About the Campaign

The Tillamook Rainforest is an oasis of secluded salmon streams, popular recreational trails and important hunting and gathering areas. It is one of the best places on the planet to grow big trees. 

For too long, the Tillamook has been considered a tree farm.

With your help we will change that.

Our goals include:

  • Long-term, visible conservation areas on state forests, which protect fish, wildlife and recreation opportunities
  • Streamside forest buffers wide enough to keep water — and salmon — cold and clean during hot summers
  • A path to recovery for threatened and endangered species
  • Abundant and diverse recreation opportunities for Oregonians and visitors that builds appreciation for state forests and supports the growing $550 million North Coast outdoor recreation economy

Our work is carried out by thousands of Oregon residents, local businesses, partner organizations, and government agencies.

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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News

A Proud Legacy: Bob Van Dyk’s 12 Years in Oregon Policy

Wild Salmon Center’s Oregon Policy Director steps down, after a tour de force that has changed the state’s forest rules.

Shared from Wildsalmoncenter.org, December 2022

In the early 2000s, Wild Salmon Center CEO Guido Rahr started bumping into Bob Van Dyk at Oregon Board of Forestry meetings. At the time, replanted Douglas fir trees were beginning to reach merchantable sizes on state forests in northwest Oregon, five decades after the Tillamook Burn.

Rahr was deeply concerned about imminent and widespread logging scheduled for these forests, home to some of the best remaining salmon runs in the Lower 48. And Van Dyk, a political science professor at Pacific University, was coincidentally turning his academic focus to the controversy over fish and forest management. Van Dyk was also a map geek who had learned some basic GIS that allowed him to examine public land management. The more Van Dyk learned about state forest management, the clearer it became that the Oregon Department of Forestry was a case of regulatory capture: the timber industry dominated an agency that was tasked with protecting the public interest.

Nehalem River, Oregon (PC: Justin Bailie).

Thus began our long partnership with Van Dyk. Initially moonlighting with WSC for several years while holding down his tenured professorship, Van Dyk renounced tenure and came on full time as our Oregon and California Policy Director in 2015.

Bob Van Dyk documenting some of the remaining older growth trees in the Tillamook Forest in 2012 (PC: WSC Staff).

His combined accomplishments over the last 12 years are nothing short of monumental. But perhaps his greatest achievement is influencing a change of perspective: the Department of Forestry, which oversees 10.8 million acres of private and state forestland in Oregon, no longer looks at those lands as a giant tree farm. Years ago, a colleague called Van Dyk a “forest Jedi” for all his time spent deep in the Tillamook. But equally important—and more true to the moniker—were the endless hours he spent with board members and elected officials convincing them that it was time for change.

This month, Van Dyk steps away from full time work at WSC. He assures us he’ll still be around to stand up for forests, and we sincerely hope he does. Thank you, Bob, for all you’ve done to date for Oregon forests, water, and wild salmon.


2010Conservation groups push back against clearcutting state lands

A coalition of fishing and conservation groups led by WSC and Bob Van Dyk petitions the Oregon Board of Forestry to reconsider its decision to weaken conservation committments on the Tillamook and Clatsop State Forests.

Stream scientist Charlie Dewberry, WSC’s Bob Van Dyk, and former WSC staff Tom Miewald reviewing Tillamook State Forest land maps (PC: WSC Staff).

2012: Scientist appointed to Board of Forestry

WSC leads the effort to appoint the first scien­tist, Cindy Deacon Williams of Medford, to the Oregon Board of Forestry, which oversees rules for state and private forest land in Oregon. It brings a more analytical approach to decision making.


2012: Oregon Board of Forestry supports conservation

Before a growing chorus of more than 100 conservation supporters in Tillamook, the Board of Forestry approved designating part of Oregon’s state forests as “high value conservation areas.”

Tillamook River, Oregon
Tillamook River, Oregon (PC: Guido Rahr).

