On behalf of Friends of OSU Old Growth, I am submitting the attached PDF of a recent blog piece as public comment on the draft management plan for the McDonald-Dunn Forest. 

On behalf of Friends of OSU Old Growth, I am submitting the attached PDF of a recent blog piece and Corvallis Advocate article as public comment on the draft management plan for the McDonald-Dunn Forest.  

I hope you will consider my input to your draft plan. My input is based on my familiarity with McDonald Dunn, my background in natural resource and NEPA planning as well as cultural resources. One of my fondest memories of McDonald Dunn was having the opportunity to assist on a tour of the forest with visiting Taiwan foresters. This was probably 2003 or 2004. We walked the Old Growth trail. I took up the rear to make sure everyone kept up. As we passed one tree close to the trail on our right, each of the members of the international delegation put their hand out to touch the tree. There was a recognition of the unique feeling of being in a stand of old trees. That should not be lost so that future distinguished foreign visitors to the College of Forestry, that they may have the same experience and opportunity. The position of the College of Forestry and the Research Forests goes way beyond the generation of revenue. The Research Forest serves as an educational and research tool. Wearing a College of Forestry cap while walking the streets of Santiago, Chile in 2002 I heard in a crowd someone voice Oregon State University. Any decisions you make will have repercussions beyond the local area. Attached are my comments in the uploaded file.

