Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
alan@socan.eco
541-500-2331
February 5th 2024

 

 

Reference Bill Number SB1596

Chair Sollman and Members of the Senate Energy and Environment Committee:

I write as cofacilitator of Southern Oregon Climate Action Now, an organization of some 2,000 Southern Oregonians who are concerned about the climate crisis and encourage state action to address it.  As rural Oregonians, we live on the frontlines of the warming, reducing snowpack, heatwaves, drought, and the increasing wildfire risk that these trends conspire to produce.  Because of this, we pay close attention to what is happening in Salem in terms of legislative proposals.

I write today to offer our support for SB1596.  During the 1970s, the decade that was launched with the first Earth Day, Americans were becoming aware of the environmental cost of consumerism (Dagger 2023).  The trio of terms, Reduce, Reuse, Recycle, and their collective logo was promoted to reduce the waste stream. It is noteworthy that, although ‘recycle’ seems to have become the lead term in our consciousness, it was then, and still remains, the last term in the sequence. Essentially, recycling should be what we do when we have reduced and reused to the maximum extent possible.  More recently, to the famous trio have been added two more Rs. Thus, the twenty-first century environmentalist call to sustainability urges us to: Refuse, Reduce, Reuse, Repurpose, Recycle (e.g., Roadrunner 2023). Note that recycling remains the final effort in the sequence as we encourage both declining to consume so much and repurposing what we cannot reuse.

Closely aligned with the environmental concern about consumerism, is the concern about our ‘throw-away society (Hadjiosif 2021) in which we “we choose ‘convenience’ over what’s better for the planet.” This author lays the blame, at least in part, on the industrial revolution after which it became easy to mass produce items and the invention of plastics. While it is unfortunate that we have adopted the convenience of simply throwing away items such as plates, napkins and plastic bottles it is also unfortunate that we have seen the same disposable behavior include items such as electronics that could be repaired if only owners or technicians had the manuals allowing them to undertake the repair.  As we have seen, and SB1596 addresses, one of the reasons for this inability to repair is a conscious effort on the part of some manufacturers to limit access to the tools necessary to allow the easy repair of items. Maybe we should add another R so that the admonition is to Refuse, Reduce, Reuse, Repair, Repurpose, Recycle.

One of the driving factors behind the 3, now 5 (or 6), Rs is that adopting the mindset that this behavior encourages reducing our use of both materials and energy. While reducing both leads to a more sustainable lifestyle, reducing energy consumption also has a profound impact on addressing the climate crisis by reducing our use of fossil fuels to generate energy.  In addition, making repairing items easier also has huge social justice benefits since it is low-income Oregonians who are less able to adopt the consumerist ‘throw-away’ approach to materials.

For the above reasons, Southern Oregon Climate Action Now endorses SB1596 and encourages its swift passage.

Respectfully Submitted

Alan Journet

Dagger 2023 What are the 3Rs (for the environment)? Reduce, reuse, recycle. GWP Group. https://www.gwp.co.uk/guides/what-are-the-3rs/#:~:text=There%20is%20considerable%20debate%20on,became%20much%20more%20environmentally%20conscious.

Hadjiosif, S 2021 How We Became A Throw-away Society. Terra Movement. https://www.terramovement.com/how-we-became-a-throw-away-society/

Roadrunner 2023 THE 5 R’S: REFUSE, REDUCE, REUSE, REPURPOSE, RECYCLE. Roadrunner Modern Waste + Recycling.   https://www.roadrunnerwm.com/blog/the-5-rs-of-waste-recycling#:~:text=The%205%20R’s%3A%20Refuse%2C%20Reduce%2C%20Reuse%2C%20Repurpose%2C%20Recycle

 

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
alan@socan.eco
541-500-2331
February 17th 2024

 

Reference Bill Number SB1593

Chair Meek and Members of the Senate Committee on Finance and Revenue:

I write as cofacilitator of Southern Oregon Climate Action Now, an organization of some 2,000 Southern Oregonians who are concerned about the climate crisis and encourage state action to address it.  As rural Oregonians, we live on the frontlines of the warming, reducing snowpack, heatwaves, drought and the increasing wildfire risk that these trends conspire to produce.  Because of this, we pay close attention to what is happening in Salem in terms of legislative proposals. Living in rural Oregon, we are naturally quite aware of and concerned about the problem of wildfire since they have recently wrought havoc and pose a direct risk to us on an almost annual basis.

I write today to offer our perspective on SB1593. Before commenting on the proposal itself I offer a little fire ecology background.

Oregonians live in a Mediterranean-type climate (MTC) where summers are very dry, and winters are wet. This is a very unusual climate, occurring in just a few locations around the globe (e.g., Geodiode undated): around the Mediterranean ocean (of course), western North America (from Washinton down to California), western S. America (especially Chile), western South Africa (around Cape Town), southwestern Australia (around Perth) and South Australia (north of Adelaide). Discussing fire and plant diversification in this climate Rundel et al. (2018) argue: “The onset of MTCs in the middle Miocene brought summer drought, a novel climatic condition, but also a regime of recurrent fire.” They also report the conclusions of Keeley et al. (2012) that: “Mediterranean-type climates with summer drought conditions are conducive to regular fire. The mild wet winter-spring seasons lead to moderate productivity generating broad landscapes of contiguous fuels, and the annual summer drought converts this biomass into available fuels.” I stress this history to underline that fire has been a constant factor influencing the forest ecosystems of Oregon for millennia and certainly throughout the period that our current associations of tree species have occupied the region.  As a result, our forests, particularly our dry forests, are fire prone, fire adapted and fire dependent.  Ongoing forest health requires recurrent fire.  In addition to the impact of climate on fire frequency, Native Americans, who have existed alongside our western forests essentially for thousands of years, have successfully incorporated into their forest management regimes frequent burning (e.g. Philips 2023).

The recent history of climatic conditions has displayed considerable variability.  During the last century, for example, we have experienced fluctuations in the Pacific Decadal Oscillation (PDO).  The PDO cycles every several decades between a warm and dry climate inland and a cool moist climate.  Not surprisingly, the former phase is likely to stimulate dry vegetation and the spread of wildfires once they are ignited, while the latter tends to suppress that risk. For example, over a decade ago, Keeton et al. (2007) concluded from 20th century data: “Forest fires showed significant correlations with warm/dry phases of the PDO at regional and state scales…” The Oregon Department of Forestry has been reporting data since 1911 on the area under its fire management burned by wildfire. In recent years, this has been related to the PDO transitions (Figure 1 – modified from ODF 2022).

