To Oregon Department of ForestryFrom Beyond ToxicsDate June 21 2021Re Annual Operations Plans for Fiscal Year 2022

To Whom It May Concern

Thank you for the opportunity to comment on the draft Annual Operations Plans (AOPs) for state forestsin the Astoria Forest Grove Klamath-Lake Tillamook West Oregon and Western Lane Districts forFiscal Year 2022 State forests are required by law to provide economic environmental and socialbenefits to Oregonians We request that the Department of Forestry (ODF) revise the draft plans tomanage our public lands in a manner that does not jeopardize public and environmental health for thesake of financial gain Notably missing from the draft plans are a thorough consideration of (1) climatechange impacts and (2) drinking water concerns Failing to manage state forests in a way that effectivelymitigates the impacts of climate change and protects drinking water for millions of Oregonians would bea costly mistake that adds to the cascading effects of climate loss of property and habitat and harm towildlife and Oregon residents

Carbon Implications

In order to mitigate the most dire impacts of the climate crisis we must change the way we manage ourpublic lands and carbon sequestration potential must be considered alongside financial viability and healthimpacts Managing state forests to reduce emissions and increase carbon storage and sequestration is botha priority of the Board of Forestry and necessary to achieve the directives set out in Governor BrownrsquosExecutive Order 20-04 We ask that the Department conduct operations using a climate lens taking intoaccount the emissions from fuel use in logging operations emissions from road construction soil andnative vegetation disturbance during harvest operations emissions from slash burning and transport ofslash offsite emissions from trucking in and spraying pesticides and the estimated loss of carbon storagewhen a tree is harvested transported and processed into wood products chips and pellets

1 Longer Logging Rotations

According to Diaz et al ldquo[e]xpanded riparian protections increased green tree retention and theextension of rotation ages can translate into substantially higher carbon storage than contemporarycommon practice for Douglas-fir management in the Pacific Northwestrdquo1 Clearcutting plans set out in theAOPs however reflect harvest levels that are unsustainable and detrimental to climate mitigation needsODF is managing areas available for clearcut on an approximately 55-year rotation By allowing trees togrow for longer time periods ODF can improve carbon stocks while also increasing timber yield and

1 David D Diaz Sara Loreno Gregory J Ettl and Brent Davies 2018 Tradeoffs in Timber Carbon and Cash Flowunder Alternative Management Systems for Douglas-Fir in the Pacific Northwest Forests 9 (8) 447httpswwwmdpicom1999-490798447

1

timber quality Studies suggest that 80-year rotations of Coastal Douglas fir may provide optimal carbonstorage benefits depending on assumptions about product longevity and substitution of alternativematerials2

2 Carbon Reserves

In addition state forests that exhibit old forest characteristics should be identified and prioritized by theDepartment for their carbon and biodiversity value Mature and old growth forests store and sequesterimmense amounts of carbon Wherever native stands of large trees exist they should be protected asclimate reserves Further ODF should work to identify additional areas of the highest carbon storagepotential that should also be protected as part of this carbon reserve These stands also provide highquality habitat for salmon and other at-risk wildlife helping managers achieve two objectives at once toachieve proactive management of lands for a changing climate and future HCP requirements

3 Diverse Regeneration

When replanting harvested forests we appreciate where plans intend to increase species diversity andselect species that will be more resilient to climate change Forests replanted with a dense monoculture ofDouglas-fir for example can provide more fuel for wildfires exacerbated by climate-induced hotter andwindier conditions Further monoculture forests are less resilient to pests and disease which may lead totree losses and future applications of chemical inputs that harm drinking water sources and fish andwildlife habitat

Watershed Impacts

In addition to carbon storage climate adaptation strategies are needed to ensure that forest operations areprotecting watersheds Clearcuts and post-fire logging operations increase the risk of mudslides andsediment runoff negatively impacting Oregonrsquos rivers and streams and pesticide application can pose arisk to local community drinking water sources Water infrastructure for water service providers isoutdated and treatment needs are costly Further drinking water violations disproportionately occur incommunities of color especially in rural and tribal areas3 As the impacts of climate change worsen(including drought heat waves less snowpack and more extreme precipitation events) Oregonrsquos forestsmust be managed for clean water quality water quantity and flood prevention as an adaptation tool

3 Samayoa Monica ldquoStudy Safe Drinking Water Violations Are Higher For Communities Of Colorrdquo September 252019httpswwwopborgnewsarticlesafe-drinking-water-act-violations-communities-color-study see alsoReyes-Santos Case-Scott and Singh ldquoAddressing Issues of Water Justicerdquo June 1 2021httpswwwregisterguardcomstoryopinioncolumns20210601guest-view-addressing-issues-water-justice-oregon-water-futures5250163001

2 See eg Stephen J Fain Brian Kittler Amira Chowyuk 2018 Managing Moist Forests of the Pacific NorthwestUnited States for Climate Positive Outcomes Multidisciplinary Digital Publishing Institute DOI103390f9100618httpswwwresearchgatenetpublication328229114_Managing_Moist_Forests_of_the_Pacific_Northwest_United_States_for_Climate_Positive_Outcomes

2

timber quality Studies suggest that 80-year rotations of Coastal Douglas fir may provide optimal carbonstorage benefits depending on assumptions about product longevity and substitution of alternativematerials2

2 Carbon Reserves

In addition state forests that exhibit old forest characteristics should be identified and prioritized by theDepartment for their carbon and biodiversity value Mature and old growth forests store and sequesterimmense amounts of carbon Wherever native stands of large trees exist they should be protected asclimate reserves Further ODF should work to identify additional areas of the highest carbon storagepotential that should also be protected as part of this carbon reserve These stands also provide highquality habitat for salmon and other at-risk wildlife helping managers achieve two objectives at once toachieve proactive management of lands for a changing climate and future HCP requirements

3 Diverse Regeneration

When replanting harvested forests we appreciate where plans intend to increase species diversity andselect species that will be more resilient to climate change Forests replanted with a dense monoculture ofDouglas-fir for example can provide more fuel for wildfires exacerbated by climate-induced hotter andwindier conditions Further monoculture forests are less resilient to pests and disease which may lead totree losses and future applications of chemical inputs that harm drinking water sources and fish andwildlife habitat

Watershed Impacts

In addition to carbon storage climate adaptation strategies are needed to ensure that forest operations areprotecting watersheds Clearcuts and post-fire logging operations increase the risk of mudslides andsediment runoff negatively impacting Oregonrsquos rivers and streams and pesticide application can pose arisk to local community drinking water sources Water infrastructure for water service providers isoutdated and treatment needs are costly Further drinking water violations disproportionately occur incommunities of color especially in rural and tribal areas3 As the impacts of climate change worsen(including drought heat waves less snowpack and more extreme precipitation events) Oregonrsquos forestsmust be managed for clean water quality water quantity and flood prevention as an adaptation tool

3 Samayoa Monica ldquoStudy Safe Drinking Water Violations Are Higher For Communities Of Colorrdquo September 252019httpswwwopborgnewsarticlesafe-drinking-water-act-violations-communities-color-study see alsoReyes-Santos Case-Scott and Singh ldquoAddressing Issues of Water Justicerdquo June 1 2021httpswwwregisterguardcomstoryopinioncolumns20210601guest-view-addressing-issues-water-justice-oregon-water-futures5250163001

2 See eg Stephen J Fain Brian Kittler Amira Chowyuk 2018 Managing Moist Forests of the Pacific NorthwestUnited States for Climate Positive Outcomes Multidisciplinary Digital Publishing Institute DOI103390f9100618httpswwwresearchgatenetpublication328229114_Managing_Moist_Forests_of_the_Pacific_Northwest_United_States_for_Climate_Positive_Outcomes

2

1 Slope

Do not execute plans to clearcut steeply-sloped areas The risk of landslides increased sedimentation andrunoff into waterways is too high The maps below depict the location of an ODF logging operation in asteeply sloped high landslide susceptibility area near Foley Creek in the Nehalem watershed in closeproximity to salmon and steelhead streams These maps exhibit just one of the many ODF loggingoperations on state lands that are greater than 80 slope and are directly uphill from fish streamsapproved in AOPrsquos Washingtonrsquos Forest Practices Rules in comparison do far more to reduce landsliderisks and excessive runoff by requiring logging operations on steep slopes to meet higher standards ofriparian protections than those in Oregon4

4 Washington State Forest Practices Rules (Title 222 WAC)

3

2 Riparian Buffers

Oregonrsquos buffer zone regulations are weak when compared to standards of forest practices required inneighboring states In Washington for example 50-foot no-cut buffers are required around fish-bearingand non-fish streams Oregonrsquos logging operations should expand no-cut buffers for fish-bearing streams(currently 20 feet) and leave no-cut buffers on headwater streams (currently nonexistent) to protect waterquality as these are major sources of drinking water and often upstream from fish streams

