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."
Chris Lorenzen
07/18/2025
After reading through most of your proposed management plan, I have a few very important comments.
I've been an Oregon resident in Benton County for over 33 years and have enjoyed many weekly hikes in the state forest, specifically Peavy Arboretum. In fact, during Covid lockdown, this was a daily activity to keep my family sane. I also have a friendgroup that hikes the various McDonald and Dunn State forest trails every week all year long.
Your current proposal to reduce the area of cutting size down to under 40 acres is disturbing and I don't support this idea. Many old growth trees will be lost forever around Cronemiller lake, which is one of the most scenic areas in and around Peavy.
I don't support clearcutting this forest one bit.and the practise of cutting one-third of the timber every 20-30 years. Keeping the larger (older growth forest) should also be spared.
Rene Zamora
07/18/2025
"Thank you for the opportunity to review the draft of the plan. Please consider the following recommendations as constructive suggestions intended to support the continued refinement of the document. As a new faculty member, I acknowledge that some of these points may already have been addressed, but I hope they prove helpful. My comments are informed by my background in the field, particularly in optimization, which frames my perspective. • Inclusion of Water as a Forest Value: It is not clear how water is accounted as a critical forest value. It was not explicitly included in the metrics developed to evaluate trade-offs across land allocation scenarios (Table 4). Clarifying this or incorporating water-related impacts and tradeoffs may strengthen the plan. • Job Type Differentiation: In the job-related metrics, it would be beneficial to distinguish between permanent and temporary jobs, as each has distinct social implications and contributes differently to community. • Monitoring and Sustainability Index: I recommend considering the development of a sustainability index for the entire McDonald-Dunn forest as part of the monitoring framework. This index could synthesize various desired impacts into a scorecard format, allowing for both disaggregated and aggregate analysis. Such a tool may also enhance communication with the public by presenting progress in a clear and accessible manner. Like the health of the patient, being the patient the landscape and forest. I can help with that if required. • Woodstock Model: Would it be possible to review the Remsoft Woodstock model used in the analysis, particularly how the constraints were handled? This would allow for more detailed feedback and potentially support further refinement of the model's structure and assumptions."
Dale Draeger
07/18/2025
I have often ridden my horse or driven on Tampico Road past OSU Forestry land after a harvest. It is called a ‘research’ forest, but this is difficult to understand because the same practices are done over and over. Passing a clear cut, one can see that there are just a few trees left standing, separated from each other. Months pass. Here comes the wind and rain and those solitary trees have no protection and they die or are blown down. If someone is doing research, surely they could see that this practice doesn’t make for an environment where trees thrive! Where is the study, where is the learning here? Trees like to group, hence the phrase, ‘stand of trees’. It appears pretty obvious that OSU functions more on a logging company model. Years ago Dunn Forest was a heaven of beautiful trails. Mountain bikers had affectionate names for the trails through the trees and ferns. Now the trails and trees are gone. What remains is bulldozed ground. Is the importance to you about this ‘Public Land’ all about how much money you can make? I know for sure that is not every student’s reason for enrolling in Forestry at OSU. Many who enroll want to preserve what little old growth we have left in our state/country. Let’s give them something to get inspired about! Can OSU be an inspiration for change and preservation? Now that would be something to be known for! Not giving a student the ability to be hired by a logging company.
Amanda Larson
07/18/2025
I am a very concerned resident of Corvallis with the OSU proposed forest management plan. The proposed plan would have disastrous environmental consequences that will compromise the health and safety of the forest and community. Expanding the practice of clear cutting to 40 to 80 acres will have catastrophic impacts to wildlife, recreation, watersheds and ecosystem diversity. As a research institution and facility of higher learning, you should know better! Another area of concern is the expansion of logging into old growth areas of the forest. These areas are critical to biodiversity and once they are gone, they do not come back! Please protect the very little old growth that remains in the forest. When is OSU going to change course from short term profit, to recognizing the more important long term value that a healthy forest brings to this community? Why is OSU not focused on becoming a leader in selective, sustainable forest management? Why has OSU failed to value and protect this vital resource that has so much to offer future generations? This matter hits deep within our immediate family. My family survived the devastating Paradise wildfire in 2018, due to climate change, and the negative changes to our forests. I do not want others to go through what our family had to go through. We need to HEAL our forests!! We need to COLLABORATE and PROTECT our forests for future generations before it is too late. This plan is a disgrace. Please do not implement this plan and reconsider protecting and being stewards of the land that you are responsible for managing. Greediness is the main reason why humans, the earth, and all the living things are profoundly suffering. Please care about our community, the plants, and the animals that live here. Let's create, not destroy! Be the leaders in sustainable forest management!!