Many Oregonians are surprised to discover that, with the exception of the remarkable year of 2020, the area annually burned during the early decades of the last century exceeded that burning recently.  Note the graph indicates that fire initiations, though variable year-to-year, show no overall trend.  Meanwhile, on the other hand, the area burned was clearly greater in the early years of the 20th century than now – with the singular exception of 2020.  Note also how the decline in the area burned in the early 1940s coincided both with the transition in the PDO from a warm to a cool phase, and with the launch of the Smokey Bear campaign of fire suppression (added to depict its potential relevance). Then the recent increase in area burned from the late 1980s coincides first with the return of the PDO warm phase but also with the statewide increase in temperature consequent upon global warming (Figure 2) where we can see that the recent warming phase started its upward climb in the mid-1980s and has continued essentially unabated.

One consequence of the successful fire suppression campaign has been an extension in the historic Fire Return Interval (FRI), particularly in our dry forests.  The FRI in the Southwest historically ranged from single digits to the low teens (e.g., Metlen et al. 2018). With successful fire suppression, the FRI has lengthened substantially. This has resulted in the invasion into the forests of fire intolerant species (Zouhar et al. 2008) and an increased density of vegetation serving as fuel for fires once ignited (e.g., Philips 2023). Thus, we can reasonably infer that the data on the area burned display a correlation with both climatic shifts and human fire suppression efforts.  While correlations don’t necessarily imply cause and effect, it seems reasonable to infer that climate and fire suppression have been implicated in the increase in area burned over the last few decades.  Interestingly, these trends, notably climate and fire suppression influencing fire risk, are not restricted to the Mediterranean climate of the western United States but are described elsewhere, for example in the Appalachian forests (Reilly et al. 2022).

The patterns described above are compounded by current climate projections available from the USGS (Alder and Hostettler 2013). These projections rely on the latest Intergovernmental Panel on Climate Change scenarios (IPCC 2023) involving an array of Shared Socioeconomic Pathways (SSPs) that depict different future human behaviors and their atmospheric and climate consequences.  In these USGS graphs, the blue lines and shading represent the SSP 4.5 scenario, the orange line and shading represent the SSP7.0 scenario and the red line and scenario represent the SSP 8.5 scenario. These are discussed by Hausfather (2019). Schaumann (2022), meanwhile, states “RCP-8.5 is not only the arguably most popular climate change scenario, but is also often framed in a very specific manner: as the business-as-usual trajectory that humanity is on if no climate change policies are adopted.” Since managing climate change comprises risk management, it seems rational to focus on what may be the most serious outcome which is reflected in the 8.5 future.

If Oregon follows the temperature trend consistent with the recent past (Figure 3), by the end of the century, annual temperatures will likely climb over 10⁰F (about 6⁰C) above the 1981-2010 average. The same source indicates that the projected trend of increasing temperature is greater during summer months than winter months.

The same USGS source (Alder and Hostettler 2013) provides projections that suggest average annual precipitation will change little (Figure 4) although seasonal patterns are different: winters will likely exhibit a slight increase in precipitation while summers will likely exhibit a slight decrease. As a result, we can expect the very conditions (increasing temperature and decreasing water availability during summer and fall) stimulating wildfire spread will become more severe.  A decade ago, Marlon et al. (2012) reported on the historical relationship between climate and areas burned by wildfires over several thousand years. They concluded that the western U.S. is already currently experiencing a substantial fire deficit, meaning that according to climatic patterns, the area burned should currently be much greater than it is.  Presumably, the projected climate trends will only exacerbate this fire deficit, creating conditions where even greater risk of megafires can be expected.

This leads to the critical question of what we should do to address and manage this wildfire problem. There is no magic bullet. However, history and evidence tell us that management that simply suppresses and extinguishes all fires, rather than management that recognizes the need for fires in our forests, is doomed to failure. Rather than develop management plans that simply increase our susceptibility to fires spreading once initiated, we need to develop plans that both manage fires once initiated and include prescribed fires that simulate the historic pattern and thus promote healthy forests. This illustrates the problem of unintended consequences.  While there is no doubt that Oregonians have recently suffered much from the smoke and disastrous loss that have resulted from fire, it is critical that those making decisions on policy and funding acknowledge the fire ecology of our forests and respond appropriately.

It is also worth recognizing a commonly voiced and false opinion (e.g., VBC 2022) that many Oregonians maintain is that most destructive wildfires start on public rather than private land. However, in the western United States, fires that cross ownership boundaries (so-called cross boundary fires) more frequently originate on privately owned land and cross onto USFS lands than the reverse (Downing et al. 2022). Lunderberg (2022) summarized these findings with the conclusion: “Of all ignitions that crossed jurisdictional boundaries, a little more than 60% originated on private property, and 28% ignited on national forests. Most of the fires started due to human activity.” Lundquist (2022) summarized the same study by stating: “The data showed that ignitions on Forest Service land resulted in fewer than 25% of the most destructive wildfires – those causing the loss of more than 50 structures.”

Given this context, we offer the following comments on SB1593:

There can be little doubt among Oregonians that wildfires are a problem.  Data from forests managed by the Oregon Department of Forestry (Figure 1 above) should be sufficient to demonstrate this. Although, as noted previously, 2020 was an extreme case and fires a century ago burned greater areas than recently, the evidence suggests that, though not consistent or inevitable, the last decade has seen an increase in area burned compared to several decades ago.  During the 2021-23 biennium, the problem was recognized by the legislature which then passed SB762 committing $200 million to addressing the wildfire problem. Regrettably, this allocation has not been maintained, thus starving Oregonians of the funds needed to address the wildfire problem.  Given that there is a need for funds to address the problem, the question becomes: from where should these funds come?

The current debate regarding the source of the funds to address the wildfire problem presents us with a choice between raising the funds from all Oregonians or from those landowners engaged in forestry and ranching who benefit directly from the Oregon Department of Forestry firefighting activities.

