Klamath Marsh National Wildlife Refuge Comprehensive Conservation Plan Comments due March 15, 2007


(Update #1: An Introduction to the Refuge) Klamath Marsh Refuge Programs Today



(Note: Please scroll down to find my public comments.)


From: http://www.fws.gov/klamathbasinrefuges/KlamathMarshCCP/PU1f(web).pdf (8 pages)

The comprehensive conservation planning process upon which we are about to embark allows the public an opportunity to share ideas and make comments about how the refuge will be managed over the next 15 years. To assist you, we'd like to describe our current programs.

Habitat Management Programs

Klamath Marsh Refuge is comprised primarily of wetland marshes and pine forest habitat types. Located within the Williamson River Watershed, the Williamson River traverses across most of the refuge where it creates a narrow band of river and willow riparian habitats. Approximately 36,000 acres of the 40,855-acre refuge are classified as permanent and seasonal marsh. Ponderosa and lodgepole pine forest communities occur on approximately 3,400 acres of the refuge. Sedge meadows and upland grass habitats surround the periphery of the cattail and bulrush dominated emergent marsh and form the transition zone between the wetland marsh and forested uplands.

Haying, grazing, prescribed fire, and the seasonal diversion of water to optimize flooding of wetland areas are the main habitat management strategies used to maintain or improve the wetland, sedge, and grass meadows habitat types. Although these management strategies have been reasonably successful on a small scale, there have been habitat shifts resulting from long-term drought along with other factors (e.g., drainage, ditching). Existing sedge meadows are relatively healthy, diverse, and unchanged since refuge establishment; however, since the early 1900s, the open water habitat of the marsh has been gradually displaced by solid stands of emergent vegetation (cattail and bulrush) that have changed the biological diversity of the marsh. Haying, grazing and prescribed fire programs are the current management strategies used to create more open water areas within the wetlands and stimulate or reinvigorate the regeneration of wetland plant species to enhance the structural diversity of the marsh.

Beginning around 1920, wildfires were actively suppressed in and around the refuge. The result has been ponderosa and lodgepole pine stands that have grown up in the absence of natural low-severity, frequent fires for many decades. Without frequent fires, dense stands of stunted or dying pines have been created, reducing habitat quality for wildlife. Management of pine forests on the refuge has been minimal since the refuge was established. Although some selected logging and prescribed fires have been implemented, a more active management program is needed to create healthy refuge forests that are reasonably stable, self sustaining, and productive for forest dwelling wildlife. An estimated 85 species of native landbirds breed in ponderosa pine habitats along with numerous mammals, insects, etc. Restoration of surrounding forests through cooperative relationships with adjacent landowners is required for successful future forest restoration.

Willow riparian habitat exists along portions of the Williamson River and other springs or seeps that enter the refuge. Riparian areas have been protected by fencing out domestic livestock that often like to forage and rest in these areas.

A major focus is the control of invasive plant species in all habitat types. The land protected by the refuge has very few populations of invasive weeds. Canada thistle, perennial pepperweed, knapweed, and reed canary grass are a few of the species that have been located and treated on the refuge. Cheatgrass has recently invaded upland areas and poses a significant threat to these areas if future control is not successful.

Tribal Consultations

The Klamath Marsh lies within the former Klamath Indian Reservation established by the 1864 Treaty between the United States of America and the Klamath and Modoc Tribes and Yahooskin Band of Snake Indians (Tribes). Former tribal reservation lands remain very important to the Tribes culturally, spiritually, and for subsistence gathering. The refuge staff collaborate with the Klamath Tribes regarding wildlife management, forestry practices, and the protection of cultural sites. It is imperative to continue consulting with the Tribes during the management planning process to create a successful comprehensive conservation plan.

Visitor Services

The FWS estimates between 2,000 to 4,000 visits per year, with a majority of visits focused on wildlife observation, especially birds. The objective of the current public use program is to provide high quality, wildlife-dependent visitor services that are compatible with refuge purposes and cultural resources. Public uses that are currently accommodated on the refuge include wildlife observation and photography, environmental education and interpretation, waterfowl hunting, fishing, and canoeing. Development of visitor services and infrastructure on the refuge has remained minimal because of its remote nature, minimal staff, local tribal concerns, and low visitation rate. The entire refuge, except specific interpretive sites and designated roads, is closed to public entry to reduce disturbance to wildlife and for protection of cultural resources. The exceptions are canoeists, who may seasonally boat through the Wocus Bay Marsh, and duck hunters, who may walk or boat into areas south of Silver Lake Road during the waterfowl season.