When you know better, do better!
Seth A Barnes
07/18/2025
Attn: Oregon State University College of Forestry 140 Peavy Forest Science Center 3100 SW Jefferson Way Corvallis, OR 97331
RE: Draft 2025 MacDonald-Dunn Forest Plan
Dear Oregon State University College of Forestry,
Thank you for the opportunity to provide feedback on the Draft 2025 MacDonald-Dunn Forest Plan (draft plan). The Oregon Forest Industries Council (OFIC) is a statewide trade association representing large private forest landowners and wood products manufacturers in Oregon. OFIC’s core mission is to advocate on behalf of its members to maintain a positive, stable business operating environment for Oregon's forest products community that fosters long-term investments in healthy forests; to ensure a reliable timber supply from Oregon's public and private forestlands; and to promote stewardship and sustainable management of forestlands that protect environmental values and maintain productive uses on all forestlands. OFIC members’ businesses employ tens of thousands of Oregonians in Oregon’s forest sector, including many professional foresters, engineers and managers who are alumni of the College of Forestry (COF) at Oregon State University (OSU). Central to the mission of land grant universities are the ideals of education, scientific research and outreach, to promote economic development through practical application of knowledge. The OSU COF website lists its mission as an effort to “explore, evaluate, communicate and catalyze new possibilities in forestry and advance sustainable solutions to challenges facing society.” As a research forest owned and operated by the OSU COF, the MacDonald-Dunn Forest (Mac-Dunn) is a direct reflection of those combined missions. The forest was donated with the intention of being actively managed to provide a living laboratory to students and faculty to explore, experiment, study, learn and demonstrate the values, ideals and possibilities surrounding forestry. The COF has a key role in educating tomorrow’s professional forestry workforce, generating world class research that supports sustainable management of public and private lands and demonstrating to the lay public what sustainable, actively managed forests look like. With this in mind, and in the spirit of constructive feedback intended to improve the plan to better achieve these objectives and aspirations for the Mac- Dunn Forest, OFIC offers the following important critiques.
1. The draft plan must keep management as a goal of every acre of the Mac-Dunn, with a particular focus on harvest and reforestation. Manipulating forest composition and structure is achieved primarily through harvest and reforestation - which are the basic tools of silviculture. The goal of the forest should always be to use active management to achieve desirable outcomes. We are concerned that this plan more than doubles the number of acres that will be designated on a trajectory towards late-successional forest. There are ample living laboratories of late successional forests in Oregon already: the Elliot State Research Forest, the H.J. Andrews, and the hundreds of thousands of acres set aside by the U.S. Forest Service and Bureau of Land Management, to name a few. It’s implied within the draft plan that many of the acres that will be slated for this designation on the Mac-Dunn are currently of a younger age class and would benefit from activities to accelerate their trajectory towards a late- successional forest type. Furthermore, within the description of the Late-successional Forest Management Strategy, on page 63, the plan implies that areas where older forest already exists, no harvest will occur unless they are individual trees that must be removed for safety concerns. OFIC urges the COF to reconsider the plan to designate more acres going into this category, only to stagnate in perpetuity. Rather, the COF should use the abundant forests already available - as listed above - to conduct research on old forest reserves. On the acres already existing on the Mac Dunn in a late-successional state, it is our strongly held belief that the COF should utilize these areas to promote active management practices and challenge the dangerous and pervasive no-management paradigm that has led to catastrophic wildfires and insect infestations across thousands of acres of late successional reserves and wilderness areas on public lands throughout the western United States. Research has shown that harvest is an effective tool for increasing forest resiliency and preventing low-intensity fires from becoming stand-replacing events. If the COF desires to study and manage late successional forests, this should be done in combination with a research strategy that explores how to actively manage such forests to promote forest health and resiliency as well as economic opportunity. No trees in the Mac-Dunn should be precluded from harvest. Rather, the plan should give professional foresters the latitude to treat stands in accordance with sound forestry principles to promote the goals outlined above. Doing this will ensure that the COF stays on mission as a land-grant university.
