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.
Steve Cook
07/18/2025
Comments from Steve Cook on the proposed management plan for the McDonald-Dunn “Research” Forest.
Nothing says “It’s our forest, we’ll do what we want, and it’s none of your business,” like changing clearcut size from five acres to eighty acres. It’s simply a poke in the eye with a sharp stick to those who believe in the intrinsic value of public forests.
Others are commenting on the shortcomings of the plan in general, covering ecosystems, climate change, and carbon sequestration. I am going to comment very specifically on several components. Invasive Species:
The coverage in the plan is totally inadequate. Suggesting that false brome is so widespread that it is impossible to do anything about it just means that this invasive was ignored until it was widespread. Next, we’ll hear “oh, well, teasel is so widespread that we can’t do anything about it.” And all the other invasives; shiny leaf marigold; reed canary grass; various thistles; cheat grass; knapweed—“oh, well, ____________ is so widespread that we can’t do anything about it.” This is unacceptable.
Appendix J “Invasive species”
P. 81 Prevention
• To reduce the introduction of non-native plant seed, logging and construction equipment are washed and inspected prior to entering the McDonald-Dunn Forest for contract work. The following equipment is exempt: rock trucks, log trucks, and contractor vehicles that do not leave roads or treated roadsides.
• Forest roads and roadsides are treated with herbicide on an as-needed basis to limit the propagation of invasive plants, generally every 1-2 years.
Invasives are spread by vehicles traveling the road system, as invasives are not effectively controlled along major roads. A specific example is Oak Creek Road 600, which sees extensive vehicle traffic. Currently in mid-July thistles, teasel, reed canary grass and many others are overhanging the road where vehicles gather seeds and spread them. The only herbicide plan that is consistently followed is spraying of recent clearcut areas. Having lived adjacent to the McDonald Forest Oak Creek access for ten years, I’ve watched ineffective spraying of weeds along the 600 road. Spraying roadside weeds in fall, as has been done in the past is totally ineffective and just highlights the lack of knowledge of herbicides demonstrated by forest managers.
There is a nice “Herbaceous Invasive Weeds” demo site immediately west of the Oak Creek entrance parking area. The CoF should put up a sign noting how it actually encourages the spread of invasives. Oak Creek parking area is a great place for an invasive weed interpretive sign indicating how CoF is encouraging invasives by its management.
Unregulated mountain bike travel, especially on “unauthorized trails” spread invasives deep into the forest. There is a derelict washing station at Oak Creek parking area, so cyclists could wash their bikes. But no longer. The plan suggests that at some future point a recreation plan should be written is simply a joke. There is an entire Forest Recreation Department in the CoF, but one searches in vain to find any involvement of this department in management of the thousands of visitors to the forest. And they all spread invasives.
The McDonald Forest Arboretum:
Everyone in the College of Forestry from the Dean down to the most recent summer hire should be embarrassed at the condition of the Arboretum. I’ve visited arboretums all over the world, and invariably they are showcases of local and exotic vegetation, well maintained areas. The entire discussion of invasive species is simply a joke when viewing the area of the arboretum where invasive English ivy is climbing trees right in the parking area, no control attempts visible. And even worse is the spread of English holly in the same area. This species, which crowds out other woody vegetation is spreading in a mat north of the arboretum as well as other areas. A recently logged area near Kronmiller Lake has nearly all vegetation removed except the English holly trees, which seem to have been carefully retained. The only conclusion that can be drawn is that the silviculturalists that demand hegemony over the forest simply don’t care. Other commenters speak of complete ecosystems, but it is impossible to have a complete ecosystem without controlling invasives.
I’ve found no discussion in the plan of invasive herbaceous plants—thistles, shiny leaf geranium, reed canary grass and a zillion others. They impact woody vegetation establishment. It is impossible to manage woody shrubs while ignoring invasive herbaceous plants.
I’ve not been able to find in the plan interactions of various activities/uses of the forest:
Herbicides and stream quality monitoring
Mountain bike use and invasive species spread
When a public forest is managed solely by silviculturalists, the management emphasis is going to be on growing wood fiber. Issues and other activities—recreation, indigenous species, invasive species, water quality, value of dead and down woody vegetation all are secondary and appear to be ignored most of the time. A quick online query indicates that there are 209 teaching and research faculty in the OSU CoF. Yet less than twenty are involved in the management of the OSU Research Forests. Why? Where are you guys? Do you not feel that this forest is a public resource deserving of your respect and involvement? I’m not sure which
Land Use Zoning
2.7 “Visitor Use” p. 42
2.5.1 Land Use Zoning.
There is an omission in this paragraph. Trails are “infrastructure.”
Other uses within a forest conservation zone are considered ‘conditional’, meaning that some activities may be allowed, but only under certain predetermined conditions. Both Goal 4 and Benton County Chapter 60 specify outdoor recreation opportunities as important and protected resources within Forest Conservation Zones, and recreation is fully embraced by research forest staff. However, the development of infrastructure (e.g., parking, toilets) to support these recreation opportunities is considered a conditional use which is potentially inconsistent with the overarching land classification (forest conservation) but deemed beneficial or necessary in specific situations or locales.
The above paragraph clearly misrepresents the Benton County Conditional Use Permit required for recreation on land zoned as “Forest Conservation.” It appears from the text that the county embraces recreation on “Forest Conservation” zoned land. This is simply not true. A Conditional Use Permit was required and signed by both OSU and Benton County in 2017. And the plan glosses over what is included in infrastructure. Trails are infrastructure. New trails are prohibited by the 2017 Conditional Use Permit. Indigenous animals and spreading recreational use, especially “unauthorized” mountain bike use in the unroaded areas.
