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.

Thank you for the opportunity to comment on the draft McDonald-Dunn Forest Plan (or Plan). As you may know, Hampton Lumber is a fourth-generation, family-owned company that has been operating and headquartered in Oregon since 1942. Many Hampton family members, as well as employees, are Oregon State University (OSU) alumni, and the company has been a longtime supporter of the College of Forestry (or College). We are writing today to express our concerns over the direction of this draft Plan and what it means for the future of OSU’s research forests and students.  The management changes in the draft Plan appear to be a shift from an active, working forest with a variety of research opportunities to more passive management with a singular focus on older forest types with little active management. The proposal indicates a desire to balance environmental, societal, and economic pillars, but the reduction in timber harvest volume and increase in older stands puts the forest and the College on a misguided trajectory – similar to the plight of our federal forests.  The draft Plan proposes a 28 percent reduction in timber harvests from 6 MMBF to 4.3 MMBF, while at the same time more than doubles late-successional forest stands. The draft also calls for longer harvest rotations and fewer even-aged stands. This shift will not only hinder economic opportunities for the College, but it also succumbs to the mindset that active management and robust silvicultural practices are somehow not sustainable forestry.  We understand and are sympathetic to the pressure you face from public outcry from a vocal minority over their misunderstanding of what an active research forest should look like. However, OSU should use this as an opportunity to educate the misinformed rather than give in to their demands without considering the impacts on the College, students, and industry it supports.  We are passionate about our industry and want graduates from the College to be eager to join our collective workforce. We seek vigorous research and experiments that range from a variety of forest and management types. Unfortunately, this plan is not set up to achieve the outcomes we desire. We hope that you consider changes to the draft that are more reflective of the 2005 Forest Plan.  Please know that Hampton hasn’t purchased a timber sale from the McDonald Dunn in many years. We write principally out of concern for the management direction and cultural shift we fear this draft plan signals. As alumni and supporters of the university, we respectfully ask that you reconsider.   

Dr. Tom DeLuca
Dean of the College of Forestry, OSU
140 Peavy Forest Science Center
3100 SW Jefferson Way
Corvallis, Or 97331

In Response to: Draft 2025 McDonald-Dunn Forest Plan

Dear Dean DeLuca,

Introduction

Thank you for the opportunity to comment on the Draft Forest Plan for the McDonald-Dunn Research Forest. The Oregon Society of American Foresters (OSAF) has nearly 700 members, making it the largest state affiliate of the national Society of American Foresters (SAF). Our mission is to support and represent the forestry profession by advancing the science, education, technology, and practice of forestry. OSAF members work throughout the state in a variety of organizations, including local, state and federal agencies; higher education institutions; Partnerships & Collaborative, and the private sector, including industrial and non-industrial forest landowners. The objectives of the Society are:

1. To advance the science, technology, education, and practice of professional forestry;

2. To enhance the competency of its members;

3. To establish professional excellence;

4. To use the knowledge, skills, and conservation ethic of the profession to ensure the continued health and use of forest ecosystems and the present and future availability of forest resources to benefit society; and to provide an opportunity for better communication among the individual members, their regional representatives and the Society.

Our mission and these objectives guide our comments on the draft plan. We strongly support the College of Forestry’s stated intent to provide opportunities for research, teaching, and outreach while maintaining sustainable forest management practices.

Overview

We recognize and appreciate the extensive planning process that engaged faculty, stakeholders, and Tribal partners (p. 6–9). The effort to incorporate diverse perspectives, strengthen relationships with Tribal Nations, and emphasize resilience and adaptability is commendable. We note that the planning process occurred over a period of 2.5 years and involved two key committees, the Faculty Planning Committee and the Stakeholder Advisory Committee, the latter comprised of an array of key outside stakeholders. In addition, there was a robust process for gathering input and comments from OSU faculty & staff and the interested public through public input sessions and providing an open and on- going opportunity for the public to provide comments via a web-link.

We’ve reviewed the mission, vision, and goal statements, which not only covers the McDonald-Dunn Forest, but all the Research Forests managed by the College of Forestry. We agree with these and note that the 10 goal statements are appropriate and wide-ranging and cover the most important aspects of an actively and sustainably managed research forest.