Taxes raised from timber fall into several categories: Privilege taxes comprise a charge for the privilege of harvesting timber in Oregon with revenue distributed to local counties (LRO 2012) , the rate being charged per thousand board feet of timber harvested. The Timber Harvest tax is another tax also imposed per thousand board feet with revenues assigned quarterly to administering the Forest Practices Act, Forestry Research at OSU, Oregon Forestland protection Fund, Oregon Forest Resources Institute (ODOR undated).  Severance taxes were imposed on the value of harvested timber in eastern Oregon in 1966 and western Oregon in 1972 with revenue distributed to local taxation districts to replace property taxes (LRO 2012). Prior to the phase out of the Severance tax, Oregon’s timber counties received substantial income for county services from this tax.  Finally, specifically to fund fire protection, Oregon established an acreage assessment in 1973 (Rocco and Hill 2016) whereby landowners are charged a “pro rata share per acre for fire protection based on the number of acres they own within a specific fire district.”

Holvey (2021) produced a graph (Figure 5) illustrating the history of timber tax revenue from 1990 – 2012. As a result of abolishing the Severance tax in 1999, generated revenue dwindled, disappearing completely by 2003-2004.  However, as ODOR (2015) states, a small tract forest severance tax (STF) is in place, with fees indexed to reflect changes in forestland values. The STF was established in 2003 (LRO 2012) with revenues distributed to the state school fund, community college fund and the counties. Presumably because of different forestland values, the 19 western counties are taxed at a different rate from the 17 eastern counties (ODOR 2015).

Green (2018) reported the findings of Chuck Willer of the Coast Range Association that: “Oregon’s west-side county governments are collecting 85 percent less in tax revenue from private timber companies than they were in the early 1990s, while logging on private lands has remained largely unchanged.” Younes and Schick (2020) reported that Oregon’s western counties (Multnomah was excluded) lost $2.3 billion between 1991 and 2019 as a result of the Severance tax being abolished.  Incidentally, these counties also lost $3.5 billion from diminished Federal payments resulting from reduced payments to counties as revenue from timber sales on federal lands, and subsidy payments made as federal logging levels declined.

Additionally, in an assessment of proposals before the Oregon legislature in the current session Baumhardt (2024) reported that taxes collected from timber harvest in Oregon (in 2018) were approximately half those imposed in the state of Washington.

The evidence indicates clearly that revenues from the harvest of timber in Oregon are lower than Washington state and haves declined since the Severance tax was repealed. This has been profoundly detrimental to the counties where timber revenue has been important.

We applaud the principle embedded in the bill that exempts small landowners harvesting and selling under 25,000 board feet.  While we may not always be thrilled by actions undertaken by the Oregon Department of Forestry, we certainly acknowledge the benefit of funding that agency.  Given the increasing risk that Oregonians face from wildfire, we also support funding efforts to reduce the risk faced by individual Oregonians.  Since the evidence demonstrating the immense loss of revenue suffered by rural timber counties, and the consequent threat to community services, we endorse the principle that a substantial proportion of the revenue generated from a Severance tax should be allocated to the counties.

We are mindful that there is an increasing trend towards Oregon private forests not being owned by regional individuals or even regional corporations but by Timber Investment Management Organizations (TIMOs) and Real Estate Investment Trusts (REITs).  In many cases these are not even based in Oregon and view our forests as merely resources to be exploited for maximizing shareholder profits (e.g., Latter 2023, Schick et al. 2020, Hickman 2020, Coast Range 2024).  Latter (2023) pointed out that Weyerhaeuser, the largest forest owner in western Oregon is a REIT while Coast Range (2024) assessed the proportion of the 4.4 million acres of Western Oregon private forest land owned by REITs or TIMOs as 62%.  We argue that Oregon’s forests should be managed to counter the climate crisis, and in the service of Oregonians not distant shareholders who are concerned only about short-term profits.

For these reasons, we appreciate the principles that (a) the tax rate should rise with increasing acreage, and (b) landowners managing their forests according to Forest Stewardship Council principles should be awarded a tax break.

We support SB1593 with and without amendment -01.  While we would prefer a hastier adoption of the principles embedded in SB1593 than will be permitted by establishing a study, we recognize that procedural limitations may make this the best option for moving the concept forward.

Respectfully Submitted

Alan Journet

References Cited

Alder J and Hostetler S, 2013. USGS National Climate Change Viewer. US Geological Survey  https://doi.org/10.5066/F7W9575T

Baumhardt A 2024 Democrats split on charging public or timber industry for more of Oregon’s wildfire protection. Oregon Public Broadcasting. https://www.opb.org/article/2024/02/06/oregon-wildfire-protection-politics-timber-industry-forest-logging-taxes/

Coast Range 2024. Documenting Forest Ownership in Oregon. Coast Range Association. https://coastrange.org/challenging-wall-street-forestry/ownership/

Downing W, Dunn C, Thompson M, Caggiono M , Short K. 2022. Human ignitions on private lands drive USFS cross-boundary wildfire transmission and community impacts in the western US Nature Scientific Reports  12:2634. https://www.nature.com/articles/s41598-022-06002-3

Geodiode. undated. Secrets of World Climate, Chapter 6 Mediterranean. Secrets of World Climate Series. Geodiode, The Ultimate Educational Resource for Climate and Biomes. https://geodiode.com/climate/mediterranean

Green E 2018 Cut and run dry: Do Oregon tax laws favor the timber industry? Street Roots. https://www.streetroots.org/news/2018/09/07/cut-and-run-dry-do-oregon-tax-laws-favor-timber-industry

Hausfather 2019 Explainer: The high-emissions ‘RCP8.5’ global warming scenario. Carbon Brief https://www.carbonbrief.org/explainer-the-high-emissions-rcp8-5-global-warming-scenario/

Hickman C 2020 TIMOs and REITS- An Intro by Cliff Hickman. The Smokey Wire : National Forest News and Views. https://forestpolicypub.com/

Holvey P. 2021 HB2379 Representative Paul Hovey.  https://olis.oregonlegislature.gov/liz/2021R1/Downloads/PublicTestimonyDocument/24304

IPCC 2023 AR6 Synthesis Report: Climate Change 2023. Intergovernmental Panel on Climate Change. https://www.ipcc.ch/report/ar6/syr/