In fact, the plan notes that the OSU CoF doesn’t even know what indigenous animals exist in the forest, let alone if they are being impacted by recreational use. Logging a site has a huge immediate impact upon many animal species, but they simply move aside while the logging activity occurs. Recreational usage is insidious, always present along usage corridors and frequently has a larger impact than the intensive short-term logging activities.
The plan states on page 86: “Managers can minimize these potential negative impacts by naturalizing unauthorized trails where feasible, building trails and roads to meet sustainable standards, and leveraging education and messaging to help positively influence compliance on trails.”
“Naturalizing unauthorized trails?” What the hell does that mean? If it means closing them down, then this is simply a lie. The CoF as well as other land managers know full well that it is impossible without serious on the ground policing complete with fines to stop the construction of unauthorized trails. And legitimizing “unauthorized” trails as has been so often the case in the McDonald “Research” Forest demonstrates an ignorance of recreation planning. This does nothing to reduce the impacts to vegetation, wildlife, invasive species spread by usage of these trails. The lack of a trails plan is a severe shortcoming of this plan. Allowing mountain bikers to cut in “unauthorized” trails with no negative repercussions and then legitimizing those same trails just encourages the mountain bike community to cut in more “unauthorized” trails, which CoF will legitimize, ad infinitum.
Page 87:
Emergent technologies: There are significant management challenges associated with changing outdoor recreation technologies and emergent visitor uses. Electric-powered devices such as e- bikes, hoverboards and e-unicycles are among the new types of recreational uses on forest trails, although they are prohibited in the McDonald-Dunn Forest. These technologies and vehicles are increasingly impacting how visitor use is managed in non-motorized nature-based environments, and their potential for social and environmental impacts continues to be explored and studied. As long as users know that there is no physical presence of CoF personnel in the McDonald-Dunn Research Forest or any enforcement of rules, there is no point of even discussion things like “Emergent technologies” E-bikes, especially run rampant in the forest, unimpeded by the tiny “No E-bike” signs posted. To adequately manage recreational activities requires a significant presence on the ground of CoF personnel. As long as CoF does not allocate resources for this, all discussion is simply that—discussion.
Page 89:
Guidelines for Visitor Use: Following the initiation of the 2025 McDonald-Dunn Forest management plan, a separate McDonald-Dunn Forest visitor use management planning (VUMP) process will commence. The new VUMP will expand on these guidelines and provide a more detailed outline of policies and practices related to trail development, improving access, recreation research and monitoring, hunting, education and interpretation, volunteers, and other visitor programming on the research forests. There seems to be a misconception among the authors of this plan. No further infrastructure development, including trail development is allowed under the 2017 Conditional Use Permit from Benton County without a further conditional use permit being approved by Benton County.
3.7.2 Wildland/Urban Interface
Page 90:
Intrusion:
Intrusion into the forest from the WUI expands two management issues: potential encroachment of non-native plants onto forest property and the creation of unauthorized trails from adjacent private lands into the forest.
This is simply self-serving nonsense. See that first isolated dot along the lower left (SW) border on Figure 24? That’s my house. Invasive herbaceous species, at least fifteen that I, as a non-botanist, can identify, have spread onto our property from the McDonald Forest like a tsunami wave. I’ve beaten invasives back for ten years. The intrusion is from the McDonald Forest onto my private land, not the other way around. Others adjacent property owners have reported the same problem to me.
The authors also seem to have not included fire as an “intrusion.”
Again, from the McDonald Forest onto my private land.
CoF personnel only seem to see woody vegetation—trees and shrubs in relation to WUI fires. But ask any WUI professional (For elucidation, I have a Ph.D. related to WUI fire issues) and they will tell that weeds and grasses carry fire faster and spread embers farther and more quickly than woody vegetation. For ten years I’ve protested the fire hazard resulting from uncontrolled invasive weeds that grow annually to five feet tall between my property and the Oak Creek parking area, which on a typical day sees a hundred vehicles. Just one loser among these hundreds of people; just one flipped cigarette butt; just one kid playing with matches; just one hot exhaust pipe touching the weeks growing hard against the asphalt; just one loser and poof, these weeds carry flames to my property. Intrusion from OSU land onto adjacent private property truly is a problem.
As mentioned in section 3.6.2, a recent fire risk analysis indicates higher burn probabilities immediately outside rather than inside the McDonald-Dunn Forest (Scruggs 2024)
I guess Scruggs must not have investigated the situation at the Oak Creek entrance to the McDonald Research Forest. In fact, when I requested that CoF personnel come review the wildfire hazard presented by the weeds behind my barn, DeLuca told me that CoF had its own professionals and refused to send anyone to review the situation. If this is the typical interactions between CoF and adjacent property owners, we are all in trouble.