2. Share more details on what went into the modeling, consider using a higher discount rate and explain the assumptions and constraints that were embedded in the modeling. In reviewing the modeling information that was provided, we found it odd that in some of the scenarios, despite more acres allocated for early harvest (“short rotations”), which would also presumably be acres that would require early harvest of older forests, the model was predicting a lower overall net revenue. Given that all discounted cash flow models prefer early returns on investments, this seems flawed. Subsequent conversations uncovered two potential reasons for this unexpected conclusion in the modeling: first, the use of a lower than industry standard discount rate (four percent), and second, a constraint on the model forcing it to harvest at an arbitrary average age that may be lower than optimal for the site classes associated with much of the Mac-Dunn Forest. The use of a four percent discount rate is inappropriate for the Mac Dunn. That discount rate is on the low end of what is used in state and federal discounted cash flow models. An industry standard of six to eight percent may be more appropriate. It was presented that four percent was used because that is the rate of return that the college could achieve with the best alternative investment. However, this is only half of the equation when picking an appropriate discount rate. We recommend that the college follow the standard practice of using the discount rate to account for other risks such as wildfire, insect outbreaks, disease or pathogens, market risks such as mill closures and log price fluctuation, regulatory risks, and social risks, all of which could lead the college to higher constraints and lower revenue production. When all these risks are considered, a strong case is made for a higher discount rate than the four percent that was used. Furthermore, it would behoove the COF to remove the distinction of “short rotation” altogether and instead let the model find the optimal harvest volume at the age it chooses, while using an appropriate discount rate and other relevant constraints. This is, in fact, how most of the industry does similar modeling - we are unaware of any landowner that artificially constrains their modeling efforts to harvest at certain average ages. Given the site classes associated with the Mac-Dunn, it is possible that a rotation closer to 50 to 60 years may be optimal. OFIC recommends re-modeling with a higher discount rate - closer to industry standard - without an artificial constraint for a particular age, thus allowing the model to find the optimal harvest rotation for the forest. This could be re-imagined as a “sustainable harvest strategy” and replace both the “short” and “long” rotation strategies currently listed. It would likely result in higher volume and revenue outputs, and more closely align with private land management, which would allow better opportunities for studies more relevant to the forest sector in Oregon.
3. Add language that clearly articulates the parameters around what constitutes an “appropriate” time or circumstance for pursuit of an alternative revenue stream for the Mac-Dunn. On page 58 of the draft plan, it states that “adaptive funding strategies will be pursued when appropriate.” Alternative revenue streams should be pursued only when they fit the mission, vision and purpose of the OSU COF as a land grant university, and the Mac- Dunn as an “actively and sustainably managed forest.” It would be inappropriate to adopt an alternative funding source that would constrain the COF’s ability to harvest or otherwise alter standard and accepted sustainable forestry practices. To do so would be off-mission and harm or completely dismantle the university’s ability to deliver on their land grant purpose to the sector and to the citizens of Oregon. This would be a devastating outcome, one that should be avoided by providing clearly articulated expectations for these potential alternative revenue streams up front in the plan itself.
4. Provide additional inventory data and projections. The draft plan is missing key data that is standard in many management plans. The plan is missing an estimate of current or projected timber volume by species, estimated volumes by land management objective over time, estimated growth across the forest, etc. We would like to see the planning horizon and planning periods presented in the model. These planning horizons should be at least two full rotations in length in order to capture how the proposed silvicultural prescriptions will change the forest over time as each stand is transitioned from current condition to the regenerated condition under a 2 LP harvest scheduling model. We would also like to see more detailed information regarding the standing live tree inventory, standing dead and periodic growth across the forest. Currently the draft plan provides sparse details, primarily on page 47, showing only the current average age classes and a three paragraph, broad description of site class, species composition and tree heights.
5. Provide additional information regarding targets and baselines for measuring the relative success of the draft plan. There was no baseline or minimum amount of revenue identified as necessary to pay for staff, maintenance, etc. Without this clear benchmark the forest is at risk of running a deficit. Furthermore, there is no clearly defined revenue goal. Without these factors, it is difficult to understand the benchmarks for success of this plan from a revenue perspective.
6. Certain statements in the draft plan should be removed or re-written. We request that the COF review the plan for language that should be written more clearly or more appropriately. Below are a couple of examples:
a. On page 58 the draft plan states that “the funding model for the research forests was created at a time when research forests nationwide functioned like industrial plantations.” This statement is incredibly broad and presumptuous and is not supported by tangible evidence. There are no references in this document to the history of other research forests across the nation, nor is there an explanation as to what is meant by the phrase “industrial plantations.” Surely it is not the conclusion of the COF that forests across all private land ownerships nationwide were historically managed in a homogeneous manner. This is a paragraph that should be re-written with clear language that removes bias and overly broad or false statements.
b. The use of the term “short rotation” throughout the document should be reconsidered. What is short? This is a term that betrays a universally-agreed-upon definition. Section 2 of these comments offers a helpful alternative to such a subjective, value-laden language.
