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These comments relate to the ODF-OWEB  Report on Voluntary Resoration Efforts by Forest Landowners

BEFORE THE OREGON BOARD OF FORESTRY
June 7, 2017
Public Comment on Agenda Item 5
ODF/OWEB Report on Voluntary Restoration Efforts by Forest Landowners
Mary Scurlock, Coordinator, Oregon Stream Protection Coalition (OSPC)
Mary.scurlock@comcast.net

We appreciate the collaborative effort that went into producing March 2017 report entitled “Voluntary Efforts by Forest Landowners to Restore Salmon Habitat and Watersheds in the Oregon Coast Range.” We strongly support full recognition of land managers who voluntarily go above and beyond minimum regulatory requirements to improve aquatic habitats for their intrinsic value at their own expense. These efforts should continue to be encouraged.

However, OSPC is concerned about the extent to which the report implies that completion of projects is known to have benefited coho salmon in one way or another without reference to either implementation or effectiveness monitoring studies, or to whether the actions taken actually address recovery priorities under the federal ESA recovery plan. We note that, in general, NOAA Fisheries has cautioned that we will need to evaluate returns affected by the poor marine conditions of the last several years to understand the sufficiency of freshwater habitat.ⁱ  The 2016 Status review specifically notes that:

“New information available since the last status review indicates that a number of restoration and protection actions have been implemented in freshwater and estuary habitat throughout the range of OC coho salmon. However, at this time we do not have information that would reveal improvements in habitat quality, quantity, and function. Future status assessments would benefit from a systematic review and analysis of the amount of habitat addressed against those high priority strata identified in the NMFS 2015 Proposed Recovery Plan. We remain concerned about degraded habitat conditions throughout the range of the OC coho salmon ESU, particularly with regard to land use and development activities that affect the quality and accessibility of habitats and habitat-forming processes such as riparian condition and floodplain function as well as water quality. Overall, we conclude that the risk to the species’ persistence because of habitat destruction or modification has not changed since the last status review.”ⁱⁱ

Effectiveness Monitoring is Needed.  The report itself acknowledges that effectiveness monitoring still is needed. Many of the projects acknowledged in the report were likely carefully designed for benefits to aquatic habitat, including the primary limiting factor for  coho recovery of habitat complexity. But this report does not itself evaluate the effectiveness of specific projects or the overall cumulative effectiveness of projects relative to any particular criteria or metrics (e.g. increased numbers of pools, channel-to-floodplain connectivity, off-channel habitat, stream temperature/water quality concerns, location of projects in priority reaches or which address priority recovery actions). In our view, the most important investment that the Department of Forestry’s monitoring unit can make related to voluntary efforts goes beyond merely counting the number and cost of projects to robust effectiveness monitoring — something that this report only aspires to do under next steps, resources permitting.

Until such monitoring is done, it is premature to make statements about the benefit of restoration projects – voluntary or otherwise – for coho.

We further encourage the Board’s attention to the participation of small forest landowners whose management objectives and need for incentives differ from those of industrial owners.

Expectations for the ecological benefits of voluntary restoration efforts should be realistic and based on metrics that relate to recovery outcomes. This effort to catalogue the last 20 years of voluntary restoration is an important piece of information because it will help set realistic expectations for voluntary efforts. The federal coho recovery plan recognizes the potentially positive role of these efforts.ⁱⁱⁱ But unless and until such voluntary efforts are demonstrated to be effective and obviate the need for regulatory change, the need for stronger land use controls will remain.

Also needed is a further clarity about the metrics that will be used to demonstrate attainment of desired habitat recovery outcomes through any mechanisms, including those identified in the federal recovery plan. For timberlands, these metrics should relate to increased shade through increased retention of riparian trees, increased sustainable natural recruitment of large wood, and other factors related to habitat complexity and road system impact reductions. ^iv

ⁱ See e.g. NOAA-NMFS, 2016, 2016 5-Year Review at 12: “it is only when marine survival is low that it becomes apparent whether habitat quality and quantity are sufficient to support self-sustaining populations. With marine survival rates expected to decrease for OC coho salmon entering the ocean in 2014 (Peterson et al. 2014a and b), 2015, and 2016, it may be advisable to wait to observe how populations fare during this potential downturn before deciding to change their status (NWFSC 2015).” http://www.westcoast.fisheries.noaa.gov/publications/status_reviews/salmon_steelhead/2016/2016_occoho.pdf

ⁱⁱId. at pp. 19-20, emphasis added. http://www.westcoast.fisheries.noaa.gov/publications/status_reviews/salmon_steelhead/2016/2016_occoho.pdf
ⁱⁱⁱhttp://www.westcoast.fisheries.noaa.gov/publications/recovery_planning/salmon_steelhead/domains/oregon_coast/oc_coho_plan_exec_summary_12_16.pdf ^ivhttp://www.westcoast.fisheries.noaa.gov/publications/recovery_planning/salmon_steelhead/domains/oregon_coast/final_north_coast_stratum.pdf.