Page 94:
Example 3: Team Dirt - The OSU research forests partner with the Corvallis chapter of Team Dirt, a Chapter of the International Mountain Bike Association (IMBA). Team Dirt is a nonprofit, volunteer organization that works in partnership with the forest and other local agencies to build and maintain trails throughout the Willamette Valley. The organization is dedicated to the stewardship of sustainable, multiple-use, and purpose-built trails, to preserve access for mountain bikers through advocacy and education, and to promote responsible trail use. Team Dirt works closely with McDonald-Dunn Forest staff to design, build, and maintain sustainable, primary- use and multi-use trails that better meet the needs of the mountain bike community. The radical fringe of mountain bikers hack in “unauthorized” trails and then Team Dirt comes to the CoF to volunteer to upgrade the unauthorized trail into an established trail. CoF then agrees and a new trail is constructed where none was proposed by CoF due to a lack of a recreation plan. Thus, no consideration for the impact upon shy wildlife, since CoF has no recreation plan, let alone a plan for native wildlife, for which it has virtually no information. Currently (June 2025) Team Dirt is building a new trail in the Oak Creek drainage. CoF is allowing this construction, even though the 2017 Conditional Use Permit prohibits new trail construction. Unregulated mountain bike activity has resulted in the spread of invasives and negative impacts on wildlife and water quality.
Page 96:
Strategy 4: Invest in new signage at key areas – specifically Peavy Arboretum – to better describe the history of Kalapuyan Peoples on this land, the mission and goals of the forest, as well as the role active management has played in creating the forest conditions the community has come to love.
Have any of the authors of this proposed plan actually visited the Peavy Arboretum? Old Peavy must be flopping over in his grave at the condition of the arboretum. It is a shambles. An offense to the title “Arboretum.” It is mostly a mess of invasive species, most obviously English ivy and English holly, but including many others. If this area demonstrates the attitude of the OSU CoF towards its stewardship of the public land under its management, us Oregonians who own this land as well as all the flora and fauna that call it home are all in trouble. I’m skeptical that a Kalapuyan transported ahead two hundred years would be pleased at this disgrace to the title “arboretum.” “Please don’t put up signs with my name on it,” that Kalapuyan would plead, “This mess is nothing that I recognize.”
I’ll complete my comments with a note about OSU and indigenous people. The plan contains considerable verbiage about indigenous people this and indigenous people that, but there is, in reality, only one true documented connection between OSU and the indigenous people of Oregon. That is the Morrill Act. The plan glosses over this so quickly that the typical reader will miss it. But here are the facts (and these facts are readily obtainable, all the way down to exact parcel numbers). Under the Morrill Act, OSU received indigenous land valued at $20 million, expropriated from indigenous people by the Federal government. Twenty Million Dollars! This is where the “land” in “Land Grant” came from. I suspect that many others are like me; I previously thought the idea of “Land Grant Universities” was a generous action by the Federal government to encourage educational activity related to our land, when in fact, it was a disgraceful, even disgusting action, essentially stealing indigenous land. OSU should be careful proudly calling itself a “Land Grant University.”
Writing in this plan that OSU will allow indigenous people to collect plants and such must be an insult to them. A pittance. Why not do something meaningful? Why not set aside a significant portion of the McDonald “Research” Forest as a reserve honoring indigenous people? The Oak Creek Drainage, for example would be easily definable. This drainage contains much of the older forest in the McDonald “Research” Forest. A Kalapuyan transported ahead two hundred years might actually recognize some of it. There could be an interpretive center located in one of the unused buildings at the parking area. When I suggested this to DeLuca several years ago, he had two possible responses: 1) “This is an idea worth discussing further, including with the tribes; or 2) “Cook didn’t get input from the tribes before suggesting this, so we can ignore him.” DeLuca, of course, chose the second response. Does this reflect the true CoF attitude towards indigenous people? Why not do something truly meaningful, not only to recognize the existence of Kalapuyans in this area, but also as a gesture to the Oregonians that believe some of the forest should be exempt from logging.
Trygve Steen
07/18/2025
Hello to those it should concern,
Please accept these brief reactions to the Draft McDonald-Dunn Forest Plan
My primary concern with this draft plan relates to the protections for old-growth forest stands and their trees. I am especially concerned that the draft plan reduces protections for older trees and stands by removing the previous 160-year limit for felling older trees throughout the forest. All old-growth trees need to be protected. In addition, protections for forested areas that will soon qualify as old-growth needs to be strengthened. The draft plan clearly needs revision to provide more adequate protections for all forest stands, that are presently 80 years old or older, so that they can develop the full suite of old-growth forest characteristics and conditions. The coast range presently is seriously deficient in relation to the area of forest with old-growth characteristics, and as a public forest area, responsibility for acting to protect and enhance the development of old-growth forested areas is an especially important management responsibility. This responsibility is highly significant, given the importance of older forested areas for carbon sequestration.
The carbon sequestration and climate change implications of this plan need much more extensive and careful consideration. At this point, this plan does not adequately incorporate the best available science into its processes and conclusions. Given that this plan involves responsibility for management of a significant forested area in the state of Oregon by a major academic institution, I feel that climate change implications warrant more complete exploration and incorporation into your planning process.
The above considerations for shifting your management paradigm are fundamental to the lessons forest managers need to learn for the future of this region’s forests. As a research forest, new and different lessons need to be learned. These lessons need to focus on an ecological approach to forest management rather than the present industrial model for forest management, with its emphasis on short rotation logging.
Given that the draft plan applies an industrial forest management paradigm to the majority of the McDonald-Dunn forest, clearcutting and regeneration harvests fundamentally fail as management practices that fit an ecological management approach to forestry. We already have a substantial experience base for industrial forestry, and as a research forest, learning more about an ecological management approach to forest management is something that is badly needed and should be implemented more fully.
