Comment on the Oregon Department of Forestry’s Forest Management Plan for Western Oregon 

Dear ODF,

Thank you for the opportunity to comment on the draft Forest Management for Western Oregon State Forests. Like the vast majority of Oregonians, I value state forests for their fish and wildlife, cold clean rivers, recreation opportunities, and scenic vistas. For too long, management of these forests has been out of balance, heavily favoring industrial-scale clearcutting and timber revenue over multiple sustainable values cherished by Oregonians. The draft Forest Management Plan is an opportunity to restore balanced management to state forests by focusing on ecological forest management, restoring damaged ecosystems, improving water quality, and aiding the recovery of at-risk species pushed to the brink of extinction by decades of industrial forest practices.

For over a decade, the ODF has ignored requirements of its own rules and key performance measures that require the protection and enhancement of older mature forests adopted by the legislature. From now forward, the ODF must manage state forest in compliance with all existing rules and policies. The draft Forest Management Plan is an essential opportunity to start this paradigm shift toward accountability and compliance.

To restore this balance and accountability on state forests, I urge you to make the following amendments to the draft plan:

•  The FMP must be based on the best available science: Add a requirement for all actions to be based on the best science available, as required under existing law.
•  Require accountability: Amend the draft FMP to require compliance with applicable laws, policies, plans and key performance measures adopted by the Board of Forestry and the state legislature. Incorporate these by reference into the FMP.
•  Bring balance back to state forests: Delete or amend Principle 3 in the draft FMP. Principle 3 would require revenue from timber harvest to fund all of state forest management activities, continuing to prioritize logging over all other values in state forests in violation of state law.
•  Restore healthy mature forests: Stop all clearcut timber harvest of complex layered forest stands on North Coast state forests at least until a minimum of 30% of the forests are in this condition, as required by current rules and policies.
•  Ensure clean healthy waterways for salmon and communities: Develop forest management and restoration plans for watersheds with impaired water quality to restore water quality to levels healthy for salmon and other aquatic species within ten years and support safe drinking water for communities.
• Fight climate change and build climate resilience: Add strategies to implement the Climate Change and Carbon Plan for state forests and meet directives in Governor Kotek’s Executive Order 25-26 on climate resilience. Shift to longer rotations between harvest and reduce reliance on large-scale clearcutting.
• Commit to the recovery of threatened and endangered species: The Habitat Conservation Plan (HCP) is a necessary step to prevent the local extinction of imperiled fish and wildlife, but it won’t lead to the recovery of these species by itself. The FMP should include specific strategies, in addition to the HCP, to contribute to the meaningful recovery of the 17 imperiled species clinging to to survival in our state forests.

Thank you in advance for making these changes to the draft plan and protecting Oregon’s state-managed public forests for current and future generations.

Thank you.