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. 

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

Ecologically – 

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

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

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

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

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

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

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

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

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

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

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

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

When do we learn? 

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

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

Let me help you with some basics. 

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

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

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

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

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

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

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

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

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

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

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

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

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

Understand the core aspects upon which all benefits are derived.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Craig Patterson 

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

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.   

"I strongly disagree with the draft McDonald-Dunn Forest Management Plan. The forest management plan should not be built around the subjective opinions of College of Forestry administrators and faculty who have huge financial conflicts of interest in determining the future of the forest. The draft plan is extraordinarily disappointing, and the way in which public participation has been minimized and public input has been ignored is a disgrace to the university.

Despite a smoke screen of empty rhetoric and selective statistics, the draft McDonald-Dunn Forest Management Plan clearly disregards both the long-term ecological health and integrity of the forest, and the voices of the broader community. The plan appears to embody a 1950s man-over-nature mindset that has no place in modern forest stewardship.

The plan reflects what appear to be the two main priorities of the dean of the College of Forestry concerning the forest: To generate logging revenue and to cater to the interests of industry partners and key donors in the forest products sector. The dean's dismissive attitude toward the local community is sad and disheartening. As long as the dean continues to seemingly regard the forest as a private tree farm rather than accepting the reality that these are public lands held in public trust in perpetuity, this outdated extractive approach will not change.

This fundamentally flawed planning process and the resulting document are unsatisfactory. Both the forest and the public deserve much better."

"Thank you for the opportunity to review the draft of the plan. Please consider the following recommendations as constructive suggestions intended to support the continued refinement of the document. As a new faculty member, I acknowledge that some of these points may already have been addressed, but I hope they prove helpful. My comments are informed by my background in the field, particularly in optimization, which frames my perspective.
• Inclusion of Water as a Forest Value: It is not clear how water is accounted as a critical forest value. It was not explicitly included in the metrics developed to evaluate trade-offs across land allocation scenarios (Table 4). Clarifying this or incorporating water-related impacts and tradeoffs may strengthen the plan.
• Job Type Differentiation: In the job-related metrics, it would be beneficial to distinguish between permanent and temporary jobs, as each has distinct social implications and contributes differently to community.
• Monitoring and Sustainability Index: I recommend considering the development of a sustainability index for the entire McDonald-Dunn forest as part of the monitoring framework. This index could synthesize various desired impacts into a scorecard format, allowing for both disaggregated and aggregate analysis. Such a tool may also enhance communication with the public by presenting progress in a clear and accessible manner. Like the health of the patient, being the patient the landscape and forest. I can help with that if required.
• Woodstock Model: Would it be possible to review the Remsoft Woodstock model used in the analysis, particularly how the constraints were handled? This would allow for more detailed feedback and potentially support further refinement of the model's structure and assumptions."

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?

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.

To whom it may concern:

Please accept my comments on the draft McDonald-Dunn Forest Plan. Over the past thirty years as a watershed scientist, I have conducted research and participated in planning efforts for western Oregon forests. Thus, consistent with my training and experience, the following observations target the plan components most directly affecting riparian and aquatic ecosystems. I commend the inclusion of plan provisions, such as managing to increase the acreage in older forests, that are likely to benefit riparian and aquatic habitats. However, by relying on the minimum standard of compliance with the Oregon Forest Practices Act (OFPA) rules, the draft plan falls well short of its overall vision, mission, and goals and specifically regarding management of riparian areas as an Ecosystem of Concern. Additionally, as an essential forest product, water was not identified in Human Dimensions nor were the effects of forest management on water quality and quantity meaningfully considered.

The draft plan defaulting riparian protection to the OFPA rules for large forestland owners in western Oregon presents several issues. First, the “Purpose and Goals” of the OFPA water protection rules (629-635-0100(1)) for riparian areas states that “The leading use on private forestland is the growing and harvesting of trees, consistent with sound management of soil, air, water, fish and wildlife resources.” Unless “growing and harvesting of trees” rather than the broad spectrum of goals specified in the draft plan is the primary purpose of management, the OFPA water protection rules are unlikely to provide the desired level of stewardship for riparian and aquatic resources on McDonald-Dunn Forest.