More adequate recognition of the greenhouse gas emissions from industrial forest management needs to be incorporated into this plan. I would expect this to result in a lower emphasis on the use of clearcuts and regeneration harvest practices. Your management should result in both a reduction of greenhouse gas emissions and an increase in the greenhouse gas sequestration as you appropriately transition to a more ecological paradigm for forest management.
The draft plan will produce extensive areas of tree plantations that will bring a substantial increase of fire risk into the McDonald-Dunn Forest ecosystem. This consideration is especially significant given the projected implications of climate change, with its more extreme temperatures and drying of our forested landscapes. Note, the drying effects of clearcuts extend into surrounding forested areas which not only increases fire risk but also reduces the beneficial habitat characteristics of the associated older forests.
I trust the teams involved in developing this forest plan realize the extensive and impactful adverse consequences of the clearcut/industrial approach to forest management. Therefore, I will resist the temptation to present a full litany of those substantial negative impacts.
I have a substantial interest in and involvement in the biodiversity implications of forest management. The draft plan fails to adequately account for the biodiversity impacts of logging with shorter rotations where you propose to do that kind of logging. The number and diversity of taxa that are considered in your modeling are not adequately representative for the full suite of old-growth organisms. Short rotation forest management leaves a forest seriously deficient in the dead wood component of a forest ecosystem, and that impacts the availability of important ecological niches available for the relevant organisms.
Finally, my thoughts as articulated above represent the input of a person who has studied and taught forest ecology in Oregon’s forested ecosystems for more than the last 50 years. They also likely reflect the sentiments of a major portion of Oregon’s thoughtful residents.
Thanks for your consideration,
Trygve Steen, Ph.D.
Helen Tennican
07/18/2025
Profit margin seems to be the highest priority for this forestry plan. In addition to the forest that are slated for clear cutting, the restoration efforts feel like a thinly veiled way to log more sensitive areas containing more old growth trees. The forestry plan describes a desire to return to a habitat created by native peoples in the pre-industrial time. This does not reflect the needs of the people of the 21st-century. This restoration plan also does not consider that when native people created the oak savanna habitat to support the camas fields that were a necessity to their way of life they had an intact ecosystem (likely dense coniferous forests) surrounding the habitat that had been not impacted by the low intensity burns and camas propagation. In our current environment, the area surrounding our OSU forests are primarily dominated by agricultural or residential use. This current ecosystem fragmentation does not allow for non-human populations to migrate and flourish. The Willamette Valley has sparse intact tracts of forests that provide shade to cool and retain water and allow for filtration of the watersheds affected.
I am concerned that this forestry plan is truly crop rotation plan described either as restoration, fire management and only partially earmarked for timber sales. This plan over time will deplete not only the soil as we cut our 2nd or 3rd crop of trees from this land but also disrupt small fragment of beautiful habitat that we are fortunate enough to steward in the Willamette Valley.
The other concern that seems glaringly obvious is that the only forestry practice that is being “ studied or researched” utilizes clear cutting for removal of trees slated for timber sales. I would have hoped for application of a more nuanced assessment and approach to logging our well utilized (and loved) forests which might prioritize protection of “mother trees”/ old growth trees within areas of logging and by prioritizing shading/cooling (as the global temperature rises), water retention (as threat of drought conditions increase), maintaining stabilization of hillsides and waterways for maintaining habitat for existing aquatic and land species and for enjoyable recreation by the public, (which is the current human use of the OSU forest not camas farming) by applying selective logging practices. Globally, forests that are in high human use areas are selectively logged to lower the impact on both human use and non-human use rather than maximizing profits. I would love to see a plan which reflects current human use with low impact selective logging that maintains a healthy unfractured ecosystem for the plants and animals that currently call the OSU forests their home.
Thank you for providing a public comment period,
Helen Tennican
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).
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.
Patti Haggerty
07/18/2025
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.
Kelly Burnett
07/18/2025
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.
I am writing to share my concerns regarding your draft management plan for the McDonald-Dunn Forest.
My significant concerns about the plan include: • It allocates 40% of the forest to “even-age, rotational forestry” - which means we’ll see lots of clearcutting in the forests for years to come. Oregonians are overwhelmingly opposed to clearcutting. The College of Forestry should be promoting ecological forest stewardship, not ecologically-destructive forestry practices!
• Only 10% of the forest will be designated “late-successional forest” despite broad community support for protecting more of the forest. This plan does NOT honor public input or community values!
• Restrictions on cutting older trees will be substantially reduced, as the 160 age-limit will be removed. OSU’s foresters will be given broad discretion to cut older trees in the name of “public safety” and to create their desired stand conditions.
• The plan ignores watershed boundaries and fails to include buffers around older stands, increasing fragmentation of the forest. This diminishes the ecology and biodiversity of the forest.
• The plan’s reliance on the Oregon Forest Practices Act as the only enforceable standard is inconsistent with OSU’s desire to be a leader in forestry education. The OFPA is a very low bar and does not exemplify leadership in forestry practices!
• Destructive practices, such as herbicide spraying and slash burning, will continue to be used widely throughout the forest, despite broad public opposition to these practices.
• The plan echoes industry propaganda on topics like forest carbon sequestration and biomass energy, and reflects poorly on OSU’s scientific integrity.
• The plan fails to address climate change in any meaningful or substantive manner. The wood products industry is the largest contributor to GHG emissions in Oregon. OSU ought to be leading the way in addressing these problems, but the plan lacks specifics and accountability in this area. Thank you for your consideration of my comments.