Specific Comments on the Draft McDonald Dunn Forest Plan
Why does your land acknowledgement statement not clearly define Kalapuya instead of “a diversity of Indigenous Peoples?” The College of Forestry also has forests in other homelands, but McDonald Dunn is clearly Kalapuya land. This land acknowledgement is for McDonald Dunn not everywhere there are research forests associated with OSU. Oberteuffer for example should include references to the Cayuse and Nez Perce. A land acknowledgement statement is a commitment to manage the land with care and to protect those values that the pre-colonial peoples valued. Otherwise, this is just some person driving by in your truck that they did not pay for and waving thanks for the truck. Spending time on a land acknowledgement statement and then not identifying those concerns seems insincere.
In general, this document reminded me of the 1970s and 80s with the addition of identification of some concerns that are more recent. Forests have plans whether you are private or public. Are they multidisciplinary lists of concerns or do they represent a truly interdisciplinary communication between disciplines needs to be better clarified.
Here are my comments with the associated page numbers.
P 5 Under Goals and stewardship why aren’t tribal issues discussed? Are the cultural resources just “other resource values?”
P 34 Where does the 20,000 date for Indigenous occupation come from, see also page 37. Is this in reference to the 18,250 date for Rimrock Draw near Burns, Oregon? I don’t think there is such a date in the Willamette Valley. In conversations with Kathryn Harrison who was active in getting the Grand Ronde restored and a tribal chair, she said her people had been here forever. There appears to be an assumption by the writer that the Kalapuya are late arrivals by constantly referring to nebulous “Indigenous people” while at the same time referring to historical trauma. Later on, page 103 we have a Kalapuya Nation. These are sovereignty issues and they are being ignored. They are properly the Confederated Tribes of Grand Ronde and the Confederated Tribes of Siletz. Where is this information coming from? Why isn’t Lindon Hylton’s thesis cited in the history section. It can be found at: . It was partially funded by the COF and a grant from the State Historic Preservation Office.
Why isn’t Oregon ash mentioned as having been controlled by fire pre contact? Ash trees have moved into what were camas fields. Burning kept the ash back and protected that essential food resource.
Page 37 refers to archaeological sites in Oregon date back to 13,000 BCE ( is this the 20,000 year old site mentioned on page 34?), this is not in the Willamette Valley. This comment also contrasts to an earlier statement citing Boyd that burning goes back 20,000 years. Let’s get this straight and consistent. Boyd is an overview, not MacDonald Dunn specific. The people are also referred to as the “Idegenous people.” They were moved to Siletz and Grand Ronde where they would become confederated tribes. There is NO mention of the treaties. Treaties were signed and lands ceded.
Page 38: This is Kalapuya land and not land of other Indigenous peoples. How performative that first paragraph on this page is. The second paragraph is in error. The Warm Springs only have a small sliver of the Willamette Valley further north associated with Willamette Falls as I understand it. What happened to the Commission on Indian Services and the State Historic Preservation OKice? Are the authors familiar with the State Cultural Cluster meetings? It is diKicult to see how broad statewide synthesis of information are misapplied to McDonald Dunn and not the actual information of the Willamette Valley or from McDonald Dunn specifically. Maybe you should have talked to the tribal cultural history peoples and to David Lewis on the OSU faculty. Maybe you should have talked to the cultural resources manager of the forest from 1994 to 2004. She knows approximately where that sweat lodge was.
Page 39 Why isn’t Goal 5 of LCDC addressed? Are you all aware of the potential changes to this rule targeted for July 2026?
Page 39 Under 2.5.2 regulations why aren’t the cultural resource laws linked. Did you all know that disturbing an archaeological site can aKect the applicant’s ability to acquire future funding under section 110 C of the National Historic Preservation Act as codified in 36 CFR 800.9?
Nowhere is there a mention in this history discussion the Civilian Conservation Corps (CCC) . This was part of the Vancouver Barracks under the direction of General George C.
Marshall. All CCC structures and remains are potentially significant to the National
Register of Historic Places due to this association with Marshall and the importance of the CCC work in reforesting the Tillamook Burn. Many CCC men went on to be important in numerous aspects of Oregon politics and also at the national level.
P 42 the discussion of visitor usage might be a more realistic interpretation if the size of
OSU and of Corvallis was included and how this population growth has changed through time. As for vehicles, many people did not own vehicles. Diachronic change can be useful information.
P49 The disease history is much more than this. This is again a generalization. Boyd identifies the diseases in the 1770s to 1850s as were smallpox, malaria, viral influenza, yellow fever, measles, typhus, bubonic plague, typhoid fever, cholera, and pertussis. There were also secondary deaths of individuals who did not get the diseases, but who died because there was nobody to take of them such as children and elders.
P50 Don’t the co-stewardship and ecocultural restoration emphasis contradict the timber harvest plan? This is really performative. If you really want co-stewardship, the tribes need to be paid for their time. They are busy with many tribal issues.
P 51 Item 9 seems to contradict tribal sovereignty of the Confederated Tribes of Siletz and Confederated. Tribes of Grand Ronde. I probably should have mentioned sovereignty in other places where this generalized “Indigenous people” keeps appearing. It is Kalapuya land.
Working on MOUs, you should involve the Oregon Commission on Indian Affairs to help identify the groups. In addition to the Cultural Cluster there is an Education Cluster and a Natural Resources Cluster. Why do I feel like you really do not want to talk to the tribes?
P 53 Glad to see the long-term studies recognized. I hope the list is complete. I did not double check it.
P 56 We finally get to the money. That is the real purpose of the plan. I am still looking for the creative approach.
P 66 After all that talk about the tribes, there is no mention on table 4 of their concerns. In the past the concerns have included camas swales and the potential to gather basketry materials that are not sprayed. There are many other traditional plants associated with the Kalapuya available at McDonald Dunn.
P 80 Why is there no post fire assessment to archaeological sites. Previously recorded sites may have been impacted. Previously undiscovered sites may be identified due to duff and vegetation removal.
P 83 Why isn’t the Emerald Ash Borer Readiness and Response Plan for Oregon cited? Here it is https://www.oregon.gov/odf/Documents/forestbenefits/eab-readiness-and-re... . I also think Dave Shaw is a good resource on the bug. As well as the thesis by Sean Privie as he includes McDonald Dunn and the Ag lands
I am finding it odd at how specific this section on insects and pathogens is and how generalized the tribal references are. How many archaeological sites are on McDonald Dunn?
P 85 3.7 Human dimensions- Why aren’t tribes mentioned here. You have a newly installed sweat lodge. I feel this is a continuation of systemic racism.
P 103 Numbers 14 and 15 under Table 7 should really be presented to Commissioner on
Indian Affairs and the tribal Councils of Siletz and Grand Ronde. I am not sure what a Kalapuya Nation is as such a term is not recognized at the Federal or State level. Are we being performative again or making it up as we go?
P 121 I think your glossary needs more work. The glossary looks like this was pulled from another document.
P 130 to 132 It looks like the cultural resource’s summary stuff. Again, I am not sure where that 20,000 year comes from at this point and it is not out of the question, but where it that site. The definitions are out of date, as the administrative rules have been changed. A qualified archaeologist is determined by the SHPO office. This section also clearly states McDonald Dunn is the ancestorial home of the Kalapuya, so why is there all that earlier stuff in the plan about Kalapuya and Indigenous peoples. Your earlier parts do not agree with your appendix. The cultural resource manager was hired in 1994. Contracting began in 2005. How is the contractor active in management?
P 132 should be the Confederated Tribes of Grand Ronde and Confederated Tribes of Siletz instead of Oregon tribes. If you need help to identify the appropriate tribes, ask the Commissioner on Indian AKairs. Also, the collection of artifacts on lands of the State is incorrect due to changes in the laws and rules. Please review the current revisions and amend this section including the new SHPO Guidelines and other info can be found here https://www.oregon.gov/oprd/OH/pages/archaeology.aspx . If the McDonald Dunn is a model for cultural resource management, then they should be mindful of changes on the laws. Given the director and the associate director of operations are in charge of cultural resources, what is their training? They should be required to take a training similar to what my previous employer offered. This was USDA- NRCS cultural resource modules. Modules 1-6 are online and Modules 7 and 8 include a field component. While they are at it, maybe they should also see about a course similar to USDA-NRCS’ course on Working Effectively with American Indian Tribes. What happened to the requirement for training as part of a settlement that was generated in compliance to an agreement with the OSU EEO Office about 20 years ago?

