SOCAN Comments on the ODF draft Climate Change and Carbon Plan

The following comments were submitted in response to the draft Oregon Department of Forestry Climate Change and Carbon Plan.

SOCAN Comments on ODF Climate Change and Carbon Plan
Alan Journet, June 28th, 2021


I write as cofacilitator of Southern Oregon Climate Action Now on behalf of over 1500 Southern Oregonians who are SOCAN and who are concerned about the climate crisis and are committed to promoting solutions to address the cause of increasing atmospheric greenhouse gas concentrations.  Our Mission is to promote awareness and understanding of the science of climate change and its consequences and motivate individual and collective action to solve the underlying cause.  In the context of these comments, as concern relates to reducing the emissions that result from logging operations, and promoting the sequestration (capture and storage) of carbon from the atmosphere.

I start by complimenting ODF for developing this Climate Change and Carbon Plan despite the turmoil that has befallen agency leadership during this period.  While I judge much of the language of the plan to offer a reasonable and rational roadmap, I also offer some comments of concern along with suggestions.

First, I offer congratulations and encouragement on the Purpose and Vision statements but with some reservations about the term ‘climate smart,’ an issue to be discussed later.   While I appreciate the inclusion in the Vision statement goals other than forest products, I remain concerned that overall, the document seems to retain the focus on Oregon’s forests as a source of timber rather than fully recognizing that other aspects of the multiple use function of our forests, are also important, notably:  wildlife, water quality and storage, recreation (including tourism), and spiritual refreshment.  Also, although ‘climate health’ is included, given the nature of this document, it would seem entirely reasonable for ODF to include specific mention of carbon sequestration in the list of forest attributes that ODF wishes to promote.

I appreciate the acknowledgement in bullet point 3 regarding the opportunities for sequestration, though, strangely, carbon is not identified as the target for this sequestration.  It is a little disturbing, however, to see the argument that harvested wood products are identified as providing meaningful sequestration of carbon since this claim has been challenged repeatedly by research pointing out the small percentage of carbon in standing trees that ends up in marketed timber products and the vast amount that is emitted during the logging, and processing of these products, along with the combustion of the slash piles (Smith et al 2006, Gower et al 2006, Ingerson 2007, Hudiberg et al. 2019, Law et al. 2018).

Under ‘Definitions,’ Greenhouse Gas I note, maybe somewhat pedantically, that the conventional plural of the noun ‘gas’ is ‘gases.’  The word ‘gasses’ is conventionally used as the present tense of the verb ‘to gas.’(

Comments on Climate Smart from Charisse Sydoriak are presented below, but I draw attention to the definition here as being vague and incomplete.  I suggest that Climate Smart management is not merely an extension of sustainable management.  It is, rather, a novel way of approaching management that recognizes that we have an unknown future climate and need to adjust management away from the principle of trying to restore forests that existed in some historic time where a climate existed that will not return. Rather, we need to embrace experimentation, monitoring, and adjust management to achieve goals. Indeed, in a changing climate the goals themselves should be constantly subjected to re-evaluation.

Throughout this set of definitions, especially that for ‘Carbon Finance,’ I note that ‘sequestration’ seems to be used as a synonym for ‘capture.’  In fact, although this usage is common, ‘sequestration’ actually means capture and storage ( so in this definition: “A market based mechanism to pay for sequestration and storage of carbon dioxide”  the addition ‘and storage’ is redundant. Admittedly, however, for those who misunderstand the term ‘sequester,’ this redundancy may be helpful and needed.

The last word ‘is’ on p 3 should be removed.

The Problem statement on p 5 starts with an accurate statement “Climate change is threatening Oregon’s forest and forest products industry…” However, the inclusion of ‘and forest products industry’ is unnecessary and again rather seriously reveals an underlying principle that the forest products industry is the main reason for our concern about forests when it is but one of many of the values of our forests.  I suggest that simply deleting ‘and forest products industry’ would not compromise the point and still be accurate.

While there is no doubt that wildfire risk is a critical example of the impact of climate change, it is probably also worth noting that there is evidence that some species are responding negatively to the changing climate itself (e.g. Douglas fir) either through the direct impact of changed conditions or an impact via the intermediary of pests, especially insects (e.g. Davis et al 2019,  Halofsky et al. 2019, Halofsky et al. 2020, Millar and Stephenson 2015).  Although the next paragraph includes some of these issues, I have frequently had conversations with individuals who ascribe the climate impact on our forests as being a fire-mediated impact without acknowledgment of the direct impact of climate on our forest species, each of which has a range of conditions to which it is physiologically adapted.