Anonymous
07/18/2025
"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."
Forest Management Plan Draft Comments
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.
Comments from Steve Cook on the proposed management plan for the McDonald-Dunn “Research” Forest.
Nothing says “It’s our forest, we’ll do what we want, and it’s none of your business,” like changing clearcut size from five acres to eighty acres. It’s simply a poke in the eye with a sharp stick to those who believe in the intrinsic value of public forests.
Others are commenting on the shortcomings of the plan in general, covering ecosystems, climate change, and carbon sequestration. I am going to comment very specifically on several components. Invasive Species:
The coverage in the plan is totally inadequate. Suggesting that false brome is so widespread that it is impossible to do anything about it just means that this invasive was ignored until it was widespread. Next, we’ll hear “oh, well, teasel is so widespread that we can’t do anything about it.” And all the other invasives; shiny leaf marigold; reed canary grass; various thistles; cheat grass; knapweed—“oh, well, ____________ is so widespread that we can’t do anything about it.” This is unacceptable.
Appendix J “Invasive species”
P. 81 Prevention
• To reduce the introduction of non-native plant seed, logging and construction equipment are washed and inspected prior to entering the McDonald-Dunn Forest for contract work. The following equipment is exempt: rock trucks, log trucks, and contractor vehicles that do not leave roads or treated roadsides.
• Forest roads and roadsides are treated with herbicide on an as-needed basis to limit the propagation of invasive plants, generally every 1-2 years.
Invasives are spread by vehicles traveling the road system, as invasives are not effectively controlled along major roads. A specific example is Oak Creek Road 600, which sees extensive vehicle traffic. Currently in mid-July thistles, teasel, reed canary grass and many others are overhanging the road where vehicles gather seeds and spread them. The only herbicide plan that is consistently followed is spraying of recent clearcut areas. Having lived adjacent to the McDonald Forest Oak Creek access for ten years, I’ve watched ineffective spraying of weeds along the 600 road. Spraying roadside weeds in fall, as has been done in the past is totally ineffective and just highlights the lack of knowledge of herbicides demonstrated by forest managers.
There is a nice “Herbaceous Invasive Weeds” demo site immediately west of the Oak Creek entrance parking area. The CoF should put up a sign noting how it actually encourages the spread of invasives. Oak Creek parking area is a great place for an invasive weed interpretive sign indicating how CoF is encouraging invasives by its management.
Unregulated mountain bike travel, especially on “unauthorized trails” spread invasives deep into the forest. There is a derelict washing station at Oak Creek parking area, so cyclists could wash their bikes. But no longer. The plan suggests that at some future point a recreation plan should be written is simply a joke. There is an entire Forest Recreation Department in the CoF, but one searches in vain to find any involvement of this department in management of the thousands of visitors to the forest. And they all spread invasives.
The McDonald Forest Arboretum:
Everyone in the College of Forestry from the Dean down to the most recent summer hire should be embarrassed at the condition of the Arboretum. I’ve visited arboretums all over the world, and invariably they are showcases of local and exotic vegetation, well maintained areas. The entire discussion of invasive species is simply a joke when viewing the area of the arboretum where invasive English ivy is climbing trees right in the parking area, no control attempts visible. And even worse is the spread of English holly in the same area. This species, which crowds out other woody vegetation is spreading in a mat north of the arboretum as well as other areas. A recently logged area near Kronmiller Lake has nearly all vegetation removed except the English holly trees, which seem to have been carefully retained. The only conclusion that can be drawn is that the silviculturalists that demand hegemony over the forest simply don’t care. Other commenters speak of complete ecosystems, but it is impossible to have a complete ecosystem without controlling invasives.
I’ve found no discussion in the plan of invasive herbaceous plants—thistles, shiny leaf geranium, reed canary grass and a zillion others. They impact woody vegetation establishment. It is impossible to manage woody shrubs while ignoring invasive herbaceous plants.
I’ve not been able to find in the plan interactions of various activities/uses of the forest:
Herbicides and stream quality monitoring
Mountain bike use and invasive species spread
When a public forest is managed solely by silviculturalists, the management emphasis is going to be on growing wood fiber. Issues and other activities—recreation, indigenous species, invasive species, water quality, value of dead and down woody vegetation all are secondary and appear to be ignored most of the time. A quick online query indicates that there are 209 teaching and research faculty in the OSU CoF. Yet less than twenty are involved in the management of the OSU Research Forests. Why? Where are you guys? Do you not feel that this forest is a public resource deserving of your respect and involvement? I’m not sure which
Land Use Zoning
2.7 “Visitor Use” p. 42
2.5.1 Land Use Zoning.
There is an omission in this paragraph. Trails are “infrastructure.”
Other uses within a forest conservation zone are considered ‘conditional’, meaning that some activities may be allowed, but only under certain predetermined conditions. Both Goal 4 and Benton County Chapter 60 specify outdoor recreation opportunities as important and protected resources within Forest Conservation Zones, and recreation is fully embraced by research forest staff. However, the development of infrastructure (e.g., parking, toilets) to support these recreation opportunities is considered a conditional use which is potentially inconsistent with the overarching land classification (forest conservation) but deemed beneficial or necessary in specific situations or locales.
