To: Oregon Department of Forestry From: Beyond Toxics Date: June 21, 2021 Re: Annual Operations Plans for Fiscal Year 2022 to Wh
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To: Oregon Department of Forestry From: Beyond Toxics Date: June 21, 2021 Re: Annual Operations Plans for Fiscal Year 2022 To Whom It May Concern: Thank you for the opportunity to comment on the draft Annual Operations Plans (AOPs) for state forests in the Astoria, Forest Grove, Klamath-Lake, Tillamook, West Oregon, and Western Lane Districts for Fiscal Year 2022. State forests are required by law to provide economic, environmental and social benefits to Oregonians. We request that the Department of Forestry (ODF) revise the draft plans to manage our public lands in a manner that does not jeopardize public and environmental health for the sake of financial gain. Notably missing from the draft plans are a thorough consideration of (1) climate change impacts and (2) drinking water concerns. Failing to manage state forests in a way that effectively mitigates the impacts of climate change and protects drinking water for millions of Oregonians would be a costly mistake that adds to the cascading effects of climate, loss of property and habitat, and harm to wildlife and Oregon residents. Carbon Implications In order to mitigate the most dire impacts of the climate crisis, we must change the way we manage our public lands and carbon sequestration potential must be considered alongside financial viability and health impacts. Managing state forests to reduce emissions and increase carbon storage and sequestration is both a priority of the Board of Forestry and necessary to achieve the directives set out in Governor Brown’s Executive Order 20-04. We ask that the Department conduct operations using a climate lens, taking into account the emissions from fuel use in logging operations, emissions from road construction, soil and native vegetation disturbance during harvest operations, emissions from slash burning and transport of slash offsite, emissions from trucking in and spraying pesticides, and the estimated loss of carbon storage when a tree is harvested, transported, and processed into wood products, chips and pellets. 1. Longer Logging Rotations According to Diaz et al., “[e]xpanded riparian protections, increased green tree retention, and the extension of rotation ages can translate into substantially higher carbon storage than contemporary common practice for Douglas-fir management in the Pacific Northwest.”1 Clearcutting plans set out in the AOPs, however, reflect harvest levels that are unsustainable and detrimental to climate mitigation needs. ODF is managing areas available for clearcut on an approximately 55-year rotation. By allowing trees to grow for longer time periods, ODF can improve carbon stocks while also increasing timber yield and 1 David D. Diaz, Sara Loreno, Gregory J. Ettl and Brent Davies 2018 Tradeoffs in Timber, Carbon, and Cash Flow under Alternative Management Systems for Douglas-Fir in the Pacific Northwest. Forests 9 (8) 447 https://www.mdpi.com/1999-4907/9/8/447. 1 timber quality. Studies suggest that 80-year rotations of Coastal Douglas fir may provide optimal carbon storage benefits depending on assumptions about product longevity and substitution of alternative materials.2 2. Carbon Reserves In addition, state forests that exhibit old forest characteristics should be identified and prioritized by the Department for their carbon and biodiversity value. Mature and old growth forests store and sequester immense amounts of carbon. Wherever native stands of large trees exist, they should be protected as climate reserves. Further, ODF should work to identify additional areas of the highest carbon storage potential that should also be protected as part of this carbon reserve. These stands also provide high quality habitat for salmon and other at-risk wildlife, helping managers achieve two objectives at once to achieve proactive management of lands for a changing climate and future HCP requirements. 3. Diverse Regeneration When replanting harvested forests, we appreciate where plans intend to increase species diversity and select species that will be more resilient to climate change. Forests replanted with a dense monoculture of Douglas-fir, for example, can provide more fuel for wildfires exacerbated by climate-induced hotter and windier conditions. Further, monoculture forests are less resilient to pests and disease, which may lead to tree losses and future applications of chemical inputs that harm drinking water sources and fish and wildlife habitat. Watershed Impacts In addition to carbon storage, climate adaptation strategies are needed to ensure that forest operations are protecting watersheds. Clearcuts and post-fire logging operations increase the risk of mudslides and sediment runoff, negatively