Commercial forest soil units 42D, 70F, and 71F total 35.50 acres and make up 40.5 percent of the Proposed Pioneer Meadow Subdivision.

3. Agency Conclusions On Forest Productivity

According to the ODF, USFS, and BLM all three soils meet the forest productivity definition of forest land. The ODF, USFS, and BLM all use the 20 cf/ac/yr standard as the commercial threshold for commercial forest lands. Their position is that this threshold has been set for good reason. Biologically, 20 cf/ac/yr is the point where stands change from being dominated by low value, non-commercial species like hardwoods or juniper to being capable of producing stands of commercially valuable species like pine.

The Josephine County Forestry Program is managing all three soils (soil units 42D, 70F, and 71F) on an adjacent 40 acres (Tax Lot 600, Section 14, T.35 S., R.6W., WM.) as commercial forest land (Map 18). These soils are the same as the three forest soils on the Proposed Pioneer Meadow Subdivision. In 2004 an inventory of six stands on the 40 acres identified by the county as the North Valley 40 included 175,000 board feet of standing timber for trees 10 inches dbh and larger.

In the last 20 years the Josephine County Forestry Program has sold two salvage sales on the North Valley 40. During the Spring of 2006 the Josephine County Forestry Program sold a 57,000 board feet timber sale (Interstate Timber Sale 2006T-3). Douglas-fir #4 sawmill and better made up almost the entire sale. The sale covered 28 acres of tractor logging out of the 40-acre North Valley 40 parcel. The average dbh of the sold trees was 16"; the largest dbh was 36". The type of cut was identified as "Partial Harvest." The prescription was a type of selective harvest as 116,000 board feet was left standing in the North Valley 40.

4. Internal Rate of Return

Goal 11 provides the rules and procedures for amending the various components of the Josephine County Comprehensive Plan (JCCP).¹ The JCCP contains the general goals and policies, maps, inventories, functional plans and implementing ordinances that are required to guide the future development of Josephine County. Article 46 of the Josephine County Rural Land Development Code (RLDC) is the zoning ordinance that implements the rules and procedures.

The Josephine County, Oregon internal rate of return (IRR) system is part of the JCCP (Goal 11: Policy 3. Non-Resource Land Criteria) and Article 46 where authorized lots or parcels (but not portions thereof) which have been zoned Woodlot Resource may be designated as non-forest land because it is not included within the following definition of forest land:

"A lot or parcel is considered forest land when the predominant (more than 50%) soil or soils on the parcel have an internal rate of return of 3.50 or higher (if a single forest-rated soil is present), or composite internal rate of return of 3.5 or higher (if multiple forest-rated soils are present)."

"For the purpose of this criterion, any evaluation of the internal rates of return for forest soils shall be made pursuant to the document entitled, Using The Internal Rate Of Return To Rate Forest Soils For Applications In Land Use Planning (1985), by Lawrence F. Brown, as amended; or"

Josephine County retained Larry Brown & Associates, a forestry consulting firm, to develop a forest soil rating system which could be used to rate the quality of the forest soils in the County. These forest soils would be then placed in the three (3) standard zones, based upon developed criteria. These zones are represented by:

(3) Generally Unsuitable - A zone which forest land of lesser quality than Woodlot Resource should be placed.

The Land Evaluation and Site Assessment system was used as a basis for the method developed. The methods suggested for use on forest lands were refined by utilizing a "Forestry Investment Analysis" computer program. The program allowed each forest soil to be rated upon the soil’s "Internal Rate of Return". This economic evaluation of each forest soil was a comparative analysis using 1883 economic parameters and forest development costs projected over the life of the forestry investment. In this way, the potential of the specific forest soil was determined.

The Internal Rates of Return (IRR’s) generated varied from 1.2% of poor soil to 4.91% on the best forest soil in the county. This range of IRR’s was broken down into the three (3) zones. Soils with an IRR over 4.00% were considered of commercially higher quality, while those between 3.50 - 3.99% were classified Woodlot Resource. Those soils below 3.49% were considered generally unsuitable.

The Brown Report^{2 & 3} rated 56 soils of the 111 soils identified in the 1983 Soil Survey (pages 178 - 181). The internal rate of return (IRR) system for analyzing soils became part of the Josephine County Comprehensive Plan (JCCP) and code.

The IRR system in the Brown Report and the JCCP are in conflict with how Josephine County actually manages commercial forest lands and with the ODF, USFS, and BLM’s management policy on soils meeting the forest productivity definition of forest land. The ODF, USFS, and BLM all use the 20 cf/ac/yr standard as the commercial threshold for commercial forest lands. Per previous statements in this section the Josephine County Forestry Program is managing the North Valley 40, adjacent and south of the Proposed Pioneer Meadow Subdivision, as commercial forest land (Map 18; Map 19).⁴ The North Valley 40 has the same forest lands as the Proposed Pioneer Meadow Subdivision.

 All three soils on the North Valley 40 parcel have IRR ratings below 3.5, the index below which the county considers the land to be non-resource lands (i.e., non-forest lands) and suitable for conversion to rural residential lands.

The IRR ratings for the three forest soils on the North Valley 40 parcel as non-commercial forest lands are in conflict with the conclusions of the ODF, USFS, BLM , and Josephine County which is managing the North Valley 40 as commercial forest lands.

5. Summary

All three of the commercial forest soils of the Proposed Pioneer Meadow Subdivision meet the forest productivity definition of forest land used by the ODF, USFS, BLM, and the operational management actions of the Josephine County Forestry Program.

The Josephine County Forestry Program is managing the same three commercial forest soils (soil mapping units from the Soil Survey) as on the subject property as commercial forest land. On May 2007 the county had 57,000 board feet of timber harvested (Interstate Timber Sale 2006T-3) from the same forest mapping units as identified for the Proposed Pioneer Meadow Subdivision.

4. Hugo Neighborhood Association & Historical Society; Josephine County Historical Society; Goal One Coalition; Rogue Advocates; Oregon-California Trails Association, and the Pleasant Valley Cemetery Association. June 2007. Hugo Granite Tombstone Quarry Site: Preliminary Resource Assessment. Hugo, OR.