Please accept my comments on the 2025 McDonald-Dunn Forest Draft Plan (Plan). For years OSU has over-harvested and mis-managed the McDonald and Dunn forests by clear-cutting large swaths of mature forest while ignoring the science of forest ecology and disregarding public concern. It is imperative that the management of our public lands prioritize ecological value over profit and the false argument that clear-cutting is the answer to climate-related wildfires (DellaSala 2019; McRae et al., 2001). Mature forest habitat is essential for sustaining viable populations of fish and wildlife, for keeping the forest cool and for carbon storage. Clear cuts and tree farms strip the forest of habitat diversity which is critical for supporting species diversity. What’s more, clear cuts and tree farms promote disease and wildfires. The Plan as presented will further degrade the habitat and ecosystem function, while increasing greenhouse gas emissions and fuel wildfires. 

As stewards of our public land (yes, this land belongs to the public!) OSU must manage the forest for ecological health and diversity. Please preserve the remaining mature forest of the McDonald and Dunn Forests. 

Thank you for considering my comments.

References

Dominick A DellaSala 2019. “Real” vs. “Fake” Forests: Why Tree Plantations Are Not Forests 

D.J. McRae, L.C. Duchesne, B. Freedman, T.J. Lynham, and S. Woodley, 2001.Comparisons between wildfire and forest harvesting and their implications in forest management. Environ. Rev. 9. 223-260 (2001); DOI: 10.1139/er-9-4-223.

Jerry

First and foremost, it is past time to understand there is NOTHING sustainable regarding Industrial forestry; not ecologically, not socially and certainly not economically. It’s time to understand the causes and consequences, the big, interrelated picture and the seriously compromised future we are leaving our children.You MUST do better. 

Ecologically – 

Industrial forestry represents a onetime 'take' of future generation’s legacies of resources and ecological services. Nature provides all basic resources and ecosystem services for free when Nature is respected, revered, and protected. Nature is a web of infinite symbiotic inter-relationships and wisdom. When we do not respect Nature and treat her with arrogance, domination, and the illusion of control, we all (Nature and us) suffer. It is time to see the fallacies of our myopic analysis, our choices and consequences and our undeniable trends of compromised ecosystems, busted rural communities and increasing extreme wildfires. It is time to connect the dots. 

When Science and higher education ask the wrong questions, only wrong answers can emerge. When openness and transparency disappear, education stops, and brainwashing (Group think) begins. Example: A seminar at the H.J. Andrews experimental forest entitled: How to create ‘structural diversity’ in a plantation? While ignoring that ‘diversity’ was destroyed in the name of logging, profits, waste/residue and subsidies. There is a complete disconnect between cause (short term focuses) and effects (long term ecological destruction) to justify and perpetuate Industrial logging. This is not education when it leads nowhere. 

The trends in my lifetime show in stark detail how technology, greed.

Subsidies and complicit research and Universities perpetuate unsustainable practices. The evidence is overwhelming. Here are some specifics: 

1. “There are No thriving rural forested communities in America today” – Communication with Mary Mitsos of the National Forest foundation. 

When I was 17, I worked with my grandfather in a resaw milling in Redding California (Summer of 1967). A man’s wage was $2.89 an hour, enough to support a family and have a boat on Lake Shasta as many relatives did. Jobs were everywhere and the economy was booming. My grandfather had worked in the timber Industries all his life. Thu, I grew up in the heyday of jobs and production. Today, even in the heart of the once most productive soft wood forests in the world, there are no jobs. The timber industries when from 70% of Lane county’s employment base (1950 – 1990) to 5% today. Classic short boom followed by a protracted bust – every time. No exceptions. When do we learn when Higher education ignores these trends? 

2. Forest research has designed and created bigger, faster ways to convert sustainable forests into unsustainable plantations. Yet all the ‘consequences’ of that ‘taking’ remain outside our economic, ecological, and social analysis. 

