Oct 6, 2025
TO: The Blue Mountain Forest Plan Revision Team,
The 4.9 million acres under this plan is absolutely vital not just to the people who live in eastern Oregon and Washington, but to the survival of many threatened species unique to Region 6. These species need inviolable protection of their few remaining habitats. The reason national forests were set aside in the first place was not just for timber production, but because if all land were private, there would be almost no corridors left to support food and habitat for wildlife. If we do not protect our forests with strong standards and mandatory rules, humans cannot be relied upon to do the right thing for others, or other species, and that is why we have laws and rules. The revised plan must ensure that wildlife survival is not left to individual choice. We do need to harvest timber, we all recognize this fact, but we do not need to harvest trees over 21 inches in diameter or that are over 125-150 years old which provide the only places certain species can live, and are found in only 3% of our eastern forestland. There are plenty of smaller trees available within this area for timber production, especially now with mass timber production. Our standards need to hold firm and not be reduced to mere guidelines. Trees are not just a commodity, but actually provide far more value living and standing than when cut and sold. A balance can be achieved, but for far too long, the Forest Service has favored timber production above all other priorities. We need to preserve existing standards that are refined and improved by science over time, rather than be driven by expediency.
Specifically, on page 46, the desired conditions for Old Forest and Individual Old-Large Trees states:
“Many wildlife species require structural complexity typical of old forests and the presence of large trees and old trees within a stand can increase wildlife habitat values in both old and young forests. Rare lichen species also require old trees in old forests. Old trees, especially large old trees, found both within old forest stands and as scattered individuals are acknowledged to have great importance as ecological keystones, developing physiological and structural features. This makes them valuable in terms of wildlife habitat, fire and drought resistance, and as genetic resources.”
Yet, this revised management approach and these guidelines are so weak, that large trees can be removed too easily for the following justifications which can be left open to interpretation:
“This may necessitate a short-term loss of large or old trees in some areas for a long-term gain of meeting multiple desired conditions.” We would like to see this sentence stricken from the document.
Similarly, Under Desired Conditions (FW-FOR-OLD-DC) the Guidelines (FW-FOR-OLD-GDL) state:
01. To provide large tree habitat in the short and long term, management activities should retain and manage for the recruitment of old trees (150 years or older), large trees and legacy trees, except as provided in other plan components.
02. To reduce threat to human life and infrastructure, old trees and large trees identified as hazards may be felled or removed. These situations may include but are not limited to roads, developed sites, and powerlines. See Region 6 Field Guide for Tree Risk Assessments and Hazard Tree Mitigation document.
03. To avoid hazardous conditions, landings, skid trails, and corridors should be located where the felling or removal of large trees is avoidable except where doing so conflicts with other plan components.
04. To reinforce, facilitate, or improve effectiveness of fuel reduction in Community Protection Areas and within planned and emergency fuel breaks, old trees and large trees may be removed when unavoidable.
05. To maintain, move toward, or achieve ecological desired conditions where removal of smaller trees alone is not effective, old trees and large trees may be felled or removed.
We believe these need to be standards and not just recommended practices. We suggest removing the text underlined and italicized above or change “may” to “may not”. There are no other “desired conditions” that should be allowed to override the preservation of large and old growth trees for exactly the reason stated above that they “are acknowledged to have great importance as ecological keystones, developing physiological and structural features. This makes them valuable in terms of wildlife habitat, fire and drought resistance, and as genetic resources.”
They also serve as part of the system of wildlife corridors. Wildlife habitat connectivity is essential to restoring ecosystem health, resilience and stability. A large old growth tree once cut, cannot be replaced for over a hundred and fifty years, and only 3% of these trees remain in these ecoregions. We cannot afford to lose any of them for the short-term benefit of wood products that last a mere decade or two and end up decomposing in a garbage heap emitting methane.
And lastly, and most importantly these giants are one of the planet’s most effective and free methods of reducing air pollution. They are also water and soil protecters. If we want to slow down the rise in world temperature, leaving these trees alone to do their most valuable work is so well documented in the scientific literature that I don’t need to repeat the sources here.
There is no doubt that our planet is warming and this will inevitably affect the health of our trees. Recovery will be longer and slower for growing the next generation of trees. Mixed aged classes including old trees and a variety of tree species are the best insurance against projected changing conditions.
This management plan needs to take into account that trees will need better care, not less, as we are bound to lose terrestrial and aquatic species to pests and disease from changes to hotter drier conditions and ever-increasing weather events and fire disturbances. Policy addressing these near future conditions needs to be included, but is not even mentioned in this plan.
Please do your best to manage not only for the benefit of wildlife and the threatened species listed in this document, but also for the many Oregonians who value these forests for all they offer from hunting and fishing to tourism and recreation.
I hope public comments will be considered seriously and incorporated into the final plan and are not simply a pro forma exercise in the process as required by the 2012 Planning Rule and by state and federal law.
MCAT Steering Committee