Comment on ODF’s Draft Forest Management Plan

Why this matters

The Oregon Department of Forestry (ODF) has opened a comment period (through 11:55pm Jan 31st) on a draft Forest Management Plan for state forests in Western Oregon and the future of our state forests hangs in the balance! Tell the ODF to stop clearcutting older legacy forests, and improve water quality!

Oregon state forests comprise 640,000 acres of temperate rain forests, concentrated on Oregon's North Coast. These forests once provided a home to massive runs of salmon and thriving populations of northern spotted owls, marbled murrelets and many other species currently at risk. In all, more than 300 species of wildlife and plants depend on state forests for habitat, including several species found nowhere else in the world. In addition, these forests have a tremendous capacity to capture and store carbon, far more than current management practices provide.

Decades of industrial-scale clearcuts and over harvesting have pushed 17 species to the brink of local extinction. Older legacy forests continue to be clearcut as habitat for imperiled fish and wildlife dwindles, despite laws requiring protection of older forest stands. As a result, the ODF must adopt a new Forest Management Plan (FMP) with a habitat conservation plan (HCP) included to prevent the further decline of imperiled fish and wildlife. The HCP is definitely progress, but it alone will not result in the recovery of endangered salmon and wildlife populations.

Large-scale clearcutting on state forests has also led to the decline of water quality to the point where nearly half of salmon streams in the Clatsop State Forest are listed as “impaired” for water quality under the Clean Water Act. A final approved FMP must contain strategies to improve water quality for salmon and local communities.

Tell the ODF to stop clearcutting older legacy forests today!

Steps to Take

Step 1

Write your own comment, or modify and use the pre-written comment below. Personal messages make a big impact on decision makers, so please add a note about why this issue matters to you! Also, if possible it's always best if you submit it directly to the agency, as identical comments or mass submitted comments don't get as much attention. (Approx 1,000 characters remaining in this pre-written comment)

Step 2

Submit written public comment:

By email: odf.sfcomments@odf.oregon.gov

By mail: Justin Butteris, State Forests Division
2600 State St., Salem, OR 97310

Sample Text

Dear Kate, Justin, and ODF staff,
Thank you for the opportunity to comment on the draft Forest Management for Western Oregon State Forests.

Like the vast majority of Oregonians, I value state forests for their fish and wildlife, cold clean rivers, recreation and scenic vistas. For too long, management of these forests has been out of balance, favoring industrial-scale clearcutting and timber revenue over multiple values cherished by Oregonians. The draft Forest Management Plan is an opportunity to restore balanced management to state forests by focusing on ecological forest management, restoring ecosystems, improving water quality and the recovery of at-risk species pushed to the brink of extinction by decades of industrial forest practices.
For over a decade, the ODF has ignored requirements of its rules and legislatively adopted key performance measures that require protection and enhancement of older mature forests. From now forward, the ODF must manage state forest in compliance with all existing rules and policies. The draft Forest Management Plan is a great place to start this needed shift toward accountability.  To restore this balance and accountability on state forests, I urge you to make the following amendments to the draft plan.
•The FMP must be based on the best science available. Add a requirement for all actions to be based on the best available science, as required under existing law.
•Improve accountability by amending the draft FMP to require compliance with applicable laws, policies, plans and performance measures adopted by the Board of Forestry or the state legislature. Incorporate these by reference into the FMP.
•Bring balance back to state forests by deleting or amend Principle 3 in the draft FMP. It would require revenue from timber harvest to fund all of state forest management activities, continuing to prioritize logging over all other values in state forests in violation of the law.
•Restore healthy mature forests: Halt all clearcut timber harvest of complex layered forest stands on North Coast state forests until a minimum of 30% of the forests are in this condition, as required by current rules and policies.
•Ensure clean healthy watersheds for salmon and communities. Develop forest management and restoration plans for watersheds with impaired water quality. Restore water quality to levels healthy for salmon and other aquatic species within 10 years.
•Fight climate change and build climate resilience. Add strategies to implement the Climate Change and Carbon Plan for state forests. Shift to longer rotations between harvest, reduce reliance on large-scale clearcutting and establish a carbon market program.
•Commit to the recovery of threatened and endangered species. The HCP is a necessary step to prevent the local extinction of imperiled fish and wildlife, but it won’t lead to the recovery of these species. The FMP should include specific strategies, in addition to the HCP, to contribute to the recovery of the 17 imperiled species clinging to to survival in our state forests.

Thank you in advance for making these changes to the draft plan and protecting the state forests for our children and future generations.

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