Economic – subsidies abound for privatized profits divorced from social liabilities in many forms from road building and logging costs passed onto the public, timber and land tax rates artificially low relative to the benefits, and all ‘restoration needs and costs’ are disconnected and independent from the causes which created the need for ‘restoration’. Then allowing the market to freely fluctuate for little logically embedded reasons, has made and broken many fortunes.

The mentality is remanence of the 1860-70’s and the slaughter of the Bison/Buffalo. So much waste, arrogance and greed all packaged as ‘progress and manifest destiny’. It’s time to see the implications/consequences across decades and generations. The lessons are clear, if we care to see. 

Ecological- Industrial forestry and Monocultures are the absolute opposite of Nature's evolution, wisdom and sustainable functions. To not see and understand this is the height of human arrogance, greed and stupidity. The fact that Oregon State University still teaches the past where historically once seemingly untouched vast forests could continue to support massive conversions of multi-story/species and wildlife into war zones of slash, hot direct sun, wind all driving extreme wildfires. Our advancing technologies have destroyed the forests into highly compromised and questionable plantations, where ecosystems and human communities are left with compounding consequences. Where are these being addressed, and why not? OSU and all other Universities are not teaching toward a future of hope and opportunity for future generations, quite the contrary. Not only do they not learn from the past, but ignore the consequences and repacking them into justifications, deferrals and lies. It is time to hold higher education accountable for the critical and compromised future that is a reality for our children, our ecosystems and our economies. It is past time to have an in-depth reality check thru integration and synthesis through our history which I hope my comments will spawn. 

Economically - Direct consequences of Industrial forestry is a onetime huge paycheck, federal sales of timber are highly subsidized timber sales by design and administration. We allow privatized profits to be disconnected from socialized liabilities so that the public and future generations get the consequences. From seriously compromised wood products (OSB, TJI's and CLT’s) to increased cataclysmic wildfires, increased insect morality, more fuel loading after harvest, less shade, more drying and then more wind with every tree cut. Our extreme wildfires today are a function and consequences of one hundred years of Industrial forestry. Current analysis which blames climate change and fire suppression are misguided and ignoring real science.

Certainly, climate change is real but very different from the perspectives of intact multi-age/canopy/species forests or clear cuts or plantations. While fire suppression becomes far more problematic as beneficial surface fires quickly become crown fires as crown heights are reduced with logging conversions. More wind, less shade more fuel loading = extreme fires. 

When do we learn? 

I have lived in the heart of the most productive softwood forest in the world - The Willamette National Forest for the last 51 years. I have witnessed firsthand how jobs have all but disappeared in a short boom followed by a protracted economic bust that continues today. How is it that 40 years ago over 70% of jobs in lane country were forestry/wood products based while today it's under 5%? Or our McKenzie school district which use to have 800-1200 students in 13 grades, today enrollment is around 170 students. We can't have families without local jobs. 

While I have asked many scientists and managers over 4 decades, when do you deal with this reality? There Is no response. OSU ignores this reality which has serious implications for every graduate who spends over 100K for a questionable piece of paper. How does 'higher education' ignore this without seeing how critically important ‘alternative’ forestry approaches are needed and required (Value-added from volume, labor intensive from capital intensive and local control from corporate control? Ways that address the 3 critical transitions directly. 

Let me help you with some basics. 

First, NATURE is the master, not us or our illusions of domination and control. They are short-lived and have profound consequences for our children and grandchildren. It is for their benefits that our work and education should focus on. 

Second, we must stop all Industrial logging. The consequences are far too extreme and pervasive to ignore relative to wildfire, ecological 'restoration', fish and wildlife, rural communities and jobs, erosion, declining water quality and hydrologic cycles while the only benefit is big profits for the 'owners'. Universities and OSU have perpetuated an agenda that benefits the few and creates fire consequences for the many. Hardly the kind of system that is 'enlightened or socially sustaining’, quite the contrary. 