3 Pesticide Application

When developing site preparation plans we urge you to avoid using methods that harm drinking watersources ODF continues to rely on wide scale pesticide application in state forests Chemical sitepreparations kill native beneficial plants such as ceanothus vine maple and alder which naturallyre-colonize Oregon forests after a disturbance These plants provide valuable habitat and food for wildlifefrom elk and blacktail deer to songbirds State forest pesticide applications also allow chemicals withknown health effects such as herbicides and fungicides to enter surface waters through runoff or drift orinfiltrate precious groundwater sources This puts drinking water and wildlife at risk Washingtonrsquos forestpractices restrict the application of chemicals known to persist in groundwater (such as atrazine andhexazinone) Oregon should adopt protections that are at least equivalent or better to protect groundwatera critical and limited resource

4

4 Road Construction and Maintenance

The draft plans propose miles of newly constructed roads to allow for harvest operations in addition to theseveral thousand miles of roads already owned and managed by ODF Minimize construction of newroads to avoid habitat fragmentation and detrimental impacts to waterways When constructing new roadsdo so in a way that minimizes sediment introduction to waterways Sediment runoff can clog waterwaysdegrade fish habitat and negatively impact drinking water for local communities Establish safeguardssuch as drain dips above and away from stream crossings so that road drainage water is filtered naturallythrough vegetation before reaching waterways Construction of sediment retention structures andout-sloping of road segments would also minimize sediment input to streams When siting harvests andconstructing or maintaining roads take into account changing precipitation and streamflow levels due toclimate change

Equity amp Environmental Justice

Equitable and ecologically-appropriate stewardship of Oregon state forests is critical for all Oregoniansbut especially for historically disadvantaged populations The impacts of unsustainable natural resourcemanagement decisions disproportionately burden disadvantaged groups including Black Indigenousand People of Color (BIPOC) communities and low income communities The impacts of forestmanagement decisions unfold against a backdrop of enduring racial and socioeconomic inequities thathave shaped how historically underserved and underrepresented communities can withstand thoseimpacts

In finalizing the Annual Operations Plans for our state forests the Department must engage multipleperspectives communicate directly with impacted communities Together with these communities theagency should consider unintended outcomes when developing policies Community input is essential toadvancing natural climate solutions that also reduce or eliminate harm The Department must ensure thatthese communities may continue to reap the recreational health social and cultural benefits of ourforests for generations to come and are not disproportionately burdened by unsustainable forestoperations as the climate crisis worsens

Thank you for your consideration of these comments and work developing these plans

Sincerely

Grace Brahler Oregon Climate Action Plan amp Policy Manager gbrahlerbeyondtoxicsorg

Beyond ToxicsLane County Office 120 Shelton McMurphey Blvd Suite 280 Eugene OR 97401Jackson County Office 312 N Main St Suite B Phoenix Oregon 97535

5

2 Riparian Buffers

Oregonrsquos buffer zone regulations are weak when compared to standards of forest practices required inneighboring states In Washington for example 50-foot no-cut buffers are required around fish-bearingand non-fish streams Oregonrsquos logging operations should expand no-cut buffers for fish-bearing streams(currently 20 feet) and leave no-cut buffers on headwater streams (currently nonexistent) to protect waterquality as these are major sources of drinking water and often upstream from fish streams

3 Pesticide Application

When developing site preparation plans we urge you to avoid using methods that harm drinking watersources ODF continues to rely on wide scale pesticide application in state forests Chemical sitepreparations kill native beneficial plants such as ceanothus vine maple and alder which naturallyre-colonize Oregon forests after a disturbance These plants provide valuable habitat and food for wildlifefrom elk and blacktail deer to songbirds State forest pesticide applications also allow chemicals withknown health effects such as herbicides and fungicides to enter surface waters through runoff or drift orinfiltrate precious groundwater sources This puts drinking water and wildlife at risk Washingtonrsquos forestpractices restrict the application of chemicals known to persist in groundwater (such as atrazine andhexazinone) Oregon should adopt protections that are at least equivalent or better to protect groundwatera critical and limited resource

4

4 Road Construction and Maintenance

The draft plans propose miles of newly constructed roads to allow for harvest operations in addition to theseveral thousand miles of roads already owned and managed by ODF Minimize construction of newroads to avoid habitat fragmentation and detrimental impacts to waterways When constructing new roadsdo so in a way that minimizes sediment introduction to waterways Sediment runoff can clog waterwaysdegrade fish habitat and negatively impact drinking water for local communities Establish safeguardssuch as drain dips above and away from stream crossings so that road drainage water is filtered naturallythrough vegetation before reaching waterways Construction of sediment retention structures andout-sloping of road segments would also minimize sediment input to streams When siting harvests andconstructing or maintaining roads take into account changing precipitation and streamflow levels due toclimate change

Equity amp Environmental Justice

Equitable and ecologically-appropriate stewardship of Oregon state forests is critical for all Oregoniansbut especially for historically disadvantaged populations The impacts of unsustainable natural resourcemanagement decisions disproportionately burden disadvantaged groups including Black Indigenousand People of Color (BIPOC) communities and low income communities The impacts of forestmanagement decisions unfold against a backdrop of enduring racial and socioeconomic inequities thathave shaped how historically underserved and underrepresented communities can withstand thoseimpacts

In finalizing the Annual Operations Plans for our state forests the Department must engage multipleperspectives communicate directly with impacted communities Together with these communities theagency should consider unintended outcomes when developing policies Community input is essential toadvancing natural climate solutions that also reduce or eliminate harm The Department must ensure thatthese communities may continue to reap the recreational health social and cultural benefits of ourforests for generations to come and are not disproportionately burdened by unsustainable forestoperations as the climate crisis worsens

Thank you for your consideration of these comments and work developing these plans

Sincerely

Grace Brahler Oregon Climate Action Plan amp Policy Manager gbrahlerbeyondtoxicsorg

Beyond ToxicsLane County Office 120 Shelton McMurphey Blvd Suite 280 Eugene OR 97401Jackson County Office 312 N Main St Suite B Phoenix Oregon 97535

5

4 Road Construction and Maintenance

The draft plans propose miles of newly constructed roads to allow for harvest operations in addition to theseveral thousand miles of roads already owned and managed by ODF Minimize construction of newroads to avoid habitat fragmentation and detrimental impacts to waterways When constructing new roadsdo so in a way that minimizes sediment introduction to waterways Sediment runoff can clog waterwaysdegrade fish habitat and negatively impact drinking water for local communities Establish safeguardssuch as drain dips above and away from stream crossings so that road drainage water is filtered naturallythrough vegetation before reaching waterways Construction of sediment retention structures andout-sloping of road segments would also minimize sediment input to streams When siting harvests andconstructing or maintaining roads take into account changing precipitation and streamflow levels due toclimate change

Equity amp Environmental Justice

Equitable and ecologically-appropriate stewardship of Oregon state forests is critical for all Oregoniansbut especially for historically disadvantaged populations The impacts of unsustainable natural resourcemanagement decisions disproportionately burden disadvantaged groups including Black Indigenousand People of Color (BIPOC) communities and low income communities The impacts of forestmanagement decisions unfold against a backdrop of enduring racial and socioeconomic inequities thathave shaped how historically underserved and underrepresented communities can withstand thoseimpacts

In finalizing the Annual Operations Plans for our state forests the Department must engage multipleperspectives communicate directly with impacted communities Together with these communities theagency should consider unintended outcomes when developing policies Community input is essential toadvancing natural climate solutions that also reduce or eliminate harm The Department must ensure thatthese communities may continue to reap the recreational health social and cultural benefits of ourforests for generations to come and are not disproportionately burdened by unsustainable forestoperations as the climate crisis worsens

Thank you for your consideration of these comments and work developing these plans

Sincerely

Grace Brahler Oregon Climate Action Plan amp Policy Manager gbrahlerbeyondtoxicsorg

Beyond ToxicsLane County Office 120 Shelton McMurphey Blvd Suite 280 Eugene OR 97401Jackson County Office 312 N Main St Suite B Phoenix Oregon 97535

5

To The Oregon Department of Forestry (JasonRCOXoregongov)

From Bob Van Dyk Wild Salmon CenterBob Sallinger Audubon Society of PortlandSean Stevens Oregon WildNancy Webster amp Trygve Steen North Coast Communities for Watershed ProtectionSteve Griffiths Audubon Society of Lincoln CityDavid Harrison Salem Audubon SocietyNoah Greenwald Center for Biological DiversityIan Fergusson Association of Northwest SteelheadersDavid Moskowitz Conservation AnglerLisa Arkin Beyond ToxicsJennifer Fairbrother Native Fish SocietyBob Rees Northwest Guides and Anglers AssociationChuck Willer and Mike Manzulli Oregon Coast Range AssociationRebecca White Cascadia Wildlands