OFIC values the symbiotic, collaborative relationship that has existed between Oregon’s forest sector and the COF at OSU. The land grant mission of the university is the foundation of that relationship, and as such, should always be reflected in the purpose and goals expressed in the management plan for the Mac Dunn Forest. OFIC appreciates the opportunity to offer these comments on behalf of our members for ways that this plan can be improved to better reflect and deliver on this broad mission and looks forward to continuing its long and fruitful relationship with the OSU COF.
Sincerely, Seth A Barnes>br> OFIC Director of Forest Policy OSU Alumni, FM, Class of 2002
Damon Motz-Storey
07/18/2025
Oregon State University Board of Trustees
652 Kerr Administration Building
Corvallis, OR 97331
Submitted via email
Subject: OSU’s Draft Management Plan for the McDonald-Dunn Forest
Dear OSU Trustees,
On behalf of the 58,000 statewide members and supporters of the Oregon Chapter of the Sierra Club, we
urge you to advocate for better stewardship of the public forests under OSU’s management. As the
highest oversight body of our public university, you are the ultimate stewards of these amazing natural
resources that belong to all Oregonians.
The Oregon Chapter has long encouraged OSU to prioritize ecological considerations and public values
over OSU’s traditional management and monetization of the research forests. The Sierra Club’s core
values reflect both the best available science and the public interest, which align with protecting older
forests. These same values ought to coincide with OSU’s educational and research missions.
Unfortunately, the draft management plan for the McDonald-Dunn Forest falls short in a number of
alarming ways. The substantial amount of clearcutting and lack of meaningful protections for older forests
are both contrary to scientific leadership and the public interest. The continued focus on industrial
forestry, with its adverse impacts like herbicide use and slash-burning, contrasts sharply with the lack of
consideration of ecological forest management. The deliberate removal of specific protections for older
forests (like the 160- year cutting limit) and expansive allowance for discretionary cutting (under the guise
of restoration, fuels reduction, and public safety) are deeply concerning. The reliance on the low bar of the
Oregon Forest Practices Act and the absence of enforceable constraints is equally alarming. The plan is
full of “guidelines” and “recommendations”, but lacks meaningful and firm commitments.
We are also deeply concerned by the echoing of timber-industry propaganda and the lack of substantive
measures to mitigate climate change. Numerous studies, including those of renowned OSU scientists,
have concluded that the forest sector contributes ~1/3 of our state's total GHG emissions.1 The language
of the draft plan seems designed to downplay the pivotal role of forest carbon sequestration in addressing
the climate crisis. This is especially disappointing, as OSU’s own scientists have been leaders in the field of
forest carbon and climate research for decades. The plan’s forest carbon metric ignores below-ground
carbon losses, skewing the results in favor of clearcutting, which dramatically reduces carbon stored in
the soil. These are just a few examples of the systemic bias that can be found throughout the draft plan.
The College of Forestry’s technical competency is also undermined by the draft plan’s reliance on
Woodstock software, a traditional linear modeling tool which is heavily biased in favor of traditional
timber management. The resulting metrics are largely meaningless. The same goes for the surveys of
forest users, which falsely concluded there are relatively minor differences in public perception of
clearcuts vs. older forests. Independent surveys have repeatedly found that a large percentage of
Oregonians are opposed to clearcutting and favor increased protections for older forests.2 Despite facing
overwhelming criticism for these types of shortcomings, OSU has failed to address them in the draft plan.
The continual reluctance of the planning team to improve their approach undermines confidence in the
draft plan and the College of Forestry’s integrity and competence.
We have previously shared our deep concerns about the biases in the process used to develop this forest
plan.3 It does not come as a surprise that the resulting plan is heavily skewed toward industrial forestry at
the expense of ecological considerations. What is perhaps most disappointing is that the OSU
administration has failed to take effective corrective actions along the way. State law calls on the trustees
of our public universities to provide transparency and public accountability. OSU’s draft plan for the
McDonald-Dunn and the flawed process that produced it show that public accountability is largely absent.
We call on you to intervene and reset the forest planning process. It is time for OSU to demonstrate better
stewardship of this public forest.
