs to determine if additional agency action is necessary. The EPA has been strongly advised to put the NOI effort on pause pending the Supreme Court review. No wrap up of this issue would be complete without extending kudos to Tim Bishop at Mayer Brown for superb advocacy in support of the cert petitions with both the Court and the Solicitor General. Also, a nod of acknowledgement is due the state of Oregon for sticking with us as full partners on this case for the past six years. sustained timber production increased from about 25 to 40 million board feet per year and the acreage of conservation areas also increased. The state essentially agreed to a preliminary injunction by withdrawing many scheduled timber sales and suspending several existing contracts. The litigation is in its early stages but a trial is likely to be scheduled later this year or early next year. The Oregon Forest Industries Council, Douglas Timber Operators, Scott Timber, Seneca Sawmill Company, and Hampton Tree Farms are intervenors in the case. AFRC’s staff attorney is co-counsel for intervenors. We will continue to report on future developments. / Scott Horngren OFIC, July 9, 2012 AFRC, July 23, 2012 THOMAS MANESS Following a thorough search, Thomas Maness was selected to serve as the next Dean of the College of Forestry at Oregon State University. Maness has been a professor and head of OSU's Department of Forest Engineering, Resources and Management since 2009, and was one of three finalists for the job. Also considered were two candidates from North Carolina State University, but in the end, OSU decided to promote from within. Maness will be the second holder of the Cheryl Ramberg and Allyn C. Ford Deanship of Forestry, and the eighth dean in the history of the college. Maness previously was an engineer with Weyerhaeuser Co. in the Klamath Falls region, where he developed strategic forest planning models and improved manufacturing systems for West Coast sawmills. He returned to school and earned his Ph.D. in forest economics from the University of Washington in 1989, then joined the faculty of the University of British Columbia. In addition to his expertise on Northwest forests, Maness has worked extensively in South America. Maness will begin his new duties as dean on August 1. OFIC, July 9, 2012 8 TIMBER TOPICS WESTERN GOVERNORS LETTER TO CONGRESS On July 11, four Governors from the Western Governors’ Association including Chairman Gary Herbert (R-Utah), Vice-Chairman John Hickenlooper (D-Colorado), and Forest Health Lead Governors C.L. “Butch” Otter (R-Idaho) and John Kitzhaber (D-Oregon) sent a letter to the Majority and Minority leaders in both the U.S. Senate and House of Representatives requesting that Congress provide supplemental funding needed to aid federal, state, and local firefighters battling wildfires this season. The Governors pointed out in the letter that without supplemental funding, management agencies could be forced to redirect resources from other program budgets such as proactive fire risk reduction work to fund the suppression. In the letter the Governors also request that Congress act to: Fully fund the Federal Land Assistance, Management and Enhancement Act’s (Flame Act Funds) to en sure emergency suppression costs do not impact federal non-fire budgets and programs. Ensure completion and implementation of the National Cohesive Wildland Fire Management Strategy. Take action necessary to address deficiencies in the nation’s aerial firefighting resources. Reform federal land management policies so they encourage and expedite active forest and land manage ment to improve forest function and landscape resiliency. Provide funding and direction to federal agencies to coordinate with state agencies on required reviews under environmental laws to ensure timely review and approval of salvage and restoration work necessary to sustain both the built and natural environments. Finally, they asked that Congress act on the several legislative proposals that have been introduced that would improve the health of our forests, reduce the number and severity of wildfires, and build capacity of our firefighting resources. AFRC appreciates the proactive positions put forth in this letter and thank the Governors for their work on these very important issues. / Tom Partin AFRC, July 23, 2012 NATIONAL FOREST SYSTEM REWORK Last week, a two-day conference was convened in Sacramento, California to discuss possible legislative and administrative actions to restore sustainable forest management to the National Forest System. The conference, organized by the National Institute for the Elimination of Catastrophic Wildfire, brought together county elected officials, rural school administrators, local law enforcement, forest products industry representatives and a large number of Forest Service retirees. Former Forest Service Chief Jack Ward Thomas and Oregon State University College of Forestry Dean Hal Salwasser were among the speakers who stressed the need to institute reforms to improve the ability of the Forest Service to implement forest management activities or explore alternative approaches for managing the land, including some of the legislative proposals being proposed in Congress that are focused on trustbased management. Douglas County, Oregon County Commissioner Joe Laurance spoke about the worsening social and economic ills his county grapples with due to a lack of sustainable management on the National Forests and the BLM O&C Lands. Local law enforcement, school administrators and community members shared similar stories that have now become evident due to ever-declining and uncertain Secure Rural School payments. AFRC, July 23, 2012 DOUGLAS TIMBER OPERATORS MISSION STATEMENT Douglas Timber Operators (DTO) is a community-supported forest products organization whose mission is to actively promote timber harvest, reforestation, and production of forest products on public and private timberlands, and the enhancement of forest ecosystems, through multiple use forest management. Douglas Timber Operators has served southwestern Oregon since 1968. www.dougtimber.org 9