Cc Governor Kate BrownOregon Board of Forestry

Date June 21 2021

Re Comments on ODFrsquos 2022 Annual Operations Plans

On behalf of the many thousands of Oregonians who support our fourteen organizations we submitthese comments on Oregon Department of Forestryrsquos (ODF) FY2022 Annual Operations Plans(AOPs) As in past years it is a daunting task to review these plans which include dozens of separateunits of clear-cut timber sales numerous partial cuts many miles of new roads and thousands ofacres of aerial spray (locations not identified) We appreciate the effort of ODF staff to prepare theseplans the technical capability afforded by ODFrsquos postings and web-app and ODFrsquos prompt sharingof GIS data

We have very serious concerns with the proposed plans which fall in three key buckets First we have noconfidence that the proposed harvest levels are sustainable under current Forest Management Plancommitments Second ODF continues to liquidate rare complex stands despite being a long way from theboard and legislatively approved Key Performance Measures Third the AOPs clearly undermine thestill-developing Western Oregon State Forest Habitat Conservation Plan by including extensive clearcutting in the proposed Habitat Conservation Areas

Context justifies a more conservative approach

One significant change since the last (FY 2021) AOP is the Boardrsquos advancement of a draft HabitatConservation Plan (HCP) into the start of federal review and public comment The draft HCP containsproposed Habitat Conservation Areas (HCAs) in important forest habitat These areas represent importantconservation commitments and the proposed AOPs not only undermine their potential value as HCAs but

1

also the value of the HCP Our members and supporters remain committed to long-term sustainable andbalanced management of our publicly-owned state forest lands We want to support ODF as a public landmanager But unfortunately these balanced values are not adequately reflected in the AOPs

Aside from the draft HCP the FY 2022 AOPs are set in a context of growing concerns among Oregoniansand the broader public over (a) climate change (both its threats to the resilience of Pacific NW forestswater quality and stronghold salmon streams as well as the role coastal temperate rainforests play inpositively mitigating impacts through climate-smart forestry) (b) chemical spray operations (on privateand state public forest lands) and (c) impacts to drinking water (from forest management and sprayoperations in watersheds containing ODF lands) The FY 2022 AOP timber sales are harmful towatersheds biodiversity and ODFrsquos credibility as a public lands manager particularly regarding theAstoria District where continued destruction of complex forest is proposed and the Tillamook Districtwhere clearcutting of steep landslide prone slopes continues This concern is especially pronounced nowas the state moves towards an HCP as timber markets are lucrative and as both unanticipated salvagelogging revenue and previous anticipated harvest efforts have created more robustness in the ForestDevelopment Fund

Instead of continuing to forge ahead with aggressive harvest levels at the high-end of the current Forestmanagement Plan (FMP) as the current AOPs do the sustainable approach to take now would be to savefor the future--both in terms of harvest volume left available for later years and securing conservationcredit relevant to an HCP

Neglect of performance measures

In recent years ODF and the Board have abandoned a metric-driven and indicator-based approach to stateforest management Of course metrics are available to assess progress on other aspects of forestmanagement such as those found in the Performance Measures adopted by the Board of Forestry to guidestate forest management1 The Performance Measures contain useful and specific targets on forestmanagement goals including on such topics as hydrologic connectivity of roads As you know there arealso Key Performance Measures on which the Board and ODF report to the legislature including complexforests which has been in steady decline under ODFrsquos stewardship despite clear direction to increase theamount of complex forest The only metric we see regarding justification of AOP harvest levels areharvest projections that are a decade old

Unsustainable harvest levels

The aggressive clearcutting pace set out in the AOPs reflect harvest levels that are very likelyunsustainable and thus inconsistent with the FMP As stated in our comments last year according to theanalysis completed by ODF as part of the exploration of a new FMP current restrictions on harvestableareas were presented to the Board in a document entitled ldquoPlanning Area Constraintsrdquo2 That document

2 httpswwworegongovODFBoardDocumentsAFMP1520-20Constraintspdf

1 The 2013 Board of Forestry State Forests Performance Measure Report (84pp) identifies only 3 of 9 performancemeasures tied to revenue production It can be found here httpsdigitaloslstateorusislandoraobjectosl29613But not on the Department of Forestry website

2

concluded 49 of the state forest land base was constrained which in practice means these areas areclosed to clearcutting3 This left 51 available for clearcutting (on average across the planning area)Cumulative clearcut acres in recent years across this available 51 of the forest provide an estimate ofthe rate of final harvest or rotation age which reveal ODF is currently managing the areas available forclearcutting on an approximately 55 year rotation

A 55-year rotation is more typical of an industrial forest and it is troubling for several reasons First themajority of the stands clearcut by ODF are over 55 years of age with many harvests in 80-year and olderstands These older stands produce much higher volumes that will not be available under a shorterrotation creating an unsustainable volume and revenue picture for the future Second intensive harvestsat this rate are not consistent with developing complex forest structure relevant to supporting biodiversityODF should not be harvesting at levels that impair or prevent the attainment of its long-termcommitments for complex forest habitat development under its operative Board-adopted FMP

Third the level of risk of a total loss from a forest fire is increased by a 55 year rotation When theBeachie Creek fire burned in the Santiam State Forest plantations younger than 25 years were a total lossIn a future where fire frequency is likely to be much greater older forests offer a significant financialadvantage Young plantations are especially easily burned within an area affected by fire Growing treesfor only 55 years involves at least a 25-year period where a fire likely represents a total loss - - Therefore45 of the time when the trees are growing there is a high risk of a total loss When trees are grown for100 years the time period where there is the risk of a total loss shrinks to only 25 of the time for theoperation Even longer growth cycles provide even lower relative risks of a total loss Clearly with drierhotter weather from climate change and the associated increased fire risk serious consideration needs tobe given to longer rotations

Finally as a state agency ODF needs to reverse its movement toward a 55 year rotation onldquounencumbered acresrdquo by ending harvest on 80 year and older stands Short rotation management resultsin a net output of carbon dioxide to the atmosphere which is especially severe from private lands whichare commonly managed on rotations of 35 to 45 years It can also have detrimental impacts on instreamflows and hydrographs which during a time of climate change need conservation attention in coastalstreams flowing through state forest lands It is essential for ODF to lead the way toward havingOregonrsquos forests effectively sequester carbon dioxide from the atmosphere This can best beaccomplished by avoiding all harvest of trees 80 years old and older as well as by maintaining complexhabitat development with its older trees wherever it occurs Scientific evidence clearly supports thecritically unique role that trees older than 80 years and older forest ecosystems can play in thesequestration of carbon dioxide Governor Brownrsquos Executive Order NO 20-04 contains importantGeneral Directives to State Agencies part C states ldquoAgency Decisions To the full extent allowed by lawagencies shall consider and integrate climate change climate change impacts and the statersquos GHGemissions reductions goals into their planning budgets investments and policy making decisions rdquoBecause of this executive order and general environmental ethical considerations no further logging of 80year old and older trees should be occurring on ODF-managed state public lands In other words as therest of this input to the 2022 AOP is being considered all older complex forest needs to be fully protectedwherever it occurs without exception

3 Only some of these constraints relate to conservation values For example road surfaces are ldquoconstrainedrdquo fromclearcutting as they have no trees and the roads generally represent a threat to many conservation values andrarely a benefit

3

Undermining future proposed Habitat Conservation Areas

In October of 2020 the Board of Forestry unanimously voted to continue advancement of an HCP tocomply with the Endangered Species Act (ESA) and provide operational viability related to timber harvestacross western Oregonrsquos public state forest lands In the spring of this year ODF submitted a draft HCP tofederal agencies to begin the federal review and permitting process The HCP strategy is founded on anetwork of proposed Habitat Conservation Areas (HCAs) that would ensure conservation outcomes onthis portion of public state forest lands while permitting harvest activity to occur on the remainder of thelandscape even if it results in ldquotakerdquo of ESA-listed species (or some likely to be listed in the future)incidental to that harvest or related actions In as much as an HCP creates conservation certainty onportions of state forest lands it also increases certainty for timber harvest across much of the landscape bypermitting impacts otherwise prohibited by the ESA The key premise in this legal arrangement is that anadequate quantity and quality of HCAs will exist to achieve conservation outcomes needed to balance outthe harvest and related impacts across the landscape ODFrsquos FY 2022 AOPs reveal numerous timber salesthat undo this premise

ODF appears to believe that logging proposed HCAs with clearcuts and partial cuts in the near-term willnot undermine their conservation value in the long-term We believe this logic is flawed and that takingthis action in the near term would and should reset the calculus related to the proposed HCP (ie arguingeither for additional HCAs elsewhere in order to offset habitat lost to AOP-proposed logging or undoingproposed HCA designations where these timber sales exist and instead designating other habitat that is notlogged just prior to HCA designation) We say this recognizing that active management (ie tree cuttingand removal) would be allowed within HCAs in the future if an HCP is fully approved But that HCAlogging would be confined by a directive of promoting habitat conservation values whereas there is littleto indicate the proposed FY 2022 AOP logging in HCAs is designed or driven by reasons other thanrevenue production