I particularly appreciate the following sentences on p 6: “A business-as-usual approach will not accomplish the needed adaptations, mitigations, and transformations needed. Increasing impacts on natural systems will force the human element to adapt in ways that are not fully understood at this time.” I note, however, the second ‘needed’ in the first sentence is duplicative.

p 8: What Is Climate-Smart Forestry?

This section leaves the reader with very little idea about what Climate Smart management is and how it is different from current conventional management.  Indeed, it seems to offer rather bland statements about ‘some people think this,’ and ‘some people think that,’ but doesn’t really identify the experimental essence of the approach. To assist a revision of this section to include the essence of the approach, the following discussion by Charisse Sydoriak should be helpful:

An Introduction to Climate Smart Natural Resources Conservation (by Charisse Sydoriak)

  • Ecosystems can no longer be preserved or restored to some sort of historic or “pristine condition” due to the rapidity of climate change and the far reach of human influence. Addressing the growing threats brought about or accentuated by rapid climate change requires a fundamental shift in the practice of natural resource management and conservation.
  • The future climate will be the primary factor determining vegetation conditions and species viabilities in this century. In the face of rapid climatic changes, species will be faced with one of three potential responses: adapt in place; shift in distribution to track with evolving suitable conditions; or go extinct.
  • For valued species and ecosystem services to persist, diverse natural resources management activities must be considered over extended timescales and geographic scope. Management activities need to be evaluated continuously to determine whether goals, objectives, and assumptions remain viable.
  • Being “climate-smart” means INTENTIONALLY making a transition from a paradigm of protection and restoration (resisting change), to one that anticipates and actively manages for uncertain yet plausible future conditions. The challenge is to manage for desired outcomes, with uncertainty clearly in mind.
  • Climate-Smart Conservation: Putting Adaptation Principles into Practice offers guidance for designing and carrying out natural resource conservation activities in the face of a rapidly changing climate.

Key characteristics of the “Climate Smart” approach are:

  • Linking actions to climate impacts. Natural resources management strategies and actions are designed specifically to address the impact of climate change in concert with existing threats. Actions are supported by an explicit scientific rationale and understanding of potential climate vulnerabilities.
  • Embrace forward-looking goals. Management goals focus on future, rather than past conditions. Strategies take a long view (decades to centuries) but account for near-term challenges and needed transition strategies.
  • Consider broader landscape context. On-the-ground actions are designed in the context of broader geographic scales to account for likely shifts in species distributions, to sustain ecological processes, and to promote collaboration across land management boundaries.
  • Adopt strategies robust to uncertainty. Strategies and actions ideally provide benefit across a range of possible future conditions to account for uncertainties in future climatic conditions, and in ecological and human responses to climate shifts.
  • Employ agile and informed management. Natural resources managers and the public embrace experimentation, continuous learning and dynamic adjustment to accommodate uncertainty–regularly taking advantage of new knowledge to cope with rapid shifts in climatic, ecological, and socioeconomic conditions.
  • Minimize carbon footprint. Adopt strategies that minimize energy use & greenhouse gas emissions and employ tactics that enable systems to naturally cycle and store carbon.
  • Account for climate influence on project success. Monitor the results of actions taken. Avoid investing effort likely to be undermined by climate-related changes unless part of an intentional strategy.
  • Safeguard people and nature. Adopt strategies and tactics that enhance ecosystems’ capacity to protect human communities and co-beneficial biota from climate change impacts.
  • Avoid maladaptation. Take care not to exacerbate human/climate-related vulnerabilities or undermine conservation goals and broader ecosystem sustainability.

The Climate-Smart Adaptation Process Cycle

There are many change adaptation planning frameworks to choose from. The process cycle shown in Figure 1 demonstrates the iterative nature of the National Wildlife Federation climate-smart approach (Stein et al. 2014). Note that there are opportunities throughout the process to interact with stakeholders. At a minimum, stakeholder engagement is essential in steps 1, 3, and 4.

The first step in the process is to clearly articulate values of concern in a collaborative manner and describe why they are important ecologically and socioeconomically. The purpose of the organization’s goals for a resource is often defined in law or policy, but sociopolitical concerns (e.g., equity) should be integrated in the process.