P140 Here we go again on generic tribal nations and not Kalapuya descendants or the appropriate Federally recognized tribal reference. Then in the next section it is the Kalapuya people. Please consistency, this is all kind of sloppy how terms in regard to the Kalapuya and tribal people are thrown around. This is disrespectful.
P 141-142 While conservation and restoration of Oregon white oak prairies is mentioned, there is no discussion of climate change and oaks. Fern Ridge reservoir is the northern extent of black oak in the Willamette Valley. This is approximately 60 miles from the forest. Assisted migration maybe should be considered. The acorns of the black oak are also more favored for food. Also are you familiar with the oak restoration projects in southwest Oregon by the Klamath Bird Observatory?
P143 It is finally mentioned that Confederated Tribes of Siletz and Confederated Tribes of Grand Ronde are the descendants of the Kalapuya ancestors who were at the forest. Who are those many other generalized groups previously mentioned in this document?
P 144 Make sure in seeking Federal funds for restoration that there is full compliance with 36 CFR 800.9
P145 Under restoring ecological functions of low quality remanent …. suggested management actions include partnering with Confederated Tribes of Grand Ronde and Confederated Tribes of Siletz, have you already talked to them about these types of activities? Given the high use of herbicides, cultural plants should be tested prior to any harvesting and use. Who would pick those costs up? Also, the USDA Natural Resources Conservation Service might be helpful. They generate cost lists.
P 146 Indigenous people universal term of “ancestor tree” is another generalization. There is a Kalapuya lexicon which might help you. I would contact Ester Stuzman who helped put the lexicon together. I have heard the Nez Perce have use the term “grandfather” tree.
P 147 Did you know the riparian areas were also important to the Kalapuya lifeways?
P150 I guess cultural resources are not a Forest Value. No attempt at metrics for this are presented. You spend a lot of time mentioning indigenous people in this document in a very general way, including some items which are not of relevance to the homeland of the Kalapuya. Evidently recreation acceptability is a value and not the presence of the Kalapuya. Cultural resources are a non-renewable resource.