Respectfully,
Damon Motz-Storey
Oregon Chapter Director, Sierra Club
1821 SE Ankeny St, Portland, OR 97214
Susan Salafsky
07/18/2025
I am deeply concerned about the proposed management plan for the MacDonald-Dunn Forest, because it prioritizes short-term profits from historical forest management practices over the sustainability of public resources. Thus, as written, the current forest management plan is counterproductive to long-term profits and forest health. Accordingly, it is in our best interests to revise the OSU draft forest management plan. To increase efficiency, the plan should include strategies for developing landscape characteristics that mitigate the impacts of extreme weather and wildfires on forest habitat quality AND improve timber production, while increasing biodiversity, enhancing water retention, and sequestering carbon. This can be accomplished by:
* Retaining ALL trees greater than 80 years old. These legacy and heritage trees provide habitat for numerous species in addition to shade, water, and nutrients. Consequently, older trees increase forest productivity and are critical to withstanding the greater frequency, duration, and intensity of climate extremes. * Restricting thinning and harvesting to younger forest stands and trees less than 80 years old. As a result, most of the MacDonald-Dunn Forest (2/3) would still be subject to active timber management and generate revenue. * Using protective buffers, irregular edges, and structural complexity in timber harvests to create microclimates, microhabitats, and an evolving mosaic of environmental conditions.
We do not have to sacrifice the health of our forests to obtain wood products and reap profits. So, before finalizing the MacDonald-Dunn Forest Management Plan, please incorporate ecological principles and holistic strategies to increase the resilience of forests, and ultimately our economic stability, in a rapidly changing environment. Thank you for your consideration.
Forest Management Plan Draft Comments
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."
After reading through most of your proposed management plan, I have a few very important comments.
I've been an Oregon resident in Benton County for over 33 years and have enjoyed many weekly hikes in the state forest, specifically Peavy Arboretum. In fact, during Covid lockdown, this was a daily activity to keep my family sane. I also have a friendgroup that hikes the various McDonald and Dunn State forest trails every week all year long.
Your current proposal to reduce the area of cutting size down to under 40 acres is disturbing and I don't support this idea. Many old growth trees will be lost forever around Cronemiller lake, which is one of the most scenic areas in and around Peavy.
I don't support clearcutting this forest one bit.and the practise of cutting one-third of the timber every 20-30 years. Keeping the larger (older growth forest) should also be spared.
"Thank you for the opportunity to review the draft of the plan. Please consider the following recommendations as constructive suggestions intended to support the continued refinement of the document. As a new faculty member, I acknowledge that some of these points may already have been addressed, but I hope they prove helpful. My comments are informed by my background in the field, particularly in optimization, which frames my perspective.
• Inclusion of Water as a Forest Value: It is not clear how water is accounted as a critical forest value. It was not explicitly included in the metrics developed to evaluate trade-offs across land allocation scenarios (Table 4). Clarifying this or incorporating water-related impacts and tradeoffs may strengthen the plan.
• Job Type Differentiation: In the job-related metrics, it would be beneficial to distinguish between permanent and temporary jobs, as each has distinct social implications and contributes differently to community.
• Monitoring and Sustainability Index: I recommend considering the development of a sustainability index for the entire McDonald-Dunn forest as part of the monitoring framework. This index could synthesize various desired impacts into a scorecard format, allowing for both disaggregated and aggregate analysis. Such a tool may also enhance communication with the public by presenting progress in a clear and accessible manner. Like the health of the patient, being the patient the landscape and forest. I can help with that if required.
• Woodstock Model: Would it be possible to review the Remsoft Woodstock model used in the analysis, particularly how the constraints were handled? This would allow for more detailed feedback and potentially support further refinement of the model's structure and assumptions."
Expanding the practice of clear cutting to 40 to 80 acres will have catastrophic impacts to wildlife, recreation, watersheds and ecosystem diversity. As a research institution and facility of higher learning, you should know better!
Another area of concern is the expansion of logging into old growth areas of the forest. These areas are critical to biodiversity and once they are gone, they do not come back! Please protect the very little old growth that remains in the forest.
When is OSU going to change course from short term profit, to recognizing the more important long term value that a healthy forest brings to this community? Why is OSU not focused on becoming a leader in selective, sustainable forest management? Why has OSU failed to value and protect this vital resource that has so much to offer future generations?
This matter hits deep within our immediate family. My family survived the devastating Paradise wildfire in 2018, due to climate change, and the negative changes to our forests. I do not want others to go through what our family had to go through. We need to HEAL our forests!! We need to COLLABORATE and PROTECT our forests for future generations before it is too late.
This plan is a disgrace. Please do not implement this plan and reconsider protecting and being stewards of the land that you are responsible for managing. Greediness is the main reason why humans, the earth, and all the living things are profoundly suffering. Please care about our community, the plants, and the animals that live here. Let's create, not destroy!
Be the leaders in sustainable forest management!!
When you know better, do better!
