| District Name | Comment Summary | Theme Category | Scope | FMP Alignment (Y/N) | IP Alignment (Y/N) | Improve AOP Clarity (Y/N) | New Information (Y/N) | Improved Efficiency / Effectiveness (Y/N) | District Resolution | ||
| Physical Description of Operation Area | |||||||||||
| FG | Coffee Bean: GIS shape file of sale boundary indicates portions of the sale are types 65 and 66 which are layered. Please clarify. | 1 | O | N | N | Y | N | N | These types are not included in this timber sale. GIS shape file boundary do not match up with OSCUR types. | ||
| K-L | You should provide acreage for Huckleberry Hound and Triple Arc in the Integrated Forest Management narrative. | 1 | O | N | N | Y | N | N | District will make this change. | ||
| Current Stand Summary | |||||||||||
| ALL | I have read the reports concerning the errors ODF has made in their evaluation or status of certain forests, i.e., that certain stands were saleable and not environmentally sensitive when in fact the trees were the oldest of the naturally regenerated forest and were also environmentally sensitive (i.e., important habitat for wildlife). Apparently, ODF itself has admitted to faulty misclassifications on many forest areas. It is unfortunate that we cannot trust our forest stewards to make sure the right thing is done concerning timber sales. | 2 | M | N | N | N | N | N | Comment does not contain a recommended action. | ||
| ALL | I am also suspicious of ODF’s land classification system as it has recently come to light that it is faulty; older forests being classified as young plantations, for example. | 2 | M | N | N | N | N | N | Errors are corrected as they are identified. As a further precaution, stand Level Inventory is being conducted on some stands in order to better assess their current classification. | ||
| AST | Particular concern on my part is the difference between the stand structures indicated in the Pre-Sale Reports and the stand structures indicated on the shapefiles of current condition issued with the Draft IPs. The Draft IP current condition maps indicate that many stands are more complex than indicated in the Pre-Sale Reports. The problem is most pronounced in the Astoria District. | 2 | D | Y | Y | Y | N | N | A comparison of the IP inventory information and the 2003 AOP inventory information showed the the inventory information for both processes matched. The stand classifications determined by the computer for the 2003 AOP were found to be correct; whereas, it was discovered that the March IP classifications were incorrect due to a formula error. To correct the matter, it is recommended that the next draft of the IP, the district use the Stand00.shp inventory file that match the 2003 AOP stand classification file. | ||
| AST | Punchbowl -- Differences between the stand structures indicated in the Pre-Sale Reports and the stand structures indicated on the shapefiles of current condition issued with the Draft IPs. (Oscur Type 450 - presale csc, Draft IP uds) Also, is stand 448 included in this sale? | 2 | O | Y | Y | Y | N | N | See 10a.For Type #450 the 2003 AOP stand classification is correct; whereas, the March 2001 IP is not correct. No modifications or changes are needed. For Type #448- the draft pre-operations report will be modified to ensure that the majority of this type is not within the proposed sale boundary. | ||
| AST | Back Break Ridge -- Differences between the stand structures indicated in the Pre-Sale Reports and the stand structures indicated on the shapefiles of current condition issued with the Draft IPs. (Oscur Type 192 - presale csc, Draft IP uds; Oscur Type 492 - presale csc, Draft IP uds) | 2 | O | Y | Y | Y | N | N | See 10a. For Type #192-- the pre-op plan is incorrect and will be modified. For Type #492-- the second draft of the of the pre-op plan was updated using new SLI inventory information. | ||
| AST | Thick and Thin -- Differences between the stand structures indicated in the Pre-Sale Reports and the stand structures indicated on the shapefiles of current condition issued with the Draft IPs. (Oscur Type 146 - presale csc, Draft IP lyr) | 2 | O | Y | Y | Y | N | N | The 2003 AOP stand classification is incorrect and will be modified in the final draft pre-operations report. | ||
| AST | West Creek Comb -- Differences between the stand structures indicated in the Pre-Sale Reports and the stand structures indicated on the shapefiles of current condition issued with the Draft IPs. (Oscur type 152 - presale lyr, Draft IP ofs; Oscur type 154 - presale uds, Draft IP lyr; Oscur type 136 - presale lyr, Draft IP ofs; Oscur type 89 - presale csc, Draft IP uds; Oscur type 122 - presale csc, Draft IP lyr; Oscur type 126 - presale csc, Draft IP uds) | 2 | O | Y | Y | Y | N | N | See 10a. For Types #151, 152, 154 (510), 130, 133, 134 and 136-- the second draft of the pre-op plan was updated using new SLI inventory information. For Type #89-- the 2003 AOP stand classification is correct; whereas, the March 2001 IP is not correct. For Type #122-- the 2003 AOP classification was confirmed and corrected to LYR. | ||
