"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tree farm rather than accepting the reality that these are public lands held in public trust in perpetuity, this outdated extractive approach will not change.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."
Matthew Betts
07/18/2025
I had an enjoyable few hours (late) last night going through the plan. As I mention in my response, this has been an epic effort and there is much to be pleased with. Still, it would be great to see some fairly major improvements if this is to truly be a world-class plan that I can satisfactorily defend when challenged (I often am). What are your plans for handling comments and incorporating into the plan?
Comments on McDonald-Dunn Management Plan, as well as external critiques of the plan
July 17
Matt Betts, Professor, College of Forestry, Oregon State University
McDonald-Dunn Forest Management Plan
Overall, I appreciate the massive effort the team has undertaken to produce this plan and engage with the public. The main components are in place for a good management plan. I appreciate the balance between wood, revenue and other objectives that you’ve attempted to balance. Nevertheless, I think there are several elements that could be substantially improved to make this a world-class forest management plan that I’d be proud to discuss with the public, my colleagues and friends. I’ve described both major and minor points below. The major ones are: (#1) the need for more rigorous monitoring, (#3) how will you use the responses (like this one) in making adjustments to the plan? (#5) formalized flexibility within “management strategies” to allow adaptive management and explore alternative silvicultural options (including testing “ecological forestry”), (#8) additional recruitment of old growth forest, (#14) full transparency when it comes to wood yields, AAC projections, projected habitat change, habitat relationships used in the linear programming model. These should be basic elements of any forest management plan.
I have also included my response to some widely circulating critiques of the plan (below). I did not look at these before developing my own review below.
1. Monitoring. Monitoring is a key component of forest management and biodiversity conservation in that it enables “adaptive management” (the capacity to learn whether forest management strategies are working, and adjust accordingly if they are not). Although monitoring is mentioned in the plan (to be conducted by “consultants” and via “participatory science”) there are no details on sampling intensity, sampling design or spatial extent. As such, it is difficult to evaluate whether adaptive management will be possible at all. A next step needs to be the development of a formal monitoring plan. Ideally, this would not be conducted by consultants but could be included in the OSU Forest Curriculum and /or OSU research labs are given the opportunity to develop sampling designs. Monitoring should be considered a key component of the overall plan and should be paid for by harvest revenues. It is remarkable (looking at Table 2) that there are very few (any?) forest-wide monitoring efforts, but only very study specific, spatially restricted research. No end dates are provided in Table 2 so it is impossible to determine the length of past/current studies.
2. Perhaps semantics: I’m surprised that one of the goals does not include biodiversity conservation (mentioned in the Mission, but not in specific goals)
3. Response to public input. Figure 1 shows the process of plan development but gives no indication of how public comment will be incorporated in to plan revisions. The next step is simply “Draft to dean and forest exec committee”. Will revisions be made following public comment?
4. Historical forest composition and structure. I suspect that Fig. 8 greatly oversimplifies the historical distributions of “forest”, “oak savannah” and “prairie”. It would be a useful and interesting exercise to do some dendro work to determine the distributions of large stumps, and date them to determine what this historical range of variation might have been. This is particularly important given the stated priority of restoration. An additional test would be to look at the logging history of the forest to estimate how many board feet (and of what species) have been harvested over time. Under the hypothesis that the land was primarily oaks and that Douglas fir colonization was very recent, most harvest in early years should presumably have been oak.
5. Categorical management strategies. I am curious about why five categories of “management strategies” are being presented rather than offering the opportunity to examine gradients among these strategies to test how best to balance stand-level yield with other important outcomes like climate adaptability, biodiversity and public acceptance. Binning management into these categories runs the risk of severely limiting creativity when it comes to silvicultural approaches. Since this is a research forest, there should be a formal plan on how variation within these categories plays out in terms of yields, biodiversity, carbon, microclimate etc.
(a) Why, for instance, does the short-rotation strategy only aim for 6% cover of hardwood trees rather than deliberately exploring variation in this amount to see if yield is compromised?
(b) Why adhere only to the minimum Oregon Forest Practices of 2 trees & snags/acre rather than examining a range of retention, even in this short-rotation strategy?
(c) Why not conduct formal research on various approaches to controlling competing vegetation rather than doing-business-as-usual herbicide application? What are the economic and wood costs of different approaches to controlling competing vegetation?
(d) Why not test the effects of varying degrees of retention in the long-rotation harvest stands (on yields, wildlife habitat, carbon etc.)? Is there a “sweet spot” between two trees per hectare and multi-aged silviculture that could provide habitat/carbon and still generate revenue?
6. Testing Ecological Forestry. Relating to (d) above, I would like to have seen a higher proportion of management and research focused on ecological forestry approaches. Given that so little is known about yields from these methods, wildlife responses etc., along with poor public opinion about management of the McDonald-Dunn, it seems prudent to do more experimentation on various non-traditional approaches to management, even if it ends up coming at some cost to yields (by the way, which we can’t even quantify because so little has been done along these lines).
7. Forest Fragmentation. To what extent will attention be paid to limiting forest fragmentation effects (enhancing connectivity, reducing edge etc.). Looking at the map in Fig. 22 it does look as though attempts have been made to put multi-aged treatments beside old-forest (which is good from a limiting edge perspective). Was this ever quantified formally? What will be the timing of spatial layout to minimize fragmentation effects?
8. Old-growth recruitment: I don’t see the term “stand establishment” as being compatible with multi-aged management. When is the stand established given that there will be no stand-initiating disturbance? Why is the oldest age of trees in the multi-aged stands 120? Why not let some forest age past that? It is likely the case that the historical range of variation in this forest did tend toward oak woodland, but clearly some significant patches of old growth exist (and have been cut quite extensively in the past). Given that old growth is in such short supply in the Coast Range as a whole (see Spies et al. 2007 – Ecol Apps), and that old growth has microclimate buffering effects (Frey et al. 2016 – Science Advances, Kim et al. 2022 – Global Change Biology) it makes sense to plan for increasing this development stage over time in the McDonald-Dunn.