So, what would be necessary to make/co-create a relevant education for future generations? Here are a couple of specifics relative to 'transitions' ahead. 

1) From volume to value-added where total utilization is the goal.

Example: Doing forestry like the Sioux harvested their Bison with total utilization, not like the white settlers who through manifest destiny slaughtered the Buffalo and Indigenous cultures almost to extinction for their hides and tongues. Who is out of balance, here?

What is ‘progress’? When does our concern for the seventh generation emerge? How can ‘appropriate technology’ bring technology on a human level for slow and thorough processing into value added finish products. 

2) Capital intensive to labor intensive coupled with 'appropriate' technology Is the antidote of Industrial forestry. Complete utilization requires a slow and thoughtful process to evaluate each resource in its most useful, economic and socially relevant manner.

Focusing on slow, selective harvesting, local processing with portable sawmills and end-product forest management where utilization and utility is key in reducing all 'waste', can protect all ecosystem services while providing a litany of natural resources and products. 

3) From Corporate control to local control including all aspects of forestry related jobs/work. Where natural resources are plentiful, the OPPORTUNITY to create a sustainable economic, social and ecological foundation is possible. The fact that our society and higher education continues to ignore the consequences of past choices and the changing realities of future choices is inexcusable. That should be the fundamental principle and focus of higher education. The fact that it does not speak volumes on its relevance. This must change at once. 

If these three principles were explored at OSU and the H.J. Andrews experimental forest more socially relevant questions would/could be asked/researched. If not now, When? If not here, where? 

How can Universities become relevant to our young and provide them hope and opportunity going forward? Instead of repackaging the last dying gasps of a dying, wasteful, unsustainable Industry? It is your job, after all. 

Some specific questions to consider in your research to embody ‘social relevance’. 

1) First understand all the interdependent inter-relationships which provide healthy and sustainable ecosystem functions and processes.

Understand the core aspects upon which all benefits are derived.

Example: Trees are not the most critical/valuable resource in the landscape, the soil is. Without soil, no trees. Focus on foundational issues first. Tom DeLuca should reflect on this as a soil scientist, while his recent actions have undermined the soil. 

Identify where management/focus has undermined ecosystem functions and processes. Begin the process of accounting for all ‘externalities and unintended consequences and bring them into the effort toward whole cost/consequence accounting. 

Identify all possible alternatives that address the problems of past miotic management in new and creative ways? Understand that ‘Less is more’, slow/thorough forestry without waste being no longer acceptable and greatest utility delivered coupled with ‘Appropriate technology’ is the antidot of unsustainable Industrial logging. 

2) Value added becomes the key metric for determining a project's value. What if the key question became how many jobs could create and sustain from 1000, 10,000 and 100,000 board feet of logs? From trees/logs of varied species and diameters to milling in unique dimensions? How can portable milling encourage and explore differing techniques, lumber dimensions and natural edge applications?

Opportunities are endless when creativity is encouraged within all processes – from species utilization to harvest thru specific ‘end-products. Creativity abounds when logging and processing Is done slowly and without ‘waste’. 

3) Evaluate the cost benefit analysis including the externalities Industrial forestry including all subsidies (road building, logging costs, minimized real estate taxes, revenue tied to public education etc.) with wildfire changes and rapidly increasing costs, significantly compromised man-made products like OSB - outgassing, TJI's failure in house fires and CLT's failures in juvenile, fast growing wood. All point to the dead end ahead while extrapolating the future. The future is now, if we care to look and see. Increasing extreme wildfires, busted and fire ravaged rural communities, very few jobs including with the massive (millions of dollars) ‘restoration spending, few local jobs are created or maintained. No one keeps tract of the numbers. 

