Comments on the Draft Interim Implementation Plans for State Forests

To: Oregon Department of Forestry
From: State Forest Coalition

Date: March 21, 2025

Re: Comments on the Draft Interim Implementation Plans for State Forests

Thank you for the opportunity to provide comments on the Oregon State Forest Implementation Plans (IPs). These comments are submitted by the State Forest Coalition member organizations representing tens of thousands of Oregonians. We support a strong Western Oregon State Forest Habitat Conservation Plan (HCP) and the inclusion of the requirements of the draft HCP in the proposed IPs. We also support the integration of the Climate Change and Carbon Plan (Climate Plan) into the IPs. The IPs are a first step in restoring balanced management and durable conservation measures in Oregon’s state forests to achieve the greatest permanent value over time for all Oregonians.

General Comments
The Oregon Legislature directed the Board of Forestry (Board) to manage state forests for the “greatest permanent value” for the state. (ORS 530.050) The Oregon Supreme Court affirmed the authority of the Board to manage state forests for the greatest permanent value for Oregonians when it let the court of appeals decision in the Linn County v. Oregon lawsuit stand.

In OAR 629-035-0010 (3), the Board may direct the state forester to achieve the greatest permanent value for multiple uses, including but not limited to protecting state forests from fire and disease, forest products, fish and wildlife habitat, recreation, landscape effects, water supplies and flood and erosion protection.

OAR 629-035-0010 (4) states that the Board and the State Forester are not required to maximize revenues, exclude all non-revenue producing uses on these forest lands, or produce revenue from every acre of forest land.

Instead, OAR 629-035-0010 (6) and (7) determine that active management for economic value over the long term and promotion of healthy sustainable ecosystems that produce timber; maintain and restore fish and wildlife habitat; protect soil, air and water; and provide recreation opportunities is in the best interest of the state.

We recognize that the interim IPs attempt to restore balanced management to state forests. However, as drafted they fall short of addressing the past imbalance that prioritized timber harvest and resulted in overharvesting state forests to the detriment of all other values. We recommend the implementation of additional measures to restore complex layered forest stands into the landscape, protect mature stands of forest and implement the Climate Plan.

Forest Structure and Desired Future Condition Targets
Western Oregon State Forests have historically been overharvested and managed for timber production at the expense of structural diversity, species diversity and age distribution. This is due, in part, to overly optimistic growth and yield projections that resulted in unsustainable harvest levels. Modeling has improved and projected growth and yield predictions are probably more accurate, but there is still a large amount of uncertainty, particularly considering the likely effects of climate change on growth and yield.

More than 15 years ago, the ODF established the goal of having 30% of state forests in complex, layered (LYR) structure. Today, only 13% of forest stands are in this condition. Of this 13%,only 2% of stands in the North Coast districts of Astoria, Forest Grove and Tillamook have current stand conditions of Older Forest Structure (OFS).

The FMP sets targets for stand structure types of 15-25% in LYR condition and 15-25% of stands in OFS structure for each district across the landscape. To achieve these targets, make up for overharvest for the past decade, and address the anticipated reductions and growth and yield resulting from climate change, our groups recommend proceeding conservatively. Timber harvest will have to be reduced to achieve these targets. Mature stands should be retained and any healthy stands over 90 years old should not be harvested.

The Forest Grove District does not meet, or barely meets the stand structure targets with 17% mapped with a Desired Future Condition (DFC) of LYR and 13% as OFS. In the Astoria District, 15% of forest stands have a DFC as LYR and 15% as OFS. Some basins have no stands designated as LYR or OFS. To address the overharvest in the past decade and inherent uncertainties in the growth and yield model, more stands need to be designated with DFC of complex structure (LYR and OFS) and harvest of these stands should be reduced.