9. Fire as a restoration tool in old growth. I would like to see the evidence that fire was a regular occurrence in existing old-growth stands. Is this published? Also, is there evidence that reductions in “surface fuel loading” reduces fire risk/severity on the west side? My understanding is that that practice is highly controversial. Dead wood in the understory and multi-canopy stands are likely to be the mechanisms behind old-growth microclimate buffering (Frey et al. 2016 Science Advances). Removing these materials/trees could therefore increase temperatures in the understory, elevate VPD and enhance fire risk and spread.
10. Forest inventory and yields. How reliable are the inventories and yields used to build the linear programming model? These models are clearly highly sensitive to parameterizations. For instance, to my knowledge, yields for multi-aged forest management are non-existent. From where did you generate yields for short and long- rotation management? Importantly, how will you determine whether or not various treatments are responding (in terms of yield) following harvest? (How frequently and at what sampling intensity will post-harvest inventories be conducted; I see there is some mention of this later in the plan, but details are lacking). The plan should include (at least in the appendix): (a) yield curves, (b) inventory data, (c) species habitat relationships, (d) trajectories of habitat, yield, and growing stock over time.
11. I appreciate the use of coarse and fine-filter approaches. For the indicator species, was an effort made to (a) estimate their habitat requirements, (b) model future habitat for these species over time? These should also be reported in the plan for full transparency. Again, what rigorous long-term monitoring will be conducted to test whether projections are indeed correct?
12. Hardwoods. For the 6% hardwood threshold that you cite from Ellis and Betts (2012) this is for the abundance of all birds. A more conservative threshold from the same paper is ~16% (for leaf-gleaning birds that are your indicator species). However, an alternative explanation is just “the more hardwoods the better”: “Quantification of a threshold at 15.89% (SE = 5.71) cover for all leaf gleaners was ambiguous, with slightly greater support for the linear model”. I do think the 6% threshold is incautious. I appreciate that you have the target at 10% for long-rotation forestry, but I suggest that even this should be higher.
13. Dead wood conservation. After quite a nice review on the importance of dead wood, the plan then goes on to state that the bare forest practices minimums will be used in various harvests. If the objective is to demonstrate sound forestry, these levels of downed wood and snags should be increased. Again, adaptive management should be used to hone the targets that are initially established.
14. Transparent projections about future forest conditions. I’ve mentioned this above, but it is important to emphasize that forest management plans should show projections for all of the elements considered in those plans under various scenarios (I thought that a consulting company did these for you?) Included in those projections should be estimates of uncertainty. Where are the projections for annual cut over the next 100 years? Wildlife habitat? Growing stock? I think some of the existing critiques of the plan might have less impact if it were shown quantitatively that total above-ground carbon in the McDonald-Dunn will be accumulating (I expect it will given the relatively conservative harvest rate estimates – if the inventory is correct). If I missed, these, my apologies! Showing forest inventory and wildlife habitat projections are critical if the public (and CoF employees) are going to effectively evaluate the efficacy of the plan. My response to some external critiques of the plan (I only focused on critiques that are within my area of expertise).
• allows clearcuts of 40 to 80 acres (“long- rotation” vs. “short-rotation”) compared to the 2005 plan (which limited the size of cuts in the southern portion of the McDonald Forest to four acres in size) - Smaller cuts are not necessarily better in that they tend to fragment the forest even more (e.g., create more edge, result in smaller future patches of mature forest). Rather, cuts should consider natural terrain boundaries, have considerable retention (dispersed and aggregated). Notably, a later critique also focuses on increased fragmentation in the plan, but limiting cut size would amplify fragmentation.
• relies on continued, widespread use of poisonous herbicides at the discretion of forest managers - Agreed that it should not be default to use herbicides. Formal research should be done on herbicide alternatives, as well as minimum amounts of herbicide to achieve regeneration objectives.
• relies heavily upon (“Woodstock”) forest modeling which is widely regarded as promoting wood fiber production over ecological values - Woodstock is just a tool that can be used for any sort of forest management planning. We have used this model to primarily examine ecological values in relation to wood yields
• relies on the relatively low standards of the Oregon Forest Practices Act (OFPA) as the primary constraint for forestry activities - Agreed. I don’t understand why we’re just adhering to the minimums rather than test of flexible alternatives (see above)
• promotes polluting, ecologically- destructive biomass energy as a “renewable source of energy - I didn’t see this in the plan?
• promotes a skewed biodiversity metric which relies on a limited number of taxa, rendering the conclusions arbitrary - I’m not sure what is being referred to here. Yes, a wider range of indicator species could be used, but the approach used was quite ambitious even compared to some Forest Stewardship Council certified forests that I’ve visited. The alternative to indicator species is to monitor all biodiversity (1000s of species) which is intractable.
• uses modeling that falsely concluded OSU’s continued reliance on even-aged, monoculture tree plantations will increase the resilience of the forests - What is the evidence that forest management will result in monocultures? I didn’t see that part (I do argue above that the hardwood component could be increased based on best available science).
• changes the old-growth reserves to allow logging for a variety of reasons, including “public safety” and to create/maintain, “structural and compositional diversity” - I assume that any activity in old growth stands would be extremely light touch. I do agree with this point that very little should be done in reserves (especially not fuels reduction or understory burning) – see my point above that there isn’t much science to support this (to my knowledge).