The next step is what makes the climate-smart process unique. The values identified in step 1 are evaluated for their vulnerability based on the best available science and global climate change modeling to determine if those values are likely to be affected positively or negatively by climate change. All living things exist within a range of conditions that may not be available in the future climate.

Vulnerability is assessed by looking at exposure potential over time, inherent sensitivity, and adaptive capacity.  At a minimum, the value-of-interest is examined relative to existing stressors such as pollution, habitat loss, or invasives and its physiological vulnerability to persist given increasing temperatures and changes in precipitation patterns in the next decade, mid-century, or longer.  This step requires expert knowledge, geospatial tools, and review of the scientific literature.

Step 3 requires delving deeply into the information developed in step 2 for a reality check. If the value is at high risk in the face of climate change, the original goals and objectives may be unrealistic. When this occurs, the goals and objectives should be intentionally revised.

In step 4, a suite of adaptation options is identified based on the vulnerability assessments, management feasibility, and costs. This step entails looking at plausible future conditions (scenario planning) to find places where valued resources could persist with or without management intervention; or electing to invest, despite feasibility or cost, to protect values-at-risk where they are now. It is wise to pick multiple options because of climate change uncertainty and flawed assumptions.  Take care not to invest in one strategy or limit tactics – instead “put your eggs in multiple baskets.”

An action plan is the product of step 5. To support the plan, stakeholders need to be educated starting with the original goals and objectives (step 1) and walked through the findings in steps 2-4 to show why, where, when, and how goals and objectives can or cannot be attained based on the best available science, plausible future condition forecasts, time constraints, and available resources. The plan also must identify assumptions made and provide the means for evaluating success based on climate sensitive metrics.

During implementation (steps 6 & 7) it is likely that adjustments will be needed. This means that metrics need to be regularly monitored and an administrative structure set up to be responsive to unforeseen situations. The plan implementers should take the long view and be humble, nimble, and responsive rather than defensive when things don’t go as planned.  When conditions warrant, the planning process should be reinitiated to validate and correct original assumptions and planned actions.

p. 10: Climate-Informed Silviculture

Goal: Establish a just and equitable transition to climate-informed silviculture and climate-smart forestry that optimizes climate mitigation and adaptation, while maintaining a sustainable flow of wood products to ensure long-term resource benefits and viability of the forest products industry and flow of long-lived forest products.

This language is considerably troubling in that it underlines the concern expressed earlier that while the CCCP offers encouraging thoughts regarding forest management reflection and adjustment, the essential view of ODF seems to remain that the raison d’être for our forests and ODF is purely to serve timber harvest rather than the full array of other forest values.

p. 11: Fire Management, Response and Fire / Smoke Adapted Communities

Goal: Modernize Oregon’s complete and coordinated wildfire protection system to respond to the increased severity of wildfire. Promote fire and smoke adapted communities in the wildland-urban interface, to mitigate the impacts of climate-induced increases in wildfire severity.

There is no doubt that the fire risk faced by Oregonians is a major problem for a multiplicity of reasons many of which are articulated in this section.  However, somewhat troubling is the absence of an acknowledgment that Oregon’s forests exist in a Mediterranean climate and are thus fire prone and fire adapted.  The result is that they are also fire dependent.   Indeed, as this reality implies, fire is not only inevitable, it is also essential to maintain forest health.
One specific reason for incorporating the Climate Smart management principles articulated above is that we need greater reflection and flexibility in management given the implications of climate change in combination with increased fire risk for forest composition and function.  Continuing the pretense that ‘fire is bad and must be suppressed’ as this document implies without explicitly so stating, is inconsistent with the ecological reality of our forests.

  1. 12: State Forests Management

Goal: Lead by example and demonstrate climate-informed forest management on State Forests to achieve Greatest Permanent Value.

It is certainly encouraging to see ODF acknowledging the carbon sequestration potential of our coastal forests and proposing to use state forests as models for management in the era of climate change. We know that carbon sequestration should be a high priority in forest management, particularly management that includes climate smart principles – hopefully as articulated above rather than as articulated by those who think current forestry practices are climate smart.  It is less encouraging, however, to see the focus remain on timber harvest as the mechanism for promoting sequestration rather than consideration given to maintaining a healthy growing forest, especially comprising mature and old growth trees.  It is also disturbing to see again the specter of harvested wood products offered as a reasonable means of sequestering carbon.  It has long been demonstrated that the proportion of carbon in the original tree that is retained in timber products is relatively minor.  Indeed, many years ago, studies revealed that only about 15% of the carbon in standing trees ends up in the processed timber (Smith et al. 2006, Gower et al. 2006, Ingerson 2007). Meanwhile a more recent study reported that some 81% of the carbon harvested from Oregon trees since 1900 has returned to the atmosphere or been deposited in landfills, from where it will ultimately return to the atmosphere (Hudiberg et al. 2019) leaving just 19% stored in the harvested timber product.  In addition, of course, logging both removes the stored carbon in harvested trees and precludes those trees from sequestering further carbon, thus compromising future reductions in atmospheric CO2.

