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.
Southern Oregon Climate Action Now
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

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