Attn: Oregon State University College of Forestry
140 Peavy Forest Science Center
3100 SW Jefferson Way
Corvallis, OR 97331
RE: Draft 2025 MacDonald-Dunn Forest Plan
Dear Oregon State University College of Forestry,
Thank you for the opportunity to provide feedback on the Draft 2025 MacDonald-Dunn Forest Plan (draft plan). The Oregon Forest Industries Council (OFIC) is a statewide trade association representing large private forest landowners and wood products manufacturers in Oregon. OFIC’s core mission is to advocate on behalf of its members to maintain a positive, stable business operating environment for Oregon's forest products community that fosters long-term investments in healthy forests; to ensure a reliable timber supply from Oregon's public and private forestlands; and to promote stewardship and sustainable management of forestlands that protect environmental values and maintain productive uses on all forestlands. OFIC members’ businesses employ tens of thousands of Oregonians in Oregon’s forest sector, including many professional foresters, engineers and managers who are alumni of the College of Forestry (COF) at Oregon State University (OSU). Central to the mission of land grant universities are the ideals of education, scientific research and outreach, to promote economic development through practical application of knowledge. The OSU COF website lists its mission as an effort to “explore, evaluate, communicate and catalyze new possibilities in forestry and advance sustainable solutions to challenges facing society.” As a research forest owned and operated by the OSU COF, the MacDonald-Dunn Forest (Mac-Dunn) is a direct reflection of those combined missions. The forest was donated with the intention of being actively managed to provide a living laboratory to students and faculty to explore, experiment, study, learn and demonstrate the values, ideals and possibilities surrounding forestry. The COF has a key role in educating tomorrow’s professional forestry workforce, generating world class research that supports sustainable management of public and private lands and demonstrating to the lay public what sustainable, actively managed forests look like. With this in mind, and in the spirit of constructive feedback intended to improve the plan to better achieve these objectives and aspirations for the Mac- Dunn Forest, OFIC offers the following important critiques.
1. The draft plan must keep management as a goal of every acre of the Mac-Dunn, with a particular focus on harvest and reforestation. Manipulating forest composition and structure is achieved primarily through harvest and reforestation - which are the basic tools of silviculture. The goal of the forest should always be to use active management to achieve desirable outcomes. We are concerned that this plan more than doubles the number of acres that will be designated on a trajectory towards late-successional forest. There are ample living laboratories of late successional forests in Oregon already: the Elliot State Research Forest, the H.J. Andrews, and the hundreds of thousands of acres set aside by the U.S. Forest Service and Bureau of Land Management, to name a few. It’s implied within the draft plan that many of the acres that will be slated for this designation on the Mac-Dunn are currently of a younger age class and would benefit from activities to accelerate their trajectory towards a late- successional forest type. Furthermore, within the description of the Late-successional Forest Management Strategy, on page 63, the plan implies that areas where older forest already exists, no harvest will occur unless they are individual trees that must be removed for safety concerns. OFIC urges the COF to reconsider the plan to designate more acres going into this category, only to stagnate in perpetuity. Rather, the COF should use the abundant forests already available - as listed above - to conduct research on old forest reserves. On the acres already existing on the Mac Dunn in a late-successional state, it is our strongly held belief that the COF should utilize these areas to promote active management practices and challenge the dangerous and pervasive no-management paradigm that has led to catastrophic wildfires and insect infestations across thousands of acres of late successional reserves and wilderness areas on public lands throughout the western United States. Research has shown that harvest is an effective tool for increasing forest resiliency and preventing low-intensity fires from becoming stand-replacing events. If the COF desires to study and manage late successional forests, this should be done in combination with a research strategy that explores how to actively manage such forests to promote forest health and resiliency as well as economic opportunity. No trees in the Mac-Dunn should be precluded from harvest. Rather, the plan should give professional foresters the latitude to treat stands in accordance with sound forestry principles to promote the goals outlined above. Doing this will ensure that the COF stays on mission as a land-grant university.