The McDonald-Dunn Research Forest is unique in that the research paradigm focuses on evaluating tradeoffs of ecosystem services in sustainably managed forests. There are often questions from forest managers, forest owners, and the public about managed forests. Developing a scientific basis for evaluating tradeoffs can assist forest managers in balancing forest management objectives. The environmental, ecological, and social aspects of sustainability have been incorporated in the overall approach. It is important for the public to see a sustainably managed forest in their backyard. However, we have concerns that the current draft plan, as written, will reduce opportunities for applied forestry research, limit the development of operational and workforce skills, and undermine the financial sustainability of the McDonald-Dunn Forest.

Commitment to Active Management and Research

The McDonald-Dunn Research Forest must remain a premier site for demonstrating active, sustainable forest management. The plan (p. 7) aspires to showcase a “model for actively and sustainably managed forest systems,” yet the proposed land allocation and harvest reductions suggest a transition in focus with less emphasis on management and research on production forestry along with its association silvicultural systems, logging methods, and assessment of cost-effective practices. Reducing annual harvest from 6 MMBF (2005 plan) to 4.3 MMBF (p. 67) and cutting the proportion of short-rotation even-aged management from 26 percent to 10 percent (p. 68, Fig. 22) will significantly reduce research and teaching opportunities in the very practices dominating Oregon’s productive forestlands. This shift is inconsistent with OSAF’s position supporting active management to achieve and maintain healthy forests and ensure workforce readiness. Applying this alternative management emphasis across the forest means less applied research on industry standard harvest prescriptions and all of the practical engineering, logging systems, and innovative approaches that go along with it. However, we are hopeful the McDonald-Dunn Research Forest will continue showcasing how active and intensive management is not incongruent with wildfire resilience, climate resilience, and overall landscape resilience.

Wildlife habitat has been raised as a significant concern by local stakeholders. A wide range of forest age classes provides the structural diversity needed to support diverse species and “keep common species common,” as noted by wildlife professionals. Active management through a mix of even-aged and multi-aged strategies creates early seral conditions, mid-rotation stands, and older forests, ensuring habitat for species that depend on different stages of forest succession. Reducing short- rotation areas risks losing these early-seral habitats that are critical for many species, including pollinators, ungulates, and songbirds.

The Research Forest exists not to mimic preservationist approaches such as “proforestation” but to lead in demonstrating solutions for the future desired by the broader forest sector. Proforestation1, which seeks to ban timber harvesting and active management on public lands, is not supported by science as a long-term carbon or climate strategy. Sustainable management offers far greater benefits by reducing disturbance risks, storing carbon in durable wood products, and maintaining diverse wildlife habitats. Inaction does not protect forests from wildfire, insects, or disease; it increases their vulnerability. Thankfully the Research Forest stands as a beacon modeling adaptive, active strategies rather than passive management. Where lighter touch management direction is applied, research should be applied to monitor the real benefits and costs that flow for those decisions on carbon within forests and harvested woods products pools, on wildfire risk and fuels profiles, on jobs and socioeconomics, on milling and logging infrastructure, and on tree to tree competition and vigor among many other factors that must be weighed by foresters, biologists, planners, the public, policymakers, and even the justice system in determining what treatment decisions directly and indirectly affect.

Although we feel the reduction of even-aged short-rotation may produce fewer opportunities to research common forest practices across Oregon, we appreciate the overall thought and balance across age classes and seral-classes in the McDonald-Dunn Research Forest.

Economic Sustainability and Revenue Expectations

Economic self-sufficiency has long been a guiding principle of the Research Forests. The plan eliminates the $500,000 annual contribution target for the College of Forestry (noted in previous planning discussions but absent from this draft). Table G3 (p. 154) previously included jobs as an outcome metric, which has also been removed. Without clear financial targets, accountability for sustaining operations and by extension, research and teaching, remains uncertain.

We urge OSU to clarify:

• How will reduced harvest levels affect the ability to cover operating costs, fund monitoring (p. 99), and maintain staff?

• What alternative revenue sources are secured (p. 58), and how will these be implemented without compromising core research and management objectives?