As a state funded research forest, riparian and road management strategies consistent with those in either the draft Western Oregon State Forests Habitat Conservation Plan (HCP) or in the final Elliott State Research Forest HCP would be more supportable than rules intended for industrial forestlands. Both of those plans require more conservative management than under the OFPA rules. For example, the prescribed width for the no-harvest riparian management area on either side of a fish-bearing stream is 120 feet in the Western Oregon State Forests HCP, ranges from 100 to 200 feet in the Elliott State Research Forest HCP, and ranges from 100 to 110 feet under the OFPA rules. As another example, the no-harvest riparian management area under both of the HCPs extends the full length of every small non-fish-bearing perennial stream in recognition of the value of those streams as potential amphibian habitats. However, under the OFPA rules, small non-fish-bearing streams require a no-harvest riparian management area only when these are a direct tributary to a fish-bearing stream and only on the first 600 to 1,150 feet upstream of the junction with the fish-bearing stream. Both HCPs require that the widths of riparian management areas be measured based on horizontal distance, providing greater protection for streams in steeper areas. In contrast, the OFPA rules use slope distance. The second major concern is uncertainty around the durability of the current OFPA rules for private forest lands, which began taking effect in 2022. Senate Bill 1501, which modified ORS 527.610 to 527.770 to authorize development of the current rules, contained a “sunset clause.” It directs the newly adopted OFPA rules to remain in effect provided that “An incidental take permit related to an approved habitat conservation plan consistent with the Private Forest Accord Report dated February 2, 2022, and published by the State Forestry Department on February 7, 2022, is issued on or before December 31, 2027…” Despite confidence that an incidental take permit will be issued by the deadline, the draft McDonald-Dunn Forest Plan should acknowledge the uncertainty and specify contingencies. Uncertainty is heightened by federal budget and staffing cuts at NOAA and the USFWS, the two regulatory agencies responsible for issuing an incidental take permit under the Endangered Species Act. According to Oregon statute, failure to meet the deadline would cause reversion of the current OFPA rules to the pre-2022 rules, which were substantially weaker. For instance, under the pre-2022 rules, riparian management areas on either side of fish-bearing streams ranged from 50 to 100 feet with only a 20-foot no-harvest zone closest to the stream. If the intent is to have management direction for the McDonald-Dunn Forest similarly roll back to the pre-2022 rules, this should be disclosed and the effects analyzed. If not, then that should be clearly stated.

Post-disturbance management in riparian areas under the current OFPA rules is another topic of uncertainty. The Oregon Board of Forestry found that OAR 629-643-0300(3) for catastrophic events was likely to cause degradation. Thus, a rulemaking for riparian post-disturbance management is underway but has not yet been finalized.

The third major issue is that the draft plan offers no substantive scientific justification for applying the current OFPA rules, does not analyze the likely effects of the rules for meeting the articulated plan goals for fish and water resources, and presents no plan to monitor outcomes under the rules for aquatic organisms or water resources. The scientific justification is limited to a few brief sentences (p33-34), which inadequately/incorrectly assess the effectiveness of the current OFPA rules. One of these sentences states, “recent evidence has illustrated that adherence to Oregon’s Forest Practice Rules results in minimal changes in stream temperature (Bladon et al. 2016; Miralha et al. 2024)...” The first cited study was well designed, implemented, and interpreted by the authors regarding its limitations. However, those limitations are not mentioned in the draft plan, and the study examined the effects on stream temperature under the pre-2022 water protection rules at only three harvested sites. Field and modeling studies were not cited in the draft plan that had larger sample sizes and found greater site-level increases in stream temperature from harvest under the pre-2022 rules than did Bladon et al. (2016) (e.g., Groom et al. 2011; Groom et al. 2018). Similarly, studies with evidence of temperature increases downstream of units harvested under the pre-2022 rules were not cited (e.g. Davis et al. 2015; Bladon et al. 2018). The second cited study in the draft plan was conducted in northern California and did not directly examine the western-Oregon applicable OFPA water protection rules - either past or current. Although implementation of the current OFPA water protections rules has not been scientifically evaluated, the draft plan could have cited studies supporting the likely effectiveness of those rules and issues around which knowledge gaps exist.

Although some aspects of biodiversity and human dimensions are evaluated for the various scenarios and monitoring plans for those aspects were identified for the preferred scenario, the draft plan excluded aquatics other than habitat for amphibians. Under the section 2.5.2 Regulations, the draft plan fails to include the Clean Water Act. Accordingly, whether streams on or downstream of the planning area currently meet beneficial uses under the Act is not identified. No analysis of potential management effects on or monitoring of water quality and quantity in those streams is offered and other elements of fish habitat remain unaddressed.

Respectfully submitted,

Kelly M. Burnett

Kelly M. Burnett, Ph.D.
Watershed and Fisheries Consultant
Corvallis, OR 97333

Literature Cited

Bladon, K.D., N.A. Cook, J.T. Light, and C. Segura. 2016. A catchment-style assessment of stream temperature response to contemporary forest harvesting in the Oregon Coast Range. Forest Ecology and management 379: 153-164.

Bladon, K. D., C. Segura, N.A. Cook, S. Bywater‐Reyes, and M. Reiter. 2018. A multicatchment analysis of headwater and downstream temperature effects from contemporary forest harvesting. Hydrological Processes 32(2): 293-304.

Davis, L. J., M. Reiter, and J. D. Groom. 2016. Modelling temperature change downstream of forest harvest using Newton's law of cooling." Hydrological Processes 30(6): 959-971.

Groom, J. D., L. Dent, and L. J. Madsen. 2011. Stream temperature change detection for state and private forests in the Oregon Coast Range. Water Resources Research 47(1) .

Groom, J. D., L. J. Madsen, J. E. Jones, and J. N. Giovanini. 2018. Informing changes to riparian forestry rules with a Bayesian hierarchical model. Forest Ecology and Management 419: 17-30.

Miralha, L., C. Segura, and K.D. Bladon. 2024. Stream temperature responses to forest harvesting with different riparian buffer prescriptions in northern California, USA. Forest Ecology and Management 552: 121581.