impacting Oregon’s rivers and streams, and pesticide application can pose a risk to local community drinking water sources. Water infrastructure for water service providers is outdated and treatment needs are costly. Further, drinking water violations disproportionately occur in communities of color, especially in rural and tribal areas.3 As the impacts of climate change worsen (including drought, heat waves, less snowpack, and more extreme precipitation events), Oregon’s forests must be managed for clean water quality, water quantity, and flood prevention as an adaptation tool. 2 See, e.g. Stephen J. Fain, Brian Kittler, Amira Chowyuk, 2018. Managing Moist Forests of the Pacific Northwest United States for Climate Positive Outcomes. Multidisciplinary Digital Publishing Institute. DOI: 10.3390/f9100618. https://www.researchgate.net/publication/328229114_Managing_Moist_Forests_of_the_Pacific_Northwest_United_ States_for_Climate_Positive_Outcomes. 3 Samayoa, Monica. “Study: Safe Drinking Water Violations Are Higher For Communities Of Color.” September 25, 2019. https://www.opb.org/news/article/safe-drinking-water-act-violations-communities-color-study/; see also Reyes-Santos, Case-Scott, and Singh. “Addressing Issues of Water Justice.” June 1, 2021. https://www.registerguard.com/story/opinion/columns/2021/06/01/guest-view-addressing-issues-water-justice-orego n-water-futures/5250163001/. 2 1. Slope Do not execute plans to clearcut steeply-sloped areas. The risk of landslides, increased sedimentation, and runoff into waterways is too high. The maps below depict the location of an ODF logging operation in a steeply sloped, high landslide susceptibility area near Foley Creek in the Nehalem watershed in close proximity to salmon and steelhead streams. These maps exhibit just one of the many ODF logging operations on state lands that are greater than 80% slope and are directly uphill from fish streams approved in AOP’s. Washington’s Forest Practices Rules, in comparison, do far more to reduce landslide risks and excessive runoff by requiring logging operations on steep slopes to meet higher standards of riparian protections than those in Oregon.4 4 Washington State Forest Practices Rules (Title 222 WAC). 3 2. Riparian Buffers Oregon’s buffer zone regulations are weak when compared to standards of forest practices required in neighboring states. In Washington, for example, 50-foot no-cut buffers are required around fish-bearing and non-fish streams. Oregon’s logging operations should expand no-cut buffers for fish-bearing streams (currently 20 feet) and leave no-cut buffers on headwater streams (currently nonexistent) to protect water quality, as these are major sources of drinking water and often upstream from fish streams. 3. Pesticide Application When developing site preparation plans, we urge you to avoid using methods that harm drinking water sources. ODF continues to rely on wide scale pesticide application in state forests. Chemical site preparations kill native, beneficial plants, such as ceanothus, vine maple, and alder, which naturally re-colonize Oregon forests after a disturbance. These plants provide valuable habitat and food for wildlife, from elk and blacktail deer to songbirds. State forest pesticide applications also allow chemicals with known health effects, such as herbicides and fungicides to enter surface waters through runoff or drift or infiltrate precious groundwater sources. This puts drinking water and wildlife at risk. Washington’s forest practices restrict the application of chemicals known to persist in groundwater (such as atrazine and hexazinone). Oregon should adopt protections that are at least equivalent or better to protect groundwater, a critical and limited resource. 4 4. Road Construction and Maintenance The draft plans propose miles of newly constructed roads to allow for harvest operations in addition to the several thousand miles of roads already owned and managed by ODF. Minimize construction of new roads to avoid habitat fragmentation and detrimental impacts to waterways. When constructing new roads, do so in a way that minimizes sediment introduction to waterways. Sediment runoff can clog waterways, degrade fish habitat, and negatively impact drinking water for local communities. Establish safeguards such as drain dips above and away from stream crossings so that road drainage water is filtered naturally through vegetation before reaching waterways. Construction of sediment retention structures and out-sloping of road segments would also minimize sediment input to streams. When siting harvests and constructing or maintaining roads, take into account changing precipitation and streamflow levels due to climate change. Equity & Environmental Justice Equitable and ecologically-appropriate stewardship of Oregon state forests is critical for all Oregonians, but especially