p. 13: All-Lands Forest Restoration 

Goal: Accelerate the pace, scale, and quality of forest restoration to increase the resilience to increased wildfire severity and incidence. Support implementation of the recommendations of the Governor’s Council on Wildfire Response.

It is laudable that ODF is acknowledging the increasing risk of wildfire that climate change is presenting.  It is unfortunate, however, that in approaching the issue, ODF clings to the outdated notion that restoration of forests, presumably to some historic condition, is the appropriate strategy.  While the statement: “It is important that work to reduce wildland fire risk take into account the historical, current, and future predicted local fire behavior and frequency…..” is laudable especially the notion of paying attention to historical fire behavior, presumably including its benefits, embedding this concept in ‘Restoration’ cloth suggests that ODF has yet fully to appreciate exactly what climate smart forestry is and why it is necessary.  As Charisse Sydoriak stated above: “Ecosystems can no longer be preserved or restored to some sort of historic or “pristine condition” due to the rapidity of climate change and the far reach of human influence.” Efforts to impose management that seeks to retore forests to historic conditions rather than acknowledge that changing climate will preclude achievement of such a goal is doomed.

p 15: Urban and Community Forests 

GOAL: Increase the extent and resilience of urban and community forests to maximize the climate mitigation and health benefits of urban forests canopy.

It is encouraging to see ODF accord attention to urban forestry and the benefits trees can offer urban communities.

  1. 16. Reforestation and Afforestation

Goal: Facilitate and encourage the reforestation of areas burned by wildfire and afforestation of low-productivity lands that are understocked or not in forest use.

Given the valuable role trees can play in sequestering carbon from the atmosphere, it seems highly reasonable for ODF to consider promoting both reforestation and afforestation.  It is important, however, that reforestation not become an excuse for timber harvest since removal of growing trees compromises their sequestered carbon and the potential of those trees to sequester further carbon.  It is also critical that climate smart principles be applied to this process since many ecologically and commercially important tree species will be rendered less viable this century through much of their range by climate change (  A diversity of species should be included in such plans rather than a monoculture which produces stands of trees that bear the same relation to a forest as a corn field bears to a prairie.  It should be recognized, also, that – unlike mature forests – plantations are well understood to be severe wildfire hazards (e.g. Zald & Dunn 2018). It’s important also to appreciate that afforestation should be undertaken with the same cautions as above regarding diversity, and the application of climate smart principles.  In addition, afforestation should be carefully planned such that it doesn’t undermine productive agricultural land.

p. 17. Maintain and Conserve Forests

Goal: Support a strong, but flexible, Land Use Planning System as a cornerstone of maintaining Oregon’s forests on private lands.

While it’s encouraging to note that Oregon has lost relatively little forestland, it’s important to account for the fact that the presence of trees does not mean a forest exists.  Massive expanses of plantation monoculture, for example, do not comprise forestland.

While conservation of forest resources is valuable, again it’s important to appreciate that restoration of degraded forestland will likely be unsuccessful unless real climate smart principles are applied and it is understood that species occupying a region historically may no longer be adapted to that location in the future, hence the need for experimentation.

Indeed, one consequence of the shifting climatic conditions may be that conifer or mixed conifer forests may be replaced by climate suitable for oak woodland.

p. 17: Research and Monitoring

Goal: Maintain a research and monitoring program to track the status and trends of ecological, economic, and social indicators and the effects of climate change and to track progress related to this plan.

It is very encouraging to see this included in the plan since, as the climate smart chart above indicates, monitoring the results of the experimental application of management tactics is critical to determining what is successful and what needs adjustment.   In this context, to the list of bullet points should be added:

  • Which management tactics are apparently successful in terms of promoting management goals and which are not?
  • Given the outcomes of the various management tactics, should our management goals be revisited?