4) Determine the ‘hierarchy of threats to fish, wildlife, rural communities (socially, economically and ecologically? Then determine a strategy forward that understands the big and symbiotic picture for the best possible outcomes in our children’s lifetimes. NOT just in ours. How do you frame and explore each threat? How do they impact or influence one another? How do you begin to account for restoration costs on the front end of your analysis? If not, do those costs impact on final analysis and cost benefit analysis? How, when and where does your accounting for all the 'externalities and unintended consequences" as critical components of your analysis show up? 

5) When does Oregon State openly engage with differing views/visions of forestry and how do you assess value, sustainability and lessons learned to each triple bottom line aspect? I and many others have long and varied histories with OSU and a total lack of openness of willingness to engage and address different points of view, fundamentally contrary to the purpose of higher education. 

In closing, let me offer 5 tenets to consider as foundational and essential. 

1) 'There is enough for everyman's need, but not for everyman's greed' Gandhi 

2) 'Life can be a pleasure and pastime if lived simply and wisely'; Thoreau. 

3) ‘Consciousness is the key, the means and the end' Sri Aurobindo 

4) 'Less is more and small Is beautiful ' R. Buckminster Fuller 

5) 'Nature is the Master, not our illusions of dominance and control'

Craig Patterson 

If Oregon State University is smart enough to understand, integrate and synthesize my comments and questions, I would be honored. If ignored once again, I will take that to heart and double down with renewed vigor. “EDUCATE toward our children’s future, not your rear view mirror past illusions”.

Among other things, the fact that this plan allows for 40-80 acre clear cuts and removes protections for older trees is unacceptable. These forests are a massive part of the draw of living in and visiting Corvallis. Please reconsider these changes.

Your faculty planning committee suggests 10% late successional forests to remain intact. That is not enough, given the carbon sequestration ability of douglas firs. Please review the science OSU has conducted in the past to learn more.

Hello to those it should concern, 

Please accept these brief reactions to the Draft McDonald-Dunn Forest Plan 

My primary concern with this draft plan relates to the protections for old-growth forest stands and their trees. I am especially concerned that the draft plan reduces protections for older trees and stands by removing the previous 160-year limit for felling older trees throughout the forest. All old-growth trees need to be protected. In addition, protections for forested areas that will soon qualify as old-growth needs to be strengthened. The draft plan clearly needs revision to provide more adequate protections for all forest stands, that are presently 80 years old or older, so that they can develop the full suite of old-growth forest characteristics and conditions. The coast range presently is seriously deficient in relation to the area of forest with old-growth characteristics, and as a public forest area, responsibility for acting to protect and enhance the development of old-growth forested areas is an especially important management responsibility. This responsibility is highly significant, given the importance of older forested areas for carbon sequestration. 

The carbon sequestration and climate change implications of this plan need much more extensive and careful consideration. At this point, this plan does not adequately incorporate the best available science into its processes and conclusions. Given that this plan involves responsibility for management of a significant forested area in the state of Oregon by a major academic institution, I feel that climate change implications warrant more complete exploration and incorporation into your planning process. 

The above considerations for shifting your management paradigm are fundamental to the lessons forest managers need to learn for the future of this region’s forests. As a research forest, new and different lessons need to be learned. These lessons need to focus on an ecological approach to forest management rather than the present industrial model for forest management, with its emphasis on short rotation logging. 

Given that the draft plan applies an industrial forest management paradigm to the majority of the McDonald-Dunn forest, clearcutting and regeneration harvests fundamentally fail as management practices that fit an ecological management approach to forestry. We already have a substantial experience base for industrial forestry, and as a research forest, learning more about an ecological management approach to forest management is something that is badly needed and should be implemented more fully. 

More adequate recognition of the greenhouse gas emissions from industrial forest management needs to be incorporated into this plan. I would expect this to result in a lower emphasis on the use of clearcuts and regeneration harvest practices. Your management should result in both a reduction of greenhouse gas emissions and an increase in the greenhouse gas sequestration as you appropriately transition to a more ecological paradigm for forest management. 