The following proposed timber sales total over 2400 acres of proposed clearcut or partial cut loggingwithin proposed HCAs Many of them are in relatively large proposed HCAs and along with either othertimber sales proposed within the same HCA or sales adjacent to it will result in direct habitat loss qualitydiminishment andor fragmentation Other sales are within smaller HCArsquos rendering them less viableoverall for the same reasons as above but with amplified effect because of the HCArsquos small size

Astoria District Kessler (Units 1-6 512 acres total) Hard Target (Unit 1 and 2 67 and 98acres) Green Saddle (Unit 2 101 acres) Wickiup (110 acres) Toolbox (Units 2-5 234 acrestotal) Deep 6 (Units 8 and 10 42 and 115 acres) Plympton East (Unit 2 26 acres)

Tillamook District Coast Range South (225 acres) Coast Bill (Units 96 and 104 99 and 118acres respectively) Schmeagle Hill (Unit 924 32 acres) Four DB Cronin (Units 222 and 224 104 and 115 acres)

Forest Grove District (all PCrsquos) Larch Madness (72 acres) Point Belding (309 acres) Ingersoll(96 acres)

Conducting clearcuts in areas of proposed HCAs is not supported by our organizations especially wherethere is nothing in the AOPs indicating such logging is designed by wildlife biologists to attainconservation objectives The Pre-Operations Reports reveal that many of these projects will not justclearcut trees within the HCA but will have combined effects with recent or planned clearcuts

4

immediately on the HCA boundaries4 Unless ODF can indicate how a clearcut has been designed for thepurpose of attaining HCA objectives (which is not apparent in the Pre-Operations Report information) weask that ODF delay any further advancement of clearcuts in HCAs until attainment of an HCPandor until active management prescriptions are designed based on the conservation objectives ofthe proposed HCAs Aside from this reason the Pre-Op Reports in the AOPs indicate other informationthat we believe argues in favor of this request

The Pre-Op Reports for these sales often indicate stream surveys and surveys for species likeMarbled Murrelet or Northern Spotted Owls are either ongoing or have not yet been done withrespect to several of these sales Such information will and should inform the design of activemanagement in HCAs and may argue for reshaping sale design For projects proposed in HCAsthis kind of information should be available for integration during the project planning phase notas work to do after an AOP has been issued For some sales information exists in the Pre-OpReport that further underscores this5

For several sales the Pre-Op Reports indicate language such as ldquoDistrict will consult with AreaBiologist on general wildlife leave tree strategies during sale layoutrdquo6 Or in other areas of saleseither partly in or adjacent to proposed HCAs ldquoIt was determined by the Biologist that there is anopportunity to scatter the wildlife trees throughout the unit by selecting the biggest and best treesmixed with minor species The Biologist will be consulted if the Forester needs assistance withthe wildlife tree strategyrdquo7 Our point is that for active management or especially in the case ofclearcuts or partial cuts located within overlapping or adjacent to HCAs the planning approachshould be different ODF should be integrating wildlife prescriptions and conservation-relevantdesign into the planning not afterwards and not discretionarily as a potential afterthought

Many Pre-Op Reports indicate this kind of language ldquoThere is potential for stream enhancementopportunities in fish bearing streams associated with this sale Additional field work will beconducted to determine the best candidates to focus stream enhancement efforts on over this fiscalyear The Aquatic and Riparian Specialist will be consulted to help identify these candidates andmay consult with ODFW fish biologists as neededrdquo8 As above for activity within overlapping oradjacent to proposed HCAs ODF should be planning differently than it normally does Given theconservation objective of proposed HCAs activity like stream enhancement planning should beintegrated into the planning phase up front not after a project has been laid out and designed tothe level of being put into an AOP

8 See for example Toolbox Coast Bill Coast Range South and Kessler (which also adds ldquoThe local watershedcouncil has expressed an interest in working together on projects in this area and would like to be included indiscussions for future projectsrdquo

7 See Doty Mill (emphasis added)

6 See for example Coast Range South Coast Bill (emphasis added)

5 See for example Green Saddle (notes an MMMA located to the east with an intent to build upon that habitatthrough this project with green tree retention Also notes intent to leave scattered green trees that target wind firmwildlife trees to create a wind buffer to the existing MMMA But it is not clear this has been integrated into sale designor mapping) Toolbox (ldquoMM potential habitat was IDrsquod to the west of Unit 1 Layout forester will need to ID these treesand Ensure sale boundary is posted 330rsquo away from themrdquo)

4 Wickiup--clearcut removal of trees in the peninsula of the proposed HCA that neighbors private land to the north thathas been recently clearcut see also Coast Bill Coast Range South and Hollywood Hills all contain units within ordirectly bordering on four proposed HCAs within a common landscape in the Tillamook State Forest that has alreadybeen heavily impacted by past private land and state clearcuts

5

With respect to partial cuts proposed in HCAs in several instances these sales are proposed within thesame proposed HCA boundaries as clearcuts or other partial cuts proposed within or immediately adjacentto it creating a fragmentation concern9 We recognize that there is a distinction between partial cuts andclearcuts and that some proposed thinning could in theory be designed to support attainment of proposedHCA objectives in the future But what seems more clear is that the partial cuts are not targetingconservation objectives but rather revenue objectives or commercial timber stand development objectives(which a future HCA designation would replace)10 There may be some exceptions in the form of PreOperations Report language for certain projects (below) but whether these projects have been plannedfrom the start through a conservation lens (consistent with HCA intent) is something we would like tobetter understand and regardless we ask that ODF ensure the exception is the rule for all partial cutsproposed in HCAs so as to ensure the future potential conservation value of HCAs is notundermined

For example in the Point Belding and Ingersoll proposed partial cuts ODF clearly states

ldquoThis moderate partial cut will be designed to improve stand diversity and the growing conditionwithin the stands District staff will consult with the Biologist on prescriptions during sale layoutPrescriptions may incorporate a mix of gap-cuts areas of untreated stands and variable densitythinning prescriptions This management prescription will reserve minor species and hardwoodsenhancing the development of the stand towards a more complex and biologically diverse standcommonly associated with older forestsrdquo

ldquoThis is a first entry thinning which will improve the growing conditions for this stand Themanagement prescription will reserve minor species and hardwoods enhancing the development

10 See for exampleLarch Madness (42 acres of planned commercial within 15 miles of Middle Drift Ck NSO pair site)

A Preliminary Biological Assessment letter from the wildlife biologist to unit forester ldquoI wouldconsider this stand suitable dispersal roosting or foraging habitat for northern spotted owlshellipFollowing completion of the light commercial thin prescription the sale unit will not be suitablenorthern spotted owl habitat for upwards of 15 yearsrdquo

The letter also notes that there has been significant variable density thinning within the NSO circleover that last 20 years as well as recent regeneration or salvage harvests in the circle from2016-2020 While the biologist concludes this partial cut has a low risk of negatively affecting theoccupancy and productivity of the NSO site this is largely because of the amount of suitable habitatacreage that will exist in other areas surrounding the site the sale ldquowill not dramatically increasefragmentationrdquo and the proposed activity is a light thinning

Our contention is not that ldquono actionrdquo is the proper approach but given the context has this PC thinning project been planned with NSO habitat conservation objectives in mind (which we presumewas part of what drove the designation of a proposed HCA here) versus a ldquotry not to make it worserdquoframework This would include considerations of barred owl removal which are noted to be presentin the Pre-Op Report in addition to the thinning activity

Toolbox Thin ldquoMM potential habitat was IDrsquod to the west of Unit 1 Layout forester will need to ID these trees and

Ensure sale boundary is posted 330rsquo away from themrdquo Also ldquoThere is a small sliver of DFC OlderForest Structure that runs adjacent to the northern boundary of Unit 5 This is intended to be withinthe stream buffer and is planned to be outside of the posted timber sale boundary Unit 5 is a partialcut unit and the planned prescription would coincide with Older Forest Structurerdquo

To us this indicates that planning is occurring through a lens of trying to minimize impacts to knownconservation values rather than crafting a project so as to enhance those values which is whatshould happen with respect to any project in a proposed HCA

9 Point Belding PC is within the same large HCA that also includes Ingersoll PC to the east Kesler to the NW and theDoty Mill project on the north edge The Toolbox Thin is in a proposed HCA that also includes the Deep 6 PC

6

of the stand more quickly towards a more complex and biologically diverse standrdquo

The Point Belding project has a desired future condition of OFS or LYR while the Ingersoll project has adesired future condition of ldquogeneralrdquo under the Forest Grove District IP (2011) That said since theseprojects are in proposed HCAs we believe it is appropriate for all projects in proposed HCAs to havethis kind of language linking project planning to attainment of conservation values in the project area (iedevelopment of more complex and biologically diverse stands associated with older forests or any otherspecific conservation value objective for a given HCA location) While we believe biologist integrationshould occur early during project planning and not simply during sale layout it is positive to see this kindof advance thinking related to HCA values in these two projects The Pre Operations Reports for otherpartial cuts lack such language