This statement is particularly applauded: “Understanding the impacts of climate change on the benefits we value and expect from Oregon’s forests requires a robust, long-term research and monitoring system that provides reliable information reported on a regular basis.”

p. 20: Accountability Measures:

Agency Leadership: Agency leadership will prioritize climate change in their planning to align with Executive Order 20-04.”  It is very encouraging to see this sentence included though I have to note that the remainder of the text of the plan suggests that the priority will remain providing logs for the timber industry.  It is critical that the Climate Change and Carbon Plan reflect the sentiments contained within this statement: i.e. that carbon sequestration will be prioritized.  It is critical that ODF and the Board of Forestry appreciate that this statement constitutes a substantial change from historical ODF priorities of timber harvest as this is reiterated and implied even in this Climate Change and Carbon Plan.

  1. 20: The Agency Decisions and Board Accountability statements offer excellent thoughts about promoting the reduction in greenhouse gas emissions, but do not include a statement about promoting greenhouse gas (essentially carbon) sequestration. I suggest that a new item (new 2) should be inserted as follows:

(2) Prioritize actions that promote carbon sequestration in our publicly owned and privately owned forests;

Other numbers should be adjusted accordingly.

Under Board Accountability, I presume “of this Executive Order” should be “of Executive Order 20-04.”

As above, I suggest adding

GHG Gas (Carbon) Sequestration Goals Agencies shall exercise any and all authority and discretion vested in them by law to help facilitate Oregon’s achievement carbon sequestration as set forth in paragraph 2 of Executive Order 20-04.

Then, add to the end of Expedited Agency Processes

“and carbon sequestration”

p. 22. Supporting Actions

It is evident from the text of this Climate Change and Carbon Plan that understanding exactly what comprises climate smart forest management is somewhat lacking.  This is evident from the overall tenor of the plan, which seems to suggest that ODF is already practicing climate smart forestry. Instead, ODF staff need to appreciate that climate smart forest management will require a substantial rethinking of how forestry is undertaken in Oregon.

In addition to proposing programs to help ODF staff understand what climate smart management is, it would seem reasonable to organize workshops for public and private forest owners/managers to help them understand the basic principles of climate smart management and how these differ from ‘business as usual.’  This would reasonably include discussion of how the Forest Practices Act might be adjusted to reflect the imperatives of climate change and the principles of climate smart management.

In order to incentivize climate smart forestry, as suggested on p. 23, it will be necessary for ODF and forest managers to understand what this means.

p. 23: Forest Management Plan and State Forests Carbon Storage:

The bullet points on p 24 seem a reasonable starter set, but # 4 could be improved by adding the notion of climate appropriate species to ‘site appropriate species,’ since the latter concept is likely grounded in history rather than in recognition of the uncertain climatic future.

  1. 26 Afforestation of Low Productivity Lands:

The discussion of promoting afforestation through drought tolerant species and diversity seems entirely reasonable and consistent with climate smart management but please recognize the experimental nature of the process and the need for monitoring and re-evaluating.

p 27 Forest Carbon Offsets:

It will be entirely appropriate for ODF to develop a forest offset program.  Presumably this would operate within the umbrella of the Community Climate Investment program being developed by DEQ within its Climate Protection Program.  However, ODF should be aware that as those rules were developed and shared during the Rulemaking Advisory Committee meeting 6, DEQ’s draft rules for these investments did not include projects that promote carbon sequestration, only greenhouse gas emissions reductions.  Discussion during that meeting resulted in a seeming agreement to reinstate this component.  However, it would behoove ODF to contact Colin McConnaha at DEQ to confirm that the carbon sequestration offset option has been included.  It will be critical to ensure that the rules for such are carefully worded to guarantee that carbon sequestration projects are not a sham, investments are protected from wildfire, and projects do not result in social injustice.
The language that I have suggested to DEQ regarding this concern follows:
It is critical that such projects and those applying to invest in them, meet certain requirements:

  • To be eligible for these investments, polluting entities should not be permitted to apply for Community Climate Investment credits:
    1. unless they have already installed the best available technology (BAER) for reducing emissions or have solid plans for undertaking such installation,
    2. that allow them to continue releasing co-pollutants that undermine the air quality and health of neighboring communities whether or not such emissions compromise the air quality attainment status of such communities.