The draft plan will produce extensive areas of tree plantations that will bring a substantial increase of fire risk into the McDonald-Dunn Forest ecosystem. This consideration is especially significant given the projected implications of climate change, with its more extreme temperatures and drying of our forested landscapes. Note, the drying effects of clearcuts extend into surrounding forested areas which not only increases fire risk but also reduces the beneficial habitat characteristics of the associated older forests. 

I trust the teams involved in developing this forest plan realize the extensive and impactful adverse consequences of the clearcut/industrial approach to forest management. Therefore, I will resist the temptation to present a full litany of those substantial negative impacts. 

I have a substantial interest in and involvement in the biodiversity implications of forest management. The draft plan fails to adequately account for the biodiversity impacts of logging with shorter rotations where you propose to do that kind of logging. The number and diversity of taxa that are considered in your modeling are not adequately representative for the full suite of old-growth organisms. Short rotation forest management leaves a forest seriously deficient in the dead wood component of a forest ecosystem, and that impacts the availability of important ecological niches available for the relevant organisms. 

Finally, my thoughts as articulated above represent the input of a person who has studied and taught forest ecology in Oregon’s forested ecosystems for more than the last 50 years. They also likely reflect the sentiments of a major portion of Oregon’s thoughtful residents. 

Thanks for your consideration, 

Trygve Steen, Ph.D.

I had an enjoyable few hours (late) last night going through the plan. As I mention in my response, this has been an epic effort and there is much to be pleased with. Still, it would be great to see some fairly major improvements if this is to truly be a world-class plan that I can satisfactorily defend when challenged (I often am).  What are your plans for handling comments and incorporating into the plan?

Comments on McDonald-Dunn Management Plan, as well as external critiques of the plan

July 17

Matt Betts, Professor, College of Forestry, Oregon State University

McDonald-Dunn Forest Management Plan

Overall, I appreciate the massive effort the team has undertaken to produce this plan and engage with the public. The main components are in place for a good management plan. I appreciate the balance between wood, revenue and other objectives that you’ve attempted to balance. Nevertheless, I think there are several elements that could be substantially improved to make this a world-class forest management plan that I’d be proud to discuss with the public, my colleagues and friends. I’ve described both major and minor points below. The major ones are: (#1) the need for more rigorous monitoring, (#3) how will you use the responses (like this one) in making adjustments to the plan? (#5) formalized flexibility within “management strategies” to allow adaptive management and explore alternative silvicultural options (including testing “ecological forestry”), (#8) additional recruitment of old growth forest, (#14) full transparency when it comes to wood yields, AAC projections, projected habitat change, habitat relationships used in the linear programming model. These should be basic elements of any forest management plan.

I have also included my response to some widely circulating critiques of the plan (below). I did not look at these before developing my own review below.

1. Monitoring. Monitoring is a key component of forest management and biodiversity conservation in that it enables “adaptive management” (the capacity to learn whether forest management strategies are working, and adjust accordingly if they are not). Although monitoring is mentioned in the plan (to be conducted by “consultants” and via “participatory science”) there are no details on sampling intensity, sampling design or spatial extent. As such, it is difficult to evaluate whether adaptive management will be possible at all. A next step needs to be the development of a formal monitoring plan. Ideally, this would not be conducted by consultants but could be included in the OSU Forest Curriculum and /or OSU research labs are given the opportunity to develop sampling designs. Monitoring should be considered a key component of the overall plan and should be paid for by harvest revenues. It is remarkable (looking at Table 2) that there are very few (any?) forest-wide monitoring efforts, but only very study specific, spatially restricted research. No end dates are provided in Table 2 so it is impossible to determine the length of past/current studies.

2. Perhaps semantics: I’m surprised that one of the goals does not include biodiversity conservation (mentioned in the Mission, but not in specific goals)

3. Response to public input. Figure 1 shows the process of plan development but gives no indication of how public comment will be incorporated in to plan revisions. The next step is simply “Draft to dean and forest exec committee”. Will revisions be made following public comment?