Partial cut projects also commonly contain this language

ldquo the RMA is not currently in Mature Forest Condition (MFC) and without thinning is unlikelyto reach MFC Therefore the Rx for the Inner Zone may be the same as for the surrounding areaThe prescription exceeds the FMP riparian standards It removes small diameter conifer treesincreasing diameter growth on residual trees and opening the stand for understory growth thuspromoting MFC to develop faster than if the RMA was left alone Ground disturbance will beminimized to less than 10 of the ground in these areasrdquo11

Riparian thinning in HCAs has been discussed by ODF with state and federal fish and wildlife agencies inthe context of the proposed HCP Our organizations do not oppose this kind of activity outright but wewant to be sure such riparian thinning is designed with the direct engagement of state and federal fish andwildlife biologists It is not clear this has happened in the case of the AOPs proposed partial cuts involvingriparian thinning Instead it appears ODF has drawn a conclusion for the RMA condition and advanced aprescription that is equal to the area surrounding the inner zone Because such activity within proposedHCAs and RCAs that are a focal part of an HCP that asks for state and federal agency approval we askthat ODF ensure riparian thinning in proposed HCAs is planned jointly

Finally in addition to the sales mentioned above there are several proposed timber sales immediatelyadjacent to proposed HCAs where a portion of the sale boundary dips into the HCA boundary We havenot included the details in these comments but can easily provide them if ODF is interested in addressingthis situation as we do not believe these areas of overlap are necessary for sale viability While we haveconcerns related to several of these sales related to conversion of complex habitat to clearcut acres ourimmediate request in the context of resolving HCA concerns is that ODF take action to exclude theareas of overlap from the sale boundary

Astoria Dist Iron Fire (Unit 1 and 4) Wage Earner (Unit 1) Tillamook Dist Hollywood Hills Forest Grove Dist Double Parked Doty Mill Hoggendas West Oregon Dist Cool Hand Lucas Beaver Believer Thin Western Lane District Speed Walker

11 Kessler Toolbox7

Clearcutting complex forest

In 2007 the Board of Forestry set performance measures for management of state forests These includeda goal of reaching 17-20 of the forest to be complex by 2027 Almost fifteen years later and just under 5years away from the goalrsquos target compliance date ODF is well short of this goal across state public forestlands (approx 11 is our understanding of the current compliance level with the Astoria Dist beingclosest at approx 15) Despite being well short of the 2027 goal ODF continues to propose clearcuttinghundreds of acres of complex stands instead of prioritizing progress towards goal attainment including onthe Astoria District

Continued clearcutting of complex stands is particularly alarming because of the sharp decrease in overallcomplex forest that has occured in recent years largely due to corrections in modeling and partly due toODF elimination of such stands12 Clearcutting layered stands while already short of performance measuregoals and while operating at an effective 55-year rotation on the available acres clearly contravenes Boarddirection and the mandates of the current FMP as well as Governor Brownrsquos Executive Order 20-04 asstated above Doing so in proposed HCAs as is the case in several sales compounds the concern byundermining the integrity of the proposed HCP

In 2019 ODFW discouraged destruction of these forests in their comments on the 2020 AOP for theAstoria District

Layered Stands ODFW also noticed several examples where layered stands with largerdiameter trees have a proposed treatment of modified clear-cut (MC) We recognize thefinancial situation of ODF but these habitats provide some of the highest qualitywildlife habitat on the district We encourage modified clear cuts to be focused inclosed single canopy (CSC) or understory development (UD) stands (our emphasis)13

We continue to endorse ODFWrsquos recommendation and are disappointed that it has not been betterreflected in AOPs released during a period of HCP-planning and negotiation In addition to deferringharvest of complex stands ODF should track by district the progress toward the stand structure goals inthe AOPs It is a relatively easy thing to do is important as baseline work relevant to showing futureprogress and would help the publicrsquos understanding of the trajectory of forest development and itsconfidence in ODF as a manager

The following sales in the FY 2022 AOP would remove layered or complex habitat to the detriment ofconservation values and ODFrsquos already unmet performance measure goals for complex forests Many arealready listed above as concerns due to being within HCAs (and we include them here to demonstratethat the values at risk in proposed HCAs often relate to future structure potential with logging notfocused on simple current UDS habitat alone which is contrary to ODFrsquos policy guidance ldquoInterimDirection on the Implementation of the Forest Management Plan while Developing a HabitatConservation Planrdquo dated 10302021) Other sales not listed earlier and listed here would often removecomplex habitat in areas directly adjacent to HCAs

13 Astoria District AOP 2020 Appendix C

12 httpswwworegongovODFBoardDocumentsBOF20190904D1_BOFATTCH_20190904_D_01_Annual20Performance20Progress20Report202019pdf

8

Astoria Dist Kessler14 Bam Bam15 (Unit 1) Iron Fire16 Wage Earner17 Wickiup18 West Lane Dist Speed Walker19 Forest Grove Dist Doty Mill20

West Oregon Dist Cool Hand Lucas21 Doe a Deer22

Protecting complex forest patches in timber sales

In addition to stopping the logging of complex forests across state public lands until the performancemeasure target is reached we encourage ODF foresters to protect small patches of complex forest oftenfound in larger units that are typed as less complex We ask that ODF exclude these smaller patches ofexisting older or complex forest from sales Doing so is consistent not only with ODFrsquos complex forestgoal but climate change considerations and directives The following are relevant examples

Deep 6mdashisolated small acre stands exist in Unit 5 (105 years 6 acres) Unit 8 (85 yrs 2 acres)Unit 10 (85 yrs 1 acre) Units 8 and 10 are within a proposed HCA Despite this all units are

22 Located mostly on DSL CSF land (87) and would log large fir (DF-L) on all 3 sale units Unit 3 would clearcut 26acres of 23rdquo dbh trees aged 73-86 years and in LYR condition forest directly adjacent to a proposed HCA directlyacross Bevens Ck Unit 2 would clearcut 15 acres of 19-25rdquo dbh trees aged 75 years and in current LYR conditionGiven its location and current condition a better approach would be to expand on the proposed HCA boundary byadding Unit 3 and other CSF land to the south (condition looks older and complex)

21 Located just adjacent to or within a proposed HCA (western portion of sale appears to be in HCA) and wouldclearcut moderately-aged currently layered habitat converting 43 acres of currently designated LYR forest to GENand 5 acres of currently GEN forest that otherwise is intended as LYR in the future In addition the Knife RidgeMMMA has been reconfigured to the west of this sale (with a notation of future sale boundary adjustments beingneeded if there is conflict with this new MMMA configuration)

20 Located immediately adjacent to or slightly in a proposed large HCA (maybe a GIS layer error) this sale wouldclearcut 108 acres of productive (49mbf acre) forest with a current average age of 82 yrs and 24rdquo dbh The TPA isonly 63 and the basal area is 195 While the current condition designation is UDS (and future is GEN) we questionthe approach of clearcutting here versus thinning and promotion of old forest age structure to help achieve ODFrsquoscomplex forest goal and in consideration of the adjacent or overlapping proposed HCA stands

19 Located adjacent to or partly within (Unit 1 and maybe Unit 2) a proposed HCA and would clearcut currently LYRcondition habitat across 95 acres of productive forest (47 mbf acre) currently aged 75-81 yrs Also a portion of thesale is within the MeVey Ck NSO circle and sale units are immediately adjacent to BLM land making this seemingly abetter candidate for HCA expansion than LYR habitat removal

18 Would remove the peninsula of a proposed HCA by clearcutting 110 acres of 50 mbf acre forest currently aged80-86 years While currently designated UDS condition (and GEN desired future) with a note indicating forest healthissues may be driving this project (ie ldquocrown ratiordquomdashrdquovery densely stocked with very low crown to diameter ratiosand is starting to fall apart at a stand level The stand is expected to continue blowing down if harvest does not occursoon) we question whether clearcutting (as opposed to thinning or other conservation-based prescriptions given theproposed HCA location) is the best forest health solution here This concern is exacerbated by the neighboringlandowner to the N of Unit 1 having recently clearcut that ground

17 Total of 187 acres (Unit 1 appears to be partly in a proposed HCA) all in productive 55mbf acre forest with 80year stands and relatively low TPA (betw 71-112) and relatively large DBA (betw 20-25 and TPA) would seem toargue for a better retention approach despite UDS current designation and GEN desired future condition

16 No map for the Iron Fire project is included with the Pre-Op Report but Unit 1 (40 acres) appears partly inside aproposed HCA and Unit 4 (59 acres) would cut productive forest (45 mbf acre) of current and desired futurecondition LYR habitat with a 77 year age avg 20rdquo dbh and 126 tpa In addition the ORBIC Species of Concern(Animals) layer indicates the possible presence of ldquoCopersquos giant salamanderrdquo (Dicamptodon copei)