| AST | John Day Point Thinning -- Differences between the stand structures indicated in the Pre-Sale Reports and the stand structures indicated on the shapefiles of current condition issued with the Draft IPs. (Oscur type 81 - presale uds, Draft IP lyr; Oscur type 82 - presale uds, Draft IP lyr; Oscur type 76 - presale csc, Draft IP uds) Is stand 73 in this sale? Stand01 data shows area 3 as 81 years old. | 2 | O | Y | Y | Y | N | N | These are previously managed (thinned stands), therefore the stand classification is different. Therefore, the Unit Forester examined the stands and determined that they were actually UDS and not LYR. This will be noted in the updated PreOps Report. | ||
| Coos | 2a: "…the OP & thinning sale descriptions lack any apparent procedures for surveying the thinning units for residual old growth trees or pockets of naturally regenerated mature forest…&other ecologically important…" | 2 | A | N | NA | Y | N | N | A description of how Coos District determines if these resources exist in a proposed sale area will be added to the "Integrated Forest Management" section of the AOP Summary. | ||
| FG | Raven Ridge: OSCUR type 230 appears to be in sale from GIS shape file but not included in OSCUR summary in presale report. | 2 | O | N | N | N | Y | Y | District is looking into this and will make appropriate corrections and adjustment to the sale. | ||
| FG | Raven Ridge: DFC complex (OFS) in sale boundary. Not noted in pre-sale report. | 2 | O | Y | N | N | Y | Y | District is looking into this and will make appropriate corrections and adjustment to the sale. | ||
| K-L | Need to give ages for each stand. | 2 | D | N | N | Y | N | N | These are uneven-age stands, so do not have a "stand Age". Age ranges are currently discussed in the Proposed Management Prescription section. This discussion will also be included in the Current Stand Condition section. | ||
| TL | Describe plans for reviewing stand classifications. | 2 | A | N | N | Y | N | N | Add information about Stand Level Inventory. | ||
| TL | Foss Alder - We recommend that you eliminate the sale. Biologist Clint Smith in his comments on the Tillamook District's 2003 Sale Plan says about Foss Alder. "Based on an on-ground review, I would not categorize the stand type as CSC, as stated in your report. The sale area encompasses a diverse array of patch types that would be best described as 'Understory' with many components of 'Layered'. He also says, "I believe that much of the sale area would develop LYR/OFS structure without further management". We believe Foss Alder is an excellent candidate for a "control" stand. | 2 | O | N | Y | N | N | N | Discuss Clint's comments in pre sale plan. This sale is aligned with the FMP and IP and will continue as planned. | ||
| Desired Future Condition | |||||||||||
| ALL | We have lost all our “open” habitat areas we historically had in the last 45 years. We desperately need small 2-5-10 acre clearcuts in the forest for wildlife enhancement, especially the blacktail deer and various owl species. The little clearings hold lots of mice and just hold potential for all kinds of habitat. These clearings should be cleared, burned, and small seasonal ponds built to promote forest health. I do plant – red clover plus a pasture mix on the ground after burning. | 3 | A,M | N | N | N | N | N | Openings are being created through clearcut and partial cut harvest. Some areas are managed for wildlife forage in cooperation with ODFW. | ||
| ALL | It appears to me that some areas are being clearcut that are not even age plantations. The presentations I have heard from ODF make the overall plan logging on state lands sound like a reasonable multiple use approach. However care has not been taken in identifying and preserving the areas which are best suited to creating an old growth type setting needed by many creatures. | 3 | A,M | N | N | N | N | N | The strategies contained in the Forest Management Plan apply to all forest stands, not just plantations. | ||
| AST | The inappropriate and undefined category "Intensive Management" is not mentioned in the FMP or IP's yet is repeatedly used in the Astoria District OP in conjunction with timber sales. Unless ODF plans to set aside "Non-Management Reserves", the Club suggests dropping this inappropriate language. | 3 | A | Y | Y | Y | N | N | Will define "intensive management" pathway in OPS Plan as "general". See multi-district Item #1. | ||