The above paragraph clearly misrepresents the Benton County Conditional Use Permit required for recreation on land zoned as “Forest Conservation.” It appears from the text that the county embraces recreation on “Forest Conservation” zoned land. This is simply not true. A Conditional Use Permit was required and signed by both OSU and Benton County in 2017. And the plan glosses over what is included in infrastructure. Trails are infrastructure. New trails are prohibited by the 2017 Conditional Use Permit. Indigenous animals and spreading recreational use, especially “unauthorized” mountain bike use in the unroaded areas.
In fact, the plan notes that the OSU CoF doesn’t even know what indigenous animals exist in the forest, let alone if they are being impacted by recreational use. Logging a site has a huge immediate impact upon many animal species, but they simply move aside while the logging activity occurs. Recreational usage is insidious, always present along usage corridors and frequently has a larger impact than the intensive short-term logging activities.
The plan states on page 86: “Managers can minimize these potential negative impacts by naturalizing unauthorized trails where feasible, building trails and roads to meet sustainable standards, and leveraging education and messaging to help positively influence compliance on trails.”
“Naturalizing unauthorized trails?” What the hell does that mean? If it means closing them down, then this is simply a lie. The CoF as well as other land managers know full well that it is impossible without serious on the ground policing complete with fines to stop the construction of unauthorized trails. And legitimizing “unauthorized” trails as has been so often the case in the McDonald “Research” Forest demonstrates an ignorance of recreation planning. This does nothing to reduce the impacts to vegetation, wildlife, invasive species spread by usage of these trails. The lack of a trails plan is a severe shortcoming of this plan. Allowing mountain bikers to cut in “unauthorized” trails with no negative repercussions and then legitimizing those same trails just encourages the mountain bike community to cut in more “unauthorized” trails, which CoF will legitimize, ad infinitum.
Page 87:
Emergent technologies: There are significant management challenges associated with changing outdoor recreation technologies and emergent visitor uses. Electric-powered devices such as e- bikes, hoverboards and e-unicycles are among the new types of recreational uses on forest trails, although they are prohibited in the McDonald-Dunn Forest. These technologies and vehicles are increasingly impacting how visitor use is managed in non-motorized nature-based environments, and their potential for social and environmental impacts continues to be explored and studied. As long as users know that there is no physical presence of CoF personnel in the McDonald-Dunn Research Forest or any enforcement of rules, there is no point of even discussion things like “Emergent technologies” E-bikes, especially run rampant in the forest, unimpeded by the tiny “No E-bike” signs posted. To adequately manage recreational activities requires a significant presence on the ground of CoF personnel. As long as CoF does not allocate resources for this, all discussion is simply that—discussion.
Page 89:
Guidelines for Visitor Use: Following the initiation of the 2025 McDonald-Dunn Forest management plan, a separate McDonald-Dunn Forest visitor use management planning (VUMP) process will commence. The new VUMP will expand on these guidelines and provide a more detailed outline of policies and practices related to trail development, improving access, recreation research and monitoring, hunting, education and interpretation, volunteers, and other visitor programming on the research forests. There seems to be a misconception among the authors of this plan. No further infrastructure development, including trail development is allowed under the 2017 Conditional Use Permit from Benton County without a further conditional use permit being approved by Benton County.
3.7.2 Wildland/Urban Interface
Page 90:
Intrusion:
Intrusion into the forest from the WUI expands two management issues: potential encroachment of non-native plants onto forest property and the creation of unauthorized trails from adjacent private lands into the forest.
This is simply self-serving nonsense. See that first isolated dot along the lower left (SW) border on Figure 24? That’s my house. Invasive herbaceous species, at least fifteen that I, as a non-botanist, can identify, have spread onto our property from the McDonald Forest like a tsunami wave. I’ve beaten invasives back for ten years. The intrusion is from the McDonald Forest onto my private land, not the other way around. Others adjacent property owners have reported the same problem to me.
The authors also seem to have not included fire as an “intrusion.”
Again, from the McDonald Forest onto my private land.
CoF personnel only seem to see woody vegetation—trees and shrubs in relation to WUI fires. But ask any WUI professional (For elucidation, I have a Ph.D. related to WUI fire issues) and they will tell that weeds and grasses carry fire faster and spread embers farther and more quickly than woody vegetation. For ten years I’ve protested the fire hazard resulting from uncontrolled invasive weeds that grow annually to five feet tall between my property and the Oak Creek parking area, which on a typical day sees a hundred vehicles. Just one loser among these hundreds of people; just one flipped cigarette butt; just one kid playing with matches; just one hot exhaust pipe touching the weeks growing hard against the asphalt; just one loser and poof, these weeds carry flames to my property. Intrusion from OSU land onto adjacent private property truly is a problem.
As mentioned in section 3.6.2, a recent fire risk analysis indicates higher burn probabilities immediately outside rather than inside the McDonald-Dunn Forest (Scruggs 2024)
I guess Scruggs must not have investigated the situation at the Oak Creek entrance to the McDonald Research Forest. In fact, when I requested that CoF personnel come review the wildfire hazard presented by the weeds behind my barn, DeLuca told me that CoF had its own professionals and refused to send anyone to review the situation. If this is the typical interactions between CoF and adjacent property owners, we are all in trouble.