4. Historical forest composition and structure. I suspect that Fig. 8 greatly oversimplifies the historical distributions of “forest”, “oak savannah” and “prairie”. It would be a useful and interesting exercise to do some dendro work to determine the distributions of large stumps, and date them to determine what this historical range of variation might have been. This is particularly important given the stated priority of restoration. An additional test would be to look at the logging history of the forest to estimate how many board feet (and of what species) have been harvested over time. Under the hypothesis that the land was primarily oaks and that Douglas fir colonization was very recent, most harvest in early years should presumably have been oak.

5. Categorical management strategies. I am curious about why five categories of “management strategies” are being presented rather than offering the opportunity to examine gradients among these strategies to test how best to balance stand-level yield with other important outcomes like climate adaptability, biodiversity and public acceptance. Binning management into these categories runs the risk of severely limiting creativity when it comes to silvicultural approaches. Since this is a research forest, there should be a formal plan on how variation within these categories plays out in terms of yields, biodiversity, carbon, microclimate etc.

(a) Why, for instance, does the short-rotation strategy only aim for 6% cover of hardwood trees rather than deliberately exploring variation in this amount to see if yield is compromised?

(b) Why adhere only to the minimum Oregon Forest Practices of 2 trees & snags/acre rather than examining a range of retention, even in this short-rotation strategy?

(c) Why not conduct formal research on various approaches to controlling competing vegetation rather than doing-business-as-usual herbicide application? What are the economic and wood costs of different approaches to controlling competing vegetation?

(d) Why not test the effects of varying degrees of retention in the long-rotation harvest stands (on yields, wildlife habitat, carbon etc.)? Is there a “sweet spot” between two trees per hectare and multi-aged silviculture that could provide habitat/carbon and still generate revenue?

6. Testing Ecological Forestry. Relating to (d) above, I would like to have seen a higher proportion of management and research focused on ecological forestry approaches. Given that so little is known about yields from these methods, wildlife responses etc., along with poor public opinion about management of the McDonald-Dunn, it seems prudent to do more experimentation on various non-traditional approaches to management, even if it ends up coming at some cost to yields (by the way, which we can’t even quantify because so little has been done along these lines).

7. Forest Fragmentation. To what extent will attention be paid to limiting forest fragmentation effects (enhancing connectivity, reducing edge etc.). Looking at the map in Fig. 22 it does look as though attempts have been made to put multi-aged treatments beside old-forest (which is good from a limiting edge perspective). Was this ever quantified formally? What will be the timing of spatial layout to minimize fragmentation effects?

8. Old-growth recruitment: I don’t see the term “stand establishment” as being compatible with multi-aged management. When is the stand established given that there will be no stand-initiating disturbance? Why is the oldest age of trees in the multi-aged stands 120? Why not let some forest age past that? It is likely the case that the historical range of variation in this forest did tend toward oak woodland, but clearly some significant patches of old growth exist (and have been cut quite extensively in the past). Given that old growth is in such short supply in the Coast Range as a whole (see Spies et al. 2007 – Ecol Apps), and that old growth has microclimate buffering effects (Frey et al. 2016 – Science Advances, Kim et al. 2022 – Global Change Biology) it makes sense to plan for increasing this development stage over time in the McDonald-Dunn.

9. Fire as a restoration tool in old growth. I would like to see the evidence that fire was a regular occurrence in existing old-growth stands. Is this published? Also, is there evidence that reductions in “surface fuel loading” reduces fire risk/severity on the west side? My understanding is that that practice is highly controversial. Dead wood in the understory and multi-canopy stands are likely to be the mechanisms behind old-growth microclimate buffering (Frey et al. 2016 Science Advances). Removing these materials/trees could therefore increase temperatures in the understory, elevate VPD and enhance fire risk and spread.