| AST | It would be helpful to have pre-harvest, post harvest and desired future conditions summarized for the 2003 plan proposed sales. | 3 | D | Y | Y | Y | N | N | Will summarize for the 2004 AOP. | ||
| Coos | 2b: "The OP and thinning sale descriptions also appear to rely on "loggers' choice" methods of tree selection . Retention of larger trees should be made a priority and an explicit tree selection parameter, to best achieve goals for development of stand structure." | 3 | A | N | NA | Y | N | Y | The timber sale contracts have very specific language and specifications that require the logger to produce the target stand. The target stand specifications include minimum DBH and basal area range in the stand after thinning. Detailed information on these requirements will be added to the AOP in the section titled: Commercial Forest Management | ||
| TL | In order to improve clarity and effectiveness of the Plan a more detailed summary of the pre-harvest, post harvest, and desired future conditions of the proposed sale areas would be helpful. The Forest Grove draft AOP provides a good example of how this information can be presented. | 3 | A | N | N | Y | N | N | The FG plan will be reviewed to determine if elements should be incorporated. | ||
| TL | Regarding the DFC: We are particularly disturbed by the number of SNC infected stands designated for LYR and OFS. Please provide an analysis of this issue. Many existing complex stands are not included in the DFC LYR and OFS category. | 3 | D | N | N | N | N | N | Current DFC distributes LYR and OFS stands across the landscape as specified in the FMP. No analysis is planned. | ||
| TL | Foss Alder - Because Foss Alder is a naturally regenerated stand, I recommend that the future desired condition for the entire sale area be designated OFS and that it not be offered for sale. | 3 | O | N | N | N | N | N | Sale follows mgt strategies in FMP and IP including landscape design. Sale will continue as planned | ||
| WL | The areas to be clearcut have UDS as their future structure goal, but some of the stands are already UDS structure | 3 | A | Y | N | Y | N | N | District currently exceeds UDS goals listed in IP. | ||
| Proposed Management Prescription | |||||||||||
| ALL | I don’t think any Oregon forests should be clearcut. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool. | ||
| ALL | It is true that in the short-term clearcutting is the cheapest way to harvest trees, and that cutting selectively (leaving some 60 well-distributed trees per acre and saving all large trees) is more expensive. | 4 | A,M | N | N | N | N | N | The decision to clearcut or partial cut a stand is based on stand characteristics and the district landscape design. Some stands may not be candidates for partial cuts because of logging engineer reasons or very high operational costs, but it is not the primary reason stands are clearcut. | ||
| ALL | History has shown that clear-cutting without serious, intense planning is BAD. Let's not repeat those mistakes. | 4 | A,M | N | N | N | N | N | The Forest Management Plan, District Implementation Plans and the Annual Operations Plans are examples of the serious and intense planing that is occurring on state forests. | ||
| ALL | [Clearcutting] makes me shudder at the threat of yet more removal of the vegetation – well known to be so truly essential to Earth’s oxygen supply. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. It is necessary to meet the DFC goals in the Implementation Plan and 75% of these clearcuts will be conducted in response to forest health issues. | ||
| ALL | No clearcut of diseased plantations should be greater than 20 acres and an emphasis on alternative treatments or thinning is preferred. The assessment of "diseased stands" should be based on generally accepted peer-reviewed scientific studies and not simply be a euphemism for the "get-out-the-cut" policy or business as usual. In other words, ODF should not use "diseased stands" as a euphemism for the harvest of timber. | 4 | A,M | N | N | N | N | N | Harvesting of stands infected with Swiss needle cast is conducted using the "Strategic Plan for Managing State Forests in Northwest Oregon Affected by Swiss Needle Cast". | ||
| ALL | No clear-cuts in naturally regenerated stands of trees older than 60 years until ODF has fully accounted for water quality and endangered species requirements under the federal Clean Water Act and Endangered Species Acts. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and it does not identify age as a factor in determining stands to be harvested. Clearcutting is necessary to meet the DFC goals in the Implementation Plan and less than 1% of stand to be clearcut under this AOP are over 60 years old. | ||
