Board of Forestry

Board of Forestry

Post-Disturbance Rulemaking and State Forest Habitat Conservation Plan

Comments from the Wild Salmon Center to the Oregon Board of Forestry

January 11, 2023

Chair Kelly, Board Members, and State Forester Mukumoto:

Thank you for the opportunity to provide comments. The Wild Salmon Center is a nonprofit organization based in Oregon that works to protect and restore healthy forests and abundant clean water to support thriving wild salmon populations in the state and across the Pacific Rim. The following comments focus on two items related to the January 4th, 2023 Board meeting. 

1. Consent Agenda Item E: Initiate Rulemaking on Post-Disturbance Harvest

We thank the Board and ODF staff for your ongoing commitment to the Private Forest Accord (PFA), and related regulations which were finalized this past fall. We encourage the Board and staff  to continue the momentum and establish a prioritized timeline for key components of the PFA,  including developing technical guidance as well as establishing the Adaptive Management Program  Committee (AMPC) and the Independent Research and Science Team (IRST) that will support  implementation of the new rules. 

Another key element of the Private Forest Accord is the post-disturbance harvest rulemaking, which was included on the consent agenda at the January 4th meeting. Thank you for the Board’s unanimous vote of support to initiate the post-disturbance rulemaking to meet the November 30, 2025 deadline required by SB 1501. 

As the Board and staff move forward with the development of this post-disturbance rulemaking, we wanted to highlight some key statutory changes in SB 1501 related to the Board’s rulemaking authority.

a. Any new post-disturbance rulemaking must be consistent with the requirements of the PFA Report or the approved PFA Habitat Conservation Plan (HCP), under new changes to ORS 527.714(4) established under SB 1501.

ORS 527.714(4) If the proposed rule would change the standards for forest practices that  relate to the protection of aquatic resources, the level of protection that is desired must  be consistent with:

(a) Requirements described in the Private Forest Accord Report dated February 

2, 2022, and published by the State Forestry Department on February 7, 2022; or

(b) If a habitat conservation plan consistent with the Private Forest Accord 

Report has been approved, the terms of the habitat conservation plan.

b. The post-disturbance rulemaking must address desired future conditions (DFC),  specifically related to vegetation retention measures for streams to align with new PFA  requirements, as required under OAR 629-643-000.

629-643-0000 Vegetation Retention Goals for Streams; Desired Future Conditions

(1) The purpose of this rule is to describe the vegetation retention measures for streams, the measures’ purposes, and how the measures shall be implemented. The vegetation retention requirements for streams, as described in OAR 629-643-0100 through 629-643-0500, are designed to produce desired future conditions for the wide range of stand types, channel conditions, and disturbance regimes that exist in Oregon’s forestlands.

(2) Sections (3) through (6) of this rule, including tables in OAR 629-643-0300, are  effective until replaced by the Board of Forestry as part of the post-disturbance  harvest rulemaking directed by section 6(2)(a), chapter 33, Oregon Laws 2022 that is  to occur no later than November 30, 2025.

2. Western Oregon State Forest Habitat Conservation Plan

Additionally, we ask the Board to support a strong Habitat Conservation Plan for Western Oregon State Forests that is grounded in science, meets the requirements of state and federal law, and protects fish and wildlife for the benefit of all Oregonians. 

The Wild Salmon Center asks that you support Alternative 3 with additional measures. It is the only alternative that is fully consistent with federal law and fulfills your mandate to manage state forests for the greatest permanent value. 

For example, Alternative 3:

● Provides increased protection of stream temperatures by providing larger buffers on small streams, thus mitigating against the impacts of climate change on water temperatures. ● Is the only alternative that addresses known and foreseeable increases in the frequency and density of landslides and debris flows related to ODF’s clearcutting and road system. ● Requires ODF to “adopt a risk inventory and evaluation program” for roads and motorized  trails in RCAs as well as set targets for vacating problematic roads at a rate equal to road  construction.

In addition to Alternative 3, the following measures should be included in the final HCP:

● Include no-touch riparian buffers on non-fish-bearing seasonal streams that connect directly to fish-bearing streams. This would provide a greater chance of wood recruitment and habitat development.

● Shorten the permit period to 50 years, as contained in Alternative 4, given the climate and  biodiversity crises. This would enable the Board to adjust to the effects of climate change, such as impacts to wildlife populations, stream flows and biodiversity.