OSAF supports commercial timber harvest as an appropriate and essential tool on public and research forests when carefully planned by professionals2.

Allocation of Management Strategies

The new allocation substantially increases acres dedicated to late-successional forest reserves (Fig. 23, p. 69) and long-rotation management while reducing even-aged short-rotation stands by more than half (Fig. 22, p. 68). While diversity of strategies is important, this allocation appears to prioritize less intensive management approaches at the expense of active experimentation and applied research on intensively managed systems3.

Key concerns:

• Even-Aged Short-Rotation – Rotations 35-45 Years (10%): There is a reduction from 26% in the previous Forest Management Plan. This drastic reduction sends a signal that short-rotation forestry is less important, despite its dominance in Oregon’s private sector. There continues to be a significant need to research tradeoffs, operational efficiencies, and strategies associated with short-rotation forestry.

•Even-Aged Long-Rotation – Rotations 60-90 Years (30%): Benefits include carbon capture & storage, older forest structure for wildlife, aesthetics, and the production of high- quality forest products. However, rotations up to 90 years create opportunity costs and potential public controversy over harvesting older stands.

• Multi-Aged/Multi-Species (23%): There are still many unknowns about this form of management, so in many ways applying them in scientifically sound fashion will allow the College to provide important information on aspects of their applications, forest growth, development of various ages classes, economics including logging costs, and forest aesthetics. These treatments in many ways are hard to do and will require frequent re-entry to ensure they achieve intended ecological, economic, and social objectives.

• Late Successional Forests (10%): We are supportive of the Late Successional Forest strategy as it leaves open some level of management (very light touch) to mimic disturbances that shaped their development. The McDonald-Dunn occupies the dry end of the Douglas-fir range and historically was influenced by period disturbances that maintained a more open condition.

• Ecosystems of Concern (10%): Focused on important restoration and maintenance of oak savanna and woodlands, prairie and meadows, and riparian habitats. The restoration emphasis is an increasing aspect of forest management in efforts to enhance and maintain important habitats in Oregon on private, state, federal, tribal, county and public land trust lands. There is an increasing need for students in the College of Forestry to be aware of these activities as they are potential areas of application and employment when they enter the forestry workforce.

• Teaching and Long-Term Research (17%): This is appropriate given proximity to Oregon State University for student hands-on learning and for conducting research although this specific purpose should overlay the entire forest. Given the five management strategies and the percentages applied across the 11,500 acres of the McDonald-Dunn Forest, OSAF believes the Plan provides a variety of forest age classes. This will be important for creating conditions for future research to evaluate wildlife response to each of the management strategies. OSAF supports a targeted mix of younger and older forests across the landscape.

Impact on Education, Workforce Development, and Donor Intent

Reducing harvest and management intensity directly affects opportunities for students to experience real-world forestry operations. Future professionals need hands-on exposure to harvesting systems, silvicultural prescriptions, and market realities. This plan risks creating a generation of graduates unfamiliar with active management, which is an existential concern for Oregon’s forest sector workforce.

Donors and alumni expect the Research Forest to embody OSU’s land-grant mission: advancing practical forestry. Limiting industry standard forestry research may undermine the confidence of stakeholders who support the college financially and professionally.

Monitoring and Adaptive Management

The plan calls for robust monitoring (p. 99–109) but staffing and funding remain unclear. Having a comprehensive monitoring plan will allow the College to modify management strategies as appropriate given disturbance regimes, application of new or innovative management techniques, and economic realities.

The monitoring plan also holds the College of Forestry and forest managers accountable to the mission, vision, and goals of the forests. However, we are concerned that existing staff (6.25 FTE) are at full capacity and their ability to fulfill the multitude of monitoring plan tasks will be extremely difficult. Given the lower harvest level and revenue, it is unlikely additional staff can be hired to fulfill this important aspect of the plan. Transparency and feasibility in monitoring are critical to maintain credibility.

Summary of Recommendations

1. Reaffirm the Research Forest’s role as a working forest dedicated to applied research on active management.

2. Maintain a meaningful allocation for short-rotation forestry and operational studies to reflect real-world practices and support workforce readiness.