I have followed the COF McDonald Dunn Forests planning process for the last few years and have joined many others in demanding that the College stop its logging of late successional/old growth forests at the limited opportunities for ‘live’ input from the public, and I have also responded to the email requests for public comments. I again am again adding my voice to the many calls from the citizenry of Oregon to stop the demolition of old growth and mature forests in the McDonald Dunn and move to forestry practices that promote the preservation of ALL the old growth trees in the forest and a buffer that will protect these irreplaceable trees as the pressures of an increasingly hot and dry climate.
The utter destruction of the incredibly beautiful and ecologically important Baker Creek old growth will not be forgotten by those of us who treasured it. OSU has repeatedly failed to be truthful about this catastrophe. I have been appalled at the loss and threats to old growth and mature forests across the Forest - I often visit the 440 Road old growth and have been dismayed at the logging that threatens the last remaining late successional/old growth trees in this area. I see the same in the recent harvested areas at Peavy Arboretum, Baker Creek drainage and upper Oak Creek, where the COF repeatedly goes out of its way to grab the biggest and the best of the last remaining big trees. These are our heritage from the presettlement era and yet the COF replaces them with plantations and weeds.
The Plan needs to take another look at all these sites and add a significant buffer zone as well as implement logging approaches that promote shading and thermal protection of the soil resources. It is time for the COF to fundamentally reject the logging practices of the 1950s, accept that clear cuts cause climate change, and work to revise the outdated and destructive Oregon Forest Practices Act. Research should be focused on mitigating the destructive effects of logging on watersheds - soil heating, stream drying, invasive plants.
The Plan’s recognition of the importance of wetlands, riparian zones and oak habitats is welcomed but it remains to be seen if this results in better management actions. I look at the oaks that were saved from logging along the 100 and 110 roads and yet now are being smothered by plantations of Douglas-fir regeneration. This is a prime opportunity to develop innovative practices that incorporate harvest while fostering diverse forests and uplands. OSU should be a leader in this effort but I see other universities such as Willamette University Biology Program have a much better research program to understand Oregon Oak biology and ecology.
I urge the COF and the trustees of the University to reject this plan as written, review again all the public comment asking for a more ecologically aware and sensitive approach, and offer the University and the public a better plan that can help the academic discipline of forestry meet the challenges of climate and environmental degradation.
Lara Gardner
07/18/2025
OSU doesn’t own the forest. It also seems to ignore all the public desire to maintain these forests as they are rather than serving the interests of a few. It is time for the university to consider the views of the people who live in the region and work, fund, and attend the university, rather than the interests of a few corporations whose only concern is profit.
Clear cutting kills more than trees. It destroys the ecology. It destroys shrubs, young trees, and other native plants. The herbicides kill everything that isn't part of the monoculture "replanting" which is essentially a crop that suits one profit seeking goal, and destroys all else. Many sites end up completely sterile, without wildflowers, ground covers, oaks, or other plants. A natural forest contains hundreds of plant species besides conifers. The exposed soils on the now denuded hillside are often prone to erosion during heavy winter rains or spring snowmelt. Topsoil can wash off the clearcut into downslope streams and rivers. Skid trails also form gullies that funnel water and eroded sediment into streams. Large trees, snags, and downed logs that normally create refugia habitat when they fall into streams are no longer present. The originally diverse forest is converted into a uniform tree plantation- a far less productive environment for the native plants and animals that are part of the forest ecosystem. These monoculture tree plantations have low genetic diversity, making them less adaptable to droughts, climate change, and disease; while also creating more hazardous fire conditions.
It is estimated that clear cutting kills millions of animals annually. Wild animals, insects and plants are killed by large clear cuts. After the trees are gone, groundcover plants wither in the sun and parched soils. Most die. Soil animals, bacteria and fungi, vital to tree growth and health, overheat, shrivel and die.
More mobile mammals, reptiles and amphibians become refugees. They flee their former habitats, dodging predators like red-tailed hawks and crows as they search for new shelter and food in other forests. If they find new habitats, they discover others of their kind (red squirrels, for example) have already established territories there. There are no vacant lots in nature. Newcomers are treated as invaders. Territorial battles begin. Imagine somebody arriving to commandeer your home. Displaced individuals are most frequently driven off by residents. The banished, starving and lacking shelter, quietly die or succumb to predators.
Birds like ovenbirds nest on the ground in the middle of large forested areas. Finding the woodland gone, they may opt to nest in smaller woodlands bordered by clear cuts. Raccoons, crows, skunks, blue jays and other predators that hunt forest edges find and devour the eggs or young. It’s called the “edge effect.”
In spring and early summer, many birds nest in trees. Healthy forests include tall, older trees. Some bird species spend most of their feeding time in upper tree canopies. Others habitually feed in a middle canopy zone; still others in the lower. Finding their familiar forest cut and gone, they search for new habitats. Territorial battles erupt that they usually lose. Stress and a lack of food and shelter will eventually lead to death.
Migratory birds are protected under the federal Migratory Bird Act. However, people continue to ruthlessly mow down forests and nests throughout the breeding season.
A surprising number of wildlife species use holes in trees for shelter and rearing their young. Four species of ducks, snakes, mice, several owls, nuthatches, chickadees, tree swallows, flying squirrels, bats, kestrels, wild bees, seven woodpecker species and many other animals and birds depend on such tree cavities. Current forest management regimes leave a few, largely useless, clumps of trees in clear cuts. Suddenly exposed to wind, these frequently blow down after the harvest. Forests are currently being clearcut every 30-55 years, long before trees have grown old and developed holes for wildlife use.
Size matters! No wonder there are growing lists of forest species at risk in the region, from lichens to warblers to Nova Scotia’s mainland moose.