Keeley J, Bond W, Bradstock R, Pausas J and, Rundel P. (2012). Fire in Mediterranean Ecosystems: Ecology, Evolution and Management. Cambridge: Cambridge University Press. https://scholar.google.com/scholar_lookup?&title=Fire+in+Mediterranean+Ecosystems%3A+Ecology%2C+Evolution+and+Management%2E&author=Keeley+J.+E.&author=Bradstock+R.+J.&author=Bond+W.+A.&author=Pausas+J.+G.&author=and+Rundel+P.++W.&publication_year=2012

Keeton W, Mote P, Franklin J 2007 Chapter 13.  Climate Variability, Climate Change, and Western Wildfires with Implications for the Urban-Wildland Interface. [In] Living on the Edge: Economic, Institutional and Management Perspectives on Wildfire Hazard in the Urban Interface. Editors Troy A and Kennedy R. https://www.uvm.edu/giee/pubpdfs/Keeton_2007_Advances_in_Econ_of_Env_Resources.pdf

Latter J 2023 Who Will Own the Forest? Bark https://bark-out.org/news/who-will-own-the-forest/#:~:text=Over%20the%20past%20few%20decades,operated%20by%20large%20corporate%20entities.

LRO 2012 Timber Revenue Legislative Revenue Office Background Brief – Legislative Committee Services. https://www.oregonlegislature.gov/lpro/Publications/TimberRevenue.pdf

Lunderberg S. 2022. OSU research suggests Forest Service lands not the main source of wildfires affecting communities. Oregon State University. https://today.oregonstate.edu/news/osu-research-suggests-forest-service-lands-not-main-source-wildfires-affecting-communities#:~:text=Of%20all%20ignitions%20that%20crossed,started%20due%20to%20human%20activity.

Lunquist L 2022. Study: Most Destructive Wildfires Have Started on Private Land. Missoula current. https://missoulacurrent.com/study-wildfires-land/#:~:text=A%20recent%20study%20shows%20that,focuses%20on%20people%2C%20not%20forests.

Marlon J, Bartlein P, Gavin D, Walsh M. 2012 Long-term perspective on wildfires in the western USA. Proceedings f the National Academy of Sciences. 109 (9) E535-E543 https://www.pnas.org/doi/abs/10.1073/pnas.1112839109

Metlen K, Skinner C, Olson D, Nichols C, Borgias D 2018 Regional and local controls on historical fire regimes of dry forests and woodlands in the Rogue River Basin, Oregon, USA. Forest Ecology and Management 430: 43 – 58. https://www.ashland.or.us/SIB/files/AFR/Monitoring%20Documents/Metlen_et_al_18_historical_Rogue_Basin_Oregon.pdf

NOAA 2024 Climate at a Glance Statewide Series.  National Centers for Environmental Information, National Oceanic and Atmospheric Administration. https://www.ncei.noaa.gov/access/monitoring/climate-at-a-glance/statewide/time-series/35/tavg/12/12/1895-2023?base_prd=true&begbaseyear=1901&endbaseyear=2000&trend=true&trend_base=10&begtrendyear=1895&endtrendyear=2019

ODF 2022 ODF Fire History 1911-2022. Oregon Department of Forestry. https://www.oregon.gov/odf/fire/documents/odf-century-fire-history-chart.pdf

ODOR 2015. 2015 Understanding Oregon’s Timber Tax Programs and How to Complete Forms. Oregon Department of Revenue. https://knowyourforest.org/sites/default/files/documents/understanding-timber-tax_441-409_0.pdf

ODOR undated. Timber Harvest Taxes. Oregon Department of Revenue Timber Taxes. https://www.oregon.gov/dor/programs/property/pages/timber-harvest-taxes.aspx#:~:text=This%20tax%20provides%20for%20the,lands%20classified%20under%20the%20program.

Philips C. 2023. How Forest Management Can Build Healthy Wildfire Cycles in Western North America. The Equation; Union of Concerned Scientists. https://blog.ucsusa.org/carly-phillips/forest-management-and-wildfire-in-western-north-america/#:~:text=Suppressing%20all%20fires%20and%20excluding,dead%2C%20accumulated%20in%20the%20understory.

Reilly M, Norman S, O’Brien J, Loudermilk E. 2022 Drivers and ecological impacts of a wildfire outbreak in the southern Appalachian Mountains after decades of fire exclusion. Forest Ecology and Management 524.120500. https://www.sciencedirect.com/science/article/abs/pii/S0378112722004947

Rocco K and Hill D 2016 How Oregon Funds Forest Wildfire Protection. Legislative Fiscal Office. https://www.oregonlegislature.gov/lfo/Documents/2016-3%20Forest%20Wildfire%20Protection.pdf

Rundel P, Arroyo M, Cowling R, Keeley J, Lamont B, Pausas J, Vargas P. 2018 Fire and Plant Diversification in Mediterranean-Climate Regions. Frontiers in Plant Science Volume 9. https://doi.org/10.3389/fpls.2018.00851

Schaumann F 2022 RCP-8.5: Business-As-Usual or Unrealistic Worst-Case? The contested interpretation of climate change scenarios. Climate Matters https://climatematters.blogs.uni-hamburg.de/2022/07/rcp-8-5-business-as-usual-or-an-unrealistic-worst-case/#:~:text=RCP%2D8.5%20is%20not%20only,climate%20change%20policies%20are%20adopted.

Schick T, Davis R, Younes L 2020 Big money bought the forests. Small timber communities are paying the price. The Oregonian https://projects.oregonlive.com/timber/  https://missoulacurrent.com/study-wildfires-land/#:~:text=A%20recent%20study%20shows%20that,focuses%20on%20people%2C%20not%20forests

VBC 2022 Wildfire and Forest Management. Oregon Values and Beliefs Center. https://oregonvbc.org/wildfire-and-forest-management/

Zouhar K, Smith J, Sutherland S, Brooks M. 2008. Wildland fire in ecosystems: fire and nonnative invasive plants. Gen. Tech. Rep. RMRS-GTR-42-vol. 6. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 355 pp. https://bugwoodcloud.org/mura/mipn/assets/File/Wildland%20Fire_USFS.pdf

 