3. Reinstate clear revenue and accountability targets to ensure financial sustainability.

4. Explicitly address how reduced harvest and expanded reserves align with the mission to “demonstrate contemporary and innovative aspects of an active and sustainably managed forest” (p. 13).

5. Ensure that monitoring and adaptive management commitments are supported with adequate funding and staffing.

Conclusion

The mission of Research Forests is threefold: ”to create opportunities for education, research, and outreach to address the economic, social, and environmental values of current and future generations of Oregonians and beyond; to demonstrate how an actively and sustainably managed forest fosters economic prosperity, biodiversity conservation, and resilience amidst disturbances and global change; to support social and cultural values of forests, enhancing the wellbeing of local communities, Tribal communities, and society.” We believe the McDonald-Dunn Forest Plan aims to fulfill this mission and we look forward to seeing the forest management plan put into action in the coming years.

Thank you for the opportunity to provide comments on the draft McDonald-Dunn Forest Plan.

Sincerely,

Amanda Sullivan-Astor, CF
2025 OSAF State Chair

I wrote the attached essay (Seeds of Change in the College of Forestry) six years ago, in the wake of OSU's old-growth cutting debacle. It is in your interest to not only read it, but open your minds to the history and lessons I've presented. As custodians of public trust (and distrust), your choices will have a profound impact on whether the long history of self-serving behavior and industry collusion continues, or whether seeds of change are finally allowed to grow. 

As you read it, I would encourage you to ask yourselves the following questions:

What has changed in the past six years and what has remained the same (or gotten worse)? (Hint: public trust in OSU has definitely not stayed the same...)
Which of the ten steps I've laid out at the end have been taken and which ones remain "opportunities for positive change"?
What are the systemic forces that prevent positive change from occurring within the College of Forestry and the OSU administration?
What role do you individually and collectively play in perpetuating the problems I've outlined?
What role could you individually or collectively play in solving these problems to better serve the public interest (and allow future generations to not only survive, but thrive)?
If you all are unwilling or unable to solve these problems, which higher power(s) might intercede and force change upon you?
How do your actions build or undermine public trust in the university?

Comments from Steve Cook on the proposed management plan for the McDonald-Dunn “Research” Forest.

Nothing says “It’s our forest, we’ll do what we want, and it’s none of your business,” like changing clearcut size from five acres to eighty acres. It’s simply a poke in the eye with a sharp stick to those who believe in the intrinsic value of public forests.

Others are commenting on the shortcomings of the plan in general, covering ecosystems, climate change, and carbon sequestration. I am going to comment very specifically on several components. Invasive Species:

The coverage in the plan is totally inadequate. Suggesting that false brome is so widespread that it is impossible to do anything about it just means that this invasive was ignored until it was widespread. Next, we’ll hear “oh, well, teasel is so widespread that we can’t do anything about it.” And all the other invasives; shiny leaf marigold; reed canary grass; various thistles; cheat grass; knapweed—“oh, well, ____________ is so widespread that we can’t do anything about it.” This is unacceptable.

Appendix J “Invasive species”

P. 81 Prevention

• To reduce the introduction of non-native plant seed, logging and construction equipment are washed and inspected prior to entering the McDonald-Dunn Forest for contract work. The following equipment is exempt: rock trucks, log trucks, and contractor vehicles that do not leave roads or treated roadsides.

• Forest roads and roadsides are treated with herbicide on an as-needed basis to limit the propagation of invasive plants, generally every 1-2 years.

Invasives are spread by vehicles traveling the road system, as invasives are not effectively controlled along major roads. A specific example is Oak Creek Road 600, which sees extensive vehicle traffic. Currently in mid-July thistles, teasel, reed canary grass and many others are overhanging the road where vehicles gather seeds and spread them. The only herbicide plan that is consistently followed is spraying of recent clearcut areas. Having lived adjacent to the McDonald Forest Oak Creek access for ten years, I’ve watched ineffective spraying of weeds along the 600 road. Spraying roadside weeds in fall, as has been done in the past is totally ineffective and just highlights the lack of knowledge of herbicides demonstrated by forest managers.