2013: North Coast State Forest Coalition founded

WSC helps lead a broad conservation coalition to defend Or­egon’s North Coast, including the Northwest Steelheaders, Oregon Council of Trout Unlimited, Northwest Guides and An­glers Association, the Oregon Chapter of the Sierra Club, and, eventually, Pacific Rivers.


2014: High Value Conservation Areas established

Oregon Department of Forestry finalizes protections for fish and wildlife habitat on more than 140,000 acres of the Tillamook and Clatsop State Forests in Northwest Oregon.

A tour of the Tillamook Forest in 2014 with WSC’s Bob Van Dyk, former WSC staffer Chris Smith, WSC President Guido Rahr, former Oregon Governor John Kitzhaber, fishing guide Bob Rees, and Ian Fergusson (Northwest Steelheaders, Native Fish Society).

2015: Board of Forestry increases stream buffers on private land

This marks the first major improvement in stream protections in twenty years. “But,” says Van Dyk, “there is a long way to go just to meet the level of protections that federal standards require.”

North Umpqua River, Oregon (PC: Ken Morrish).

2019: #FailingForestry Oregonian series

The “Failing Forestry” series in Oregon’s largest statewide newspaper details chronic mismanagement at the Oregon Department of Forestry. “They basically opened up some of the fattest, juiciest, most accessible stands of trees they have to clearcutting,” Van Dyk tells the Oregonian. “Our overarching concern is that this is unsustainable.”

Looking north over the Oregon Coast from atop Indian Chieftain peak towards Cannon Beach, clear cuts dominate the view. (PC: Thomas Robinson).

2020: Timber industry, conservation groups agree to negotiate

The breakthrough agreement, led by the Wild Salmon Center, means that industry and fishing and conservation interests avoided potentially costly ballot measures aimed at forest reform. Governor Kate Brown presides over the signing of the agreement in Salem.

Oregon Private Forest Accord negotiations (PC: Bob Sallinger).

2020: New statewide pesticide rules, new logging rules in Southern Oregon

In the midst of the coronavirus pandemic, the Legislature passes improved rules preventing the spraying of pesticides near homes, schools, and drinking water streams, as well as new protections from logging near streams in the Rogue-Siskiyou region of Southwest Oregon. 


2021: Private Forest Accord signed, sealed, delivered

Nine months of high stakes negotiations bear fruit on October 30, 2021, with timber interests and conservation groups—the latter led by Van Dyk—backing big improvements to the Forest Practices Act which governs 10 million acres of private lands. The Legislature adopts the agreement in full several months later.

Oregon Governor Kate Brown and key stakeholders at the signing of the Oregon Private Forest Accord in 2022.

2022: Elliott secures new role as State Research Forest

Completing a long process that reverses a potential sale of the 82,000-acre tract to be logged, Oregon’s oldest state forest is finally protected by strong and durable conservation commitments.

Elliott State Forest, Oregon (PC: Greg Vaughn).

2022: Linn County lawsuit stopped

Led by Linn County, Western Oregon taxing districts that draw revenue from logging on state forests sued the state for more than $1 billion in damages, alleging a drop in logging proceeds starting in the 1990s. Van Dyk campaigned with others against the suit, claiming the state had legal latitude to balance logging with other forest uses. The Oregon Appeals Court and Supreme Court both agree, paving the way for increased conservation on state lands.


In the coming year, a major piece of Van Dyk’s legacy for Oregon forests still hangs in the balance, as the Board of Forestry works to approve a Habitat Conservation Plan for North Coast state forests—along with other critical forestlands in the western half of the state.

This 70-year plan would assure stronger streamside and upland protections for fish and wildlife, protect drinking water, secure recreation opportunities, and create a durable and lasting rainforest stronghold for wild salmon and steelhead right here in the heart of Northwest Oregon. As Van Dyk steps back, he hands the reins to new WSC Oregon Senior Policy Managers Stacey Detwiler and Michael Lang to carry this work over the finish line. And we’ll need your help, too, to honor Bob’s work and secure this win for Oregon!