15 Located immediately adjacent to a proposed HCA and would clearcut 102 acres of currently LYR condition forestaveraging 74 years old and 24rdquo dbh with currently relatively low TPA of 63

14 Kessler Units 1 2 and 6 (total of 235 acres) are in productive forest (40 mpf acre) and current LYR condition (witha desired future of GEN for Units 1 and 2 of OFS for Unit 6) OFS is also the desired future designation for Unit 4(40acres current UDS)

9

designated current UDS (with a GEN desired future) and it is unclear that these small stands willbe protected

Wage Earner (Units 1 and 2)--proposed for clearcutting in the Astoria District While ODFcategorizes these units as less-complex understory UDS a site visit indicates areas of complexstands in the sale

Coast Range South there is a small (2 acre) older stand of complex LYR forest in Unit 885 Toolbox ThinningmdashUnits 3-5 contain small acreage stands between 80-86 yrs old some of which

are currently designated as LYR and OFS as a future condition But it is unclear whether or howthe older stands of trees will be protected during this partial cut

In addition while not the only examples sales like Cool Hand Lucas and Doe a Deer contain languagestating (respectively)

ldquo17 acres of DFC OFS will be part of a minor modification and changed to lsquoGENrsquo ornon-complex stands to make a logical operational boundaryrdquo

ldquoA minor modification was done as part of the FY 2021 AOP to move the sale unit out ofDFC Complex As part of FY 2022 AOP 54 additional acres were added to the saleThese acres are in DFC Complex and will be modified to GEN to match the intent of theoriginal DFC modificationrdquo

Unless we are reading the second bullet wrong this indicates that instead of prioritizing the retention ofexisting old forest structure and hedging in favor of ODFrsquos currently unmet old structure goal ODF ishedging in the other direction by moving older structure into timber sales rather than out of them (maybewe are reading the second bullet wrong) Further it seems very possible and not without precedent forODF to instead be protecting these older stands For example in the Mainly Sain sale (Forest Grove Dist)Unit 3 contains a range of stand ages (70-107 years) that are older than other sale units Although ODFcurrently designates all sale units as more simple UDS condition (with a future GEN designation) thissale commits that ldquoTrees over 100 years old will be retained unless they are a safety hazard Theremaining 16 acres within that stand in this sale are 70 years oldrdquo While we believe many stands in the80-100 year range (not just 100+) merit protection on ODF public forest lands and while it appears to usthat Unit 3 should be incorporated into the adjacent small HCA we raise this example because it is thekind of ODF protective action towards certain older more complex stands within surrounding simplerhabitat that we believe ODF should take with respect to other sales Instead of it being an isolatedexample ODF should adopt this more conservative approach to older complex stands across its districts

Road network continues to expand lack of metrics concern on disinvestment

As with past AOPs the FY 2022 AOP indicates many miles of new roads will be built in the forestsadding to the several thousand miles of roads already owned and managed by ODF In addition toconcerns about specific units with construction of roads on steep unstable slopes (see item on specificsales below) we have two overarching concerns about roads First ODF has a specific performancemeasure regarding roads that sets targets for hydrologic connectivity across watersheds There is littlesign in the plans that ODF is tracking or pursuing this target in a systematic way Instead the attention toroads in AOPs is generally related to maintenance and construction needed to facilitate timber salesSecond given the extensive existing road network owned by ODF we are concerned that disinvestment

10

in non-revenue-producing activities could be leading to insufficient road maintenance Roads areexpensive to build and expensive to maintain and repair While new roads built to current standards maycreate limited environmental impacts relative to the past they unavoidably create an ongoing financialliability for the maintenance necessary to ensure standards are met

Finally roads and especially poorly maintained roads are a major source of adverse impacts on waterproduced by state forests both as salmon habitat and for drinking water sources This concern isamplified during a time of climate change where more precipitation is expected to fall as rain instead ofsnow and rapid runoff or flood events are expected to occur at a higher rate than historicallyDecommissioning of roads needs to be more clearly considered and integrated in ODFrsquos planning andmanagement commitments in order to reduce water impacts As we noted last year a third-partyassessment of ODFrsquos short and long-term road-maintenance challenges is urgently needed

When combined with proposed clearcut logging on steep slopes our concerns about the construction ofnew roads and neglected maintenance of existing roads are amplified The following FY 2022 AOPtimber sales are especially concerning based on their steep slope and road impacts as well as theirproposed approach to logging layered complex forest and impacting recreation trail experiences in thearea

Four DB Cronin (Tillamook Dist) proposed logging on Slopes all gt65 with approximately15 miles of new road construction (85 rocked spur and 56 dirt spur) and 4 miles ofmaintenance

Coast Bill (Tillamook Dist) 100 cable logging on 35-65 slopes with approximately 3miles of new road constructed and 10 miles of road maintenance This area contains debris flowtorrent channels that lead directly to coho streams Nearby harvest units show signs of recentlandslides (including in the previously-logged Alder Joy sale which is directly below CoastBill and delivered harmful fine sediments to the South Fork Trask River) It appears themajority of new road work would be within Unit 104 all within the proposed HCA boundary Ifthis project moves forward we believe it may argue for un-proposing this HCA and findingacreage elsewhere

Coast Range South (Tillamook Dist) Nearly 5 miles of new road construction (433 miles ofrocked spur and 44 mi of dirt spur) 14 mi of collector road maintained Again all within aproposed HCA

Schmeagle Hill (Tillamook Dist) 100 cable logging on gt65 slopes with over 2 miles ofnew road construction (191 miles of rocked spur and 18 miles of dirt spur) Partly within aproposed HCA and Unit 14 contains significant recreation trials and is located in the SForkTrask Aquatic Anchor Site

Speed Walker (W Lane Dist) slopes gt65 with 8020 cableground logging proposed andover 15 miles of new road construction (157 mi of new rocked spur road) Part of the projectwould occur in an NSO circle (McVey Ck)

Each of these sales was noted by the ODF geotech as having numerous potential landslide hazards butinsufficient information was included for us to comment on them except to note they are hazardous towater quality and coho salmon We ask that you defer these sales until you can provide the public withmore specific maps that show areas where harvest will be excluded and where measures will be taken toprotect public values Currently this work is to be done after public comments which is not appropriate

11

In addition we reviewed FY 2022 AOP sales using the well-accepted model Shalstab parameterized toidentify areas with the steep convergent terrain that capture precipitation and generate landslides Weconducted this modeling using a lidar-based digital elevation model and in consultation with Dr JoshRoering from the University of Oregon We only identified sales as being of concern if the landslideterrain was unbuffered and was likely to impact coho streams based on ODFWrsquos fish layer Based on thismodeling the following timber sales present serious concerns of generating landslides that impact streamswith coho present

Tillamook Dist Coast Bill Schmeagle Hill Stanley Ridge Helpinrsquo Hanns Lobo Canyon Forest Grove Dist Unparalleled Elkberg

We also found that the following sales had buffers that fail to include all of the landslide terrain consistentwith ODF policy and thus may impact watershed health and salmonid habitat Wage Earner PlymptonEast Hard Target Mainly Sain and Clay Corner

Taking the lead on pesticides

Many members and supporters of our organizations as well as broader members of the public areconcerned with the intensive use of pesticides on private and state forests The context of ODF statepublic forest lands being surrounded by vast acreages of private industrial forest lands is importanthere People living on or near the Oregon Coast have seen alarming increases in clearcut logging overrecent years followed by the spraying of toxic pesticides In many cases this occurs in closeproximity to where people live and within watersheds that provide their drinking water Signatories ofthese comments and supporters of our organizations have repeatedly provided testimony to the Boardof Forestry regarding concerns on state forest pesticide use and supported the historic agreement thatresulted in recent legislation improving Oregon Forest Practices Actrsquos approach to chemical sprayingThese OFPA improvements came after significant public objection to pesticide use on state landsduring the controversy over the Norriston Heights timber sale as well as other chemical spraycontroversies As a manager of public lands ODF should not only ensure all of its managementadheres to the recent OFPA chemical spray improvements but also take the lead in both reducing theuse of pesticides especially aerial applications and in communicating with the public about their useThe AOPs do not speak to chemical use (ie part of our concern about the disintegrated approachAOPs take in reflecting how ODF is managing for public values other than harvest revenue) andtherefore show little sign of response to the ample public concern on this issue

Closing comment

For the reasons we have noted above the 2022 AOPs are inconsistent with Board direction and thecurrent Forest Management Plan as well as the proposed approach related to a potential HCP We areacutely aware of the tradeoffs that ODF and Oregon face in the management of its state public lands It isODF and the Boardrsquos job on behalf of the public to make decisions with the publicrsquos interest at centerThe FY 2022 AOPs continue to reflect direction that emphasizes near-term revenue to the agency whileignoring Board and FMP direction longer-term impacts to future strategies (ie HCP climate change)and negative consequences for non-revenue related public values

