30 September 1997
Dr. David Gilbert, Chair
Oregon Board of Forestry
Oregon Department of Forestry
2600 State St.
Salem, OR 97310
Dear Dr. Gilbert:
The Oregon Chapter of the American Fisheries Society (ORAFS) appreciates the opportunity to comment on the Department of Forestry’s proposed administrative rules to establish “… the continuous growing and harvesting of forest tree species as the leading use of forest land…” (draft OAR 629-35-000 (1), 15 July 1997). We understand that these rules will be the basis for implementation of the Northwest Oregon State Forests Management Plan (ODF 1997).
ORAFS is a volunteer organization of professionals in fisheries and aquatic sciences. We have over 500 members in Oregon, representing a diverse mix of scientists in federal, state, and tribal agencies, higher education, and in the private sector. A principal part of our Chapter mission is promoting the application of sound science in the conservation and management of fisheries and aquatic resources. Because aquatic habitats are directly affected by the management of neighboring lands, we also promote a science-based approach to forest and upland management.
We strongly urge the Board of Forestry to consider the importance of its proposed rules and the implications for salmon recovery and for potential additional Endangered Species Act (ESA) listings of Oregon salmon. In its recent decision to not list coho salmon populations along the central and northern Oregon coast, the National Marine Fisheries Service (NMFS) placed heavy reliance on the implementation of the Oregon Plan (formerly the Coastal Salmon Restoration Initiative 1997). The regulatory restrictions of an ESA listing were postponed, and perhaps avoided completely, contingent on the voluntary cooperation of Oregon citizens, agencies and landowners to take appropriate steps to restore this species. It is clear that NMFS will be looking closely at state actions to restore coho, including any rulemaking or management plans related to state forests. We suggest that the proposed rule could impede Oregon’s efforts to restore salmon along the northern Oregon coast and will raise questions about the state’s commitment to salmon restoration. To the degree that such a rule casts doubt on the commitment to salmon restoration, it will set a poor example for private landowners being asked to contribute to the restoration effort. It would also increase the probability that timber harvest from the Tillamook and Clatsop State Forests will be restricted by future Coastal Zone Management Act compliance concerns and Endangered Species Act listings and protective measures. Steelhead trout and chum salmon are two other species whose depressed status and use of rivers originating in the state forests of northwest Oregon will make management of state forest lands an important consideration in future ESA listing decisions (ODFW 1995, Klumph and Braun 1996, NMFS 1997).
We are unsure of the specific meaning of statements in the draft OARs that the continuous growth and harvest of forest tree species will be consistent with the protection and improvement of native fish and wildlife habitat and values (Draft 629-35-000). The draft OARs, and the draft resource management strategies for the Northwest Oregon Forest Management Plan do not provide much specificity as to how fish and wildlife values will be protected, maintained and enhanced over time. Some forestry operations can be conducted in ways which are consistent with recovering the habitat and ecological processes needed by anadromous and resident fish populations, and other wildlife. However, many forestry operations have been repeatedly demonstrated as not consistent with these values. It would seem premature to adopt rules establishing one leading use for public forest lands until and unless the Department of Forestry articulates how these other values important to the public will be protected, maintained and enhanced.
Our Chapter has significant reservations concerning the proposed administrative rules and what they might mean with regard to future management of Oregon’s state forests. For example, the Tillamook and Clatsop State Forests represent the largest blocks of state-owned lands and the only meaningful opportunity for public lands to anchor salmon recovery efforts within the coastal basins of northwestern Oregon. These two forests are positioned in the headwaters of erosion-prone river basins and have a critical influence on local and regional hydrology, water quality, ecological processes and anadromous fish populations. (Huntington and Frissell, 1997). Unlike salmon in the many rivers with headwaters on federal lands, salmon in the Nehalem, Wilson, Trask, Kilchis and other river basins along our northern coast will depend on conservation-minded management of the state forests if there is to be a legitimate opportunity for their recovery. Spence et al. (1996) show that Oregon’s requirements for protecting forestland riparian buffers are substantially less than those of federal forests and California. These requirements make less than adequate provision for bank stability, shade, large woody debris, sediment retention, and microclimate conditions. In addition, the U.S. Environmental Protection Agency and the Oregon Department of Environmental Quality surveyed sixty Coast Range streams over three years and found that northern coho populations suffered substantial declines following the February 1996 floods. South coast streams actually showed slight increases in coho abundance. If, as predicted, we are entering a period of above average rainfall, we could expect to see further coho salmon declines from flooding and erosion in the wake of increased logging (Alan Herlihy, OSU and Robert Hughes, Dynamac, Corvallis, OR, pers. comm.).