Alan Journet, November 17th 2023

At its November 16-17 meeting the state Environmental Quality Commission approved rules for the administration of the Climate Protection Program (CPP) developed by the state Department of Environmental Quality (DEQ) based on recommendations from a Rulemaking Advisory Committee (RAC) composed almost entirely of energy industry representatives.  The CPP had previously been approved by the EQC and seemed likely to contribute substantially to forging a pathway for the state to reduce our greenhouse gas emissions sufficient to meet our fair reduction given global demands.  Regrettably, the rulemaking proposals represented a weakening of the program previously approved. As is often noted with state and federal program proposals: ‘The devil is in the details’ and the details are always the rules that are developed to allow administration of a program. In this case, the rules weakened the program in several areas, notable the industrial Best Available Emissions Reduction (BAER) rules, and the allowance for gas utilities regarding biomethane and hydrogen.  While the draft rules elicited over 2,000 public comments, the majority of which argued against the weakened rule proposals, the rules that were ultimately approved suggested that DEQ had succumbed to pressure from the fossil fuel industry rather than impose rules that are as rigorous as we need.  The following represent the brief written comments that I developed based on the prior stated allowance of three minutes for oral comments. Unfortunately, on the day this was reduced to one minute because of the number of potential testimonies.  I submitted the following to augment my 1 minute oral allowance:

“Good morning! My name is Alan Journet from rural Jackson County

“I retired in 2010 after teaching Biology for 30 years at Southeast Missouri State University and relocated to Oregon the same year.  It was teaching the Community Ecology section of a General Ecology course, several decades ago now, that stimulated my initial alarm about the threat of global warming.  As I was teaching community ecology, I realized that the climate projections then before us would be sufficient to destroy natural ecosystems (forests, woodland, grasslands, deserts, tundra) across the planet along with the biodiversity they comprise. My ecological understanding indicated that not only would our natural world, our ecological life support system, be destroyed by these changes if they came to pass, but our agriculture, forestry, and fisheries would be equally damaged.  I realized then, and still understand, that droughts, floods, hurricanes, and wildfires, serious as they are, are not the only threats we face. We are also undermining life on the planet as we know it.

“It was then that I vowed to explore climate science to assess its credibility.  Having convinced myself of that credibility, I then dedicated myself to educating folks about the science of global warming, the threat of its climate change consequences, and what we can do to address it.

“Thus, in 2012, I co-founded and still co-facilitate Southern Oregon Climate Action Now, an organization of over 2,000 Southern Oregonians concerned about the climate crisis.  It is in that vein that I testify before you today.

“The United Nations reported on November 14th that signatories to the UN Framework Convention on Climate Change 2015 Paris Agreement are still not demonstrating the rapid downward trend in emissions that science says is necessary to direct our collective trajectory away from climate disaster.  Then, on November 15th, the World Meteorological Union reported that the atmospheric carbon dioxide concentration is now 50% higher in the atmosphere than during pre-industrial times while methane continues to increase, and nitrous oxide increased more from 2021-2022 than ever it has done. Finally, the 2023 Nation Climate Assessment concluded that nationally we are experiencing the climate impacts of global warming in every region of our country and throughout our economy.

“Governor Brown’s Executive Order 2020-04 attempted to place Oregon on a reasonable statewide emission trajectory consistent with our collective global need.  In following this order, DEQ developed and the EQC approved a Climate Protection Plan that had a good chance of contributing substantially to achieving this goal.  We are now disappointed to learn that DEQ has proposed rules that substantially undermine that plan.  Advised by a RAC dominated by the very entities that are causing the problem, DEQ seemingly underestimated the plight we are collectively in and seems to have succumbed to fossil fuel corporate pressure to weaken the CPP. 

“If we don’t all wake up and do what we can to address this problem, we are doomed. Those needing to wake up include the public, fossil fuel corporate leaders, state agency personnel, and legislators.  When the DEQ undergoes its CPP review process, I urge them to remedy the giveaways to fossil fuel interests embedded in these rules.

Rising temperatures bring an increased risk of wildfire.

Bybee Fire Photo by Alan Journet

Alan Journet Rogue Valley Times September 21st 2023

In a recent Our View, we see a discussion of a climate study that adds fuel to an existing fire. It’s always important in such discussions to consider the evidence and the science.

Rogue Valley and West Coast residents are familiar with the rainfall pattern: Every summer our grass turns brown and dries out. Then come the winter rains, and everything revives to a gorgeous green. This pattern has existed here for millennia. Once summer arrives, we can count on dry days and nights producing semi-drought conditions almost annually, conditions that only break when winter rains return.

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SOCAN’s response to the Board of Forestry regarding  efforts by the timber industry to undermine the Habitat Conservation Plan developed by the Oregon Department of Forestry following the Private Forest Accord

 

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
alan@socan.eco
541-500-2331
September 5th 2023

 

Chair Kelly and members of the Oregon Board of Forestry

Reference: Efforts to undermine the Habitat Conservation Plan

I write as cofacilitator of Southern Oregon Climate Action Now (SOCAN https://socan.eco ), an organization of over 2,000 rural Southern Oregonians who are concerned about the climate crisis and urge statewide action to address it. The mission of SOCAN is to promote awareness and understanding of the science of global warming and its climate chaos consequences and stimulate individual and collective action to address it. Since rural Oregonians occupy the frontlines in experiencing the impact of the drought, shrinking snowpack, wildfires and extreme weather that the climate crisis imposes, we are strongly committed to statewide action.

It is in this context that we watched the developing the Private Forest Accord and consequent Habitat Conservation Plan with great interest.

The Habitat Conservation Plan was developed (PFA 2022) to assure habitat for:

  • All native salmon and trout (Oncorhynchus spp.)
    ● Bull trout (Salvelinus confluentus)
    ● Mountain whitefish (Prosopium williamsoni)
    ● Pacific eulachon/smelt (Thaleichthys pacificus)
    ● Green sturgeon (Acipenser medirostris)
    ● Columbia torrent salamander (Rhyacotriton kezeri)
    ● Southern torrent salamander (Rhyacotriton variegatus)
    ● Coastal giant salamander (Dicamptodon tenebrosus)
    ● Cope’s giant salamander (Dicamptodon copei)
    ● Coastal tailed frog (Ascaphus truei)

The planning process, undertaken by the Oregon Department of Forestry, combined best available science with extensive public input producing a plan that served the defined goals.  It is unfortunate that once developed, in an effort to increase timber harvest, the plan has fallen prey to timber industry criticism and efforts to undermine it by appeals to the Governor and the Board.