Post from Citizens for a Healthy County

A majority of voters who returned to sign unsigned ballots approved Measure 21-177, bringing the total vote to 6994 for the ban versus 6933 against it, making the ban on aerial pesticide spraying in Lincoln County a reality. Thanks to the many people who volunteered and campaigned so valiantly, the vast amounts spent by corporate opponents failed to convince voters that profits are more important than health, safety, and the right to informed consent.

By this victory, Lincoln County is the first county in the United States to ban aerial spraying of pesticides by the vote of the people. This is not the first time Lincoln County has spoken truth to power and won.

“Back in 1976, folks here put Lincoln County on the map by winning a huge landmark case against the United States government, stopping federal spraying of Agent Orange on our forests and homes and waterways,” said Susan Parker Swift. “Now Lincoln County has done it again. I couldn’t be prouder to share this repeat victory!”

Barbara Davis, co-petitioner of measure 21-177, says our win brought to her mind the following quote by Margaret Mead:

“Never doubt that a small group of thoughtful committed citizens can change the world; indeed, it’s the only thing that ever has.”

This election was the first major hurdle Measure 21-177 had to overcome to become a reality. Implementation of the measure, and the obstacles to it that opponents will raise, among them superior “rights” to override the rights of the people, including the people’s right to vote and their constitutional right to safety, are next. Citizens for a Healthy County will continue to meet those challenges, and welcomes all who are willing to join us in the effort.

Citizens for a Healthy County

For more information www.yes-on-21-177.org

By Rob Davis,
The Oregonian

The Elliott State Forest, the 82,500-acre Coast Range parcel the state nearly sold to a timber company, will stay in public ownership, bringing an end to Oregon’s years-long flirtation with divesting the land.

Oregon Gov. Kate Brown, Secretary of State Dennis Richardson and state Treasurer Tobias Read voted Tuesday in Salem to halt the sale, pulling the remote forest back from the brink of a plan that was wildly unpopular with hunters, anglers and environmental groups.

The potential divestiture had put Oregon at the forefront of a nationwide debate over publicly owned land, leaving a Democrat-controlled state positioned to do something that some Republicans, including President Donald Trump’s interior secretary, have rejected.

Huge questions about the forest in Coos and Douglas counties remain unanswered. Chief among them: Which agency will manage the land, what role logging and recreation will play in its future and how many acres of the forest will be protected with a proposed $100 million investment from state taxpayers.

The sale had been driven by the archaic system by which Oregon holds the state forest. The state is constitutionally required to use revenue from logging the land to benefit schools. But logging was curtailed by environmental lawsuits after the state in 2011 tried to nearly double the amount of clear-cutting allowed each year.

The vote was a major win for Brown, who successfully fought back a February attempt to sell the land. Her plan would use $100 million in taxpayer-funded bonds to end the state’s obligation to earn money for schools from the forest’s old growth trees, riparian areas and steep slopes.

Under Brown’s proposal, decisions about the rest of the land would be entrusted to what’s called a habitat conservation plan, a blueprint that would dictate where logging could occur and where habitat for threatened species like the marbled murrelet and northern spotted owl would be protected. It would need federal approval, something that federal agencies withheld the last time Oregon tried to draft such a plan for the Elliott.

Liz Dent, a state department of forestry official, said the expected timber harvest under Brown’s plan would be about 20 million board feet each year – roughly half as much as the state’s aggressive 2011 plan that led to the situation today.

The vote was a remarkable turnaround for Read, a Democrat who has been assailed by environmental groups since siding in February with Richardson in rejecting Brown’s effort to keep the land public. Oregon Wild and the Oregon League of Conservation Voters had attacked the new treasurer through a social media campaign with the hashtag #betrayedmyvote.

Read and Richardson would have sold the forest for $221 million to Lone Rock Timber Management, which bid in conjunction with Native American tribes and The Conservation Fund. The state would’ve received an assurance that half of the forest would be kept open to public access.

Three months later, Read is now touting his own plan to build on Brown’s, offering Oregon State University the option to buy the forest for $121 million after the initial $100 million state investment.

Such an idea, which would decouple all of the forest from its school-funding obligation, appears to be a long shot.

Ed Ray, Oregon State’s president, described Read’s idea as “a burst of imagination,” noting that the university would use revenue from logging it to pay for its purchase. “I haven’t got $120 million lying around,” Ray said.