Restoration of native salmon along Oregon’s northern coast will require sustainable improvement in streams and aquatic habitat. These improvements will require restoration of watershed processes that create and maintain healthy aquatic/riparian ecosystems over the long-term. (Reeves et al. 1995, Bisson et al. 1997, Roper et al. 1997, Kauffman et al. 1997). Good salmon habitat in the Oregon Coast Range and North Coast basin evolved under a natural disturbance regime consisting of large, catastrophic wildfires with a mean return interval of several hundred years, and extended periods of natural recovery punctuated by stochastic flood events. Post-fire landslides during floods would have introduced sediment and large woody material into stream channels, initiating or sustaining stream recovery (Benda 1994, Reeves et al. 1995). With regard to land management on the Tillamook and Clatsop State Forests, stream recovery will require the restoration of watershed processes, including complex stream interactions with riparian vegetation, episodic and less frequent landsliding (relative to present frequent and chronic erosion), slide delivery of coarse woody material to streams (especially large, whole conifers) and flow regimes (Huntington and Frissell, 1997). In practical terms, this will mean watershed rehabilitation, significantly longer harvest rotations, better riparian buffering, and avoidance of unstable areas. Given the recent fire, flood, and salvage logging history of the Tillamook State Forest, we do not see how a primary emphasis on timber production and harvest will allow the Department of Forestry to consider implementing the kinds of management strategies that will be necessary to recover damaged salmon habitat.
In the spirit of the Oregon Plan, we strongly encourage the Department of Forestry to adopt rules and forest management plans consistent with a comprehensive strategy for restoring aquatic resources on state forest lands. Development and implementation of such a strategy would provide the public a blueprint for how fish and wildlife values important to Oregonians will be protected, maintained and enhanced. Huntington and Frissell (1997) have outlined such a strategy for river basins that include the Tillamook and Clatsop state forests. Their strategy includes most or all of the following elements that seem essential to salmon recovery:
1. identification of priority watersheds,
2. determination of which state lands should be given priority emphasis,
3. identification of a conservation objective and management guidelines,
4. watershed assessment,
5. land exchanges where necessary to meet conservation objectives,
6. public involvement to integrate and coordinate conservation actions on state lands
with those taken on neighboring private lands,
7. active monitoring to determine if objectives are being met, and an adaptive scheme
to address changing conditions, and
8. accountability and institutional change.
Oregon’s public lands are owned by all Oregonians. State statute, ORS 530.010 et seq., requires that state forests be managed “to secure the greatest permanent value of such lands to the state.” Thus, the management and use of these lands ought to represent the interests of Oregon’s citizenry as a whole. To that end, it would seem appropriate to manage state lands in such a way that all aspects of public use and value, including recreational, ecological and fish and wildlife values, are addressed. While timber production from state lands generates substantial tax revenues for counties and their educational infrastructure; recreation, tourism, and fish and wildlife also contribute substantially to county economies and residents. Prudent and precautionary management of public resources should seek to minimize the risk to each constituent value rather than to maximize one value which, based on historic practices, has detrimental impacts on other values. Rather than emphasizing revenues from one particular use of state lands (timber production), we suggest that Oregon state lands be managed to maximize the aggregate value of these lands to all Oregonians from all non-consumptive and consumptive uses. The Tillamook and Clatsop State Forests present the Department of Forestry with an opportunity to adopt ecologically based management practices which will conserve and restore recreational, ecological and fish and wildlife values, while still providing for timber harvest. We hope that any rules adopted by the Board of Forestry will encourage such management of these forests.
Hal Weeks, President
for the Executive Committee
c. Gov. Kitzhaber, State Capitol
Benda, L.E. 1994. Stochastic geomorphology in a humid mountain landscape. Ph.D. dissertation, University of Washington, Seattle, WA.
Bisson, P.A., G.H. Reeves, R.E. Bilby and R.J. Naiman. 1997. Watershed management and Pacific salmon: desired future conditions. in Stouder, D.J., P.A. Bisson, and R.J. Naiman, eds. Pacific salmon and their ecosystems: status and future options. New York: Chapman and Hall, pp. 447 – 474.
Huntington, C.W. and C.A. Frissell. 1997. Aquatic Conservation and Salmon Recovery in the North Coast Basin of Oregon: A Crucial Role for the Tillamook and Clatsop State Forests. Report prepared for Oregon Trout, Portland, OR.
Kauffman, J.B., R.L. Beschta, N. Otting and D. Lytjen. 1997. An ecological perspective of riparian and stream restoration in the western United States. Fisheries 22(5): 12 – 24.
Klumph, R. and K. Braun. 1996. Tillamook District, Status of Naturally Reproducing Stocks, unpublished ODFW report.
National Marine Fisheries Service, 18 August 1997, Federal Register, 62(159): 43974 – 43976.
Oregon Coastal Salmon Restoration Initiative (OCSRI). 1997. Oregon’s Coastal Salmon Restoration Initiative. Salmon Conservation Plan for the State of Oregon, Governor’s Office, Salem, OR.
Oregon Department of Fish and Wildlife. 1995. Biennial Report on the Status of Wild Fish in Oregon. Portland, OR.
Oregon Department of Forestry. 1997. Draft Resource Management Strategies: Northwest Oregon State Forests Management Plan. Salem, OR.
Reeves, G.H., L. Benda, K. Burnett, P. Bisson and J. Sedell. 1995. A disturbance-based ecosystem approach to maintaining and restoring freshwater habitats of evolutionarily significant units of anadromous salmonids in the Pacific Northwest. American Fisheries Society Symposium 17: 334- 349.
Roper, B.B., J.J. Dose and J.E. Williams. 1997. Stream restoration: Is fisheries biology enough? Fisheries 22(5): 6 – 11.
Spence, B.C., G.A. Lomnicky, R.M. Hughes, and R.P. Novitzki. 1996. An ecosystem approach to salmonid conservation. TR-4501-96-6057. ManTech Environmental Research Services Corp., Corvallis, OR. Report to the National Marine Fisheries Service.