Meanwhile, acceptable sequestration projects must:

a)  be third-party certified as achieving carbon sequestration that is real, measurable, additional, long-lived, monitored and verifiable. The concept of ‘permanent’ is difficult in the case of carbon sequestration on our natural and working lands since the carbon in forests and farms is in constant though slow flux through the system. Rather than demanding that the carbon should be permanently locked, as in a vault, we should expect that the overall carbon content of a system increases as individual carbon atoms flow through them much more slowly than previously.

b) not allow leakage of the sequestered carbon in other projects. For example, forest carbon sequestration projects cannot be compensated by activities elsewhere under the ownership of the project manager that result in an increase in emissions similar to or greater than the carbon sequestered.

c) not generate conditions that compromise equity and social justice.

p 28 Mid-term Timber Harvest Deferral:

The suggestion of extending the harvest rotation seems entirely consistent with the goal of promoting carbon sequestration and is to be lauded.  However, it is important to acknowledge the experimental nature of climate smart management and the need to monitor and evaluate outcomes to ensure that goals are being met.

p. 28 Monitoring:

Past, Present, and Future Forest Carbon Research:

Emphasis on the need for monitoring is excellent though I remain troubled by the recurring argument that the small percentage of carbon from standing trees that is retained in the timber products comprises a substantial contribution to the carbon balance and carbon sequestration goal.

p. 30 Incorporation of Climate Change and Climate Change Impact in Agency Planning Processes:

It is encouraging to see the plan urges the consideration of climate change and its impacts in Agency Planning.  I offer this comment because my experience at reading agency reports (other than ODF) reveals an almost complete absence in Environmental Assessments of reflection on this critical issue.

p.30 Encourage Low Carbon Impact Materials in Oregon:

There is no doubt that we should encourage low carbon impact materials at every opportunity.  However, ODF needs to acknowledge the vast emissions that result from current logging industry activities.  It is critical that ODF addresses this problem as we move into the future in a climate smart world.

p. 32 Future Work Needs

As noted above, a critical need in both the short term and long term is to educate ODF personnel about the essence of climate smart forestry and how it differs from business as usual.

P. 36. Considering the repeated reference to ‘climate smart forestry,’ I was particularly surprised not to see mention of the almost seminal discussion of this by Stein et al. 2014 which deserves mention both in the text and references:

References Cited:

Albrich K, Rammer, W 2020 Climate change causes critical transitions and irreversible alterations of mountain forests, Global Change Biology 26: 4013–4027.

Davis K, Dobrowski S, Higuera P, Holden Z, Veblen T, Rother M,  Parks S, Sala A,  Maneta M 2019 Wildfires and climate change push low-elevation forests across a critical climate threshold for tree regeneration. Proceedings of the National Academy of Science 116 (13) 6193-6198.

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. Not available online.

Halofsky J, PedersonD, Ho J [Editors] 2019. Climate Change Vulnerability and Adaptation in South-Central Oregon. Gen. Tech. Rep. PNW-GTR-974. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 473 p.

Halofsky J, Pederson D, Gravenmeier E. 2020 Climate Change Vulnerability and Adaptation in Southwest Oregon. Gen. Tech. Rep. PNW-GTR-xxx. Portland, OR: U.S. 60 Department of Agriculture, Forest Service, Pacific Northwest Research Station.

Hudiberg T, Law B, Moomaw W, Harmon M, Stenzel J 2019 Meeting GHG reduction targets requires accounting for all forest sector emissions. Environmental Research Lettters, 14 095005.

Ingerson A, 2007 U.S. Forest Carbon and Climate Change Controversies and Win-Win Policy Approaches, The Wilderness Society –

Law B, Hudiburg I, Berner L, Kent J, Buotte P, Harmon M 2018 Land use strategies to mitigate climate change in carbon dense temperate forests. Terrestrial Ecosystems Research & Regional Analysis – Pacific Northwest. Oregon State University, Corvallis, OR

Millar C, Stephenson 2015 Temperate forest health in an era of emerging megadisturbance. Science Magazine 349 (6250) 823 – 826.

Smith, J.E., Heath, L.S., Skog, K.E. and Birdsey, R.A. 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.

Stein B, Glick P, Edelson N, Staudt, A 2014 Climate-smart conservation: putting adaption principles into practice National Wildlife Federation.

Zald H, Dunn C. 2018 Severe fire weather and intensive forest management increase fire severity in a multi-ownership landscape. Ecological Applications. 28 (4): 1068 – 1080.

Respectfully submitted

Alan Journet Ph.D.

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