"Dear Planning People,

I recently learned about this planning process for the OSU forests and have some observations to offer:

First, your webform is CRAP! It was hard to find this form (buried at the bottom of this webpage, but not even referenced on the main page about the forest plan). It is clear you don't really want the public to submit comments!

Your form has a check box to keep my name anonymous, but frankly, I don't trust any of you! I have friends at OSU and I've heard so many tales of how people in charge (like the dean and associate dean overseeing this process) have retaliated against people who they perceive as critics and threatening to their interests. I am sure you know who these folks are because you have attacked them in your communications! This is VERY WELL KNOWN by those of us who use the forests!

I see so many comments from timber company executives (many of whom are also alumni of the Forestry Department). I cannot imagine how all of these people came to comment here unless they were contacted by someone at OSU and told they needed to comment (in favor of logging the forests). It's as clear as day! These are NOT people who generally follow a forest planning process!

So, my question is, how did you all convince these people to make their comments and who did it? The dean? The associate deans? The forest director (who everyone knows was a BAD APPLE)? Have you people no sense of objectivity and integrity?!

I was also very surprised that you don't show who is on the planning team or committee. It seems like you've made it difficult to even figure out who is behind the curtain. How can people who work for a public university behave this way? Honestly, you all seem like you're part of some secret organization or organized crime!

Which I guess you all really are! My friends all talk about how the people in charge of the forests are paid by timber receipts, how the dean is a total industry supporter, how this has gone on for many decades and everyone in Corvallis understands this if they've been around and have any common sense.

I want to know how you all live with yourselves, knowing your whole system is built on destroying these forests that we love. How do you all look in the mirror and not feel deep shame? How do you all keep acting like everything you're doing is normal and okay when you know that it is not???

No one I've talked to expects any of this to change. OSU has a long history of arrogant behavior when it comes to the forests they manage. I have lost track of how many times various officials from the college have threatened that they could take away the public's right to enjoy the forests. What kind of people do that??? BULLIES!!! Besides, you need to understand Corvallis citizens would NEVER EVER put up with that kind of BS! Try shutting the forests down to recreationist and you'd have a massive rebellion in short order! Actually, I wish you'd do it. Maybe that's what's needed to get you to understand that you really don't have the power you think you do!

I am honestly disgusted by everything I've seen, not just on your website and in the new forest plan, but having lived in the community and watched how OSU foresters/leaders behave. It is REALLY SHAMEFUL!!!

I'll quit my ranting here, but these are not YOUR forests!!! People like me are everywhere. We will NEVER GIVE UP!!!"

I am wondering if someone can tell me why the comments have not been updated since May. I know lots of people who have sent emails to OSU about this and none of their messages are showing up. It seems like maybe someone is intentionally not displaying comments because they know it might encourage others to also share their concerns. Who is in charge of this? Why aren't you posting email messages or updating comments? How do you think that makes you look?

This Forest plan builds on the 2005 plan to provide highly interesting and useful information in Chapter 2. The paradigm shifts envisioned in Chapter 3 are laudable, but may be challenging to implement. My specific comments are as follows:

1. Regarding section 3.3.2, additional sources of revenue will be needed for prairie and oak savanna restoration, given the magnitude of work proposed in Appendix E. For example, the Buchanan Farm that runs the Tyee Winery has overseen the restoration of several hundred acres of wet prairie on their land, which was accomplished with several hundred thousand dollars of outside funding, as I recall. Exploring your options for restoration funding or finding additional collaborators, such as the Nature Conservancy, who might be willing to invest in and/or conduct restoration on the College forests, would be worth a try.

A substantial fraction of grant funds goes to the University as overhead, which is used for running labs, paying for utilities and funding support staff. One could certainly argue that some fraction of the overhead from grants utilizing the “Living Lab” should go to the McDonald-Dunn Forest.

2. Regarding your late successional management strategy, ring barking smaller trees would be a non-invasive, cheap approach, which mimics the natural tree mortality that yields the snags used by wildlife. Felling trees and leaving the logs in place would increase downed woody debris, as is characteristic of old growth forests. This would increase local fine fuel densities over the short term, which might be an acceptable risk, given the small fraction of the total forest area to which this was applied.