According to statute the Greatest Permanent Value for managing Oregon’s forests includes an array of goals in ORS 530.050 (ORS undated):

Management of lands acquired; powers of forester; rules, Oregon’s forests should be managed for their Greatest Permanent Value.  This comprises:

(1) Protect the lands from fire, disease and insect pests, cooperate with the counties and with persons owning lands within the state in the protection of the lands and enter into all agreements necessary or convenient for the protection of the lands.

(2) Sell forest products from the lands, and execute mining leases and contracts as provided for in ORS 273.551.

(3) Enter into and administer contracts for the sale of timber from lands owned or managed by the State Board of Forestry and the State Forestry Department.

(4) Enter into and administer contracts for activities necessary or convenient for the sale of timber under subsection (3) of this section, either separately from or in conjunction with contracts for the sale of timber, including but not limited to activities such as timber harvesting and sorting, transporting, gravel pit development or operation, and road construction, maintenance or improvement.

(5) Permit the use of the lands for other purposes, including but not limited to forage and browse for domestic livestock, fish and wildlife environment, landscape effect, protection against floods and erosion, recreation, and protection of water supplies when, in the opinion of the board, the use is not detrimental to the best interest of the state.

(6) Grant easements, permits and licenses over, through and across the lands. The State Forester may require and collect reasonable fees or charges relating to the location and establishment of easements, permits and licenses granted by the state over the lands. The fees and charges collected shall be used exclusively for the expenses of locating and establishing the easements, permits and licenses under this subsection and shall be placed in the State Forestry Department Account.

(7) Require and collect fees or charges for the use of state forest roads. The fees or charges collected shall be used exclusively for the purposes of maintenance and improvements of the roads and shall be placed in the State Forestry Department Account.

(8) Reforest the lands and cooperate with the counties, and with persons owning timberlands within the state, in the reforestation, and make all agreements necessary or convenient for the reforestation.

(9) Require such undertakings as in the opinion of the board are necessary or convenient to secure performance of any contract entered into under the terms of this section or ORS 273.551.

(10) Sell rock, sand, gravel, pumice and other such materials from the lands. The sale may be negotiated without bidding, provided the appraised value of the materials does not exceed $2,500.

(11) Enter into agreements, each for not more than 10 years duration, for the production of minor forest products.

(12) Establish a forestry carbon offset program to market, register, transfer or sell forestry carbon offsets. In establishing the program, the forester may:

(a) Execute any contracts or agreements necessary to create opportunities for the creation of forestry carbon offsets; and

(b) Negotiate prices that are at, or greater than, fair market value for the transfer or sale of forestry carbon offsets.

It is important to note that the Greatest Permanent Value is not restricted to providing timber products, but includes serving an array of service, recreational and forest health benefits.  We note particularly that item 12 establishes a carbon offset program.  Clearly, the Greatest Permanent Value acknowledges the critical role our forests play in sequestering carbon, a reality also reflected in the passage during the 2023 Oregon Legislative Session of SB530, the natural climate solutions bill (Olis 2023a), as part of the climate package, HB3409 (Olis 2023b). That substantial carbon is stored in Oregon’s forests is recognized almost universally (e.g., OFRI 2020, Oregon Wild 2019, Christensen et al. 2019, Law et al. 2022).

What seems to be less widely recognized, however, is the role forest logging operations play in the emissions of carbon. Indeed, evidence suggests that emissions from logging are actually greater than those resulting from transportation.  That the impacts of logging are not reported in the DEQ data (e.g., DEQ 2022) on greenhouse gas emissions (Hudiburg et al. 2019) is presumably a function of DEQ’s lack of authority to measure this sector.

Evidence that logging operations constitute a threat to Oregon’s environment was discussed by Schick 2017) in relation to water concerns. That some forestry operators are guilty of violating air quality standards was reported more recently by Bonham (2023). Law et al. 2018 reported that during the period 2011-2015 carbon dioxide emissions from “net wood product emissions were 34.45 million tCO2e and almost 10-fold fire emissions…” Notably, during this same period, emissions from the largest sector reported by DEQ (transportation) fluctuated around 21-22 million tCO2e (OGWC 2017). Emissions from forestry operations are some 1.5 times the worst sector reported by DEQ.

Since the focus of SOCAN is on the climate crisis and the carbon balance in our forests, we are particularly concerned about any proposal that promotes an increase in logging which seems to be exactly what the proposed modifications to the HCP seek.  Not only does the logging of mature trees eliminate the ability of those trees to sequester further carbon, the logging and processing of that timber also emits substantial greenhouse gas (Law et al. 2018).  In defense of logging, proponents often argue that considerable carbon is stored in wood products, but this is simply untrue.  While certainly some carbon is stored, this is a very small percentage of the carbon either in the harvested tree or the harvested ecosystem. Thus, Ingerson (2007) reports results from Smith et al. (2006) and Gower et al. (2006) that indicate that the percentage of carbon ending up in forest products following harvest and processing, and allowing for emissions from this and product transportation, amounts to a scant 15%. Meanwhile, Hudiburg et al. (2019) report: “In just over 100 years, Oregon has removed the equivalent of all live trees in the state’s Coast Range forests (Law et al. 2018) and returned 65% to the atmosphere and transferred 16% to landfills.” This leaves just 19% of the harvested ecosystem carbon that is stored in wood products. In short, while some carbon is assuredly retained in wood products, the vast majority is not and is simply consigned to the atmosphere.