There is a nice “Herbaceous Invasive Weeds” demo site immediately west of the Oak Creek entrance parking area. The CoF should put up a sign noting how it actually encourages the spread of invasives. Oak Creek parking area is a great place for an invasive weed interpretive sign indicating how CoF is encouraging invasives by its management.

Unregulated mountain bike travel, especially on “unauthorized trails” spread invasives deep into the forest. There is a derelict washing station at Oak Creek parking area, so cyclists could wash their bikes. But no longer. The plan suggests that at some future point a recreation plan should be written is simply a joke. There is an entire Forest Recreation Department in the CoF, but one searches in vain to find any involvement of this department in management of the thousands of visitors to the forest. And they all spread invasives.

The McDonald Forest Arboretum:

Everyone in the College of Forestry from the Dean down to the most recent summer hire should be embarrassed at the condition of the Arboretum. I’ve visited arboretums all over the world, and invariably they are showcases of local and exotic vegetation, well maintained areas. The entire discussion of invasive species is simply a joke when viewing the area of the arboretum where invasive English ivy is climbing trees right in the parking area, no control attempts visible. And even worse is the spread of English holly in the same area. This species, which crowds out other woody vegetation is spreading in a mat north of the arboretum as well as other areas. A recently logged area near Kronmiller Lake has nearly all vegetation removed except the English holly trees, which seem to have been carefully retained. The only conclusion that can be drawn is that the silviculturalists that demand hegemony over the forest simply don’t care. Other commenters speak of complete ecosystems, but it is impossible to have a complete ecosystem without controlling invasives.

I’ve found no discussion in the plan of invasive herbaceous plants—thistles, shiny leaf geranium, reed canary grass and a zillion others. They impact woody vegetation establishment. It is impossible to manage woody shrubs while ignoring invasive herbaceous plants.

I’ve not been able to find in the plan interactions of various activities/uses of the forest:

Herbicides and stream quality monitoring

Mountain bike use and invasive species spread

When a public forest is managed solely by silviculturalists, the management emphasis is going to be on growing wood fiber. Issues and other activities—recreation, indigenous species, invasive species, water quality, value of dead and down woody vegetation all are secondary and appear to be ignored most of the time. A quick online query indicates that there are 209 teaching and research faculty in the OSU CoF. Yet less than twenty are involved in the management of the OSU Research Forests. Why? Where are you guys? Do you not feel that this forest is a public resource deserving of your respect and involvement? I’m not sure which

Land Use Zoning

2.7 “Visitor Use” p. 42

2.5.1 Land Use Zoning.

There is an omission in this paragraph. Trails are “infrastructure.”

Other uses within a forest conservation zone are considered ‘conditional’, meaning that some activities may be allowed, but only under certain predetermined conditions. Both Goal 4 and Benton County Chapter 60 specify outdoor recreation opportunities as important and protected resources within Forest Conservation Zones, and recreation is fully embraced by research forest staff. However, the development of infrastructure (e.g., parking, toilets) to support these recreation opportunities is considered a conditional use which is potentially inconsistent with the overarching land classification (forest conservation) but deemed beneficial or necessary in specific situations or locales.

The above paragraph clearly misrepresents the Benton County Conditional Use Permit required for recreation on land zoned as “Forest Conservation.” It appears from the text that the county embraces recreation on “Forest Conservation” zoned land. This is simply not true. A Conditional Use Permit was required and signed by both OSU and Benton County in 2017. And the plan glosses over what is included in infrastructure. Trails are infrastructure. New trails are prohibited by the 2017 Conditional Use Permit. Indigenous animals and spreading recreational use, especially “unauthorized” mountain bike use in the unroaded areas.

In fact, the plan notes that the OSU CoF doesn’t even know what indigenous animals exist in the forest, let alone if they are being impacted by recreational use. Logging a site has a huge immediate impact upon many animal species, but they simply move aside while the logging activity occurs. Recreational usage is insidious, always present along usage corridors and frequently has a larger impact than the intensive short-term logging activities.

The plan states on page 86: “Managers can minimize these potential negative impacts by naturalizing unauthorized trails where feasible, building trails and roads to meet sustainable standards, and leveraging education and messaging to help positively influence compliance on trails.”

