Springfield Chamber Comments Regarding the Draft Environmental Impact Statement for the Western Oregon State Forests Habitat Conservation Plan (Docket ID NOAA-NMFS-2021-0019)

June 7, 2022

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Dear Dr. Kratz and Dr. Henson:

I write to express concerns that the Oregon Department of Forestry’s (ODF) draft Habitat Conservation Plan(HCP) and the associated draft Environmental Impact Statement (DEIS) would increase the environmental and economic harm our communities and forests have faced over the past several decades, all of which were exacerbated by the 2020 Labor Day Wildfires from which we are still struggling to recover. We hope a better path forward can be found and we are reliant on your leadership to enable this.

The Springfield Area Chamber of Commerce service area that includes Springfield, Eugene and surrounding communities across Lane County and a metro population of 250,000. We work to further economic opportunity, education, and community development priorities supported by data-driven, intentional, and strategic economic policy.

The voice, views, and data-driven impacts on our local community should be represented in studies that inform policies that impact our local public safety and education tax base, economic viability, and livelihoods. The DEIS falls short in giving voice to and fully reflecting impacts of policy and alternatives on the communities and environments in the affected areas.

We call on your leadership to conduct more accurate socio-economic impact analysis, to respond to these
areas of highest concern expressed by local communities, and to find a better path forward.

We are deeply disturbed that the socioeconomic analysis in the DEIS is inaccurate and incomplete and offer a few reasons why:

The assumption of three jobs created for every thousand board feet of harvest is far below the 11-12 per thousand board feet most commonly attributed.
Veneer, plywood, and other engineered wood product manufacturers were not included in the“direct employment and wages.” This is especially troubling to us as we see economic mobility tied to diversity and sustainability of wood products manufacturing sector and jobs. In Springfield alone, mills specializing in the manufacturing of veneer, plywood, and other engineered wood products employ over 1000 individuals providing direct wages and benefits to those families; contribute to the socio-economic health of our community by supporting medical care providers; fund the maintenance and care of our roads, parks, libraries, public safety, and education; and contribute to critical quality of life benefits.
Many of these mills purchase timber directly from ODF. We are alarmed that they are not considered a direct source of jobs and see this as a critical flaw signaling that there are other significant issues within the methodology used by ODF.

The DEIS provides few alternatives to the current Proposed Action developed by ODF.

Remarkably, of 17 alternatives considered, all but three were eliminated.
Each of the three offered are barely distinguishable from the Proposed Action.

The DEIS compares the alternatives to the ‘No Action’ scenario, or the status quo.
As we have expressed in our many efforts to support our community, environment, and economy, status quo is an unacceptable baseline as it is an example of failure in state forest management.
The comparison should be with the true outputs of the land, not flawed policies.

The Board of Forestry should direct ODF and federal agencies to 1) conduct a more thorough analysis of the impacts this proposal has on rural Oregon, 2) include local business, industry, and taxing district voices in the process, and 3) while it would be careless not to provide a more thorough analysis of the hard impacts and realities the HCP would impose on our communities, should you choose not to do so, we would strongly suggest Alternative 5 be brought forth as the final proposal.

Our residents do not have a choice in this matter, but the Board of Forestry does. We’re looking to you for your wisest leadership as you move forward.

Sincerely,