| ALL | Many places in the Coast Range of Oregon are not what some people would call old-growth, but it's the closest there is in an area that's been over harvested for years and years. Timber sales such as Cougar Monster (where the majority of large trees would be cut) do absolutely nothing to enhance diverse habitat for native species of plants and animals. | 4 | A,M | N | N | N | N | N | Long range goals for stand structures are described in the Forest Management Plan and the Implementation Plans. The AOPs are designed to meet those goals. | ||
| ALL | Sierra Club is hoping there will be no clearcutting in the Tillamook Rainforest for 2003! It is not necessary to clear this land and eliminate the habitat of deer and birds. The rain could cause floods and terrible mudslides. Leave the land alone! It is great as it stands. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. 75% of these clearcut will be conducted in response to forest health issues. | ||
| ALL | Please stop clearcutting. ODF has clearcut too much in the past, that's why there isn't enough to go around now. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. It is necessary to meet the DFC goals in the Implementation Plan and 75% of these clearcuts will be conducted in response to forest health issues. | ||
| ALL | Clearcutting land slides throws away the soil. You can't grow trees in mid air. The Tillamook doesn't have enough soil to spare to clearcut. Delicate places must be treated lightly if you want them to produce for you in the future. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and provides strategies for managing risk from land slides. | ||
| ALL | No clearcuts should be made greater than 40 acres | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool. | ||
| ALL | Swiss Needle cast is a result of the MISMANAGEMENT of the timber industry of their lands by converting them to single species, single age CROPS! Now, deal with it in a much sounder, environmentally conscientious way than just resorting to the good old CLEARCUT! | 4 | A,M | N | N | N | N | N | Stands infected with Swiss needle cast are harvested in accordance with the "Strategic Plan for Managing State Forests in Northwest Oregon Affected by Swiss Needle Cast". | ||
| ALL | I do not oppose clearcuts in ANY context. However, I think I made my point very clear that in light of the FACT that there has been and continues to be far too many acres ALREADY clearcut and what is out on the landscape currently does in NO way mimic Mother Nature, as the Timber Industry would have the public believe. For this reason I oppose ANY CLEARCUTTING of forests that are in excess of 100 years old and reside on PUBLICLY OWNED LANDS! | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool. Only 0.9% of state forests in the NWOA will be clearcut with this AOP and less than 0.1% of the stands over 80 years old will be clearcut. Clearcutting is necessary to meet the DFC goals in the Implementation Plan and 75% of these clearcuts will be conducted in response to forest health issues. | ||
| ALL | I am writing to support a discontinuation of clear-cutting old growth in the State Forests, particularly the Cougar Monster and the Gnat Creek sales (which should be canceled). A high priority should be placed on preservation of older forests, and the ODF should stop “high-grading” trees in the Tillamook Forest. | 4 | A,M | N | N | N | N | N | The Forest Management Plan recognizes clearcutting as an important management tool. In addition, "Old Growth" is reserved from harvest by the Forest Management Plan. | ||
| ALL | I am unhappy that ODF is planning to clearcut over 4800 acres of Tillamook Forest in 2003, requiring miles of roadbuilding and further fragmenting spotted owl and bald eagle habitat, and mot probably exacerbating global warming. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. 75% of these clearcut will be conducted in response to forest health issues. | ||
| ALL | No clearcutting of naturally regenerated stands of trees older than 70 years until ODF has ... . | 4 | A,M | N | N | N | N | N | The Forest Management Plan contains forest management strategies based on stand structure, not stand age or origin. | ||
| ALL | In general, I do not believe that clearcutting is the proper way to manage the forest. I would urge the ODF to stop clearcutting as a management tool. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. It is necessary to meet the DFC goals in the Implementation Plan and 75% of these clearcuts will be conducted in response to forest health issues. | ||