Another argument of proponents of logging is that the newly planted trees sequester carbon rapidly to replace that which was harvested and compensate for the compromised potential for ongoing sequestration of harvested trees. Regrettably, however, it takes decades for a seedling to reach the storage capacity of a harvested tree or the rate of sequestration of that harvested mature tree. Douglas fir, for example, at 5 years captures 0.0005 pounds of carbon, while at 50 years, this climbs to 0.1763 pounds. Then, at 100 years this reaches 0.7658 pounds while at 200 years, it becomes 2.0714 pounds and at 300 years 5.6028 pounds (Treeplantation 2023). Koberstein and Applegate (2019) identify the trends in aging forest stands as follows: “While young forests tend to absorb more carbon overall because trees can be crowded together when they’re small, a tree’s carbon absorption rate accelerates as it ages. This means that forests comprised of tall, old trees – like the temperate rainforests of North America’s Pacific coast – are some of the planet’s biggest carbon storehouses.” Griscom et al. 2017., considering the benefits of Natural Climate Solutions, argue that they “provide a comprehensive analysis of options to mitigate climate change by increasing carbon sequestration and reducing emissions of carbon and other greenhouse gases through conservation, restoration, and improved management practices in forest, wetland, and grassland biomes.” They further suggest that “While some activities can be implemented without reducing wood yield (e.g., reduced-impact logging), other activities (e.g., extended harvest cycles) would result in reduced near-term yields.” It seems that those engaged in natural resource management have to make decisions regarding priorities: is it more important to harvest forests or manage them for carbon sequestration to protect our climate and life on the planet as we know it? A vote for logging as opposed to habitat protection and carbon sequestration constitutes a vote against the conservation of life as we know it. Meanwhile, Ameray et al. 2021 report: “the old-growth forest conservation strategy results in greater carbon storage in soils than do extensive and intensive forest management.” If Oregon’s forests are to be managed for carbon sequestration, as suggested in SB530 (Olis 2023a), increasing logging is not the optimal route.

Studies have suggested how future climate conditions might affect the viability of critical western tree species (Crookston and Radtke 2023, CBI undated). These analyses explore the current climate where western tree species thrive and compared these to future climate conditions given a variety of greenhouse gas emissions scenarios. They have clearly indicated that the viability and distribution of many ecologically and commercially important tree species will be compromised by anticipated climate change. Yet, the timber industry continues to resist efforts to curtail the underlying causes of the climate crisis that will threaten their industry. Instead, they petition for continued logging and continued greenhouse gas emissions, compounding the problem they will inevitably face through the century absent substantial effort to curtail emissions.

After years of apparent good faith negotiations, the conservation groups and the timber industry arrived at an agreement that resulted in the Habitat Conservation Plan.  Instead of abiding by the agreement reached during this discussion, the timber industry petitioned for an exception to allow increased logging and increased greenhouse gas emissions. As Oregon and our state agencies grapple with the problem of addressing climate change, time and again corporations engage in the process claiming good faith and a commitment to addressing the climate crisis and reducing emissions. Yet, once agreements have been reached and programs have been developed, these same corporations launch efforts either through rulemaking or through judicial action to undermine the agreements that they were involved in developing.  This occurred with the Climate Protection Program where fossil fuel corporations now seek weakening of the program endorsed by the Environmental Quality Commission. This occurs despite the fact that the program resulted from rulemaking discussions in which they engaged. Now, we see the timber industry reneging on the agreement that they accepted and trying to undermine it by appeals to the Governor and Board of Forestry.  This corporate track record suggests that conservation and climate activists should be wary of future negotiations that demand the acceptance of good faith efforts on the part of corporations.

In the case of the Forest Accord and associated Habitat Conservation Plan, which were developed as a means to avoid an expensive ballot measure dispute, the message here is unfortunate. It suggests that conservation groups should return to the ballot measure as a means of curtailing the overharvesting and environmental destruction that seem to be the modus operandi of the timber industry.

The time surely has arrived when all of us in our personal and professional lives should do whatever we can to address the climate crisis.  We therefore urge the Board of Forestry to reject the proposed increase in logging and return to the HCA accepted by conservation groups and the timber industry. Failure to reject the proposed amendment will send a clear message to conservation and climate organizations that the Board of Forestry cannot be trusted to abide by agreements.

As evident, since the focus for Southern Oregon Climate Action Now is addressing the climate crisis by promoting carbon sequestration in our forests, this is the arena in which our comments focus. While we understand the concerns expressed by conservation groups regarding the proposed abridgment of the HCP, we will leave them to comment on that aspect of this effort by the timber industry to torpedo agreements.

Sources Cited:

Ameray A, Bergerson Y, Valeria O, Montoro Girona M, Cavard X 2021 Forest Carbon Management: a Review of Silvicultural Practices and Management Strategies Across Boreal, Temperate and Tropical Forests. Current Forestry Reports https://link.springer.com/article/10.1007/s40725-021-00151-w

Bonham R 2023 Sawmill violated emissions standards more than 40 times over eight-day period, DEQ says. KEZI https://www.kezi.com/news/sawmill-violated-emissions-standards-more-than-400-times-over-eight-day-period-deq-says/article_8737e3ee-e611-11ed-8cee-7765a54f8382.html

CBI undated Species Potential Habitat Tool, Conservation Biology Institute. https://specieshabitattool.org/spht/

Christensen G, Gray A, Kuegler O, Yost A 2019 Oregon Forest Ecosystem Carbon Inventory: 2001-2016. U.S. Forest Service, Pacific Northwest Research Station, and the Oregon Department of Forestry. https://www.oregon.gov/odf/ForestBenefits/Documents/Forest%20Carbon%20Study/OR-Forest-Ecosystem-Carbon-2001-2016-Report-FINAL.pdf

Crookston N and Radtke P 2023 Plant Species and Climate Profile Predictions. Virginia Tech. https://charcoal2.cnre.vt.edu/climate/species/

DEQ 2022 Oregon Greenhouse Gas Sector-based Inventory Data: Greenhouse Gas Inventory 1990-2021. Oregon Department of Environmental Quality. https://www.oregon.gov/deq/ghgp/pages/ghg-inventory.aspx

Gower ST; McKeon-Reudifer A; Bradley M; Refkin DJ; Tollefson T; Souba FJ; Taup A; Embury-Williams L; Schiavone S; WeinBauer J; Hanetos AC; Jarvis R 2006 Following the paper trail: the impact of magazine and dimension lumber production on greenhouse gas emissions: a case study. The H. John Heinz II Center for Science, Economics, and the Environment, Washington DC
No longer electronically available.