Yes, the current old growth on the forest may be a novel state for this area (though not across western Oregon in general), but is valued as is by many visitors. Thus, leaving some of this forest unmanaged might be more acceptable to the public and could serve in comparative studies of your yet untried methods.

3. On page 85 you suggest reducing shade tolerant species, such as grand fir, in your guidelines for improving forest health. I suggest a more nuanced approach that recognizes the importance of site conditions on forest health. Grand fir trees are already dying on drier sites and their snags and fallen boles are contributing to wildlife and eventually soil humus. But in the Soap creek drainage on the north facing slopes below roads 700 and then 760 there are impressive grand fir trees up to 170 ft tall in mixed stands with Douglas-fir, that would have established or been released as saplings after that area was logged 70+ years ago. Standing dead grand firs are currently very rare in these stands, perhaps no more than one would expect due to background mortality.

4. Regarding biodiversity, your emphasis on maintenance of uncommon hardwood cover types, such as madrone, is commendable, but the maintenance of uncommon coniferous species is also important. These include redcedar and hemlock. As you note, there is a small area in the upper Soap Creek Basin in which hemlock occurs – as well as redcedar, though the distributions of these two species differs somewhat over this area. These trees are within the large area that was forested in 1800 (Fig. 8), but was logged around the time that the College acquired it in 1948 (Figs 11 & 19). Nonetheless, some hemlocks and cedars survived, perhaps as advanced regeneration, and grew up to serve as seed sources for the current understory saplings and young trees of these species.

This image outlines a potential hemlock and redcedar reserve in an area that surrounds the north end of the North Newt timber sale. Second-growth redcedar trees and saplings are abundant in parts of the upper right lobe and a small grove of old growth cedars stands adjacent the watercourse in the lower left lobe by edge of the North Newt clearcut. A sparse scattering of hemlock trees and more abundant saplings occur in the center lobe. A few older hemlocks and some younger ones stand adjacent the northwest edge of the North Newt area.

This area of 30 to 35 acres is drawn to include a buffer in order to maintain the current microclimate of the interior trees. It includes part of one of your Ecosystems of Concern areas, and much of the hemlock vine maple salal plant association shown in Fig. 9. The extent to which these hemlocks survive future global warming is uncertain, but they are healthy now. Such a reserve would provide an excellent opportunity to monitor the health and survival of both hemlock and redcedar over the coming decades. Again, site conditions may be an important factor affecting tree survival.

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.

Attn: Oregon State University College of Forestry
140 Peavy Forest Science Center
3100 SW Jefferson Way
Corvallis, OR 97331

RE: Draft 2025 MacDonald-Dunn Forest Plan

Dear Oregon State University College of Forestry,

Thank you for the opportunity to provide feedback on the Draft 2025 MacDonald-Dunn Forest Plan (draft plan). The Oregon Forest Industries Council (OFIC) is a statewide trade association representing large private forest landowners and wood products manufacturers in Oregon. OFIC’s core mission is to advocate on behalf of its members to maintain a positive, stable business operating environment for Oregon's forest products community that fosters long-term investments in healthy forests; to ensure a reliable timber supply from Oregon's public and private forestlands; and to promote stewardship and sustainable management of forestlands that protect environmental values and maintain productive uses on all forestlands. OFIC members’ businesses employ tens of thousands of Oregonians in Oregon’s forest sector, including many professional foresters, engineers and managers who are alumni of the College of Forestry (COF) at Oregon State University (OSU). Central to the mission of land grant universities are the ideals of education, scientific research and outreach, to promote economic development through practical application of knowledge. The OSU COF website lists its mission as an effort to “explore, evaluate, communicate and catalyze new possibilities in forestry and advance sustainable solutions to challenges facing society.” As a research forest owned and operated by the OSU COF, the MacDonald-Dunn Forest (Mac-Dunn) is a direct reflection of those combined missions. The forest was donated with the intention of being actively managed to provide a living laboratory to students and faculty to explore, experiment, study, learn and demonstrate the values, ideals and possibilities surrounding forestry. The COF has a key role in educating tomorrow’s professional forestry workforce, generating world class research that supports sustainable management of public and private lands and demonstrating to the lay public what sustainable, actively managed forests look like. With this in mind, and in the spirit of constructive feedback intended to improve the plan to better achieve these objectives and aspirations for the Mac- Dunn Forest, OFIC offers the following important critiques.