| ALL | No clearcutting of diseased plantations – period. | 4 | A,M | N | N | N | N | N | The Forest Management Plan provides for the management of forest pests within acceptable ranges, but when the pests exceed the acceptable range, suppression should occur. Stands infected with Swiss needle cast are harvested in accordance with the "Strategic Plan for Managing State Forests in Northwest Oregon Affected by Swiss Needle Cast". | ||
| ALL | I do not mind clear cutting in the Tillamook Forest. | 4 | A,M | N | N | N | N | N | No changes or actions suggested. | ||
| ALL | Fragmentation of wildlife habitat [by clearcutting] is unnecessarily harmful. | 4 | A,M | N | N | N | N | N | The landscape design identified in the implementation plans address the problems of fragmentation of habitat. | ||
| ALL | First, clearcutting is never justified, except to maximize timber production. I do not think that the maximization of timber production should be a goal for our state lands; therefore clearcutting should not be permitted on state lands. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. It is necessary to meet the DFC goals in the Implementation Plan and 75% of these clearcuts will be conducted in response to forest health issues. | ||
| ALL | We should not allow any more clear-cutting on our state forests. Clear-cutting damages the land, the soil, and destroys the ecosystem. It hurts fish, wildlife, creates landslides and negatively impacts water quality. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. It is necessary to meet the DFC goals in the Implementation Plan and 75% of these clearcuts will be conducted in response to forest health issues. | ||
| ALL | Areas with trees over 100 years old should be off limits to logging and road building. | 4 | A,M | N | N | N | N | N | Age is not used to determine harvest in either the FMP or the IPs. | ||
| ALL | I believe that ODF’s plan should be revised to provide maximum protection for fish and wildlife species within the district, assure clean water, maintain old growth or near old growth forest reserves and increase recreational opportunities. Road building and logging should be severely limited within the districts because both of those activities are incompatible with the goals specified above. | 4 | A,M | N | N | N | N | N | The forest management plan provides strategies that will provide for both timber harvest and the endangered species that inhabit them through active management. | ||
| ALL | Please don’t allow clearcutting and roadbuilding in the Tillamook Rainforest. Oregon permanently protects so little of its public forestlands (only 4%, compared to 10% in Washington and 13.7% in California), so that we don’t have any to “give away.” | 4 | A,M | N | N | N | N | N | Significant areas of State Forest are protected (15-20%); they are identified in the Land Management Classification and protected by the various management strategies applied to them. Some of the protected areas include the core areas of northern spotted owls, marbled murrelet management areas and riparian zones. | ||
| ALL | I am very concerned about your plans to clearcut over 4000 acres of timber in this region (Tillamook Rainforest). This is a pristine beautiful back yard for Oregonians and should not be disturbed with logging, road building and the disruption of wild life. Back in the 1960s I led many scouting groups to the old Tillamook Burn to plant trees to restore this area. Please follow a hands off policy to this wonderful area. | 4 | A,M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and only 0.9% of state forests in the NWOA will be clearcut with this AOP. 75% of these clearcut will be conducted in response to forest health issues. | ||
| ALL | No clearcutting of naturally regenerated stands of trees older than 50 years until ODF has: Completed and implemented their Watershed Assessments. | 4 | A,M | N | N | N | N | N | The Forest Management Plan contains forest management strategies based on stand structure, not stand age. The Board of Forestry directed the department to continue with management activities while conducting Watershed Assessments. | ||
| ALL | No clearcut of severely infected Swiss needle cast plantations should be greater than 40 acres. Leave at least 20 trees per acre for these areas. | 4 | A,M | N | N | N | N | N | Stands infected with Swiss needle cast are harvested in accordance with the "Strategic Plan for Managing State Forests in Northwest Oregon Affected by Swiss Needle Cast". | ||