12

In short it feels like ODF is at a crossroads Recognize the flexibility that exists right now due to goodFDF performance (and other factors) and in turn make the near-term about operating in a mannerconsistent with a more stable management future through an HCP or continue to remove valuable forestcharacteristics and public values in the name of more revenue today despite reducing inventory fortomorrow and undermining future HCP integrity We are looking to agency leadership to buildconfidence with the larger public in how it uses the current opportunity and responsibilities

13

1

COX Jason R ODF

From chuck erickson lt yahoocomgtSent Saturday May 08 2021 508 PMTo SFCOMMENTS ODF ODFSubject Public comments

Public comment on projects The future of Oregon forestry and fisheries in the near future should include keystone species that create stream complexity from wetlands Wetlands help reduce the damage from forest fires Wetlands cool our rivers and help restore and maintain artesian springs and seeps that cool our rivers and streams They also provide healthy habitat for fisheries and other wildlife We can leave Oregon better than we found itbeavers matter more than ever Tree planting along our our streams should include trees that beavers and other keystone species use A beaver colony once established will maintain these areas for free Using flow devices like beaver deceivers we can protect culverts from being plugged They also can control pond levels for a minimal investment As global warming is unfolding we need to act while we can Perhaps we cant stop the process we may be able to slow the effects of our warming climate We need a progressive and proactive state forestry that takes global warming seriously Our children deserve leaders who are not bound by flat world science Thank you for your service to Oregonwatch the video and let nature do what nature does best Chuck Erickson-ODFW Pioneer License Holder A beaver story

A beaver story

2

CONFIDENTIALITY NOTICE A river without salmon is a body without a soul This email message including any attachments may contain legally privileged andor confidential information If you are not the intended recipient(s) or the employee or agent responsible for delivery of this message to the intended recipient(s) you are hereby notified that any dissemination distribution or copying of this email message is strictly prohibited If you have received this message in error please immediately notify the sender and delete this email message from your computer

1

COX Jason R ODF

From oregon-gov-web-servicesegovcomSent Saturday June 19 2021 546 PMTo SFCOMMENTS ODF ODFSubject State forests public commentAttachments formsubmissioncsv

Name Alyssa Franta

Email gmailcom

Phone

Subject Annual Operations Plans for Fiscal Year 2022

Comments DO NOT TOUCH THE FUCKING TREES We need them They help us breathe and look nice Nature is important I encourage you to STOP and think again

Submission ID ff5d9605‐1b72‐4b81‐b02b‐db1a7b27a83a

Record ID 531

1

COX Jason R ODF

From oregon-gov-web-servicesegovcomSent Friday May 07 2021 501 PMTo SFCOMMENTS ODF ODFSubject State forests public commentAttachments formsubmissioncsv

Name Brian

Email yahoocom

Phone

Subject Other

Comments Do something about all the fuels laying on the ground in the forest Take a hike in most of the southern cascades and you will understand a big part of the catastrophic fires we now have

Submission ID 45f124f5‐c087‐4e5b‐934c‐ba2f1985f788

Record ID 405

HAMPTON LUMBER PO Box 2315

Salem Oregon 97308-2315

Telephone 5033658400

Fax 5033658900

wwwHamptonLumbercom

June 21 2021

Oregon Department of Forestry Public Affairs

2600 State Street

Salem OR 97310

RE Fiscal Year 2022 Annual Operations Plans

Dear District Foresters

Thank you for the opportunity to provide comments on the Oregon Department of Forestry (ODF)

draft Fiscal Year 2022 (FY22) Annual Operations Plans (AOP) for the Astoria Forest Grove

Tillamook and West Oregon districts Developing AOPs is an important part of managing state

forests to meet greatest permanent value (GPV) ODF has an obligation to not only provide

environmental and social benefits of GPV but economic benefits ndash specifically to the forest trust

land counties and local taxing districts

Working public forests like the Tillamook and Clatsop State Forests provide benefits to the entire

state The economic activity from these forests goes beyond the revenue generated from timber

sales The mills located near state forests provide direct and indirect economic activity For

example our mill in Tillamook provides $100 million of annual economic activity within

Tillamook County Timber sales also provide well maintained road systems and contribute to a

variety of recreational opportunities within state forests

The benefits of wood products created from working public forests also go beyond the surrounding

communities For years Oregon has faced a housing crisis that has continued to escalate Without

sustainable building products like wood this crisis will continue Any policy that puts a strain on

timber supply to local mills will negatively affect the ability to produce quality wood products

This renewable resource is also part of the solution to address climate change Working forests

and wood products are great options for storing carbon so long as those forests are actively

managed Active forest management will also reduce the risk of wildfires which can not only

decimate entire communities but is a growing public health concern due to smoke not to mention

the vast amount of carbon that is released during a wildfire

Overview of FY22 AOPs

The total planned harvest volume for the Astoria Forest Grove Tillamook and West Oregon

districts is 1906 million board feet (MMBF) for a net total revenue of $70646496 While this is

an increase from the FY 2021 AOPs the implementation plan (IP) annual harvest objectives for

the four districts combined is 193 MMBF That additional 24 MMBF that was not included in the

AOPs would result in an additional $88956763 in revenue using FY22 AOP calculations That

additional revenue would go to the surrounding communities (64) and to ODF (36) We

strongly encourage ODF meet its obligations and increase the total volume to the IP objectives at

the least

The FY22 AOPs are consistent with the current Forest Management Plan (FMP) that is following

take avoidance measures While ODF is pursuing a habitat conservation plan (HCP) and drafting

a companion FMP ODF must continue to draft and implement AOPs and other policies that are

consistent with the current FMP This approach should specifically be taken to the FY 2023 AOPs

ODFrsquos working project timelines for the final Board of Forestry consideration of an HCP and

companion FMP is scheduled for February 2023 eight months after the FY 2023 AOPs take effect

Furthermore the adoption of an HCP and companion FMP should be done to achieve GPV and

provide a balanced approach to economic environmental and social benefits ndash including

sustainable harvest levels

One consistent and broadly applied issue we have noticed is the lack of consideration for future

sales while laying out current sales Wersquove seen several instances where operators will have to

harvest around or through young stands or in areas that are geographically less safe for operators

working on the ground This also applies to road management We have noticed problems on both

ends of the spectrum with too much emphasis in road building on spur roads in the Astoria District

that wonrsquot be used again for hauling for decades but also lack of improvements near stands that

will likely be harvested in the near future in the Tillamook District Long term planning will not

only increase revenue in individual sales but also increase efficiencies and reduce logging and

hauling costs for purchasers We would be happy to give specific examples of these concerns to

district staff at their convenience

Below are specific comments and concerns organized by district

Astoria District ndash 675 MMBF $25145643 net revenue

The planned harvest output for this district is 55 MMBF lower than the target volume in the IP

The planned 675 MMBF is an increase from the previous year but still does not meet the IP goal

of 73 MMBF This district is highly productive so there doesnrsquot seem to be an obvious reason why

the output does not meet the IP goal The average harvest output doesnrsquot mean the district shouldnrsquot

still meet its annual objectives We would suggest adding a sale or expanding proposed sales in

this district

There are two thinning sales and one majority thinning sale in the AOP Thinning is an important

part of forest management and forest health The one caution with this approach is the lack of bids

when a thinning sale is offered Using the FY 2021 Popeye sale as an example only two bids were

offered for this majority thinning sale

Forest Grove District ndash 608 MMBF $28663625 net revenue

Several sales in this district are near recreation sites and facilities We do not oppose sales within

recreation areas and appreciate the priority mentioned in the AOP to mitigate conflicts with the

recreation public Public education is extremely important to the industry and we support

opportunities to better explain why active forest management is beneficial for all Oregonians

As noted in the AOP the overall proposed harvest is less than one percent of the district This is a

highly productive district and we would encourage ODF to maximize sales to reflect this

Tillamook District ndash 479 MMBF $11498658 net revenue

Fox Ridge ndash this sale is on steep ground and a 100-foot yarder tower will likely be needed to

harvest the units Due to this there are acres around unit 840 that are mature and could be included

in the sale This would prevent the need to harvest those acres later on The boundaries could be

extended toward Highway 6 to the southwest and to Jordan Creek to the northeast where the stand

flattens out Extending the boundaries would eliminate the need to work around and through young

stands in future sales

Buckskins ndash to the south of the western portion of unit 615 is a patch of merchantable timber that

could be included in this sale to avoid harvesting around young stands later on The operators will

likely use Archers Road for the landing so they could easily harvest that stand without having to

move equipment The boundaries of unit 610 seem to be mismarked While visiting the unit it

would appear a stand that was thinned three years ago in the Ax Ridge thinning sale is included in

this sale An explanation of this unit layout is needed

Helpinrsquo Hanns ndash this is a well laid out sale Unit 398 could be extended directly to the south where

there is merchantable timber and existing roads The inner gorges in the northeast corner of the

unit could be challenging to log around which raises safety concerns for operators