Griscum B, Adams J, Ellis P, Fargione J 2017 Natural climate solutions. Proceedings of the National Academy of Sciences 14 (44) 11645-11650. https://www.pnas.org/doi/10.1073/pnas.1710465114

Hudiburg T, Law B, Moomaw W, Harmon M, Stenzel J. 2019 Meeting GHG reduction targets requires accounting for all forest sector emissions. Environmental Research Letters 14 095005. https://iopscience.iop.org/article/10.1088/1748-9326/ab28bb

Ingerson A 2009. Wood Products and Carbon Storage: Can Increased Production Help Solve the Climate Crisis? The Wilderness Society https://www.sierraforestlegacy.org/Resources/Conservation/FireForestEcology/ThreatsForestHealth/Climate/CI-Ingerson-TWS2009.pdf

Koberstein P and Applegate 2019 Tall and old or dense and young: Which kind of forest is better for the climate? Mongabay https://news.mongabay.com/2019/05/tall-and-old-or-dense-and-young-which-kind-of-forest-is-better-for-the-climate/

Law B, Berner L, Mildrexler D, Bloemers R, Ripple Q 2022 Strategic reserves in Oregon’s forests for biodiversity, water, and carbon to mitigate and adapt to climate change. Frontiers in Forests and Global Change 5:1028401.  https://www.frontiersin.org/articles/10.3389/ffgc.2022.1028401/full

OFRI 2020 Carbon in Oregon’s managed forests. Oregon Forest Resources Institute. https://oregonforests.org/sites/default/files/2020-07/OFRI_CarbonSpecialReport_DIGITAL.pdf

OGWC 2017 Oregon Global Warming Commission Biennial Report to the Legislature 2017. Oregon Global Warming Commission. https://static1.squarespace.com/static/59c554e0f09ca40655ea6eb0/t/59dd4984a8b2b090a38f07a1/1507674513035/2017-OGWC-Legislative-Report.pdf

OLIS 2023a 2023 Regular Session. SB530A Oregon State Legislature Oregon Legislative Information. https://olis.oregonlegislature.gov/liz/2023R1/Measures/Overview/SB530

Olis 2023b 2023 Regular Session HB3409 Enrolled. Oregon State Legislature Oregon Legislative Information. https://olis.oregonlegislature.gov/liz/2023R1/Measures/Overview/HB3409

Oregon Wild 2019 Forest-Carbon 101. Oregon Wild https://oregonwild.org/forests/climate-change/forest-carbon-101

ORS undated Chapter 530 — State Forests; Community Forests Oregon State Statues. https://www.oregonlegislature.gov/bills_laws/ors/ors530.html

PFA 2022 Private Forest Accord.  Oregon Department of Forestry https://www.oregon.gov/odf/aboutodf/documents/2022-odf-private-forest-accord-report.pdf

Schick T 2017 After Pushback, Oregon Scraps Report Linking Private Forests To Water Quality Risks. Oregon Public Broadcasting. https:// https://www.opb.org/news/article/oregon-private-forests-to-water-quality-risks/

Smith, J, Heath, L, Skog, K. and Birdsey, R. 2006. Methods for calculating forest ecosystem and harvested carbon with standard estimates for forest types of the United States. Gen.                    Tech. Rep. NE-243. Newtown Sq., PA. USDA Forest Service, Northeastern Research Station. 216 p. https://www.fs.usda.gov/research/treesearch/22954

Treeplantation 2023 Use The Free Online Tree Carbon Calculator To Calculate How Much Carbon A Tree Captures. Tree Plantation. https://treeplantation.com/tree-carbon-calculator.html

Respectfully Submitted

Alan Journet

‘It’s time to do something’: Push is on to replace open-ditch irrigation canals with piping

Shaun Hall, Rogue Valley Times, August 14 2023

A big push is underway in Jackson County and Oregon to replace open-ditch irrigation canals with piping to reduce water loss through seepage and evaporation.

The mission by irrigation districts to modernize aging systems comes at a time of increased state and federal funding that is expected to help make the projects a reality.

The touted benefits of piping and related upgrades includes increased reliability of water through conservation, particularly in times of drought.

Not everybody loves the idea of doing away with canals, however. There’s been some opposition in the past in Bend and Ashland from people who prefer open ditches for their aesthetics and value to wildlife.

Damian Mann, Rogue Valley Times, March 7th 2023

Main Street in downtown Medford will welcome the city’s first-of-its-kind, two-way bike lane this fall.

A plan is in the works to convert a vehicle travel lane from Bear Creek to Oakdale Avenue into a separate mini-roadway just for cyclists.

“This may be the first one in the Rogue Valley,” said Ann Smith, a member of the Siskiyou Velo board of directors. “We’re hoping other cities in the area look at this.”

More

Every year, the League of Conservation Voters (LCV) publishes a scorecard evaluating the performance of Senate and House legislators. The 2022 scorecard is now available at here.

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
alan@socan.eco
541-500-2331
February 21st 2023

 

 

HB2816

Chair Marsh and members of the House Committee on Climate, Energy and Environment:

I write as cofacilitator of Southern Oregon Climate Action Now (SOCAN), an organization of over 2,000 rural Southern Oregonians who are concerned about the climate crisis and urge statewide action to address it. The mission of SOCAN is to promote awareness and understanding of the science of global warming and its climate chaos consequences and stimulate individual and collective action to address it. Since rural Oregonians occupy the frontlines in experiencing the impact of the drought, shrinking snowpack, wildfires and extreme weather that the climate crisis imposes, we are strongly committed to statewide action.

We are, therefore, delighted to have seen the progress that state agencies have made over the last two years in responding to Governor Brown’s Executive Order 20-04. We were just as delighted to see the legislature pass HB2021 two years ago requiring that retail electricity in Oregon shall be generated using 100% clean energy by 2040.

Since Oregon became a national leader in addressing the climate crisis in 2007 with HB3543 the state has drifted back in the pack. The reason we drifted back is because the program was voluntary, a reality that allowed recalcitrant businesses to evade their responsibility for stepping up.  It was not until EO 20-04 and HB2021 that Oregon regained a measure of leadership. But now, the same entities and mindset that caused our state to drift are returning to take advantage of loopholes in programs and policies whenever they can. One such problem is energy users that link in to generation facilities not covered by HB2021 such as public power utilities and Idaho Power.

Heavy duty energy users such as data centers and cryptocurrency mining operations are chief among the offenders. It’s time to close the loophole!

Those of us living in rural Southern Oregon are offended that businesses are attempting to by-pass the requirements of HB2021 and thereby increase our risk of suffering reduced snowpack, drought, wildfire, and heatwaves. We urge the legislature to correct this oversight and ensure everyone plays by the same rules.

The climate crisis is being driven by everyone who uses energy that is derived from fossil fuels. If we are to avert the looming crisis, we must ALL collaborate together to address it.

For these reasons Southern Oregon Climate Action Now urges passage of HB 2816

Respectfully Submitted

Alan Journet