Many salamanders, toads and frog species mate in woodland pools, where fish are absent so eggs and tadpoles have a better chance of survival. A forest canopy moderates temperatures. Clearcutting dries up these ponds prematurely. Raccoons and others gather to feed as tadpoles become vulnerable. Puddles in machinery ruts become new breeding sites for amphibians and fatal traps when they, too, evaporate.
Large clearcuts create drastic ground level climate changes that few forest-dwelling wildlife species can tolerate. Shady, moist, comparatively cool environments under forests are suddenly open to direct sunlight, higher air temperatures and the drying effects of winds.
Rainfall is absorbed by leaves, needles, tree roots and damp soils. After clearcutting, heavy rains hit dry, hard ground that has often been compacted by heavy machinery. Runoff rushes over bare ground. Organics and nutrients leach from the upper soil layers and wash away. Instead of slow forest absorption then gradual release of water, clear cuts flush like toilets into brooks, streams and rivers, creating increased erosion. Stream banks, torn asunder by floods, topple trees that shaded the waterway. Soil carbon begins to migrate into the atmosphere.
Silt clogs spawning beds in stream channels, causing fish eggs to suffocate and die. After heavy rains repeatedly rip their way downstream, stream channels are left wide and shallow. Summer water levels become very low. Increased amounts of sunlight overheat the water, increasing evaporation and causing cold water species like salmon and trout to suffocate for lack of oxygen in the water. (For more information on how streams and rivers fall apart with poor land use, see Saltscapes Volume 1, No. 3, 2000, entitled “Cry Me a River”.)
And then there’s winter, when wildlife needs shelter. A forest technician called me several years ago after he located a young black bear that was hibernating in a depression—out in the open elements of a clearcut.
Overwintering white-tailed deer congregate in valleys and south-facing slopes less prone to prevailing winds. They need reasonably dense softwood cover for shelter, and adjacent areas with hardwoods and softwoods for food. Years ago, cutting winter hardwoods in a mixed wood stand for firewood at the farmhouse was a help to deer, as branches on the ground became browse.
Wildlife species that share these forests with humans deserve more consideration.
None of this benefits the forest. It does not benefit our community. It does not benefit the university. It is short sighted and greedy, lining the pockets of the few for short term gain.
Sneaking this plan through without time for public comment, and ignoring the statements by the public in the past is unconsionable. The university has time and again shown that it aligns itself with special interests rather than with life. It is time for this to stop.
This plan is bad for Oregon. It is bad for forests. It is bad for the university. Do not adopt this plan.
Mark Yeager
07/18/2025
Please accept my comments on the proposed Forest Management Plan for the McDonald-Dunn Forests. Firstly, I support the comments previously submitted by the Oregon Chapter of the Sierra Club and Oregon Wild. These well-researched and articulated comment letters identify the many areas in which the Forest Management Plan needs improvement.
As a frequent visitor to the forests for enjoyment of their wildlife, exercise and recreational opportunities, it saddens me to read that Oregon State intends to further develop these important, historic assets as timber farms for revenue generation. Focused on clear cutting as the main strategy for “management,” designating major areas of functional ecosystems for clear cutting as a means of attaining a steady rotation of timber sticks for maximum profit is very disturbing. It is beyond what the community and the world expect from Oregon State University, and is inconsistent with your identified goals:
“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.” (Section 4.2, page 99)
The industrial model undermines all these goals, and there is already far too much of that happening in western Oregon on private lands. Public lands can and should do things differently.
What is being proposed is not leadership or forward thinking for research. I think we know all too well the impacts of clear cutting and herbicide spraying as forest management practices, or “thinning” as a means of extracting the most ecologically valuable timber from a stand (old growth) under the guise of some other excuse (e.g., species diversity, safety, stand rotation, etc.).
In reviewing the Plan, much of this approach is apparently driven by the need for the College of Forestry to generate revenue. That short-sighted model might be sustainable for revenue generation, but it will be to the detriment of many aspects of the environment or ecological sustainability. The Plan lacks any substantive examination of fiscal details or alternative revenue generation proposals. Those details and options need exposure and public discussion.
I encourage you to go back to the drawing board on this proposal. I urge OSU to reject the agricultural model of forestry in the McDonald-Dunn Forest and instead develop and adopt an ecological approach that is more aligned with public values.
Chris Lorenzen
07/18/2025
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.
Dale Draeger
07/18/2025
I have often ridden my horse or driven on Tampico Road past OSU Forestry land after a harvest. It is called a ‘research’ forest, but this is difficult to understand because the same practices are done over and over. Passing a clear cut, one can see that there are just a few trees left standing, separated from each other. Months pass. Here comes the wind and rain and those solitary trees have no protection and they die or are blown down. If someone is doing research, surely they could see that this practice doesn’t make for an environment where trees thrive! Where is the study, where is the learning here? Trees like to group, hence the phrase, ‘stand of trees’. It appears pretty obvious that OSU functions more on a logging company model. Years ago Dunn Forest was a heaven of beautiful trails. Mountain bikers had affectionate names for the trails through the trees and ferns. Now the trails and trees are gone. What remains is bulldozed ground. Is the importance to you about this ‘Public Land’ all about how much money you can make? I know for sure that is not every student’s reason for enrolling in Forestry at OSU. Many who enroll want to preserve what little old growth we have left in our state/country. Let’s give them something to get inspired about! Can OSU be an inspiration for change and preservation? Now that would be something to be known for! Not giving a student the ability to be hired by a logging company.