Parts of the North Cascades District were severely impacted by the Beachie Creek fire. This includes forest stands designated as HCAs and terrestrial anchors. For example, the Butte Creek area was severely impacted by the fire, contains very little complex forest structure and does not appear to currently have suitable habitat for old forest dependent species. Yes these stands are designated with a DFC of OFS, and are designated as terrestrial anchors and as an HCA. While the current stand condition maps show this area as predominantly understory, 2024 Google Earth images show a landscape severely impacted by fire. It will take 100 years or more for these forest stands to develop old forest structures. Until the forest recovers, the ODF should retain all older stands in the Santiam, especially near areas impacted by the Beachie Creek fire, to ensure availability of suitable habitat for spotted owls and other species dependent on mature forests.

Forest Road Management
New road building should be prohibited within RCAs and HCAs. In the 2024 Annual Operations Plans, new roads were proposed within HCAs and RCAs for the purpose of accessing timber sales outside of these protected areas. This is likely inconsistent with the HCP and the long-term protection of covered species. The ODF should be working to decommission roads within HCAs rather than constructing new roads that serve no conservation purpose.

During the past ten years, road building expanded dramatically on state forest lands. For example, in the Tillamook State Forests, road miles expanded by nearly 50% over a 12 year period. In some cases these roads caused landslides that adversely affected salmon habitat. Road-building and clearcut timber harvest on steep slopes above salmon-bearing streams must be avoided or risk violating the Endangered Species Act (ESA).

Climate Change and Carbon Plan
The inclusion of a one-page section on climate change and carbon in the IPs is an improvement on the 2023 IPs, which were silent on how the Climate Plan, adopted by the Board of Forestry in 2021, would be implemented. While it is correct that the current FMP does not address climate change or carbon, the goals and strategies of the Climate Plan need to be included in the interim IPs.
The goal of the Climate Plan is to establish the ODF as a national leader in promoting climate-smart forest policies and actions. The Climate Plan, page 32, includes direction to incorporate the specific management objectives in the Climate Plan into the FMP and the IPs. and states that the FMP and IPs should be consistent with Executive Order 20-04 and incorporate climate mitigation and adaptation practices. These practices include:

● Harvest rotations that increase carbon storage.
● Identify areas particularly susceptible to the deleterious effects of climate change and work to conserve them.
● Restore areas impacted by insect pests and diseases to productive forests through removal of susceptible species and use of site appropriate species.
● Identify areas that have high carbon storage potential and establish priorities for these areas that include long-term carbon storage.
● Identify areas to increase soil carbon and maintain forest carbon in stands post-harvest.
● Set an internal carbon pricing process to guide planning decisions.

While implementation of the HCP should improve carbon storage and sequestration, ESA compliance falls short of the goal of establishing the ODF as a national leader. Implementing HCP, establishing longer rotations on lands outside of the HCAs and developing a carbon market system are important steps toward establishing the ODF as a national leader in climate-smart forest practices. The path to this outcome can begin by integrating the Climate Plan into these IPs.

Terrestrial Anchors
The interim IPs propose to eliminate forest stands protected as terrestrial anchors that are outside the boundaries of HCAs and designating stands within HCA as terrestrial anchors. Our groups are concerned that mature forests in areas previously designated as terrestrial anchors will be clearcut, reducing habitat in the short term at the expense of species covered by the HCP. This is particularly a concern in the Santiam, where existing terrestrial anchors will be eliminated and exchanged for burned-over stands within HCAs. Our groups recommend retaining existing terrestrial anchor designations in the interim IPs pending further analysis of the impacts to listed species.

Thank you for considering these comments and we look forward to your responses.

Sincerely,

Joe Liebezeit
Statewide Conservation Director
Bird Alliance of Oregon

Brenna Bell
Forest Climate Manager
350PDX

Joseph Youren – Forest Policy Director Seven Capes Bird Alliance

Grace Brahler
Wildlands Director
Cascadia Wildlands

Damon Motz-Storey
Chapter Director
Sierra Club Oregon Chapter

Noah Greenwald
Endangered Species Director
Center for Biological Diversity

Nancy Webster
President
North Coast Communities
for Watershed Protection

Casey Kulla
State Forest Policy Coordinator
Oregon Wild

Michael Lang
Senior Policy Manager
Wild Salmon Center