Tillamook River, Oregon
Tillamook Forest, Oregon (PC: Jeff Mishler).
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State Forests

State Forests HCP Support Letter

A letter from our coalition to the Oregon Board of Forestry.

Also see the letter from the US EPA regarding the Draft Environmental Impact Statement (DEIS) for Western Oregon State Forests Habitat Conservation Plan.

November 11, 2022

Oregon Board of Forestry

Dear Chair Kelly and Members of the Board of Forestry:

The undersigned groups are writing to share our perspectives on the continuing challenge of finding the right balance on state forest management. As you know, balancing values on state forests has been difficult and controversial. However, the recent resolution of the Linn County litigation has provided some clarity. Now that it is established that the Board of Forestry has broad discretion to manage our state forests for all Oregonians, and not just taxing districts, we have an opportunity for a broader conversation on the path forward. We believe the Board should adopt a strong Habitat Conservation Plan (HCP) and renew efforts to identify solutions that provide more stability to both taxing districts and the state forest program budget.

We continue to strongly support your work on a Habitat Conservation Plan for Western Oregon State Forests, and we thank you for your commitment to managing Oregon’s state forests for the benefit of all Oregonians. We ask that you support an HCP that is at least as protective as Alternative 3, the conservation alternative. Alternative 3 would best ensure the “greatest permanent value” of our state forests by providing necessary long-term protections for fish and wildlife, meeting the challenges posed by climate change, and allowing for ongoing timber harvest. The Habitat Conservation Areas and Riparian Conservation Areas would not only serve the purpose of protecting habitat for threatened and endangered species, but also act as carbon reserves and aid in the implementation of the Climate Change and Forest Carbon Plan.

In order to achieve more stability in state forest management, we strongly encourage you to focus attention on the need for systemic changes to ODF’s funding and business model. With the Linn County lawsuit behind you, there is an opportunity for all sides to come together and identify solutions that ensure sustainable funding for local taxing districts while at the same time protecting fish and wildlife habitat and recreation values for Oregon’s state forests. This effort will require investment by the General Fund, and we are prepared to support work exploring those outcomes.

The Private Forest Accord is proof that the timber industry, landowners and the conservation community can work together to find solutions. We support solutions that would allow our state forests to be managed for multiple benefits, respond to the stresses of climate change, and identify stable funding sources for necessary local services.

Thank you for your commitment to managing our state forests for the greatest permanent value for all Oregonians.

Sincerely,

Brenna Bell

Forest Climate Manager

350PDX

Jason Wedemeyer

Executive Director

Association of Northwest Steelheaders

Steve Griffiths

Joseph Youren

Directors

Audubon Society of Lincoln City

Bob Sallinger

Conservation Director

Audubon Society of Portland

Lisa Arkin

Executive Director

Beyond Toxics

Grace Brahler

Wildlands Director

Cascadia Wildlands

Noah Greenwald, M.S.

Endangered Species Director

Center for Biological Diversity

Darlene Chirman

Leadership Team

Great Old Broads for Wilderness

Cascade Volcanoes Chapter

Bob Rees

Executive Director

NW Guides and Anglers Association

Mark Rogers

Chair

Oregon Council of Trout Unlimited

Julia DeGraw

Coalition Director

Oregon League of Conservation Voters

Lauren Anderson

Climate Forest Program Manager

Oregon Wild

David Harrison

Conservation Chair

Salem Audubon Society

Victoria Frankeny

Staff Attorney

Tualatin Riverkeepers

Michael Lang

Oregon Senior Policy Manager

Wild Salmon Center

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Commentary

Letter: I encourage everyone to weigh in on HCP to protect fish and wildlife

In this Headlight Herald / Gazette article it says, “Fish are forest products too.” That’s because wild fish are the backbone of an $80 million a year sport fishery on Oregon’s North Coast. 