There are three primary roads that are open to visitors for use in observing or photographing refuge resources. The paved Silver Lake Road bisects the southern portion of the refuge and offers several locations for cars to pull off and observe wildlife. The Wocus Bay Road is a 2-track road that allows visitors to observe wildlife along Wocus Bay and also access an interpretative viewing site and primitive boat ramp. The gravel Military Crossing Road bisects the central portion of the refuge and provides general wildlife viewing opportunities in upland and marsh habitats.

There are three locations on the refuge with interpretative kiosks or panels. Interpretative
kiosk panels are located at the headquarters and at the beginning of the Wocus Bay Road. A series of interpretative signs have also been placed at an overlook along Wocus Bay Road.

Fall waterfowl hunting is permitted in accordance with Federal and State Regulations
within the marsh areas south of Silver Lake Road. Often, the opportunity to hunt waterfowl is very limited because fall water levels in the marsh are very low.

Fishing is restricted to the borrow ditches along Silver Lake Road where brown bullheads
are the primary fish caught.

Canoeing opportunities are available in Wocus Bay between July 1 and September 30. The canoe area consists of approximately 700 acres of open water with bulrush and cattail marsh. There are no facilities or equipment rentals at the canoe area, so visitors must provide their own canoes. Wildlife viewing opportunities along the canoe trail are excellent, especially during the morning and evening hours.

What is a CCP?

When Congress passed the National Wildlife Refuge System Improvement Act of 1997, it incorporated an underlying philosophy that "wildlife comes first" on refuges.

The Act provides the FWS with guidance for managing refuges to ensure the long-term conservation of fish, wildlife, plants, and their habitats. Three important principles of the Act are to maintain biological integrity, diversity, and environmental health of the refuge and facilitate compatible wildlife-dependent recreation.

Every refuge is to have a Comprehensive Conservation Plan (CCP) completed by 2012. The CCP will outline refuge goals, objectives, and management strategies. It is a flexible, "living" document that will be updated every 15 years.

The CCP:

Ensures that management of the refuge reflects the purposes of the refuge and the mission, policies, and goals of the National Wildlife Refuge System;

Provides the public with an understanding of the reasons for management actions on the refuge;

Provides a vision statement for the refuge;

Ensures the compatibility of current and future uses of the refuge with its purposes;

Provides long-term continuity in refuge management; and

Provides budget justification for operation and maintenance and facility development requests.

The CCP will provide broad management direction and guidance for the refuge, contingent upon future funding and resources. The accompanying environmental document, required by the National Environmental Policy Act, will describe the alternatives considered and their environmental effects. You will have an opportunity to review and comment on the draft CCP and environmental document.

In January 2007 we will hold our first public scoping meetings to help identify issues and gather information. The key planning steps are listed above and will be listed in future updates so you can track our progress through the planning process.

Compatibility of Refuge Uses

Prior to allowing various public uses on a refuge, federal law requires that the FWS first determine that these specific uses are compatible.

A compatible use is a proposed or existing use of a national wildlife refuge that, based on sound professional judgement of the refuge manager, will not materially interfere with or detract from the fulfillment of the National Wildlife Refuge System mission or the purposes of the refuge.

Compatibility determinations are used to help evaluate such uses and will be integrated as part of the CCP planning process.

Help us plan the future

During late 2006 and early 2007, Tribes, interested individuals, agencies, organizations, and other stakeholders will be invited to express their concerns and share their visions for the refuge. This will be your opportunity to help us identify issues and concerns and receive answers to any questions
you may have. Your comments and/or participation will be critical to the success of this planning effort.

We will send you our second planning update in early 2007, announcing the beginning of the CCP effort and providing more information on how you can get involved.

Please feel free to contact us!

We are available to provide additional information about the refuge history, goals, and accomplishments to date, and to answer any questions about the planning process. Feel free to call, write, e-mail, or come to see us.