Susan Salafsky
07/18/2025
I am deeply concerned about the proposed management plan for the MacDonald-Dunn Forest, because it prioritizes short-term profits from historical forest management practices over the sustainability of public resources. Thus, as written, the current forest management plan is counterproductive to long-term profits and forest health. Accordingly, it is in our best interests to revise the OSU draft forest management plan. To increase efficiency, the plan should include strategies for developing landscape characteristics that mitigate the impacts of extreme weather and wildfires on forest habitat quality AND improve timber production, while increasing biodiversity, enhancing water retention, and sequestering carbon. This can be accomplished by:
* Retaining ALL trees greater than 80 years old. These legacy and heritage trees provide habitat for numerous species in addition to shade, water, and nutrients. Consequently, older trees increase forest productivity and are critical to withstanding the greater frequency, duration, and intensity of climate extremes. * Restricting thinning and harvesting to younger forest stands and trees less than 80 years old. As a result, most of the MacDonald-Dunn Forest (2/3) would still be subject to active timber management and generate revenue. * Using protective buffers, irregular edges, and structural complexity in timber harvests to create microclimates, microhabitats, and an evolving mosaic of environmental conditions.
We do not have to sacrifice the health of our forests to obtain wood products and reap profits. So, before finalizing the MacDonald-Dunn Forest Management Plan, please incorporate ecological principles and holistic strategies to increase the resilience of forests, and ultimately our economic stability, in a rapidly changing environment. Thank you for your consideration.
Doug Pollock
07/18/2025
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?
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
Forest Management Plan Draft Comments
"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."
I had an enjoyable few hours (late) last night going through the plan. As I mention in my response, this has been an epic effort and there is much to be pleased with. Still, it would be great to see some fairly major improvements if this is to truly be a world-class plan that I can satisfactorily defend when challenged (I often am). What are your plans for handling comments and incorporating into the plan?
Comments on McDonald-Dunn Management Plan, as well as external critiques of the plan
July 17
Matt Betts, Professor, College of Forestry, Oregon State University
McDonald-Dunn Forest Management Plan
Overall, I appreciate the massive effort the team has undertaken to produce this plan and engage with the public. The main components are in place for a good management plan. I appreciate the balance between wood, revenue and other objectives that you’ve attempted to balance. Nevertheless, I think there are several elements that could be substantially improved to make this a world-class forest management plan that I’d be proud to discuss with the public, my colleagues and friends. I’ve described both major and minor points below. The major ones are: (#1) the need for more rigorous monitoring, (#3) how will you use the responses (like this one) in making adjustments to the plan? (#5) formalized flexibility within “management strategies” to allow adaptive management and explore alternative silvicultural options (including testing “ecological forestry”), (#8) additional recruitment of old growth forest, (#14) full transparency when it comes to wood yields, AAC projections, projected habitat change, habitat relationships used in the linear programming model. These should be basic elements of any forest management plan.
I have also included my response to some widely circulating critiques of the plan (below). I did not look at these before developing my own review below.
1. Monitoring. Monitoring is a key component of forest management and biodiversity conservation in that it enables “adaptive management” (the capacity to learn whether forest management strategies are working, and adjust accordingly if they are not). Although monitoring is mentioned in the plan (to be conducted by “consultants” and via “participatory science”) there are no details on sampling intensity, sampling design or spatial extent. As such, it is difficult to evaluate whether adaptive management will be possible at all. A next step needs to be the development of a formal monitoring plan. Ideally, this would not be conducted by consultants but could be included in the OSU Forest Curriculum and /or OSU research labs are given the opportunity to develop sampling designs. Monitoring should be considered a key component of the overall plan and should be paid for by harvest revenues. It is remarkable (looking at Table 2) that there are very few (any?) forest-wide monitoring efforts, but only very study specific, spatially restricted research. No end dates are provided in Table 2 so it is impossible to determine the length of past/current studies.
2. Perhaps semantics: I’m surprised that one of the goals does not include biodiversity conservation (mentioned in the Mission, but not in specific goals)
3. Response to public input. Figure 1 shows the process of plan development but gives no indication of how public comment will be incorporated in to plan revisions. The next step is simply “Draft to dean and forest exec committee”. Will revisions be made following public comment?
4. Historical forest composition and structure. I suspect that Fig. 8 greatly oversimplifies the historical distributions of “forest”, “oak savannah” and “prairie”. It would be a useful and interesting exercise to do some dendro work to determine the distributions of large stumps, and date them to determine what this historical range of variation might have been. This is particularly important given the stated priority of restoration. An additional test would be to look at the logging history of the forest to estimate how many board feet (and of what species) have been harvested over time. Under the hypothesis that the land was primarily oaks and that Douglas fir colonization was very recent, most harvest in early years should presumably have been oak.
5. Categorical management strategies. I am curious about why five categories of “management strategies” are being presented rather than offering the opportunity to examine gradients among these strategies to test how best to balance stand-level yield with other important outcomes like climate adaptability, biodiversity and public acceptance. Binning management into these categories runs the risk of severely limiting creativity when it comes to silvicultural approaches. Since this is a research forest, there should be a formal plan on how variation within these categories plays out in terms of yields, biodiversity, carbon, microclimate etc.
(a) Why, for instance, does the short-rotation strategy only aim for 6% cover of hardwood trees rather than deliberately exploring variation in this amount to see if yield is compromised?
(b) Why adhere only to the minimum Oregon Forest Practices of 2 trees & snags/acre rather than examining a range of retention, even in this short-rotation strategy?
(c) Why not conduct formal research on various approaches to controlling competing vegetation rather than doing-business-as-usual herbicide application? What are the economic and wood costs of different approaches to controlling competing vegetation?
(d) Why not test the effects of varying degrees of retention in the long-rotation harvest stands (on yields, wildlife habitat, carbon etc.)? Is there a “sweet spot” between two trees per hectare and multi-aged silviculture that could provide habitat/carbon and still generate revenue?