Page 94:
Example 3: Team Dirt - The OSU research forests partner with the Corvallis chapter of Team Dirt, a Chapter of the International Mountain Bike Association (IMBA). Team Dirt is a nonprofit, volunteer organization that works in partnership with the forest and other local agencies to build and maintain trails throughout the Willamette Valley. The organization is dedicated to the stewardship of sustainable, multiple-use, and purpose-built trails, to preserve access for mountain bikers through advocacy and education, and to promote responsible trail use. Team Dirt works closely with McDonald-Dunn Forest staff to design, build, and maintain sustainable, primary- use and multi-use trails that better meet the needs of the mountain bike community. The radical fringe of mountain bikers hack in “unauthorized” trails and then Team Dirt comes to the CoF to volunteer to upgrade the unauthorized trail into an established trail. CoF then agrees and a new trail is constructed where none was proposed by CoF due to a lack of a recreation plan. Thus, no consideration for the impact upon shy wildlife, since CoF has no recreation plan, let alone a plan for native wildlife, for which it has virtually no information. Currently (June 2025) Team Dirt is building a new trail in the Oak Creek drainage. CoF is allowing this construction, even though the 2017 Conditional Use Permit prohibits new trail construction. Unregulated mountain bike activity has resulted in the spread of invasives and negative impacts on wildlife and water quality.
Page 96:
Strategy 4: Invest in new signage at key areas – specifically Peavy Arboretum – to better describe the history of Kalapuyan Peoples on this land, the mission and goals of the forest, as well as the role active management has played in creating the forest conditions the community has come to love.
Have any of the authors of this proposed plan actually visited the Peavy Arboretum? Old Peavy must be flopping over in his grave at the condition of the arboretum. It is a shambles. An offense to the title “Arboretum.” It is mostly a mess of invasive species, most obviously English ivy and English holly, but including many others. If this area demonstrates the attitude of the OSU CoF towards its stewardship of the public land under its management, us Oregonians who own this land as well as all the flora and fauna that call it home are all in trouble. I’m skeptical that a Kalapuyan transported ahead two hundred years would be pleased at this disgrace to the title “arboretum.” “Please don’t put up signs with my name on it,” that Kalapuyan would plead, “This mess is nothing that I recognize.”
I’ll complete my comments with a note about OSU and indigenous people. The plan contains considerable verbiage about indigenous people this and indigenous people that, but there is, in reality, only one true documented connection between OSU and the indigenous people of Oregon. That is the Morrill Act. The plan glosses over this so quickly that the typical reader will miss it. But here are the facts (and these facts are readily obtainable, all the way down to exact parcel numbers). Under the Morrill Act, OSU received indigenous land valued at $20 million, expropriated from indigenous people by the Federal government. Twenty Million Dollars! This is where the “land” in “Land Grant” came from. I suspect that many others are like me; I previously thought the idea of “Land Grant Universities” was a generous action by the Federal government to encourage educational activity related to our land, when in fact, it was a disgraceful, even disgusting action, essentially stealing indigenous land. OSU should be careful proudly calling itself a “Land Grant University.”
Writing in this plan that OSU will allow indigenous people to collect plants and such must be an insult to them. A pittance. Why not do something meaningful? Why not set aside a significant portion of the McDonald “Research” Forest as a reserve honoring indigenous people? The Oak Creek Drainage, for example would be easily definable. This drainage contains much of the older forest in the McDonald “Research” Forest. A Kalapuyan transported ahead two hundred years might actually recognize some of it. There could be an interpretive center located in one of the unused buildings at the parking area. When I suggested this to DeLuca several years ago, he had two possible responses: 1) “This is an idea worth discussing further, including with the tribes; or 2) “Cook didn’t get input from the tribes before suggesting this, so we can ignore him.” DeLuca, of course, chose the second response. Does this reflect the true CoF attitude towards indigenous people? Why not do something truly meaningful, not only to recognize the existence of Kalapuyans in this area, but also as a gesture to the Oregonians that believe some of the forest should be exempt from logging.
Hello to those it should concern,
Please accept these brief reactions to the Draft McDonald-Dunn Forest Plan
My primary concern with this draft plan relates to the protections for old-growth forest stands and their trees. I am especially concerned that the draft plan reduces protections for older trees and stands by removing the previous 160-year limit for felling older trees throughout the forest. All old-growth trees need to be protected. In addition, protections for forested areas that will soon qualify as old-growth needs to be strengthened. The draft plan clearly needs revision to provide more adequate protections for all forest stands, that are presently 80 years old or older, so that they can develop the full suite of old-growth forest characteristics and conditions. The coast range presently is seriously deficient in relation to the area of forest with old-growth characteristics, and as a public forest area, responsibility for acting to protect and enhance the development of old-growth forested areas is an especially important management responsibility. This responsibility is highly significant, given the importance of older forested areas for carbon sequestration.
The carbon sequestration and climate change implications of this plan need much more extensive and careful consideration. At this point, this plan does not adequately incorporate the best available science into its processes and conclusions. Given that this plan involves responsibility for management of a significant forested area in the state of Oregon by a major academic institution, I feel that climate change implications warrant more complete exploration and incorporation into your planning process.
The above considerations for shifting your management paradigm are fundamental to the lessons forest managers need to learn for the future of this region’s forests. As a research forest, new and different lessons need to be learned. These lessons need to focus on an ecological approach to forest management rather than the present industrial model for forest management, with its emphasis on short rotation logging.
Given that the draft plan applies an industrial forest management paradigm to the majority of the McDonald-Dunn forest, clearcutting and regeneration harvests fundamentally fail as management practices that fit an ecological management approach to forestry. We already have a substantial experience base for industrial forestry, and as a research forest, learning more about an ecological management approach to forest management is something that is badly needed and should be implemented more fully.