“Naturalizing unauthorized trails?” What the hell does that mean? If it means closing them down, then this is simply a lie. The CoF as well as other land managers know full well that it is impossible without serious on the ground policing complete with fines to stop the construction of unauthorized trails. And legitimizing “unauthorized” trails as has been so often the case in the McDonald “Research” Forest demonstrates an ignorance of recreation planning. This does nothing to reduce the impacts to vegetation, wildlife, invasive species spread by usage of these trails. The lack of a trails plan is a severe shortcoming of this plan. Allowing mountain bikers to cut in “unauthorized” trails with no negative repercussions and then legitimizing those same trails just encourages the mountain bike community to cut in more “unauthorized” trails, which CoF will legitimize, ad infinitum.

Page 87:

Emergent technologies: There are significant management challenges associated with changing outdoor recreation technologies and emergent visitor uses. Electric-powered devices such as e- bikes, hoverboards and e-unicycles are among the new types of recreational uses on forest trails, although they are prohibited in the McDonald-Dunn Forest. These technologies and vehicles are increasingly impacting how visitor use is managed in non-motorized nature-based environments, and their potential for social and environmental impacts continues to be explored and studied. As long as users know that there is no physical presence of CoF personnel in the McDonald-Dunn Research Forest or any enforcement of rules, there is no point of even discussion things like “Emergent technologies” E-bikes, especially run rampant in the forest, unimpeded by the tiny “No E-bike” signs posted. To adequately manage recreational activities requires a significant presence on the ground of CoF personnel. As long as CoF does not allocate resources for this, all discussion is simply that—discussion.

Page 89:

Guidelines for Visitor Use: Following the initiation of the 2025 McDonald-Dunn Forest management plan, a separate McDonald-Dunn Forest visitor use management planning (VUMP) process will commence. The new VUMP will expand on these guidelines and provide a more detailed outline of policies and practices related to trail development, improving access, recreation research and monitoring, hunting, education and interpretation, volunteers, and other visitor programming on the research forests. There seems to be a misconception among the authors of this plan. No further infrastructure development, including trail development is allowed under the 2017 Conditional Use Permit from Benton County without a further conditional use permit being approved by Benton County.

3.7.2 Wildland/Urban Interface

Page 90:

Intrusion:

Intrusion into the forest from the WUI expands two management issues: potential encroachment of non-native plants onto forest property and the creation of unauthorized trails from adjacent private lands into the forest.

This is simply self-serving nonsense. See that first isolated dot along the lower left (SW) border on Figure 24? That’s my house. Invasive herbaceous species, at least fifteen that I, as a non-botanist, can identify, have spread onto our property from the McDonald Forest like a tsunami wave. I’ve beaten invasives back for ten years. The intrusion is from the McDonald Forest onto my private land, not the other way around. Others adjacent property owners have reported the same problem to me.

The authors also seem to have not included fire as an “intrusion.”

Again, from the McDonald Forest onto my private land.

CoF personnel only seem to see woody vegetation—trees and shrubs in relation to WUI fires. But ask any WUI professional (For elucidation, I have a Ph.D. related to WUI fire issues) and they will tell that weeds and grasses carry fire faster and spread embers farther and more quickly than woody vegetation. For ten years I’ve protested the fire hazard resulting from uncontrolled invasive weeds that grow annually to five feet tall between my property and the Oak Creek parking area, which on a typical day sees a hundred vehicles. Just one loser among these hundreds of people; just one flipped cigarette butt; just one kid playing with matches; just one hot exhaust pipe touching the weeks growing hard against the asphalt; just one loser and poof, these weeds carry flames to my property. Intrusion from OSU land onto adjacent private property truly is a problem.

As mentioned in section 3.6.2, a recent fire risk analysis indicates higher burn probabilities immediately outside rather than inside the McDonald-Dunn Forest (Scruggs 2024)

I guess Scruggs must not have investigated the situation at the Oak Creek entrance to the McDonald Research Forest. In fact, when I requested that CoF personnel come review the wildfire hazard presented by the weeds behind my barn, DeLuca told me that CoF had its own professionals and refused to send anyone to review the situation. If this is the typical interactions between CoF and adjacent property owners, we are all in trouble.