1. The draft plan must keep management as a goal of every acre of the Mac-Dunn, with a particular focus on harvest and reforestation. Manipulating forest composition and structure is achieved primarily through harvest and reforestation - which are the basic tools of silviculture. The goal of the forest should always be to use active management to achieve desirable outcomes. We are concerned that this plan more than doubles the number of acres that will be designated on a trajectory towards late-successional forest. There are ample living laboratories of late successional forests in Oregon already: the Elliot State Research Forest, the H.J. Andrews, and the hundreds of thousands of acres set aside by the U.S. Forest Service and Bureau of Land Management, to name a few. It’s implied within the draft plan that many of the acres that will be slated for this designation on the Mac-Dunn are currently of a younger age class and would benefit from activities to accelerate their trajectory towards a late- successional forest type. Furthermore, within the description of the Late-successional Forest Management Strategy, on page 63, the plan implies that areas where older forest already exists, no harvest will occur unless they are individual trees that must be removed for safety concerns. OFIC urges the COF to reconsider the plan to designate more acres going into this category, only to stagnate in perpetuity. Rather, the COF should use the abundant forests already available - as listed above - to conduct research on old forest reserves. On the acres already existing on the Mac Dunn in a late-successional state, it is our strongly held belief that the COF should utilize these areas to promote active management practices and challenge the dangerous and pervasive no-management paradigm that has led to catastrophic wildfires and insect infestations across thousands of acres of late successional reserves and wilderness areas on public lands throughout the western United States. Research has shown that harvest is an effective tool for increasing forest resiliency and preventing low-intensity fires from becoming stand-replacing events. If the COF desires to study and manage late successional forests, this should be done in combination with a research strategy that explores how to actively manage such forests to promote forest health and resiliency as well as economic opportunity. No trees in the Mac-Dunn should be precluded from harvest. Rather, the plan should give professional foresters the latitude to treat stands in accordance with sound forestry principles to promote the goals outlined above. Doing this will ensure that the COF stays on mission as a land-grant university.

2. Share more details on what went into the modeling, consider using a higher discount rate and explain the assumptions and constraints that were embedded in the modeling. In reviewing the modeling information that was provided, we found it odd that in some of the scenarios, despite more acres allocated for early harvest (“short rotations”), which would also presumably be acres that would require early harvest of older forests, the model was predicting a lower overall net revenue. Given that all discounted cash flow models prefer early returns on investments, this seems flawed. Subsequent conversations uncovered two potential reasons for this unexpected conclusion in the modeling: first, the use of a lower than industry standard discount rate (four percent), and second, a constraint on the model forcing it to harvest at an arbitrary average age that may be lower than optimal for the site classes associated with much of the Mac-Dunn Forest. The use of a four percent discount rate is inappropriate for the Mac Dunn. That discount rate is on the low end of what is used in state and federal discounted cash flow models. An industry standard of six to eight percent may be more appropriate. It was presented that four percent was used because that is the rate of return that the college could achieve with the best alternative investment. However, this is only half of the equation when picking an appropriate discount rate. We recommend that the college follow the standard practice of using the discount rate to account for other risks such as wildfire, insect outbreaks, disease or pathogens, market risks such as mill closures and log price fluctuation, regulatory risks, and social risks, all of which could lead the college to higher constraints and lower revenue production. When all these risks are considered, a strong case is made for a higher discount rate than the four percent that was used. Furthermore, it would behoove the COF to remove the distinction of “short rotation” altogether and instead let the model find the optimal harvest volume at the age it chooses, while using an appropriate discount rate and other relevant constraints. This is, in fact, how most of the industry does similar modeling - we are unaware of any landowner that artificially constrains their modeling efforts to harvest at certain average ages. Given the site classes associated with the Mac-Dunn, it is possible that a rotation closer to 50 to 60 years may be optimal. OFIC recommends re-modeling with a higher discount rate - closer to industry standard - without an artificial constraint for a particular age, thus allowing the model to find the optimal harvest rotation for the forest. This could be re-imagined as a “sustainable harvest strategy” and replace both the “short” and “long” rotation strategies currently listed. It would likely result in higher volume and revenue outputs, and more closely align with private land management, which would allow better opportunities for studies more relevant to the forest sector in Oregon.

