The September 2014 Federal Recovery Plan for the threatened Southern Oregon/ Northern California Coast (SONNC) coho determined that timber harvest continues to pose a serious threat to the coho. The National Marine Fisheries Service (NMFS) specifically discussed the failure of the Oregon Forest Practices Act to protect the coho.
NMFS also identified revision of the Oregon Forest Practices Act as one of the highest priority recovery actions for almost all SONNC Oregon populations , including Elk River (p. 7-1), Brush Creek (p. 8-1), Mussel Creek (p. 9-1), Lower Rogue River (p. 10-1), Hunter Creek (p. 11-1), Pistol River (p. 12-1), Chetco River (p. 13-1), Illinois River (p. 30-1), Middle Rogue/Applegate (p. 31-1), and Upper Rogue River (p. 32-1).
The following is an excerpt from the plan:
At the time of listing, the Oregon Forest Practices Act (OFPA), modified in 1995 and improved over the previous OFPA, did not have implementing rules that adequately protected coho salmon habitat. In particular, the OFPA did not provide adequate protection for the production and introduction of large wood to medium, small and non-fish-bearing streams. Since the listing of SONCC coho, the Oregon Plan for Salmon and Watersheds (Oregon Executive Order 99-01; 1999) directed the creation of the Forest Practices Advisory Committee to help the Oregon Board of Forestry assess forest practices changes that may be needed to meet state water quality standards and protect and restore salmonids. As of 2003, draft water protection rules and non- regulatory recommendations based on the recommendations of Forest Practices Advisory Committee had been developed, but had not been adopted by the Board of Forestry. A review of OFPA and forest practice rules (IMST 1999) showed the regulations in place may be ineffective at protecting water quality and promoting riparian function and structure, especially in small- and medium-sized streams. In their review of the forest practice rules, the Oregon IMST found that one of the greatest shortcomings of the current rules is that they are dominated by site- and action-specific strategies which, taken together are insufficient for recovering habitat of listed stocks of salmonids (Everest and Reeves 2007). Everest and Reeves (2007) report that current forest practice rules in the Pacific Northwest represent improvements over their preceding rules, but continued change and evolution of the forest practices rules is of vital interest.
Though significant improvements have been made to the current rule package, the Oregon Forest Practice Rules represent the least conservative forest practice regulations administered by the state governments within the SONCC coho salmon ESU. Some riparian areas may be protected by narrow, no-harvest zones; however, the stands located upslope of the no-harvest zones could be subject to intense harvest, leading to diminished riparian function and cumulative effects to anadromous salmonid habitat. In a 2010 status review of Oregon Coast (OC) coho salmon, NMFS concluded that the Oregon Forest Practices Act does not adequately protect OC coho habitat in all circumstances. In particular, disagreements persist regarding: (1) whether the widths of riparian management areas (RMAs) are sufficient to fully protect riparian functions and stream habitats; (2) whether operations allowed within RMAs will degrade stream habitats; (3) operations on high-risk landslide sites; and (4) watershed-scale effects. On some streams, forestry operations conducted in compliance with this act are likely to reduce stream shade, slow the recruitment of large woody debris, and add fine sediments. Since there are no limitations on cumulative watershed effects, road density on private forest lands, which is high throughout the range of this ESU, is unlikely to decrease under the Oregon Forest Practices Act (NMFS 2009).
National Marine Fisheries Service. 2014.
Final Recovery Plan for the Southern Oregon/Northern California Coast Evolutionarily Significant Unit of Coho Salmon (Oncorhynchus kisutch). National Marine Fisheries Service. Arcata, CA.
(discussing Oregon Forest Practices in Chapters 1 through 6 at pages 3-56 and 3-57)