Lobo Canyon ndash this unit layout raises several questions and a better explanation of the boundaries

is needed

Yankee Branch ndash the Labor Day 2020 windstorm damaged this unit The timber is on the verge of

being nonmerchantable and should have been offered as a sale in FY 2021 immediately after the

storm The no harvest slopes identified in unit 926 need to be reviewed The LiDAR appears to

have misinterpreted several slopes that are indeed operable with merchantable timber The sale

boundary could be extended to include the merchantable timber to the east of the most eastern

portion of unit 926 There is no roadwork identified with sale but some improvement would be

needed for hauling operations

As noted in the AOP the overall proposed harvest is less than one percent of the district While

the target is close to the IP objective there is still more work that could be done to improve forest

health Yankee Branch is the only sale with salvageable timber Several stands were damaged in

the February 2021 ice storm Is there a reason why those were not included in sales Additionally

South Minich is the only primary sale that includes swiss needle cast (SNC) infected stands We

know SNC is prevalent in the Tillamook State Forest and is a serious threat to forest health We

would encourage ODF to treat more of these stands before the problem gets any worse

West Oregon District ndash 144 MMBF $5338570 net revenue

Old Fort Combo ndash this is a well laid out sale that addresses necessary salvage from the February

2021 ice storm Units 2 and 3 have been identified as thinning units These units have merchantable

timber that could be used to make sustainable wood products We would suggest a heavy thin or

modified clearcut in these units There is also a stand to the south of units 1 and 2 long Fort

Extension Road that includes merchantable timber We would suggest modifying the sale

boundary to include this stand

We appreciate ODFrsquos consideration our comments and willingness to adjust the draft AOPs as

needed As a long-time purchaser of ODF timber sales we see ourselves as active participants in

the long-term management of state forests We look forward to the continued working relationship

we have with the department as a whole and with the individual districts

Sincerely

Laura Wilkeson

State Forest Policy Director

Hampton Lumber

1

COX Jason R ODF

From oregon-gov-web-servicesegovcomSent Sunday June 06 2021 317 PMTo SFCOMMENTS ODF ODFSubject State forests public commentAttachments formsubmissioncsv

Name Kristin Gross

Email protonmailcom

Phone

Subject Annual Operations Plans for Fiscal Year 2022

Comments

I am asking that all planned timber sales for 2022 go through a much more thorough environmental impact study As you all certainly know the climate crisis is escalating Removing trees has a direct impact on climate change on so many levels Allowing timber sales to continue is an atrocity that puts profits over the health of the planet

Submission ID bfa8bff7‐35e4‐4872‐9f05‐957dcee1c78c

Record ID 500

1

COX Jason R ODF

From James Hupy lt gmailcomgtSent Monday May 10 2021 902 AMTo SFCOMMENTS ODF ODFSubject Timber management

My name is James B Hupy I am 80 years old I have been an Oregon resident since 1958 Before that I grew up in Salkum Washington A logging town of approx 150‐200 people Upon graduating from high school I went to work in the logging woods setting chokers on a high lead show privately held by Long Bell Nearly every able bodied male in my town also worked in the woods or were connected to the Timber Industry Log Truck drivers Mill Workers etc So I know of which I speak when it comes to timber management 1 First of all Timber is a managed cash crop that takes about 75 years to mature 2 Oregon Department of Forestry needs to recognize that there are 3 distinct owner groups here One Private timberlands Two Federal Forest Lands which is by far the largest player in this game Third is State Managed Forestlands That is the one in question here As I grew older and got married and had children we spent nearly every weekend in the wilderness areas camping and Backpacking My family and I have walked the entire Pacific Crest Trail (formerly known as the Timberline Trail System) from the California border to Bonneville Dam via the Eagle Creek Trail So I have a good understanding of the recreational value of timberlands Endangered species like the Spotted Owl wolves etc are nothing but a convenient subject for Environmentalists to hitch their wagons to for lawsuits etc A big complex picture to be sure The way that I see it ODOF has a task that seems impossible to manage Kinda like herding cats So what I suggest is to pull back their sights to State Managed timberlands only Leave privately held timberlands and their owners alone Same can be said for Federal Forestlands Not your problem Ignore the protestors and environmentalists Their issues are with the Courts and Oregon Legislature and that is where you should refer them Do not get into a situation where you become embroiled with them So that leaves us with the big issues Fire management and habitation of State Owned Timberlands by homeowners who have no business living in timberlands Right of ways along heavily traveled roads should be devoid of combustible materials at least 50 yards back from the roads on both sides through heavy timber Man caused fires is a HUGE issue and when the persons responsible for them can be determined they need to be proscecuted and held accountable for their actions No exceptions Lightning caused fires ABSOLUTELY need to be agressively fought with all means possible Smoke jumpers Helicopters Aircraft etc Never never allow them to burn This is a HUGE issue also I can be contacted at gmailcom iif you wish to follow up on anything that I have said that is unclear James B Hupy Salem Oregon

1

COX Jason R ODF

From oregon-gov-web-servicesegovcomSent Friday May 07 2021 921 PMTo SFCOMMENTS ODF ODFSubject State forests public commentAttachments formsubmissioncsv

Name Wilma Ingram

Email yahoocom

Phone

Subject Other

Comments

If a sensible approach would have been taken years ago There wouldnt of been as much pollution loss of forests animals and peoples properties If boundary lines would of been made around every few acres wide enough that when trees fall they wont fall on the next lot of trees to catch on fire I dont know who has been managing Oregons forests but they havent been doing no justice to the environment nor anything living

Submission ID 779ab2ae‐1493‐4cc3‐a13b‐f45decb3293b

Record ID 406

1

COX Jason R ODF

From oregon-gov-web-servicesegovcomSent Saturday May 08 2021 821 PMTo SFCOMMENTS ODF ODFSubject State forests public commentAttachments formsubmissioncsv

Name Gary Lovelace

Email yahoocom

Phone

Subject Annual Operations Plans for Fiscal Year 2022

Comments Leave forest management to foresters and not environmentalists

Submission ID 14113152‐fbf9‐4003‐80fe‐ac306720cdbd

Record ID 408

1

COX Jason R ODF

From oregon-gov-web-servicesegovcomSent Thursday June 03 2021 909 PMTo SFCOMMENTS ODF ODFSubject State forests public commentAttachments formsubmissioncsv

Name Jessica Munyon

Email gmailcom

Phone

Subject Annual Operations Plans for Fiscal Year 2022

Comments

To Whom It May Concern The annual operations plans in their current form that include the sale of land to be used for logging would significantly impact the hiking communityrsquos use of that land for recreation The environmental impact of over‐logging in Oregon is well documented I ask and implore that you reconsider the proposed sale of this land and preserve the land in an effort to support recreation and environmental sustainability Sincerely Jessica Munyon

Submission ID 5241df28‐42a6‐45ee‐9308‐d86d6b49a900

Record ID 490

1

18 June 2021

TO ODF Public Affairs

VIA odfsfcommentsoregongov

Subject 2022 AOP(s) mdash comments

Please accept the following comments from Oregon Wild and Cascadia Wildlands concerning

the 2022 Annual Operating Plans for State Forests

httpswwworegongovODFWorkingPagesStateForestsaspx Oregon Wild represents 20000

members and supporters who share our mission to protect and restore Oregonrsquos wildlands

wildlife and water as an enduring legacy Our goal is to protect areas that remain intact while

striving to restore areas that have been degraded This can be accomplished by moving over-

represented ecosystem elements (such as logged and roaded areas) toward characteristics that are

currently under-represented (such as roadless areas and complex old forest) Cascadia Wildlands

is part of a movement to protect and restore wild ecosystems of the Cascadia Bioregion

including vast old-growth forests rivers full of wild salmon wolves howling in the backcountry

and vibrant communities sustained by the unique landscapes Cascadia Wildlandsrsquo contact

information is PO Box 10455 Eugene OR 97440 | Eugene OR 97401 | 541-434-1463 |

infocascwildorg

ODF is taking comment on the draft Annual Operations Plans (AOPs) for state forests in the

Astoria Forest Grove Klamath Falls Tillamook West Oregon and Western Lane Districts

which includes the Tillamook Clatsop Sun Pass and Gilchrist state forests which describe on-

the-ground activities expected to take place in the coming fiscal year

To the extent portions of these comments may be deemed outside the scope of the AOPs please

consider amending the district implementation plans long-range forest plans or the Forestry

Program for Oregon as appropriate to bring current management of Oregon forests into

alignment with the public interest and the greatest permanent value

The AOPs claim that ldquoAs a public agency ODF strives to operate in the best interest of

Oregonians We provide opportunities for public participation to assist us in securing the greatest

permanent value from state forests for all Oregoniansrdquo We challenge ODF to make those words

count by actually adjusting forest management in response to public comments in order to create

more public value than the status quo such as shrinking the road system and thinning young

stands instead of clearcutting mature forests