My Public Comments on the Klamath Marsh NWR "Comprehensive Conservation Plan" (CCP)

February 27, 2007

By Julie Kay Smithson

213 Thorn Locust Lane

London, Ohio 43140

[email protected]

Emailed to: [email protected]; [email protected]; [email protected]

Cced to: Let your imagination run wild!

Hard copies mailed February 28, 2007, to:

Carol Damberg, Refuge Manager

Klamath Marsh National Wildlife Refuge

HC 63 Box 303

Chiloquin, Oregon 97624

and to:

Mark Pelz, Refuge Planner

U.S. Fish and Wildlife Service CA/NV Refuge Planning Office

2800 Cottage Way, W-1832

Sacramento, CA 95825

This entire email (and the printed version, which will be mailed by the Postal Service and postmarked February 28, 2007) is to be construed and accepted as my Official Public Comments on the Klamath Marsh National Wildlife Refuge "Comprehensive Conservation Plan" (CCP).

First, some basic facts:

The official policy of the National Wildlife Refuge System is: Closed until Open.

The Nature Conservancy, also known as "TNC," owns and controls the Sycan Marsh. The Sycan Marsh has successfully hosted both grazing by cattle and the growing and harvest of grass into hay.

The U.S. Fish and Wildlife Service, variously known as the USFWS, the FWS, "the Service," etc., currently controls the Klamath Marsh National Wildlife Refuge.

The Klamath tribes desire to reacquire the area currently known as the Klamath Marsh National Wildlife Refuge and the part of the Winema National Forest that adjoins the Klamath Marsh National Wildlife Refuge.

There is an apparent mandate, invented and handed down from the U.S. Department of the Interior, to put a "Comprehensive Conservation Plan" in force at all "national wildlife refuges."

It is important to note that there is no need for a "Comprehensive Conservation Plan" for the Klamath Marsh National Wildlife Refuge or for any other National Wildlife Refuge.

If a "Comprehensive Conservation Plan" were so vital to the health and well-being of all creatures (including human), plants and animals in the area currently known as the Klamath Marsh National Wildlife Refuge, it would certainly be able to justify its existence by a scientifically proven need. Simply taking a directive "from above," i.e., from the Department of the Interior, and using it to ensure the continued employment of far too many non-vital federal employees and their "public-private partnerships" oversteps such a scientifically proven need and does nothing for to enhance the human, plant and animal life in and near the area currently known as the Klamath Marsh National Wildlife Refuge.

"Habitat values" is mentioned in the "CCP" Internet-posted Klamath Marsh NWR Issues Workbook, but is never defined. Here: http://www.fws.gov/sacramento/ec/DARP%20Resource%20Equivalency%20Analysis%20MethodAppendix%20B.pdf on page B-3 "...no habitat value" is ascribed to "e.g., a parking lot..." -- making the reader assume that the "parking lot" is paved and contains nothing that would be beneficial to wildlife. I have personally seen birds cluster on the radiator grilles of semi trucks, and to a lesser extent, cars and pickup trucks, there to feast upon the menu of dead bugs. I have also witnessed a cedar waxwing (a magnificent bird) getting a welcome drink of water from a partially-fully paper cup -- also in a "parking lot." No habitat value? Perhaps in the thinking of U.S. Fish and Wildlife Service...

While it is important to note that I can find no reference in the scanty documents provided thus far for the "Klamath Marsh NWR Comprehensive Conservation Plan," the following reference made by U.S. Fish & Wildlife Service should prove the scope of control intended by "habitat values:"

Conservation Easements - Conservation easements give the Service the opportunity to manage lands for their fish and wildlife habitat values. Such management precludes all other uses that are incompatible with the Service's management objectives. Only land uses that would have minimal or no conflicts with the management objectives are retained by the landowner. In effect, the landowner transfers certain development rights to the Service for management purposes as specified in the easement. Source: U.S. Fish & Wildlife Service Southeast Region Division of Planning. Appendix A. Glossary -
http://www.fws.gov/southeast/planning/PDFdocuments/Noxubee/NoxFinal/Appendix.pdf

This "Plan," or "CCP," contains no glossary and thus, no definitions for words, phrases and acronyms referred to in "CCP" documents on which people are asked/expected to comment. If there were a glossary, it would likely contain such unwieldy "definitions" as the four listed below (and people's public comments would reflect an understanding of the "bill of goods" being hawked): 