More adequate recognition of the greenhouse gas emissions from industrial forest management needs to be incorporated into this plan. I would expect this to result in a lower emphasis on the use of clearcuts and regeneration harvest practices. Your management should result in both a reduction of greenhouse gas emissions and an increase in the greenhouse gas sequestration as you appropriately transition to a more ecological paradigm for forest management.
The draft plan will produce extensive areas of tree plantations that will bring a substantial increase of fire risk into the McDonald-Dunn Forest ecosystem. This consideration is especially significant given the projected implications of climate change, with its more extreme temperatures and drying of our forested landscapes. Note, the drying effects of clearcuts extend into surrounding forested areas which not only increases fire risk but also reduces the beneficial habitat characteristics of the associated older forests.
I trust the teams involved in developing this forest plan realize the extensive and impactful adverse consequences of the clearcut/industrial approach to forest management. Therefore, I will resist the temptation to present a full litany of those substantial negative impacts.
I have a substantial interest in and involvement in the biodiversity implications of forest management. The draft plan fails to adequately account for the biodiversity impacts of logging with shorter rotations where you propose to do that kind of logging. The number and diversity of taxa that are considered in your modeling are not adequately representative for the full suite of old-growth organisms. Short rotation forest management leaves a forest seriously deficient in the dead wood component of a forest ecosystem, and that impacts the availability of important ecological niches available for the relevant organisms.
Finally, my thoughts as articulated above represent the input of a person who has studied and taught forest ecology in Oregon’s forested ecosystems for more than the last 50 years. They also likely reflect the sentiments of a major portion of Oregon’s thoughtful residents.
Thanks for your consideration,
Trygve Steen, Ph.D.
Profit margin seems to be the highest priority for this forestry plan. In addition to the forest that are slated for clear cutting, the restoration efforts feel like a thinly veiled way to log more sensitive areas containing more old growth trees. The forestry plan describes a desire to return to a habitat created by native peoples in the pre-industrial time. This does not reflect the needs of the people of the 21st-century. This restoration plan also does not consider that when native people created the oak savanna habitat to support the camas fields that were a necessity to their way of life they had an intact ecosystem (likely dense coniferous forests) surrounding the habitat that had been not impacted by the low intensity burns and camas propagation. In our current environment, the area surrounding our OSU forests are primarily dominated by agricultural or residential use. This current ecosystem fragmentation does not allow for non-human populations to migrate and flourish. The Willamette Valley has sparse intact tracts of forests that provide shade to cool and retain water and allow for filtration of the watersheds affected.
I am concerned that this forestry plan is truly crop rotation plan described either as restoration, fire management and only partially earmarked for timber sales. This plan over time will deplete not only the soil as we cut our 2nd or 3rd crop of trees from this land but also disrupt small fragment of beautiful habitat that we are fortunate enough to steward in the Willamette Valley.
The other concern that seems glaringly obvious is that the only forestry practice that is being “ studied or researched” utilizes clear cutting for removal of trees slated for timber sales. I would have hoped for application of a more nuanced assessment and approach to logging our well utilized (and loved) forests which might prioritize protection of “mother trees”/ old growth trees within areas of logging and by prioritizing shading/cooling (as the global temperature rises), water retention (as threat of drought conditions increase), maintaining stabilization of hillsides and waterways for maintaining habitat for existing aquatic and land species and for enjoyable recreation by the public, (which is the current human use of the OSU forest not camas farming) by applying selective logging practices. Globally, forests that are in high human use areas are selectively logged to lower the impact on both human use and non-human use rather than maximizing profits. I would love to see a plan which reflects current human use with low impact selective logging that maintains a healthy unfractured ecosystem for the plants and animals that currently call the OSU forests their home.
Thank you for providing a public comment period,
Helen Tennican
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).
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.
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.
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.
My significant concerns about the plan include:
• It allocates 40% of the forest to “even-age, rotational forestry” - which means we’ll see lots of clearcutting in the forests for years to come. Oregonians are overwhelmingly opposed to clearcutting. The College of Forestry should be promoting ecological forest stewardship, not ecologically-destructive forestry practices!
• Only 10% of the forest will be designated “late-successional forest” despite broad community support for protecting more of the forest. This plan does NOT honor public input or community values!
• Restrictions on cutting older trees will be substantially reduced, as the 160 age-limit will be removed. OSU’s foresters will be given broad discretion to cut older trees in the name of “public safety” and to create their desired stand conditions.
• The plan ignores watershed boundaries and fails to include buffers around older stands, increasing fragmentation of the forest. This diminishes the ecology and biodiversity of the forest.
• The plan’s reliance on the Oregon Forest Practices Act as the only enforceable standard is inconsistent with OSU’s desire to be a leader in forestry education. The OFPA is a very low bar and does not exemplify leadership in forestry practices!
• Destructive practices, such as herbicide spraying and slash burning, will continue to be used widely throughout the forest, despite broad public opposition to these practices.
• The plan echoes industry propaganda on topics like forest carbon sequestration and biomass energy, and reflects poorly on OSU’s scientific integrity.
• The plan fails to address climate change in any meaningful or substantive manner. The wood products industry is the largest contributor to GHG emissions in Oregon. OSU ought to be leading the way in addressing these problems, but the plan lacks specifics and accountability in this area.
Thank you for your consideration of my 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."