The Oregon Department of Forestry (ODF) held a formal public comment period for the 2003 Annual Operations Plans (AOPs) from February 19 through April 1, 2002. The Annual Operations Plans are a district-level planning process which must be developed in accordance with the Forest Management Plans (there are four plans to cover the nine districts) and the district Implementation Plans (except for Klamath-Lake and Coos districts). The Annual Operations Plans cover specific projects such as timber sales, road maintenance, stream enhancement, and trail building which will occur during a fiscal year. The final plan for each district is approved by the district forester.

The purpose of the public comment period was to provide a time for the districts to share their plans with the public, and in addition, for the public to ask questions about and offer comments on the plans. At the end of the public comment period, the districts and ODF’s headquarters in Salem had received approximately 110 individual documents (letters, faxes and e-mails) and about 200 copies of a form letter. Once they were carefully reviewed, it was found that these documents contained nearly 500 individual statements, which consisted of comments, questions, opinions and recommendations.

Since the AOPs were a district-level planning process, each district was responsible for using a common process to evaluate the statements related to them. Approximately 20 percent of the statements were addressed to all state lands; therefore they were evaluated by Area and Salem staff. The common evaluation process consisted of the following six steps:

1. Review each document to identify the individual statements.
2. Summarize each statement in a matrix (see the ‘Field Definitions’).
3. Evaluate each statement. (What activity is it related to? What is its scope? How does it related to the AOP?)
4. Resolve the statement in the matrix. The resolution listed in the matrix is a very brief synopsis of how the district intends to change the AOP based on the statement or why the statement does not warrant a change to the AOP.
5. After the initial evaluation and response to the public comments, representatives from all state forest districts met to compare their evaluations and resolutions. The purpose of the comparison was to ensure consistency in the evaluation and resolutions to statements between districts and to seek out statements that should be applied to all district AOPs.
6. Revise district evaluations and resolutions to statements, then revise the district AOP based on the district resolutions.

The Public Comment Resolution Matrix contains all statements (and the associated evaluations and responses) that the department received during the public comment period regarding the 2003 Annual Operations Plans. The statements within the form letter were only listed once, rather than being repeated 200 times.

After the evaluation, those statements that received a "Yes" (Y) to any one of the five (5) filter questions were given further consideration (as a 'Potential Action Item'), because they contained specific recommendations appropriate to the Annual Operations Plans.

One example of a ‘Potential Action Item' was: "ODF should develop a noxious weed program, including periodic surveys and prevention measures." Although most districts have an informal noxious weed program, they did not discuss it in their AOPs. Thus incorporating this recommendation into the revised AOPs will improve their clarity. Not all ‘Potential Action Items' were incorporated into the AOPs, for a variety of technical or policy related reasons. One example was the recommendation to vacate a road sooner than was proposed in the plan. The district did not incorporate this recommendation, because that particular road was needed to conduct the harvest and there was no significant risk to resources caused by waiting to vacate the road until after the operation was completed.

Those statements that did not receive a "Yes" (Y) to any of the filter questions were not given further consideration during the AOP process, because they did not contain a recommendation appropriate to the AOP. There were a variety of reasons that statements were not given further consideration. For example, there were a number of statements that were generally in favor or opposed to the AOPs, however these statements contained no specific recommendations for change.

Many statements were not given further consideration because they either addressed a higher level plan or would require a change in a higher level plan. The Annual Operations Plan is the fourth and lowest level of formal planning on state forests; it must be conducted in accordance with the parameters set forth in the district Implementation Plan, the Forest Management Plan and the ‘Greatest Permanent Value’ rule (listed from low to high level of planning). For example, there were a number of comments that called for an end to all timber harvest on State Forests. This recommendation would require a change in all higher level plans to implement. It is clearly beyond the scope of the AOPs and outside the authority of the districts to implement.

The districts may give some of these statements further consideration when revising district Implementation Plans, Recreation Plans or Transportation Plans.

If there is a question regarding a specific statement, please contact the district to which the statement was addressed. If the statement was addressed to ‘ALL’ State Forests or there is a question regarding the overall process, please contact:

Robert Nall

NWOA State Forest Planning Coordinator

Oregon Department of Forestry

801 Gales Creek Road

Forest Grove, Oregon 97116-1199

(503) 359-7431

rnall@odf.state.or.us

The headings below describe each field in the ‘Public Comments Resolution Matrix’.

Name of the district to which the comment was directed. The term "ALL" was applied to those comments (or documents) that did not identify a specific district. (AST = Astoria, FG = Forest Grove, TL = Tillamook, CM = Clackamas-Marion, WO = West Oregon, WL = West Lane, CS = Coos Bay, SWO = Southwest Oregon, K-F = Klamath Falls)

Specific comments, opinions and recommendations derived from the documents received by each district. Most documents contained more than one comment.

Each comment was placed in a theme category, which was used to sort the comments into related topics. The list below is a modified version of the of the Pre-Operations Report.

1. Physical Description of Operation Area

2. Current Stand Summary

3. Desired Future Condition

4. Proposed Management Prescription (harvesting only)

5. Estimated Resource Outputs

6. Roads and Related Projects

7. T&E Species Considerations (including Plants)

8. T&E Fish Considerations

9. Other Wildlife Considerations

10. Slope Stability and Geotechnical Issues

11. Recreation Resources

12. Cultural Resources

13. Scenic Resources

14. Access and Property Line Surveys

15. Other Resource Considerations

16. Site Preparation (Burning, Piling, Scarification)

17. Planting

18. Vegetation Management

19. Animal Damage

20. Fertilization

21. Pre-commercial Thinning

22. Other Issue

The comments could be applied over a narrow or broad geographic or subject area. For the purpose of this evaluation, the comments were classified into four levels or scopes, using the following codes:

O Operation: the comment refers to a specific operation.

A Activity: the comment refers to all operations of a specific type on a district (e.g., "all road construction should be on stable ground").

D District: the comment refers to all activities on a district or the direction of district management (e.g., "the entire district should be managed as a park").

M Multiple Districts: the comment refers to more than one district or the entire program (e.g., "ODF should not cut any trees").

Five fields in the matrix represent the evaluation criteria that was used to identify those comments which contained a specific action items appropriate to the Annual Operations Plan process. Those fields were completed with a ‘Y’ (Yes, the comment does answer the question) or ‘N’ (No, the comment does not answer the question).

1. FMP Alignment – Does the comment enhance the consistency of an AOP with the FMP?
2. IP Alignment – Does the comment enhance the consistency of an AOP with the district IP?
3. Improve AOP Clarity – Does the comment improve the clarity of an AOP?
4. New Information – Does the comment provide new information that will affect an AOP?
5. Improved Efficiency/Effectiveness – Does the comment improve the efficiency and effectiveness of an AOP or planned operation?

This field contains a brief synopsis of how the district expects to change the Annual Operations Plan in response to the comment, or the reason the comment has not been incorporated into the plan. Greater detail on the district responses can be found in the ‘Public Comment’ Appendix to the Annual Operations Plans.