10. Forest inventory and yields. How reliable are the inventories and yields used to build the linear programming model? These models are clearly highly sensitive to parameterizations. For instance, to my knowledge, yields for multi-aged forest management are non-existent. From where did you generate yields for short and long- rotation management? Importantly, how will you determine whether or not various treatments are responding (in terms of yield) following harvest? (How frequently and at what sampling intensity will post-harvest inventories be conducted; I see there is some mention of this later in the plan, but details are lacking). The plan should include (at least in the appendix): (a) yield curves, (b) inventory data, (c) species habitat relationships, (d) trajectories of habitat, yield, and growing stock over time.

11. I appreciate the use of coarse and fine-filter approaches. For the indicator species, was an effort made to (a) estimate their habitat requirements, (b) model future habitat for these species over time? These should also be reported in the plan for full transparency. Again, what rigorous long-term monitoring will be conducted to test whether projections are indeed correct?

12. Hardwoods. For the 6% hardwood threshold that you cite from Ellis and Betts (2012) this is for the abundance of all birds. A more conservative threshold from the same paper is ~16% (for leaf-gleaning birds that are your indicator species). However, an alternative explanation is just “the more hardwoods the better”: “Quantification of a threshold at 15.89% (SE = 5.71) cover for all leaf gleaners was ambiguous, with slightly greater support for the linear model”. I do think the 6% threshold is incautious. I appreciate that you have the target at 10% for long-rotation forestry, but I suggest that even this should be higher.

13. Dead wood conservation. After quite a nice review on the importance of dead wood, the plan then goes on to state that the bare forest practices minimums will be used in various harvests. If the objective is to demonstrate sound forestry, these levels of downed wood and snags should be increased. Again, adaptive management should be used to hone the targets that are initially established.

14. Transparent projections about future forest conditions. I’ve mentioned this above, but it is important to emphasize that forest management plans should show projections for all of the elements considered in those plans under various scenarios (I thought that a consulting company did these for you?) Included in those projections should be estimates of uncertainty. Where are the projections for annual cut over the next 100 years? Wildlife habitat? Growing stock? I think some of the existing critiques of the plan might have less impact if it were shown quantitatively that total above-ground carbon in the McDonald-Dunn will be accumulating (I expect it will given the relatively conservative harvest rate estimates – if the inventory is correct). If I missed, these, my apologies! Showing forest inventory and wildlife habitat projections are critical if the public (and CoF employees) are going to effectively evaluate the efficacy of the plan. My response to some external critiques of the plan (I only focused on critiques that are within my area of expertise).

• allows clearcuts of 40 to 80 acres (“long- rotation” vs. “short-rotation”) compared to the 2005 plan (which limited the size of cuts in the southern portion of the McDonald Forest to four acres in size) - Smaller cuts are not necessarily better in that they tend to fragment the forest even more (e.g., create more edge, result in smaller future patches of mature forest). Rather, cuts should consider natural terrain boundaries, have considerable retention (dispersed and aggregated). Notably, a later critique also focuses on increased fragmentation in the plan, but limiting cut size would amplify fragmentation.

• relies on continued, widespread use of poisonous herbicides at the discretion of forest managers - Agreed that it should not be default to use herbicides. Formal research should be done on herbicide alternatives, as well as minimum amounts of herbicide to achieve regeneration objectives.

• relies heavily upon (“Woodstock”) forest modeling which is widely regarded as promoting wood fiber production over ecological values - Woodstock is just a tool that can be used for any sort of forest management planning. We have used this model to primarily examine ecological values in relation to wood yields

• relies on the relatively low standards of the Oregon Forest Practices Act (OFPA) as the primary constraint for forestry activities - Agreed. I don’t understand why we’re just adhering to the minimums rather than test of flexible alternatives (see above)

• promotes polluting, ecologically- destructive biomass energy as a “renewable source of energy - I didn’t see this in the plan?