If you did not receive this newsletter through the mail and would like to be on our mailing list, please contact us. You can also get information at our website http://pacific.fws.gov/planning/

If you would like to be removed from the list or are receiving multiple copies of these notices, please let us know.

Carol Damberg, Refuge Manager

Klamath Marsh National Wildlife Refuge

HC 63 Box 303

Chiloquin, Oregon 97624


Fax: 541-783-3382

[email protected]

Office hours: Monday-Friday 7:30 a.m. - 4:30 p.m.

Mark Pelz, Refuge Planner

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

2800 Cottage Way, W-1832

Sacramento, CA 95825


Fax: 916-414-6497

[email protected]

http://www.fws.gov/klamathbasinrefuges/KlamathMarshCCP/PU1f(web).pdf (8 pages)


Planning Update #2: Issues Workbook

Klamath Marsh National Wildlife Refuge

Planning Update #2 / Winter 2007

Comprehensive Conservation Planning Workbook & Public Scoping Meetings

Greetings from the Refuge Manager

Klamath Marsh National Wildlife Refuge (refuge) invites you to participate in the public scoping process to develop a Comprehensive Conservation Plan (CCP) for the refuge. This multi-year, master planning process will produce a plan that will help guide refuge management for the next 15 years.

Your ideas and comments will be an important part of the process, so I'd like to invite you to participate. Turn the page for more information about comprehensive conservation planning and getting involved with the process.

Recently, we mailed you Planning Update #1, which provided background about the Refuge and the National Wildlife Refuge System, and explained how comprehensive conservation planning fits into the overall picture of refuge management. Please try to read the update before our first meeting; this will help all of us start on the same page, so to speak, as we begin our public scoping meetings. If you didn't receive a copy of the first mailing, let us know and we'll be glad to send you one.

I hope you'll feel free to contact me or Mark Pelz, Refuge Planner, if you have any questions. You'll find our phone numbers and email addresses within this update. I look forward to seeing you at one of our future meetings.

Carol Damberg, Refuge Manager

Klamath Marsh NWR Issues Workbook

Inside is an a issues workbook for you to use in formulating your comments. The information you provide in this Issues Workbook will be very helpful in assisting Refuge staff in developing a draft plan. Please fill out and mail by March 15, 2007.

Help us keep our mailing list updated

If you wish to receive future "Planning Updates" about the Klamath Marsh NWR's Comprehensive Conservation Plan, please fill in the information below.

__ (Yes) Add me to your mailing list __ (No) Take me off your mailing list

Name (Please Print):____________________________________________________________

Mailing Address _____________________________________________________________

City:_______________________________ State:___________ Zip Code:____________

Are you acting in an official capacity as the representative of an organization?



Klamath Marsh NWR

HC 63 Box 303

Chiloquin, OR 97624

Values, Vision, and the Service's Role

1. What activities do you engage in on Klamath Marsh Refuge or plan to in the near future?

2. What things do you value most about the Refuge?

3. In a sentence or two, describe your future vision for the refuge. You may want to list a vision for wildlife, habitats, visitor services or other aspects of the refuge

4. What do you consider the most important problems facing the Refuge today? (List up to 3 in order of importance)

5. What technical services would you like the Refuge staff to provide? (check if appropriate)

__ wetlands management

__ management of endangered species

__ grasslands restoration

__ management to benefit wildlife

__ control of invasive and non-native species, including plants

other: ________________________________________

Provide specific comments concerning technical services you would like to see.

6. Please indicate here any additional comments you wish to make on values, vision, or the Service's role.

__ volunteer opportunities

__ enhanced visitor services

__ enhanced educational services

__ habitat enhancement on private lands

Fish, Wildlife and Their Habitats

Klamath Marsh National Wildlife Refuge provides important habitat for a wide variety of species, including several rare and declining species.

1. Are there specific areas within the Refuge that, in your opinion, need protection? If so, please list them here, and explain why you think they are important.

2. Are any of the following issues a major concern to you on the Refuge? If so, please check (or number in priority order) your top choices.

__ Refuge in holdings and boundary issues

__ control of invasive plant species

__ control of invasive insects or other animals

__ wildfire

__ haying or grazing

__ water rights and related issues

__ other issues (please specify):

3. If possible, please provide additional details on why you selected the above choices. In particular,  we would be interested to know specific locations of concern.