● To anticipate and respond to the pressures of climate change, include an ecological, climate smart approach to reforestation that would include prescribing variable spacing (and less density), retaining non-Douglas fir trees and non-conifer trees, planting diverse species mixes that are better adapted to future predicted climate scenarios, and retaining some of the understory shrubs, especially those that support ecologically important native invertebrates and birds.

The federal Environmental Protection Agency (EPA) also supports Alternative 3. In a letter to NOAA Fisheries dated May 25, 2022, the “EPA identified concerns that the Proposed Action may have adverse impacts to water quality and aquatic resources and recommends Alternative 3 (Increased Conservation) as the preferred alternative in the Final EIS to address these concerns.” 

The EPA letter contains several recommendations, including:

1. Support Conservation Action 1 to expand riparian conservation area (RCA) widths on small  perennial non-fish bearing streams and seasonal non-fish bearing streams to 50 feet in the  areas upstream of process protection zones in order to protect water quality and decrease  stream temperatures. 

2. Support Conservation Action 5 to develop a risk inventory and evaluation program for roads within proposed RCAs to identify roads that are a risk to water quality and set up a process to vacate these roads during the permit period.

While the benefits to water quality and aquatic resources in Alternative 3 are substantial, the impacts to harvest and net present value are minimal as compared to the Proposed Action. According to the Staff presentation on November 16, 2022, decadal harvest levels would be similar and remain over 2 billion board feet over the lifetime of the HCP. Net present value over the life of the HCP would differ by only $8 million, or 0.5%.

Regarding funding for local services from state forest timber revenue, we need to find solutions that stabilize funding for local tax districts and enable the state to balance the management of state forest lands for multiple benefits.  

The Wild Salmon Center supports efforts to identify alternative funding solutions for local services beyond state forest timber revenues to fill any gaps that may occur in essential services as a result of reduced timber revenues from state forests.  

We’ve seen that it’s possible for conservation and industry to come together under the Private Forest Accord. Collaboration is not only possible, but necessary. Now is the time to work together to forge a new path and find solutions.

Finally, the Wild Salmon Center is pleased to see the results of the Oregon Values and Beliefs Center’s Oregon Forest Management Survey that were presented at the January 5 meeting. The survey shows that Oregonians strongly support and prioritize habitat for wildlife, clean cool water for fish, and drinking water for nearby communities in Oregon state forests. These results closely  align with the values expressed by the Wild Salmon Center and can help inform management  decisions to determine the greatest permanent value of Oregon’s state forests for all Oregonians.

Thank you for considering these comments.

Attachment: US EPA Letter DEIS Western Oregon HCP

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Board of Forestry, State Forests

Tillamook & Clatsop Planning Process Waking from Hibernation

In 2013, the Oregon Board of Forestry decided to examine alternative approaches to managing the Tillamook & Clatsop State Forests for improved conservation and financial viability. The decision to open the existing plan up stemmed from a lack of confidence in the long term financial viability of the Department of Forestry State Forest Division, which is currently almost entirely funded by logging on state forest lands.

The Board convened a group of stakeholders from the conservation community, timber industry, and counties to provide possible alternatives for managing the forests. These alternatives underwent review by a team of scientists who issued an assessment report. The Board then recognized that a better understanding of the inventory of the forest (how much wood is on the landscape) was necessary to continue.  As inventory modeling was underway, the Linn County clearcut lawsuit abruptly interrupted the planning process.

Now, the Board is picking up where they left off. On August 3rd, members of the Alternative Forest Management Plan Subcommittee will be reminded of the process to date and choose how they want to proceed.

Wilson River, Oregon North Coast. Photo by Tyson Gillard, Outdoor Project.
Wilson River, Oregon North Coast. Photo by Tyson Gillard, Outdoor Project.
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This Monday: Speak up for Oregon’s streams and salmon

Did you know that of all the West Coast states, Oregon has the least protective rules regarding logging on fish-bearing streams? This Monday (1/30), there is a unique opportunity to speak up for clean cool water for fish and people. Join other advocates to take a stand for the water we all care about from 4:00-7:00 pm at the Ecotrust Building (721 NW 9th Ave) in Portland.

Oregon’s logging rules lag behind the best available science. Right now, the Board of Forestry is nearing the end of an eight-year-long process to update buffer rules for some of Oregon’s streams after finding that current forest practices cause excess water pollution and that the current rules need strengthening. However, the proposed new rules don’t go nearly far enough to protect our aquatic habitat and clean water sources.