• promotes a skewed biodiversity metric which relies on a limited number of taxa, rendering the conclusions arbitrary - I’m not sure what is being referred to here. Yes, a wider range of indicator species could be used, but the approach used was quite ambitious even compared to some Forest Stewardship Council certified forests that I’ve visited. The alternative to indicator species is to monitor all biodiversity (1000s of species) which is intractable.

• uses modeling that falsely concluded OSU’s continued reliance on even-aged, monoculture tree plantations will increase the resilience of the forests - What is the evidence that forest management will result in monocultures? I didn’t see that part (I do argue above that the hardwood component could be increased based on best available science).

• changes the old-growth reserves to allow logging for a variety of reasons, including “public safety” and to create/maintain, “structural and compositional diversity” - I assume that any activity in old growth stands would be extremely light touch. I do agree with this point that very little should be done in reserves (especially not fuels reduction or understory burning) – see my point above that there isn’t much science to support this (to my knowledge).

I have followed the COF McDonald Dunn Forests planning process for the last few years and have joined many others in demanding that the College stop its logging of late successional/old growth forests at the limited opportunities for ‘live’ input from the public, and I have also responded to the email requests for public comments. I again am again adding my voice to the many calls from the citizenry of Oregon to stop the demolition of old growth and mature forests in the McDonald Dunn and move to forestry practices that promote the preservation of ALL the old growth trees in the forest and a buffer that will protect these irreplaceable trees as the pressures of an increasingly hot and dry climate. 

The utter destruction of the incredibly beautiful and ecologically important Baker Creek old growth will not be forgotten by those of us who treasured it. OSU has repeatedly failed to be truthful about this catastrophe. I have been appalled at the loss and threats to old growth and mature forests across the Forest - I often visit the 440 Road old growth and have been dismayed at the logging that threatens the last remaining late successional/old growth trees in this area. I see the same in the recent harvested areas at Peavy Arboretum, Baker Creek drainage and upper Oak Creek, where the COF repeatedly goes out of its way to grab the biggest and the best of the last remaining big trees. These are our heritage from the presettlement era and yet the COF replaces them with plantations and weeds. 

The Plan needs to take another look at all these sites and add a significant buffer zone as well as implement logging approaches that promote shading and thermal protection of the soil resources. It is time for the COF to fundamentally reject the logging practices of the 1950s, accept that clear cuts cause climate change, and work to revise the outdated and destructive Oregon Forest Practices Act. Research should be focused on mitigating the destructive effects of logging on watersheds - soil heating, stream drying, invasive plants. 

The Plan’s recognition of the importance of wetlands, riparian zones and oak habitats is welcomed but it remains to be seen if this results in better management actions. I look at the oaks that were saved from logging along the 100 and 110 roads and yet now are being smothered by plantations of Douglas-fir regeneration. This is a prime opportunity to develop innovative practices that incorporate harvest while fostering diverse forests and uplands. OSU should be a leader in this effort but I see other universities such as Willamette University Biology Program have a much better research program to understand Oregon Oak biology and ecology. 

I urge the COF and the trustees of the University to reject this plan as written, review again all the public comment asking for a more ecologically aware and sensitive approach, and offer the University and the public a better plan that can help the academic discipline of forestry meet the challenges of climate and environmental degradation.

After reading through most of your proposed management plan, I have a few very important comments. 

I've been an Oregon resident in Benton County for over 33 years and have enjoyed many weekly hikes in the state forest, specifically Peavy Arboretum. In fact, during Covid lockdown, this was a daily activity to keep my family sane. I also have a friendgroup that hikes the various McDonald and Dunn State forest trails every week all year long. 

Your current proposal to reduce the area of cutting size down to under 40 acres is disturbing and I don't support this idea. Many old growth trees will be lost forever around Cronemiller lake, which is one of the most scenic areas in and around Peavy. 

I don't support clearcutting this forest one bit.and the practise of cutting one-third of the timber every 20-30 years. Keeping the larger (older growth forest) should also be spared.