Thomas Maness, dean of Oregon State’s forestry school, said the university’s 15,000 acres of timber holdings do not include any old-growth habitat home to threatened species including the coastal Coho salmon, northern spotted owl and marbled murrelet. The Elliott would provide the school with a place to conduct long-term research to understand how active timber harvesting impacts them.

“If we don’t learn how to manage with these listed species we’re going to see disaster” in the state’s timber industry, Maness said. “We’ve learned nothing about managing with spotted owls.”

Rather than borrowing $100 million from taxpayers and paying additional interest on the debt, Richardson proposed swapping the high value state land for federal forests that aren’t home to endangered species. He offered scant detail, saying it would be modeled on similar transfers in Minnesota, California and Utah.

— Rob Davis

Forestry analysis must include all the facts

by Ernie Niemi
for the Register Guard

We’re tired of the bickering over logging. Tired of people talking past one another: “Logging is good!” “No, it’s bad!”

Let’s replace the rhetoric with facts. Compare the benefits of logging against the costs. If the facts show that the benefits exceed the costs, cut the trees down; if not, let them stand.

At a recent public meeting in Springfield, staff from the Oregon Board of Forestry said the board took this approach to develop a proposed rule that will restrict logging along the banks of some streams that are home to salmon, steelhead and bull trout. Current rules permit loggers to remove trees that otherwise would shade these streams, keeping the water cool. Without the shade, summertime stream temperatures become hot enough to harm fish.

The forestry staff described the process used to decide how much to restrict logging, and where. With assistance from citizens representing different points of view, the board first identified a wide range of alternatives with different levels of stream-side logging restrictions in different parts of the state. It then weighed the benefits and costs of each alternative, rejected those whose costs exceeded the benefits, and selected the alternative that offers the best net benefits.

Excellent! This sounds like a textbook approach for fact-based decision-making about complex issues.

Hoping to learn more, I asked the forestry staff if I could see the board’s benefit-cost information. They sent me a summary, contained in the report the board recently released in response to the state law that requires it to provide the public with a “comprehensive analysis” of the economic impact of the proposed rule.

What a disappointment. The board’s report (bit.ly/2l6iwXi) fully describes the costs of logging restrictions: reductions in timber production, timber jobs, and workers’ incomes. But nowhere in its 29 pages does it have a single word about the benefits. Not one.

The report has nothing about the benefits from leaving trees on stream banks to provide more shade to cool the water and boost salmon, steelhead and bull trout populations. It has nothing about the likelihood that restrictions on stream-side logging will reduce the amount of logging-related sediment in streams, which will be good for fish and improve the quality of drinking water supplies for numerous communities. There is nothing about the potential benefits for the outdoor recreation industry from healthier, cooler streams.

Rather than a “comprehensive analysis,” the board’s report contains nothing about the recent research by Oregon State University scientists that shows letting trees grow likely will increase stream flows in the summertime, when fish have critical needs. It has nothing about the positive impacts that would result when trees left unlogged grow larger by removing carbon dioxide from the atmosphere and mitigate the impacts of climate change.

Are these important omissions? Yes. Is there readily available information the board could have used to describe the benefits? Yes again.

The Bureau of Land Management, for example, recently produced data that compare the benefits and costs from reduced logging on the forestlands it manages in Lane County and throughout western Oregon. The result: The recreation and climate-change benefits, alone, exceed the costs by more than 4 to 1.

In addition, the U.S. Department of Agriculture has estimated the benefits of reductions in stream sediment, and the Forest Service has estimated the benefits of increased stream flows. Economists at OSU have measured the positive impacts of unlogged forests on the value of nearby residential properties. And there’s lots more.

So how did the board produce a “comprehensive analysis” that isn’t? The report was prepared for the board by an economist trained to describe the proposed rule’s benefits as well as its costs. Why did he not do so? If its “comprehensive analysis” of the economic impacts ignores the benefits of logging restrictions, does this mean that the board also ignored them as it developed the proposed rule?

Was all that talk by the forestry staff about weighing benefits and costs a sham?

Getting good answers to these questions is especially important now, when The Register-Guard and other reputable news outlets carry unending stories about distortions of science and facts intended to protect big industries and allow them to continue degrading the environment.

Threats to fact-based government have never been acceptable. But in these times, when these threats are so extreme within the federal government, it is especially important to keep Oregon free of the corruption. Gov. Kate Brown should take a hard look at how this “comprehensive analysis” ignored half of the relevant facts. She should take a hard look to see if her appointees — the members of the Board of Forestry and the head of the Department of Forestry — have an unwavering commitment to fact-based government.

We all need reassurance that, in Oregon at least, facts matter.

Ernie Niemi is president of Natural Resource Economics Inc. in Eugene.