6. Testing Ecological Forestry. Relating to (d) above, I would like to have seen a higher proportion of management and research focused on ecological forestry approaches. Given that so little is known about yields from these methods, wildlife responses etc., along with poor public opinion about management of the McDonald-Dunn, it seems prudent to do more experimentation on various non-traditional approaches to management, even if it ends up coming at some cost to yields (by the way, which we can’t even quantify because so little has been done along these lines).
7. Forest Fragmentation. To what extent will attention be paid to limiting forest fragmentation effects (enhancing connectivity, reducing edge etc.). Looking at the map in Fig. 22 it does look as though attempts have been made to put multi-aged treatments beside old-forest (which is good from a limiting edge perspective). Was this ever quantified formally? What will be the timing of spatial layout to minimize fragmentation effects?
8. Old-growth recruitment: I don’t see the term “stand establishment” as being compatible with multi-aged management. When is the stand established given that there will be no stand-initiating disturbance? Why is the oldest age of trees in the multi-aged stands 120? Why not let some forest age past that? It is likely the case that the historical range of variation in this forest did tend toward oak woodland, but clearly some significant patches of old growth exist (and have been cut quite extensively in the past). Given that old growth is in such short supply in the Coast Range as a whole (see Spies et al. 2007 – Ecol Apps), and that old growth has microclimate buffering effects (Frey et al. 2016 – Science Advances, Kim et al. 2022 – Global Change Biology) it makes sense to plan for increasing this development stage over time in the McDonald-Dunn.
9. Fire as a restoration tool in old growth. I would like to see the evidence that fire was a regular occurrence in existing old-growth stands. Is this published? Also, is there evidence that reductions in “surface fuel loading” reduces fire risk/severity on the west side? My understanding is that that practice is highly controversial. Dead wood in the understory and multi-canopy stands are likely to be the mechanisms behind old-growth microclimate buffering (Frey et al. 2016 Science Advances). Removing these materials/trees could therefore increase temperatures in the understory, elevate VPD and enhance fire risk and spread.
10. Forest inventory and yields. How reliable are the inventories and yields used to build the linear programming model? These models are clearly highly sensitive to parameterizations. For instance, to my knowledge, yields for multi-aged forest management are non-existent. From where did you generate yields for short and long- rotation management? Importantly, how will you determine whether or not various treatments are responding (in terms of yield) following harvest? (How frequently and at what sampling intensity will post-harvest inventories be conducted; I see there is some mention of this later in the plan, but details are lacking). The plan should include (at least in the appendix): (a) yield curves, (b) inventory data, (c) species habitat relationships, (d) trajectories of habitat, yield, and growing stock over time.
11. I appreciate the use of coarse and fine-filter approaches. For the indicator species, was an effort made to (a) estimate their habitat requirements, (b) model future habitat for these species over time? These should also be reported in the plan for full transparency. Again, what rigorous long-term monitoring will be conducted to test whether projections are indeed correct?
12. Hardwoods. For the 6% hardwood threshold that you cite from Ellis and Betts (2012) this is for the abundance of all birds. A more conservative threshold from the same paper is ~16% (for leaf-gleaning birds that are your indicator species). However, an alternative explanation is just “the more hardwoods the better”: “Quantification of a threshold at 15.89% (SE = 5.71) cover for all leaf gleaners was ambiguous, with slightly greater support for the linear model”. I do think the 6% threshold is incautious. I appreciate that you have the target at 10% for long-rotation forestry, but I suggest that even this should be higher.
13. Dead wood conservation. After quite a nice review on the importance of dead wood, the plan then goes on to state that the bare forest practices minimums will be used in various harvests. If the objective is to demonstrate sound forestry, these levels of downed wood and snags should be increased. Again, adaptive management should be used to hone the targets that are initially established.
14. Transparent projections about future forest conditions. I’ve mentioned this above, but it is important to emphasize that forest management plans should show projections for all of the elements considered in those plans under various scenarios (I thought that a consulting company did these for you?) Included in those projections should be estimates of uncertainty. Where are the projections for annual cut over the next 100 years? Wildlife habitat? Growing stock? I think some of the existing critiques of the plan might have less impact if it were shown quantitatively that total above-ground carbon in the McDonald-Dunn will be accumulating (I expect it will given the relatively conservative harvest rate estimates – if the inventory is correct). If I missed, these, my apologies! Showing forest inventory and wildlife habitat projections are critical if the public (and CoF employees) are going to effectively evaluate the efficacy of the plan. My response to some external critiques of the plan (I only focused on critiques that are within my area of expertise).
• allows clearcuts of 40 to 80 acres (“long- rotation” vs. “short-rotation”) compared to the 2005 plan (which limited the size of cuts in the southern portion of the McDonald Forest to four acres in size) - Smaller cuts are not necessarily better in that they tend to fragment the forest even more (e.g., create more edge, result in smaller future patches of mature forest). Rather, cuts should consider natural terrain boundaries, have considerable retention (dispersed and aggregated). Notably, a later critique also focuses on increased fragmentation in the plan, but limiting cut size would amplify fragmentation.
• relies on continued, widespread use of poisonous herbicides at the discretion of forest managers - Agreed that it should not be default to use herbicides. Formal research should be done on herbicide alternatives, as well as minimum amounts of herbicide to achieve regeneration objectives.
• relies heavily upon (“Woodstock”) forest modeling which is widely regarded as promoting wood fiber production over ecological values - Woodstock is just a tool that can be used for any sort of forest management planning. We have used this model to primarily examine ecological values in relation to wood yields
• relies on the relatively low standards of the Oregon Forest Practices Act (OFPA) as the primary constraint for forestry activities - Agreed. I don’t understand why we’re just adhering to the minimums rather than test of flexible alternatives (see above)
• promotes polluting, ecologically- destructive biomass energy as a “renewable source of energy - I didn’t see this in the plan?