2. Share more details on what went into the modeling, consider using a higher discount rate and explain the assumptions and constraints that were embedded in the modeling. In reviewing the modeling information that was provided, we found it odd that in some of the scenarios, despite more acres allocated for early harvest (“short rotations”), which would also presumably be acres that would require early harvest of older forests, the model was predicting a lower overall net revenue. Given that all discounted cash flow models prefer early returns on investments, this seems flawed. Subsequent conversations uncovered two potential reasons for this unexpected conclusion in the modeling: first, the use of a lower than industry standard discount rate (four percent), and second, a constraint on the model forcing it to harvest at an arbitrary average age that may be lower than optimal for the site classes associated with much of the Mac-Dunn Forest. The use of a four percent discount rate is inappropriate for the Mac Dunn. That discount rate is on the low end of what is used in state and federal discounted cash flow models. An industry standard of six to eight percent may be more appropriate. It was presented that four percent was used because that is the rate of return that the college could achieve with the best alternative investment. However, this is only half of the equation when picking an appropriate discount rate. We recommend that the college follow the standard practice of using the discount rate to account for other risks such as wildfire, insect outbreaks, disease or pathogens, market risks such as mill closures and log price fluctuation, regulatory risks, and social risks, all of which could lead the college to higher constraints and lower revenue production. When all these risks are considered, a strong case is made for a higher discount rate than the four percent that was used. Furthermore, it would behoove the COF to remove the distinction of “short rotation” altogether and instead let the model find the optimal harvest volume at the age it chooses, while using an appropriate discount rate and other relevant constraints. This is, in fact, how most of the industry does similar modeling - we are unaware of any landowner that artificially constrains their modeling efforts to harvest at certain average ages. Given the site classes associated with the Mac-Dunn, it is possible that a rotation closer to 50 to 60 years may be optimal. OFIC recommends re-modeling with a higher discount rate - closer to industry standard - without an artificial constraint for a particular age, thus allowing the model to find the optimal harvest rotation for the forest. This could be re-imagined as a “sustainable harvest strategy” and replace both the “short” and “long” rotation strategies currently listed. It would likely result in higher volume and revenue outputs, and more closely align with private land management, which would allow better opportunities for studies more relevant to the forest sector in Oregon.
3. Add language that clearly articulates the parameters around what constitutes an “appropriate” time or circumstance for pursuit of an alternative revenue stream for the Mac-Dunn. On page 58 of the draft plan, it states that “adaptive funding strategies will be pursued when appropriate.” Alternative revenue streams should be pursued only when they fit the mission, vision and purpose of the OSU COF as a land grant university, and the Mac- Dunn as an “actively and sustainably managed forest.” It would be inappropriate to adopt an alternative funding source that would constrain the COF’s ability to harvest or otherwise alter standard and accepted sustainable forestry practices. To do so would be off-mission and harm or completely dismantle the university’s ability to deliver on their land grant purpose to the sector and to the citizens of Oregon. This would be a devastating outcome, one that should be avoided by providing clearly articulated expectations for these potential alternative revenue streams up front in the plan itself.
4. Provide additional inventory data and projections. The draft plan is missing key data that is standard in many management plans. The plan is missing an estimate of current or projected timber volume by species, estimated volumes by land management objective over time, estimated growth across the forest, etc. We would like to see the planning horizon and planning periods presented in the model. These planning horizons should be at least two full rotations in length in order to capture how the proposed silvicultural prescriptions will change the forest over time as each stand is transitioned from current condition to the regenerated condition under a 2 LP harvest scheduling model. We would also like to see more detailed information regarding the standing live tree inventory, standing dead and periodic growth across the forest. Currently the draft plan provides sparse details, primarily on page 47, showing only the current average age classes and a three paragraph, broad description of site class, species composition and tree heights.
5. Provide additional information regarding targets and baselines for measuring the relative success of the draft plan. There was no baseline or minimum amount of revenue identified as necessary to pay for staff, maintenance, etc. Without this clear benchmark the forest is at risk of running a deficit. Furthermore, there is no clearly defined revenue goal. Without these factors, it is difficult to understand the benchmarks for success of this plan from a revenue perspective.
6. Certain statements in the draft plan should be removed or re-written. We request that the COF review the plan for language that should be written more clearly or more appropriately. Below are a couple of examples:
a. On page 58 the draft plan states that “the funding model for the research forests was created at a time when research forests nationwide functioned like industrial plantations.” This statement is incredibly broad and presumptuous and is not supported by tangible evidence. There are no references in this document to the history of other research forests across the nation, nor is there an explanation as to what is meant by the phrase “industrial plantations.” Surely it is not the conclusion of the COF that forests across all private land ownerships nationwide were historically managed in a homogeneous manner. This is a paragraph that should be re-written with clear language that removes bias and overly broad or false statements.
b. The use of the term “short rotation” throughout the document should be reconsidered. What is short? This is a term that betrays a universally-agreed-upon definition. Section 2 of these comments offers a helpful alternative to such a subjective, value-laden language.
OFIC values the symbiotic, collaborative relationship that has existed between Oregon’s forest sector and the COF at OSU. The land grant mission of the university is the foundation of that relationship, and as such, should always be reflected in the purpose and goals expressed in the management plan for the Mac Dunn Forest. OFIC appreciates the opportunity to offer these comments on behalf of our members for ways that this plan can be improved to better reflect and deliver on this broad mission and looks forward to continuing its long and fruitful relationship with the OSU COF.