| ALL | Drop all units of all timber sales that would: Clearcut or build roads around Bald Eagles. Clearcut or build roads within current or historic Northern Spotted Owl circles. Clearcut or build roads within Marbled Management Areas or their buffers. | 4 | A,M | N | N | N | N | N | The Forest Management Plan provides for the protection and recovery of a variety of species. Site specific plans are develop for bald eagle sites. Northern spotted owls are managed under guidance contained in the Strum Creek agreement. Marbled murrelets are managed in accordance with the ODF policy on marbled murrelets (clearcuts are prohibited in Marbled Murrelet Management Areas). | ||
| ALL | For all timber sale operations: Retain biggest and best trees, regardless of species. | 4 | A,M | N | N | N | N | N | In partial cuts, the "biggest and best trees" are normally retained; however there may be specific situations where that may not be the case. | ||
| ALL | It is of the utmost importance to me that the wild, natural forest spaces that my family has had the privilege to live near continue to remained unspoiled for my child and for all future generations who choose to live in this area. | 4 | M | N | N | N | N | N | State Forest are managed for all Oregonians, as required in the "Greatest Permanent Value" rule, using the strategies in the Forest Management Plans. | ||
| ALL | Stay in the tree plantations and out of the older native forest. | 4 | M | N | N | N | N | N | The Forest Management Plan Strategies apply to all forest stands; plantations and naturally seeded. | ||
| ALL | WAKE UP and stop the destruction of the last pieces of AGE DIVERSITY that exists of the temperate rainforest in Oregon. | 4 | M | N | N | N | N | N | The Forest Management Plan Strategies apply to all age classes of forest. | ||
| ALL | Please don’t cut older forests on Oregon land – our children have scarcely any natural Oregon left to be seen. Wildlife, human citizens, even global warming are benefited by older forests. | 4 | M | N | N | N | N | N | The Forest Management Plan contains forest management strategies based on stand structure, not stand age or origin. | ||
| ALL | Commercial logging as a mechanism to reach forest health goals leads to abuse by the bureaucracies who receive the logging money. The ODF is a textbook case-study in this phenomena. | 4 | M | N | N | N | N | N | Comment does not contain a recommended action. | ||
| ALL | No clearcutting. Clearcutting older forests (around age 70 or more) is certainly nonsensical when there is so little of this age structure on state lands. Even clearcutting a young plantation is ecologically unfeasible because of the effects on soil. Young trees protect the soil; their roots offer protection from landslides and erosion as well as protecting the integrity of the soil (such as drying it out). For the record, I use the word "clearcut" to include "regeneration harvests" and seed tree cuts. | 4 | M | N | N | N | N | N | This Forest Management Plan recognizes clearcutting as an important management tool and it does not identify age as a factor in determining stands to be harvested. Clearcutting is necessary to meet the DFC goals in the Implementation Plan and less than 1% of stand to be clearcut under this AOP are over 70 years old. | ||
| AST | West Creek Comb -- Comments: Many stands moved from more to less complex stand structure including OFS and LYR stands. West Creek Community Watershed. Minimal clearcutting! Recommendations: All trees greater than 26" should be left standing until Plympton Basin has achieved its complex structure goals. | 4 | A | N | N | N | N | N | The FMP recognizes clearcutting as a viable silvicultural prescription. The FMP also contains forest management strategies based on achieving stand structures over time, not on stand age or origin or tree sizes. | ||
| AST | Foster Divide -- Comments: 350 of 682 acres have been reclassified to a LESS complex structure. Clearcutting will occur on slopes greater than 80%. Clearcutting inside historic Cow Creek NSO Circle. Pre-roads into Areas 5 and 6 are already slumping. Area 5 has "many characteristics of LYR stand structure" (Clint Smith's draft Comments of FY 2003 sales) but will be a 83 acres clearcut. Northrup Basin has reached and exceeded REG %. Recommendations: Stop clearcutting in Northrup Basin. See Clint Smith's draft comments for FY 2003 sales. | 4 | A | N | N | N | N | N | |||
| AST | I would note the numerous times the staff had questions about levels of downed woody debris. The standard answer was "Actual existing levels of downed woody debris will be determined during the sale preparation. Strategies to address any deficiencies will be addressed at that time." There needs to be some assurance to the public that this important step will actually get done. | 4 | D | Y | N | Y | N | N | Assurance to the public can be seen in current contracts. During the sale preparation stage, DWD levels are measured. The target levels are set per FMP and IP strategies. Any deficiencies in DWD are then required to be left to meet the goals. | ||