• promotes a skewed biodiversity metric which relies on a limited number of taxa, rendering the conclusions arbitrary - I’m not sure what is being referred to here. Yes, a wider range of indicator species could be used, but the approach used was quite ambitious even compared to some Forest Stewardship Council certified forests that I’ve visited. The alternative to indicator species is to monitor all biodiversity (1000s of species) which is intractable.
• uses modeling that falsely concluded OSU’s continued reliance on even-aged, monoculture tree plantations will increase the resilience of the forests - What is the evidence that forest management will result in monocultures? I didn’t see that part (I do argue above that the hardwood component could be increased based on best available science).
• changes the old-growth reserves to allow logging for a variety of reasons, including “public safety” and to create/maintain, “structural and compositional diversity” - I assume that any activity in old growth stands would be extremely light touch. I do agree with this point that very little should be done in reserves (especially not fuels reduction or understory burning) – see my point above that there isn’t much science to support this (to my knowledge).
I have followed the COF McDonald Dunn Forests planning process for the last few years and have joined many others in demanding that the College stop its logging of late successional/old growth forests at the limited opportunities for ‘live’ input from the public, and I have also responded to the email requests for public comments. I again am again adding my voice to the many calls from the citizenry of Oregon to stop the demolition of old growth and mature forests in the McDonald Dunn and move to forestry practices that promote the preservation of ALL the old growth trees in the forest and a buffer that will protect these irreplaceable trees as the pressures of an increasingly hot and dry climate.
The utter destruction of the incredibly beautiful and ecologically important Baker Creek old growth will not be forgotten by those of us who treasured it. OSU has repeatedly failed to be truthful about this catastrophe. I have been appalled at the loss and threats to old growth and mature forests across the Forest - I often visit the 440 Road old growth and have been dismayed at the logging that threatens the last remaining late successional/old growth trees in this area. I see the same in the recent harvested areas at Peavy Arboretum, Baker Creek drainage and upper Oak Creek, where the COF repeatedly goes out of its way to grab the biggest and the best of the last remaining big trees. These are our heritage from the presettlement era and yet the COF replaces them with plantations and weeds.
The Plan needs to take another look at all these sites and add a significant buffer zone as well as implement logging approaches that promote shading and thermal protection of the soil resources. It is time for the COF to fundamentally reject the logging practices of the 1950s, accept that clear cuts cause climate change, and work to revise the outdated and destructive Oregon Forest Practices Act. Research should be focused on mitigating the destructive effects of logging on watersheds - soil heating, stream drying, invasive plants.
The Plan’s recognition of the importance of wetlands, riparian zones and oak habitats is welcomed but it remains to be seen if this results in better management actions. I look at the oaks that were saved from logging along the 100 and 110 roads and yet now are being smothered by plantations of Douglas-fir regeneration. This is a prime opportunity to develop innovative practices that incorporate harvest while fostering diverse forests and uplands. OSU should be a leader in this effort but I see other universities such as Willamette University Biology Program have a much better research program to understand Oregon Oak biology and ecology.
I urge the COF and the trustees of the University to reject this plan as written, review again all the public comment asking for a more ecologically aware and sensitive approach, and offer the University and the public a better plan that can help the academic discipline of forestry meet the challenges of climate and environmental degradation.
OSU doesn’t own the forest. It also seems to ignore all the public desire to maintain these forests as they are rather than serving the interests of a few. It is time for the university to consider the views of the people who live in the region and work, fund, and attend the university, rather than the interests of a few corporations whose only concern is profit.
Clear cutting kills more than trees. It destroys the ecology. It destroys shrubs, young trees, and other native plants. The herbicides kill everything that isn't part of the monoculture "replanting" which is essentially a crop that suits one profit seeking goal, and destroys all else. Many sites end up completely sterile, without wildflowers, ground covers, oaks, or other plants. A natural forest contains hundreds of plant species besides conifers. The exposed soils on the now denuded hillside are often prone to erosion during heavy winter rains or spring snowmelt. Topsoil can wash off the clearcut into downslope streams and rivers. Skid trails also form gullies that funnel water and eroded sediment into streams. Large trees, snags, and downed logs that normally create refugia habitat when they fall into streams are no longer present. The originally diverse forest is converted into a uniform tree plantation- a far less productive environment for the native plants and animals that are part of the forest ecosystem. These monoculture tree plantations have low genetic diversity, making them less adaptable to droughts, climate change, and disease; while also creating more hazardous fire conditions.
It is estimated that clear cutting kills millions of animals annually. Wild animals, insects and plants are killed by large clear cuts. After the trees are gone, groundcover plants wither in the sun and parched soils. Most die. Soil animals, bacteria and fungi, vital to tree growth and health, overheat, shrivel and die.
More mobile mammals, reptiles and amphibians become refugees. They flee their former habitats, dodging predators like red-tailed hawks and crows as they search for new shelter and food in other forests. If they find new habitats, they discover others of their kind (red squirrels, for example) have already established territories there. There are no vacant lots in nature. Newcomers are treated as invaders. Territorial battles begin. Imagine somebody arriving to commandeer your home. Displaced individuals are most frequently driven off by residents. The banished, starving and lacking shelter, quietly die or succumb to predators.
Birds like ovenbirds nest on the ground in the middle of large forested areas. Finding the woodland gone, they may opt to nest in smaller woodlands bordered by clear cuts. Raccoons, crows, skunks, blue jays and other predators that hunt forest edges find and devour the eggs or young. It’s called the “edge effect.”
In spring and early summer, many birds nest in trees. Healthy forests include tall, older trees. Some bird species spend most of their feeding time in upper tree canopies. Others habitually feed in a middle canopy zone; still others in the lower. Finding their familiar forest cut and gone, they search for new habitats. Territorial battles erupt that they usually lose. Stress and a lack of food and shelter will eventually lead to death.