Sincerely,
Seth A Barnes>br> OFIC Director of Forest Policy
OSU Alumni, FM, Class of 2002
Oregon State University Board of Trustees
652 Kerr Administration Building
Corvallis, OR 97331
Submitted via email
Subject: OSU’s Draft Management Plan for the McDonald-Dunn Forest
Dear OSU Trustees,
On behalf of the 58,000 statewide members and supporters of the Oregon Chapter of the Sierra Club, we
urge you to advocate for better stewardship of the public forests under OSU’s management. As the
highest oversight body of our public university, you are the ultimate stewards of these amazing natural
resources that belong to all Oregonians.
The Oregon Chapter has long encouraged OSU to prioritize ecological considerations and public values
over OSU’s traditional management and monetization of the research forests. The Sierra Club’s core
values reflect both the best available science and the public interest, which align with protecting older
forests. These same values ought to coincide with OSU’s educational and research missions.
Unfortunately, the draft management plan for the McDonald-Dunn Forest falls short in a number of
alarming ways. The substantial amount of clearcutting and lack of meaningful protections for older forests
are both contrary to scientific leadership and the public interest. The continued focus on industrial
forestry, with its adverse impacts like herbicide use and slash-burning, contrasts sharply with the lack of
consideration of ecological forest management. The deliberate removal of specific protections for older
forests (like the 160- year cutting limit) and expansive allowance for discretionary cutting (under the guise
of restoration, fuels reduction, and public safety) are deeply concerning. The reliance on the low bar of the
Oregon Forest Practices Act and the absence of enforceable constraints is equally alarming. The plan is
full of “guidelines” and “recommendations”, but lacks meaningful and firm commitments.
We are also deeply concerned by the echoing of timber-industry propaganda and the lack of substantive
measures to mitigate climate change. Numerous studies, including those of renowned OSU scientists,
have concluded that the forest sector contributes ~1/3 of our state's total GHG emissions.1 The language
of the draft plan seems designed to downplay the pivotal role of forest carbon sequestration in addressing
the climate crisis. This is especially disappointing, as OSU’s own scientists have been leaders in the field of
forest carbon and climate research for decades. The plan’s forest carbon metric ignores below-ground
carbon losses, skewing the results in favor of clearcutting, which dramatically reduces carbon stored in
the soil. These are just a few examples of the systemic bias that can be found throughout the draft plan.
The College of Forestry’s technical competency is also undermined by the draft plan’s reliance on
Woodstock software, a traditional linear modeling tool which is heavily biased in favor of traditional
timber management. The resulting metrics are largely meaningless. The same goes for the surveys of
forest users, which falsely concluded there are relatively minor differences in public perception of
clearcuts vs. older forests. Independent surveys have repeatedly found that a large percentage of
Oregonians are opposed to clearcutting and favor increased protections for older forests.2 Despite facing
overwhelming criticism for these types of shortcomings, OSU has failed to address them in the draft plan.
The continual reluctance of the planning team to improve their approach undermines confidence in the
draft plan and the College of Forestry’s integrity and competence.
We have previously shared our deep concerns about the biases in the process used to develop this forest
plan.3 It does not come as a surprise that the resulting plan is heavily skewed toward industrial forestry at
the expense of ecological considerations. What is perhaps most disappointing is that the OSU
administration has failed to take effective corrective actions along the way. State law calls on the trustees
of our public universities to provide transparency and public accountability. OSU’s draft plan for the
McDonald-Dunn and the flawed process that produced it show that public accountability is largely absent.
We call on you to intervene and reset the forest planning process. It is time for OSU to demonstrate better
stewardship of this public forest.
Respectfully,
Damon Motz-Storey
Oregon Chapter Director, Sierra Club
1821 SE Ankeny St, Portland, OR 97214
* Retaining ALL trees greater than 80 years old. These legacy and heritage trees provide habitat for numerous species in addition to shade, water, and nutrients. Consequently, older trees increase forest productivity and are critical to withstanding the greater frequency, duration, and intensity of climate extremes.
* Restricting thinning and harvesting to younger forest stands and trees less than 80 years old. As a result, most of the MacDonald-Dunn Forest (2/3) would still be subject to active timber management and generate revenue.
* Using protective buffers, irregular edges, and structural complexity in timber harvests to create microclimates, microhabitats, and an evolving mosaic of environmental conditions.
We do not have to sacrifice the health of our forests to obtain wood products and reap profits. So, before finalizing the MacDonald-Dunn Forest Management Plan, please incorporate ecological principles and holistic strategies to increase the resilience of forests, and ultimately our economic stability, in a rapidly changing environment. Thank you for your consideration.