We need you to join us, and others from your community, in sending a loud message to the Board of Forestry that they can do better, and we demand it!

Click here for additional background and click here for talking points.

If you can’t make it to the hearing, you can submit public comment by emailing Use the subject line “Private Forest SSBT Rulemaking”.

Photo by Tom Lange
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Blog, Board of Forestry, State Forests

Clearcutting 70% of State Forests: Not a Great Idea

On October 19th, a subcommittee of the Board of Forestry met to discuss alternative management plans for the Tillamook & Clatsop state forests.  Any new plan needs to improve conservation AND make the Department of Forestry financially viable. This ongoing process has been dominated by a timber industry proposal to manage the forest as two zones: 70% for industrial clearcutting and 30% for conservation.

The Board directed the Department to model this proposal and the results are…not good.

Conservation: Under the current plan, 51% of the forest is open to clearcutting, 18% is thinned to create complex forest habitat, roughly 27% is not logged because it buffers streams, provides habitat to endangered species, or is too steep. The remaining 4% is roads, campgrounds, rock quarries, and power-line right-of-ways.

Photo by Francis Eatherington
Industrial Timber Land (photo by Francis Eatherington)

The new model shows 69% of the forest open to private industrial style clearcutting, and 27% of the forest protected. This alone is a drastic reduction in conservation acres. On top of that, the private industrial model would have very negative impacts on habitat compared to the current plan, which leaves more standing live trees, standing dead trees, and downed wood. The industrial model also involves more aerial pesticide application.

See what the model looks like on the Tillamook district and on the Clatsop forest (Astoria district).

Revenue vs. Costs

Financial Viability: 
It turns out that when you liquidate your asset by intensive clearcutting, the returns don’t last long. The model showed that the plan would pay for itself for about 25 years, after which costs far outpace revenue, leaving the Department worse off than it is now.

There are additional concerns. Based on district level groundtruthing, Department staff hinted that implementing this plan would result in less harvest than predicted. Moreover, there is a likelihood that counties and forest district would face drastic boom/bust cycles rather than steady, predictable income.

What’s next? Some timber industry modeling experts hope that there is more inventory than is currently assumed and that the forest will grow faster in the future with better stocks of wood. However, there is also reason to be pessimistic as the recent modeling didn’t account for likely forest disturbances such as wind storms or floods.

The Department is moving forward to refine their model, but so far it seems that a 70/30 fails to improve financial viability and drastically reduces conservation on our state forests.

Wilson River 2

#salmon, #orforest, #steelhead, #Tillamook, #Clatsop, #logging, #clearcut

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Board of Forestry Subcommittee August 12: Eye Openers

The Board of Forestry subcommittee that is exploring new management plans for the Tillamook & Clatsop state forests met on August 12th. While the subcommittee did not make any big decisions, there were still some alarming outcomes worth noting.

The Subcommittee is charged with exploring alternative plans that would bring about improved financial viability for the Department of Forestry AND improved conservation on the forests. It would seem that this can only be achieved if there is a favorable comparison with the current plan. However, subcommittee member Mike Rose indicated that he is not concerned with comparing an alternative plan with the existing plan to determine if either is better for conservation or revenue. He is already focused on an approach in which 70% of the forest is managed like an industrial forest, including short-rotation clearcutting and intensive pesticide spraying.

Clatsop County and Washington County have both spoken up for conservation areas as an integral part of a balanced forest management plan. However, the voice of the counties is being directed almost uniformly towards a more industrial approach to forestry. Speaking on behalf of all 15 trust land counties (including Washington County, Clatsop County, Tillamook County, Columbia County, and Benton County), Tillamook County Commissioner Tim Josi objected to protecting old growth forests. He also advocated for private industrial style stream buffers and drastic increases in clearcutting.

If Tim Josi is not representing you, tell your county commissioners!

Perhaps of most concern is the continued lack of conservation improvement concepts. Department staff brought forward another framework that shows decreases in conservation acreage rather than an increase compared to the current plan. This framework included significant loss of High Value Conservation Areas.


A new voice added to the discussion as north coast resident, Tom Bender brought forward concepts of long-rotation forestry to the Subcommittee.

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Clearcut Proposal Rejected – Areas of Agreement Sought

Last month, the Board of Forestry refused to endorse a proposal that would have seen drastic increases in clearcutting across the landscape. Our supporters drove hundreds and hundreds of thoughtful, personalized comments to Governor Brown asking her to reject this plan. Thank you for your support—we were heard loud and clear!