Migratory birds are protected under the federal Migratory Bird Act. However, people continue to ruthlessly mow down forests and nests throughout the breeding season.
A surprising number of wildlife species use holes in trees for shelter and rearing their young. Four species of ducks, snakes, mice, several owls, nuthatches, chickadees, tree swallows, flying squirrels, bats, kestrels, wild bees, seven woodpecker species and many other animals and birds depend on such tree cavities. Current forest management regimes leave a few, largely useless, clumps of trees in clear cuts. Suddenly exposed to wind, these frequently blow down after the harvest. Forests are currently being clearcut every 30-55 years, long before trees have grown old and developed holes for wildlife use.
Size matters! No wonder there are growing lists of forest species at risk in the region, from lichens to warblers to Nova Scotia’s mainland moose.
Many salamanders, toads and frog species mate in woodland pools, where fish are absent so eggs and tadpoles have a better chance of survival. A forest canopy moderates temperatures. Clearcutting dries up these ponds prematurely. Raccoons and others gather to feed as tadpoles become vulnerable. Puddles in machinery ruts become new breeding sites for amphibians and fatal traps when they, too, evaporate.
Large clearcuts create drastic ground level climate changes that few forest-dwelling wildlife species can tolerate. Shady, moist, comparatively cool environments under forests are suddenly open to direct sunlight, higher air temperatures and the drying effects of winds.
Rainfall is absorbed by leaves, needles, tree roots and damp soils. After clearcutting, heavy rains hit dry, hard ground that has often been compacted by heavy machinery. Runoff rushes over bare ground. Organics and nutrients leach from the upper soil layers and wash away. Instead of slow forest absorption then gradual release of water, clear cuts flush like toilets into brooks, streams and rivers, creating increased erosion. Stream banks, torn asunder by floods, topple trees that shaded the waterway. Soil carbon begins to migrate into the atmosphere.
Silt clogs spawning beds in stream channels, causing fish eggs to suffocate and die. After heavy rains repeatedly rip their way downstream, stream channels are left wide and shallow. Summer water levels become very low. Increased amounts of sunlight overheat the water, increasing evaporation and causing cold water species like salmon and trout to suffocate for lack of oxygen in the water. (For more information on how streams and rivers fall apart with poor land use, see Saltscapes Volume 1, No. 3, 2000, entitled “Cry Me a River”.)
And then there’s winter, when wildlife needs shelter. A forest technician called me several years ago after he located a young black bear that was hibernating in a depression—out in the open elements of a clearcut.
Overwintering white-tailed deer congregate in valleys and south-facing slopes less prone to prevailing winds. They need reasonably dense softwood cover for shelter, and adjacent areas with hardwoods and softwoods for food. Years ago, cutting winter hardwoods in a mixed wood stand for firewood at the farmhouse was a help to deer, as branches on the ground became browse.
Wildlife species that share these forests with humans deserve more consideration.
None of this benefits the forest. It does not benefit our community. It does not benefit the university. It is short sighted and greedy, lining the pockets of the few for short term gain.
Sneaking this plan through without time for public comment, and ignoring the statements by the public in the past is unconsionable. The university has time and again shown that it aligns itself with special interests rather than with life. It is time for this to stop.
This plan is bad for Oregon. It is bad for forests. It is bad for the university. Do not adopt this plan.
As a frequent visitor to the forests for enjoyment of their wildlife, exercise and recreational opportunities, it saddens me to read that Oregon State intends to further develop these important, historic assets as timber farms for revenue generation. Focused on clear cutting as the main strategy for “management,” designating major areas of functional ecosystems for clear cutting as a means of attaining a steady rotation of timber sticks for maximum profit is very disturbing. It is beyond what the community and the world expect from Oregon State University, and is inconsistent with your identified goals:
“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.” (Section 4.2, page 99)
The industrial model undermines all these goals, and there is already far too much of that happening in western Oregon on private lands. Public lands can and should do things differently.
What is being proposed is not leadership or forward thinking for research. I think we know all too well the impacts of clear cutting and herbicide spraying as forest management practices, or “thinning” as a means of extracting the most ecologically valuable timber from a stand (old growth) under the guise of some other excuse (e.g., species diversity, safety, stand rotation, etc.).
In reviewing the Plan, much of this approach is apparently driven by the need for the College of Forestry to generate revenue. That short-sighted model might be sustainable for revenue generation, but it will be to the detriment of many aspects of the environment or ecological sustainability. The Plan lacks any substantive examination of fiscal details or alternative revenue generation proposals. Those details and options need exposure and public discussion.
I encourage you to go back to the drawing board on this proposal. I urge OSU to reject the agricultural model of forestry in the McDonald-Dunn Forest and instead develop and adopt an ecological approach that is more aligned with public values.
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.
* Retaining ALL trees greater than 80 years old. These legacy and heritage trees provide habitat for numerous species in addition to shade, water, and nutrients. Consequently, older trees increase forest productivity and are critical to withstanding the greater frequency, duration, and intensity of climate extremes.
* Restricting thinning and harvesting to younger forest stands and trees less than 80 years old. As a result, most of the MacDonald-Dunn Forest (2/3) would still be subject to active timber management and generate revenue.
* Using protective buffers, irregular edges, and structural complexity in timber harvests to create microclimates, microhabitats, and an evolving mosaic of environmental conditions.
We do not have to sacrifice the health of our forests to obtain wood products and reap profits. So, before finalizing the MacDonald-Dunn Forest Management Plan, please incorporate ecological principles and holistic strategies to increase the resilience of forests, and ultimately our economic stability, in a rapidly changing environment. Thank you for your consideration.
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?
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