Page 94:

Example 3: Team Dirt - The OSU research forests partner with the Corvallis chapter of Team Dirt, a Chapter of the International Mountain Bike Association (IMBA). Team Dirt is a nonprofit, volunteer organization that works in partnership with the forest and other local agencies to build and maintain trails throughout the Willamette Valley. The organization is dedicated to the stewardship of sustainable, multiple-use, and purpose-built trails, to preserve access for mountain bikers through advocacy and education, and to promote responsible trail use. Team Dirt works closely with McDonald-Dunn Forest staff to design, build, and maintain sustainable, primary- use and multi-use trails that better meet the needs of the mountain bike community. The radical fringe of mountain bikers hack in “unauthorized” trails and then Team Dirt comes to the CoF to volunteer to upgrade the unauthorized trail into an established trail. CoF then agrees and a new trail is constructed where none was proposed by CoF due to a lack of a recreation plan. Thus, no consideration for the impact upon shy wildlife, since CoF has no recreation plan, let alone a plan for native wildlife, for which it has virtually no information. Currently (June 2025) Team Dirt is building a new trail in the Oak Creek drainage. CoF is allowing this construction, even though the 2017 Conditional Use Permit prohibits new trail construction. Unregulated mountain bike activity has resulted in the spread of invasives and negative impacts on wildlife and water quality.

Page 96:

Strategy 4: Invest in new signage at key areas – specifically Peavy Arboretum – to better describe the history of Kalapuyan Peoples on this land, the mission and goals of the forest, as well as the role active management has played in creating the forest conditions the community has come to love.

Have any of the authors of this proposed plan actually visited the Peavy Arboretum? Old Peavy must be flopping over in his grave at the condition of the arboretum. It is a shambles. An offense to the title “Arboretum.” It is mostly a mess of invasive species, most obviously English ivy and English holly, but including many others. If this area demonstrates the attitude of the OSU CoF towards its stewardship of the public land under its management, us Oregonians who own this land as well as all the flora and fauna that call it home are all in trouble. I’m skeptical that a Kalapuyan transported ahead two hundred years would be pleased at this disgrace to the title “arboretum.” “Please don’t put up signs with my name on it,” that Kalapuyan would plead, “This mess is nothing that I recognize.”

I’ll complete my comments with a note about OSU and indigenous people. The plan contains considerable verbiage about indigenous people this and indigenous people that, but there is, in reality, only one true documented connection between OSU and the indigenous people of Oregon. That is the Morrill Act. The plan glosses over this so quickly that the typical reader will miss it. But here are the facts (and these facts are readily obtainable, all the way down to exact parcel numbers). Under the Morrill Act, OSU received indigenous land valued at $20 million, expropriated from indigenous people by the Federal government. Twenty Million Dollars! This is where the “land” in “Land Grant” came from. I suspect that many others are like me; I previously thought the idea of “Land Grant Universities” was a generous action by the Federal government to encourage educational activity related to our land, when in fact, it was a disgraceful, even disgusting action, essentially stealing indigenous land. OSU should be careful proudly calling itself a “Land Grant University.”

Writing in this plan that OSU will allow indigenous people to collect plants and such must be an insult to them. A pittance. Why not do something meaningful? Why not set aside a significant portion of the McDonald “Research” Forest as a reserve honoring indigenous people? The Oak Creek Drainage, for example would be easily definable. This drainage contains much of the older forest in the McDonald “Research” Forest. A Kalapuyan transported ahead two hundred years might actually recognize some of it. There could be an interpretive center located in one of the unused buildings at the parking area. When I suggested this to DeLuca several years ago, he had two possible responses: 1) “This is an idea worth discussing further, including with the tribes; or 2) “Cook didn’t get input from the tribes before suggesting this, so we can ignore him.” DeLuca, of course, chose the second response. Does this reflect the true CoF attitude towards indigenous people? Why not do something truly meaningful, not only to recognize the existence of Kalapuyans in this area, but also as a gesture to the Oregonians that believe some of the forest should be exempt from logging.