The search for a new Forest Management Plan continues as the Board instructed Department of Forestry staff to engage in shuttle diplomacy with stakeholder groups in an attempt to find areas of agreement among the timber industry, county interests, and the conservation community.

The Board Subcommittee in charge of a new plan meets on April 8th with a lot of work to do. Tasked with improving conservation and stabilizing ODF’s funding, it is becoming more evident that the Board needs to seek alternative revenue streams rather than continuing to rely solely on logging to manage these public lands.

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ODF Proposes Massive Clearcut Plan on State Forests

The Oregon Department of Forestry recently presented a timber-centered vision for the new Forest Management Plan on the Tillamook & Clatsop state forests.

Key proposals included:

  • Devoting 70% of the forest to industrial clear cutting and pesticide spraying to dramatically increase harvest.
  • Clear cutting most of the new High Value Conservation Areas that are currently protected for older forest.
  • A formal policy to prioritize cutting of oldest trees in the “production zone” so species cannot recover.
  • Using the extra revenue to increase the ODF budget by 30%.
  • Redefining conservation areas to include clearcuts.
Trask Watershed under ODF's Proposal - RED is clrearcut
Trask Watershed under ODF’s Proposal

No, we are not making this up!

ODF’s plan is very similar to the 70-30 proposal pushed by Hampton Affiliates, a private firm that wants the logs for their mills.

Maps based on ODF data provide images of the current plan and ODF’s devastating proposal. Red areas are removed from conservation protection and opened to clearcutting:

Fortunately, a conservation-minded member of the Board blocked this initial proposal, but ODF leadership have clearly made a power move to expand their budget as the Governor changes. The Department was directed to seek alternative revenues for their state forest program, but are clearly focused only on increasing harvest levels dramatically.

Tell Governor Brown to Reject ODF’s Clearcut Plan!

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Conservation: Visible & Durable

Clatsop Forest proposed clearcut (photo by Trygve Steen)
Clatsop Forest proposed clearcut (photo by Trygve Steen)

A parcel of forest only needs to be clearcut once to destroy most of its ecological value for decades and decades. On the other hand, conservation requires constant, long-term, robust protection. That is why, as the Board of Forestry writes a new plan for managing the Tillamook & Clatsop state forests, conservation commitments need to be real–long-lasting, appropriately managed, and mapped.

Current “High Value Conservation Areas,” which we fought hard for for several years, represent an important step forward for the Oregon Department of Forestry. Their designation (covering 140,000+ acres state-wide) has helped to frame the process that will result in a new Forest Management Plan. In part because of these new designations, the Board is strongly pursuing a “land allocation” approach, which will see a conservation zone, a timber-emphasis zone, and possibly other zones that, contrasting the current approach, do not move around the landscape. Governor Kitzhaber recently promoted this type of plan.

A land allocation approach has the potential to succeed in improving conservation. Clearly, a large portion of the landscape would need to fall into the conservation zone in order for wildlife habitat and clean water to be adequately protected. What’s even more important though, is how that allocation is managed and where it is. Current conservation areas are too often managed to produce some timber volume–heavily thinned or even clearcut. In the new plan, conservation areas need to be managed for conservation without any expectation of producing timber. That means forests, left largely untouched, intended to grow old and complex. Not wilderness, but wild.

Tillamook Forest Pic

Another crucial factor in the success of this approach is maps. Public awareness and transparency are of the utmost importance for conservation. Protected areas should not be moved and changed at the discretion of ODF staff on a yearly basis. These areas need to be on long-term, publicly available maps. Oregonians deserve to know where these areas are, and for the sake of healthy salmon runs, wildlife habitat, carbon sequestering old trees, and clean drinking water, these areas should be in the public eye and the public conscience.

Conservation does not work at the whims of political tides and timber projections. It requires durable and robust commitments for the foreseeable future.

Wilson River Swimming Hole - Banner
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Board to explore a land allocation (zoned) approach to forest management

ODF Puts Forward FMP Proposals

The Oregon Board of Forestry continues to explore new Forest Management Plans that will both provide financial viability to the Department of Forestry and improve conservation outcomes on the Tillamook & Clatsop state forests. On September 29th, the Board weighed two options developed by ODF. A “Land Allocation” proposal suggests putting at least 30% of the forest into a conservation zone and managing other portions of the forest for different degrees of timber production. A “Landscape Management” proposal is similar to the current forest management plan, with various types of forest structure moved around the landscape over time. Either proposal has the potential to succeed or fail. There is room in each framework to improve conservation, but there is also the potential for harmful environmental outcomes. The latter proposal suggests sacrificing habitat in smaller forest districts, such as the Santiam.