But, the article got it wrong when it stated the proposed Western Oregon State Forest Habitat Conservation Plan would “limit timber harvest dramatically.” According to the economic analysis in the Draft Environmental Impact Statement for the HCP, timber harvest and revenues would decline more if the current approach to logging played out over the next 70 years. In other words, there is more risk to timber harvest, jobs, and county revenue by trying to maintain the status quo on state forests than under the HCP alternatives. 

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Commentary

Letter: Yamamoto’s view on HCP off-base

As a Tillamook County taxpayer and professional fishing guide, I find Commissioner Yamamoto’s opinion piece to be off-base regarding the Western Oregon State Forests Habitat Conservation Plan (HCP).

Hundreds of fishing guides and outfitters depend on wild fish runs that originate in the six world-class wild salmon and steelhead rivers here—the Trask, Wilson, Kilchis, Miami, Nehalem, and Salmonberry. These salmon strongholds contribute to a growing $550 million outdoor recreation economy on the North Coast.

But, for the first time in my 26-year guiding history, Tillamook Bay is closed to fishing for wild fall Chinook. This follows other restrictions and closures for cutthroat trout, spring Chinook, Coho, chum, and steelhead.

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Commentary

Readers respond: Protect the Tillamook State Forest

Since moving to the Pacific Northwest and becoming truly immersed in the outdoors, my relationship with the natural world has never run deeper. One of the places that has become home to me is in the Tillamook State Forest along the banks of the Wilson River. The beauty around every corner never gets old and makes one want to keep exploring.

My relationship with my food has also become extremely important after I moved out West and learned about the abundance of wild delicacies. The entire process of researching the resource, putting in the effort to harvest, processing and providing food for myself, family and friends brings a joy that’s hard to describe. It sets off primal reward systems that I didn’t know existed and has caused a sort of paradigm shift in how I view the natural world.

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News

Appeals court reverses verdict that awarded $1 billion to Oregon timber counties

The Oregon Court of Appeals on Wednesday reversed a jury verdict that awarded Oregon timber counties and taxing districts $1.1 billion they say they are owed from lost logging revenue on land they donated to the state.

The court determined that Oregon can manage more than 700,000 acres of donated forestland for a range of values like recreation, water quality and wildlife habitat — not just logging.

“The Court of Appeals decision today is a victory for Oregon’s environment as well as for sound forest management,” Attorney General Ellen Rosenblum said in a press release.

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News

Plan for logging Oregon’s state forests while protecting imperiled wildlife moves forward

A state forest plan that aims to protect endangered species across 640,000 acres of forestland west of the Cascades while providing certainty for logging is moving toward its final stages.

The proposed Western Oregon Habitat Conservation Plan would provide protections for 17 federally listed endangered species and ensure logging in other parts of the forests to limit the potential harm to those species. The species list includes the coastal marten, red tree voles, Northern spotted owl, and Oregon coast coho.

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Commentary

Guest Column: Let’s give fish a better future

I grew up fishing in Oregon. Too young to fish in the ocean, I was mesmerized by the salmon my dad and grandpa caught fishing out of Astoria. I knew salmon fishing was in my future, but at the time, didn’t know how far this passion would take me.

My early days of fishing set me on a course to provide this experience to others. I’ve been working as a professional fishing guide for 31 years.

I’ve seen good years and bad with the available catch of salmon and steelhead. These wild fish are the lifeblood of an $80 million a year sport fishery on the North Coast. Depressed wild populations of coho, Chinook, steelhead and chum salmon, as well as steelhead and cutthroat trout, have eroded away the incredible transfer of wealth from urban communities, for prospective anglers who come to fish on the coast and the rural communities who benefit from that economic activity. Degraded habitat is at the very center of less abundance in fish populations and economic opportunity.

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