Comprehensive Conservation Plan (CCP) or Comprehensive Management Plan (CMP) - A document that provides a description of the desired future conditions and long-range guidance for the project leader to accomplish purposes of the refuge system and the refuge. CCPs establish management direction to achieve refuge purposes. - U.S. Fish and Wildlife Service Glossary of Planning Terms http://www.fws.gov/pacific/planning/gloss1.htm 2. A document that describes the desired future conditions of a refuge or planning unit and provides long-range guidance and management direction to achieve the purposes of the refuge; helps fulfill the mission of the Refuge System; maintains and, where appropriate, restores the ecological integrity of each refuge and the Refuge System; helps achieve the goals of the National Wilderness Preservation System; and meets other mandates. - U.S. Fish & Wildlife Service Manual, Refuge Planning Overview http://www.fws.gov/policy/602fw1.html 3. A document that describes the desired future conditions of the refuge; and provides long-range guidance and management direction for the refuge manager to accomplish the purposes of the refuge, contribute to the mission of the Refuge System, and to meet other relevant mandates (Draft Service Manual 602 FW 1.5). http://pacific.fws.gov/planning/LPOccp/v2.pdf 

National Wilderness Preservation System - All lands covered by the Wilderness Act and subsequent wilderness designations, irrespective of the department or agency having jurisdiction. - Appendix H (Biological Assessment and Evaluation for Revised Land and Resource Management Plans and Associated Oil and Gas Leasing Decisions) http://www.fs.fed.us/ngp/final/pdf_feis/Appendix_H.pdf 

Wildlife-Dependent Recreation - A use of a refuge involving hunting, fishing, wildlife observation and photography, or environmental education and interpretation. - U.S. Fish and Wildlife Service Glossary of Planning Terms http://www.fws.gov/pacific/planning/gloss1.htm

Wildlife-Dependent Recreational Use - "A use of a refuge involving hunting, fishing, wildlife observation and photography, or environmental education and interpretation." These are the six priority public uses of the Refuge System as established in the National Wildlife Refuge System Administration Act, as amended. Wildlife-dependent recreational uses, other than the six priority public uses, are those that depend on the presence of wildlife. We also will consider these other uses in the preparation of refuge CCPs; however, the six priority public uses always will take precedence. - U.S. Fish & Wildlife Service Manual, Refuge Planning Overview http://www.fws.gov/policy/602fw1.html 

The Environmental Protection Agency (EPA) and The Property and Environment Research Center, better known by its acronym, PERC, among other agencies and organizations, admit that privately-owned land makes, by far, the best "habitat" for wildlife, from "threatened" to "endangered" to any other description of said wildlife.

That said, with the track record of the U.S. Fish and Wildlife Service for speciesism (favoring one species over another, including, but not limited to, large predators over ungulates and certain species of fish over other species of fish), there is no need for this "Comprehensive Conservation Plan." Such a "plan" will not do anything good for species, but will ensure that species may actually become "imperiled," "at risk," "threatened," or whatever wording or phraseology U.S. Fish and Wildlife Service and its parent agency, the U.S. Department of the Interior, can invent. Rather, federal agencies should be mandated to seek the scientifically proven stewardship levels that private ownership have achieved, which make private property by far better wildlife habitat than federally "managed" property.

Here are reasons why private land is proven to be far better 'habitat' than "national wildlife refuge" land:

"Seventy-five percent of U.S. wildlife live on private land, as do half of all endangered species." Source: The Property and Environment Research Center (PERC) http://www.perc.org/pdf/guide_wild.pdf (Page 5 of 14)

Endangered species, according to this Environmental Protection Agency (EPA) document http://www.epa.gov/fedrgstr/EPA-IMPACT/2003/January/Day-09/i130.htm are found "...almost entirely on private land," If private lands are clearly where endangered species prefer to reside and where wildlife thrives, it is only good sense that the private property owner is better at species care than federal government agencies. Source: http://www.epa.gov/fedrgstr/EPA-IMPACT/2003/January/Day-09/i130.htm 

Most species -- endangered and otherwise -- prefer to inhabit and apparently not only survive, but also thrive, on private rather than 'public' land. Why keep up the push for more and more layers of "plan," which are obviously ill-conceived and have an agenda that does not have the benefit of wildlife at heart? Private property owners are already doing a far better job at such things.

Scrap all such "bathwater" like "comprehensive conservation plans" and look to the baby -- the private property owner -- for proven direction on "how it's done and done right." Dig a deep hole and bury such "plans" as the "comprehensive comprehension plan." There is no responsible place for such Language Deception in all the Klamath Basin or anywhere beyond.