Counties Won’t Play

The Trust Land Counties (CFTLC), which receive a significant portion of revenue from state forest timber harvests, rejected both proposals and did not offer alternatives. County representatives implied that they would not support any new plan that did not dramatically increase clearcut levels. The Counties’ unwillingness to meaningfully participate in the process does not bode well for a new plan being created.

Speaking against the Department working with federal scientists to negotiate a Habitat Conservation Plan (HCP), the CFTLC expounded on the “risk of an aging forest,” warning that, “as forest ages and begins to provide habitat for listed species, the ability to continue timber harvest may decline dramatically. ODF and the Board of Forestry must not let this situation develop on the Trust lands.” These forests are crucial to providing habitat for listed fish and wildlife. Efforts to prevent habitat from improving are misguided and show an alarmingly single-minded view of these forests simply as tree farms.

The Timber Industry Shows Its Colors

Dave Ivanoff, of Hampton Lumber, also objected to the pursuit of a Habitat Conservation Plan and warned ODF of the “perpetual issue of creating habitat.”

Forest Practices Act "stream buffer"
Forest Practices Act “stream buffer”

Mr. Ivanoff was “dismayed” by both ODF proposals, saying that the Land Allocation approach was a “departure” from what he envisioned: “From my selfish perspective I would request support of the 70/30 zoned approach the way I’ve offered it, based on the Forest Practices Act.” “I fundamentally believe that there is absolutely nothing wrong with [the industrial approach].” There is significant scientific literature on environmental problems caused by the FPA.

When asked why he came up with the 70/30 split, Mr. Ivanoff said that it was based on “what is the level of harvest that’s going to be needed to maintain the family-owned forest manufacturing sector in NW Oregon,” what is needed to “support our company’s needs, our competitors’ needs.” The harvest level “would come close to replacing that lost fiber that is no longer coming from Washington.” It’s clear that the timber industry’s calculations of what should be cut don’t consider the forests many values, but instead stem from their own needs.

Rex Storm, representing the Associated Oregon Loggers, urged the Board to curtail public input and not seek public approval when devising a new plan, stating that the timber industry and even the Board are more important stakeholders than the Oregonians who own these lands. The Board, of course, is supposed to manage these forests on behalf of all Oregonians. Ironically, Mr. Storm delivered his alarming message during the public comment period.

Conservation Improvements Needed

Buster Creek, Clatsop State Forest
Buster Creek, Clatsop State Forest

The North Coast State Forest Coalition urged the Board to move forward keeping conservation improvements in mind. In order to improve conservation outcomes, any plan would likely need to improve riparian buffers to provide adequate shade and wood delivery to streams, increase the amount of older forest on the landscape, reduce clearcutting on steep slopes, and decrease the forest road network, which currently is very expansive and can lead to sediment problems in streams. Both ODF proposals include expanding no-cut buffer zones on fish-bearing streams to 115 feet, reflecting current scientific literature that suggests little or no riparian management is best for stream health. 115 feet is a good start, but it is unclear that it is adequate. Non-fish bearing streams would benefit from a no-cut buffer of at least 75 feet. Current standards are much less protective.

The success of either plan hinges on balance, public input, and the best science available. Dollars cannot be the only driver determining the future of these forests. These lands have been over-logged and burnt. They are just beginning to recover, and their protection is crucial to Oregon’s economy and environment.

The Board Acts

The Board moved a motion to explore/pursue a land allocation proposal, but did not move any specifics such as those in the ODF proposal. Board members Gary Springer and Mike Rose, both employees of the forest products industry, voted for a zoned approach that sees much of the landscape treated like industrial timber land. Chair Tom Imeson followed the timber representatives’ vote. The only “no” vote to this proposal came from Sybil Ackerman-Munson, who was rightfully doubtful that a zoned approach would work without any cooperation from the Trust Counties.

ODF will now move forward exploring a zoned approach, but without any sideboards for conservation and with the Counties refusing to enter dialogue, it is doubtful that a good plan will come to fruition.

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