3. Add language that clearly articulates the parameters around what constitutes an “appropriate” time or circumstance for pursuit of an alternative revenue stream for the Mac-Dunn. On page 58 of the draft plan, it states that “adaptive funding strategies will be pursued when appropriate.” Alternative revenue streams should be pursued only when they fit the mission, vision and purpose of the OSU COF as a land grant university, and the Mac- Dunn as an “actively and sustainably managed forest.” It would be inappropriate to adopt an alternative funding source that would constrain the COF’s ability to harvest or otherwise alter standard and accepted sustainable forestry practices. To do so would be off-mission and harm or completely dismantle the university’s ability to deliver on their land grant purpose to the sector and to the citizens of Oregon. This would be a devastating outcome, one that should be avoided by providing clearly articulated expectations for these potential alternative revenue streams up front in the plan itself.

4. Provide additional inventory data and projections. The draft plan is missing key data that is standard in many management plans. The plan is missing an estimate of current or projected timber volume by species, estimated volumes by land management objective over time, estimated growth across the forest, etc. We would like to see the planning horizon and planning periods presented in the model. These planning horizons should be at least two full rotations in length in order to capture how the proposed silvicultural prescriptions will change the forest over time as each stand is transitioned from current condition to the regenerated condition under a 2 LP harvest scheduling model. We would also like to see more detailed information regarding the standing live tree inventory, standing dead and periodic growth across the forest. Currently the draft plan provides sparse details, primarily on page 47, showing only the current average age classes and a three paragraph, broad description of site class, species composition and tree heights.

5. Provide additional information regarding targets and baselines for measuring the relative success of the draft plan. There was no baseline or minimum amount of revenue identified as necessary to pay for staff, maintenance, etc. Without this clear benchmark the forest is at risk of running a deficit. Furthermore, there is no clearly defined revenue goal. Without these factors, it is difficult to understand the benchmarks for success of this plan from a revenue perspective.

6. Certain statements in the draft plan should be removed or re-written. We request that the COF review the plan for language that should be written more clearly or more appropriately. Below are a couple of examples:

a. On page 58 the draft plan states that “the funding model for the research forests was created at a time when research forests nationwide functioned like industrial plantations.” This statement is incredibly broad and presumptuous and is not supported by tangible evidence. There are no references in this document to the history of other research forests across the nation, nor is there an explanation as to what is meant by the phrase “industrial plantations.” Surely it is not the conclusion of the COF that forests across all private land ownerships nationwide were historically managed in a homogeneous manner. This is a paragraph that should be re-written with clear language that removes bias and overly broad or false statements.

b. The use of the term “short rotation” throughout the document should be reconsidered. What is short? This is a term that betrays a universally-agreed-upon definition. Section 2 of these comments offers a helpful alternative to such a subjective, value-laden language.

OFIC values the symbiotic, collaborative relationship that has existed between Oregon’s forest sector and the COF at OSU. The land grant mission of the university is the foundation of that relationship, and as such, should always be reflected in the purpose and goals expressed in the management plan for the Mac Dunn Forest. OFIC appreciates the opportunity to offer these comments on behalf of our members for ways that this plan can be improved to better reflect and deliver on this broad mission and looks forward to continuing its long and fruitful relationship with the OSU COF.

Sincerely,
Seth A Barnes>br> OFIC Director of Forest Policy
OSU Alumni, FM, Class of 2002