SOCAN Comments on the ODF Post-Disturbance Logging Rules

Comments submitted by Alan Journet on behalf of SOCAN and SOCAN Activist Allen Hallmark as an individual.


Alan R.P. Journet Ph.D.
Southern Oregon Climate Action Now
April  27th 2024


Reference Post-disturbance Logging Rules

To Whom It May Concern:

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 and coastal Southern 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 and agency action.

I write today in connection with the proposed Post-disturbance Logging Rules. We understand that the Private Forest Accord (PFA) was developed as a compromise between the conservation organizations focused on promoting healthy forests that can serve Oregonians in a muti-faceted manner, and an industry which, time and again, argues that the only value in our forests is measured in terms of the profits to be made from harvesting the timber. Those of us concerned about the climate crisis stand with the philosophy that promotes conserving healthy forests because only with healthy forests can we hope to promote the kind of natural solutions to the climate crisis through carbon sequestration that the Intergovernmental Panel on Climate Change argues we need (e.g., IPCC 2018, 2023).

Adaptation to climate change requires that our stream and river aquatic ecosystems be protected from overheating and siltation, a requirement that demands sound buffers in riparian zones. Meanwhile, mitigation requires that we not promote the emissions that are associated with excessive logging and the barriers to ecosystem recovery that this logging imposes.

The compromise that is the PFA should not be circumvented under the stealth guise that post-disturbance logging is different from regular logging.  We know that our streams and rivers need to be protected from encroachment by logging and by the imposition of logging on steep slopes. We also know that the recovery of disturbed forests requires a light and sensitive hand, not the bludgeoning of logging equipment that compacts soils and promotes soil erosion.

For these reasons, we urge that the Post-disturbance Logging Rules parallel exactly the logging rules developed in association with the Private Forest Accord and be no less stringent.

Respectfully Submitted

Alan Journet

IPCC 2018 Global Warming of 1.5⁰C Intergovernmental Panel on Climate Change.

IPCC 2023 CLIMATE CHANGE 2023 Synthesis Report Summary for Policymakers. Intergovernmental Panel on Climate Change.


Dear ODF staff involved with the PDL rule-making,

I am quite concerned that the compromises made to write the new PFA rules for PDL have rendered them ineffective in protecting the forest, stream, and fishery values the rules are supposed to protect.

Please add my comments to the list of those who are urging that post-fire or other severe disturbance logging should adhere to the same setbacks from streams and other bodies of water as required for normal logging operations.  It makes no sense to waive those rules for post-disturbance logging.

It is imperative to protect our mountain streams from logging operations in riparian areas to protect salmon runs and all the other critters who live in the streams or adjacent riparian areas.  As someone who works to stem climate change, I know that keeping as much wood on the logging sites to provide shade helps regenerate the early regrowth of alders and other small trees, which is essential to protect streams, and leaving this slash provides much more carbon storage (including saving soil carbon).

So, I am asking that you revisit these rules and amend them to provide much more protection for soil and streams by increasing the size of protected riparian zones.

Thank you for considering my comments,

Allen Hallmark

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