4. Please include here any additional comments on fish and wildlife habitat issues and concerns.

__ cattle trespass

__ water quality

__ forest management practices

__ riparian habitat degradation

__ lack of active management to improve wildlife habitats

Recreation, Education, and Access

It is important to recognize there are laws and policy which guide management of public use on National Wildlife Refuges. National Wildlife Refuges are closed to public use until officially designated open and only those public uses that are "compatible" with the purpose(s) for which a Refuge was established are allowed. Klamath Marsh National Wildlife Refuge was established in 1958 "for use as an inviolate sanctuary, or for any other management purpose, for migratory birds." In 1986, the purpose of the Refuge was expanded to include "... the conservation of the wetlands of the Nation in order to maintain the public benefits they provide and to help fulfill international obligations contained in various migratory bird treaties and conventions ."

1. Are any of the current activities, or the current levels of use on the Refuge a concern to you?

2. Do current Refuge recreational facilities meet your needs (trails, parking, signs, etc.)? Please explain.

3. Are any of the following visitor service and public use issues a major concern to you on the Refuge? If so, please check (or number in priority order) your top choices.

__ lack of wildlife related visitor services (such as education, information and interpretive services; hunting programs, fishing, wildlife observation and wildlife photography) on the Refuge.

__ possible conflicts between public uses/facilities and wildlife/habitat values (please explain):

__ vehicle access or trespass

__ illegal hunting

__ cultural resource preservation

__ historical resource preservation

__ other public use issues and concerns (please explain):

4. Please indicate here any additional comments on recreation, education, and public access.

IMPORTANT: Please mail your finished workbook to the address below by March 15, 2007 (fold this side up, tape, stamp, and send).

http://www.fws.gov/klamathbasinrefuges/KlamathMarshCCP/KM%20PU2.pdf (4 pages)


Planning Update #2: Draft Goals and Vision [Statement]

Draft refuge goals have been developed that will set the framework for setting future objectives. Please review these goals and provide comments. The final goals that are developed will be the foundation of our CCP. We will refine and refer to these goals during our planning process.

Draft Refuge Goals for Klamath Marsh NWR

Emergent Marsh Goal: Restore and maintain optimum interspersion and diversity of aquatic vegetation and open water within the emergent marsh community to support migrating and nesting water birds.

Sedge meadows. Maintain and enhance the natural structure, diversity, and productivity of the seasonally flooded sedge meadows with an emphasis on providing nesting and foraging habitat for rails and sandhill cranes.

Ponderosa forest. Maintain the structure and diversity of existing old growth ponderosa pine stands and restore mature and old-growth characteristics to second growth and other degraded stands.

Aspen. Enhance and maintain the natural regeneration of existing aspen stands.

Riverine/spring riparian habitat. Restore the historic form and function of riverine and riparian systems to benefit native fish and wildlife including redband trout, spotted frog and neotropical migratory birds.

Natural Fire Regime. Where possible, restore a natural fire disturbance regime on all Refuge habitats.

Upland meadow. Restore and maintain the composition and structure of existing and historic grasslands to benefit meadowlarks, savannah/vesper sparrows, and sandhill cranes.

Recreation. Nurture an understanding of and appreciation for wildlife and other natural resources of KMNWR by providing opportunities for compatible wildlife dependent recreation while maintaining the primitive uncrowded nature of the area.

EE [Environmental Education] and Interpretation. Provide interpretive and education services that emphasize the natural setting and function of Klamath Marsh and its role in the NWRS [National Wildlife Refuge System].

Cultural Resources. Visitors gain an understanding and appreciation for the cultural significance of Klamath Marsh. Cultural resources of the refuge are preserved, and connect visitors and the community to the area's past and present.

The following is a draft refuge "Vision Statement." A refuge vision statement consists of a description of the refuge setting and a concise statement of desired future conditions for the refuge. A vision is a clear image of a desirable future- one that represents an achievable, challenging, and worthwhile long-range target toward which people can direct their energies. The vision statement should reflect the mission of the refuge system, the purposes for which the refuge was established and any other relevant mandates. We invite you to comment on this draft vision statement.

Draft Refuge Vision Statement for Klamath Marsh NWR

Klamath Marsh National Wildlife Refuge lies on a 7,000 year old layer of volcanic ash and rock in the transition zone between the Great Basin desert and the snow-capped eastern Cascades of Oregon. The expansive, 40,000-acre Refuge protects one of the largest and most pristine high elevation marshes in the Intermountain West.

The Eastern Slope of the Cascades has lost more than 75 percent of its natural wetlands, making the Refuge an integral component in preserving the biodiversity of the region. This large, contiguous block of wetlands provides important nesting and migratory habitat for a diversity of Pacific Flyway birds. The emergent/wocus (yellow pond lily) marshes, sedge meadows, and riparian habitats are encircled by stately pine forests, forming habitats that support over 250 species of wildlife, including spotted frogs, yellow rails, sandhill cranes, and Rocky Mountain elk.

Klamath Marsh NWR is also located at the headwaters of the Upper Klamath watershed. The Refuge wetlands plays a key role in maintaining the water quality of the upper basin by modifying water chemistry, the balance of nutrients, and water temperatures.

The Refuge will continue to work with others to preserve, restore, and enhance the natural hydrology and biological integrity of the Klamath Marsh and associated uplands as habitat for migratory birds and other indigenous wildlife. Refuge staff will use or mimic natural processes to restore and maintain habitats that support naturally occurring wildlife and unique species. Adaptive management techniques will be used to respond to changing environmental conditions.

Successful implementation of management actions will result in a naturally hydrologically functioning marsh that includes a complex interspersion of bulrush/cattail, wocus, and open water that supports a diversity of migrating and nesting waterbirds such as black terns, American bitterns, wood duck, redhead, marsh wren, and common yellowthroat. Native sedge meadows will be structurally diverse and support healthy nesting populations of species like yellow rails and sandhill cranes. Refuge forests will be dominated by open stands of old growth ponderosa pine with healthy regenerating aspen stands interspersed within the marsh and forest transition zone. Grassland meadows are protected from woody encroachments and provide habitat for species like vesper sparrows, meadowlarks, and sandhill cranes.

Though it is remote, this unspoiled landscape draws a variety of visitors. Current and future generations will have the opportunity to participate in wildlife dependent recreation and education that emphasizes self reliance, solitude, and a close relationship and respect for the environment. Refuge staff, visitors, and the community will have the chance to learn about and understand the cultural significance of the marsh, both past and present.

More information to help you get involved

Why is this planning effort starting now?

In October 1997, Congress passed the National Wildlife Refuge System Improvement Act, which states that, first and foremost, the National Wildlife Refuge System must focus on wildlife conservation.

This law establishes: (1) the mission of the Refuge System; (2) a new process of determining compatible public use activities on refuges; and (3) requires us to prepare CCP's for each refuge.

National Wildlife System mission:

"to administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans."

Goals of this planning process:

. Outline Refuge management priorities for the next 10 to 15 years;

. Describe significant Refuge resources and their importance;

. Identify how the Refuge can best protect these resources;

. Clarify what public uses are, and are not, compatible with managing significant resources;

. Identify the Refuge's role within the local community and as a national resource.

What are Refuges all about?

The U.S. Fish and Wildlife Service, part of the Department of the Interior, is the principal Federal agency responsible for conserving, protecting, and enhancing the nation's fish and wildlife populations and their habitats. The Service also manages the National Wildlife Refuge System, the world's largest collection of lands set aside specifically for the protection of fish and wildlife populations and habitats. Refuges also offer a variety of wildlife-dependent recreational opportunities, and many have visitor centers, hiking trails, and environmental education programs.

What activities can be enjoyed at Refuges?

There are laws and policies which guide management of public use on National Wildlife Refuges. Only those public uses which are determined to be compatible with the mission of the Refuge System and the purposes of the Refuge are allowed. The Refuge Improvement Act identified six wildlife dependent public uses as priority uses:

. Environmental Education

. Wildlife Photography

. Environmental Interpretation

. Hunting

. Wildlife Observation

. Fishing

http://www.fws.gov/klamathbasinrefuges/KlamathMarshCCP/Goals%20and%20Visions.pdf (2 pages)




Here are my comments (please feel free to take inspiration from them):


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 -


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.


There is no need for a "Comprehensive Conservation Plan" for the Klamath Marsh National Wildlife Refuge or for any other National Wildlife Refuge.
1,490 words.