| AST | I am writing to support a discontinuation of clear-cutting old growth in the State Forests, particularly the Cougar Monster and The Gnat Creek sales (which should be cancelled.) A high priority should be placed on preservation of older forests, and the ODF should stop "high-grading" trees in the Tillamook Forest. | 4 | M | N | N | N | N | N | The FMP recognizes clearcutting as an important management tool. | ||
| AST | Punchbowl -- This pre-operations report was one of the best I've seen for clarity and completeness of explanations in regard to the environmental/habitat outcomes of a sale. I was pleased to see in the Proposed Mgmt Prescription section that "Any trees that appear to have 'platforms' usable by murrelets will be left for wildlife." The outcome for this species would be much improved if you also left additional trees in a cluster around these to provide protection for the nests. In a clearcut they would be too unprotected for viable murrelet nesting. A prescription including areas of thinning or no harvest would be more desirable. | 4 | O | Y | N | Y | N | N | The FMP recognizes clearcutting as a viable silvicultural prescription. The Astoria District's IP includes goals & objectives for a level of clearcutting. This sale prescription is in alignment with the FMP and IP. Therefore, this presciption does not merit changing. | ||
| AST | High Tide Comb -- Comments: Subcanopy MAMU in Tidewater MMMA; Area 9 is in the MMMA. Areas 4,5,6 are near this MMMA. Ebsen Road MMMA is adjacent to areas 1,3,&5. NSO detected in 2001 and separate single male detected in the West Tidewater Area. Area 6 to be clearcut OSCUR Type 204 has dbh of 23 but is CSC? Areas 4,6 &8 are "Intensive Management". Area 4 was RECLASSIFIED from LYR to UDS and will be clearcut! Recommendations: Drop this sale! There are MAMU and NSO detections. See comments by Marcia Humes Wildlife Biologist Nov 9th 2001. | 4 | O | N | N | N | N | N | Active management within MMMA and NSO circles, in the form of thinning, is a viable strategy within Department policy and USFWS guidelines for the Endangered Species Act. Active management outside of MMMA and NSO circles are viable silvicultural prescriptions. All prescriptions within MMMA and NSO circles will be reviewed with wildlife biologists and will comply with all policies and ESA guidelines. | ||
| AST | Foster Divide -- The biologist (C. Smith) said they discussed retaining larger alder as much as possible to maintain and enhance existing LYR stand structure in Area 6A. The Proposed Mgt. Presc. In this area calls for removing the majority of the alder. | 4 | O | N | N | Y | N | N | A balance prescription will be employed -- balancing economics and wildlife issues. Some larger hardwoods will be left. | ||
| AST | Punchbowl -- Comments: 106 acre single unit clearcut of tree averaging 62-82 years old with dbh's from 16-20 inch. Will clearcut on slopes greater that 80%. Wasting taxpayer's money on stockpiling rocks. Recommendations: Change to a thin and retain biggest and best trees, regardless of species. | 4 | O | N | N | N | N | N | The FMP recognizes clearcutting as a viable silvicultural prescription. The Astoria District's IP includes goals & objectives for a level of clearcutting. This sale prescription is in alignment with the FMP and IP. Therefore, this presciption does not merit changing. | ||
| AST | Foster Divide -- Comments: 350 of 682 acres have been reclassified to a LESS complex structure. Clearcutting will occur on slopes greater than 80%. Clearcutting inside historic Cow Creek NSO Circle. Pre-roads into Areas 5 and 6 are already slumping. Area 5 has "many characteristics of LYR stand structure" (Clint Smith's draft Comments of FY 2003 sales) but will be a 83 acres clearcut. Northrup Basin has reached and exceeded REG %. Recommendations: Change clearcut to thin, and retain biggest and best trees, regardless of species. | 4 | O | N | N | N | N | N | The FMP recognizes clearcutting as a viable silvicultural prescription. The Astoria District's IP includes goals & objectives for a level of clearcutting. This sale prescription is in alignment with the FMP and IP. Therefore, this presciption does not merit changing. | ||
| AST | Foster Divide -- Comments: 350 of 682 acres have been reclassified to a LESS complex structure. Clearcutting will occur on slopes greater than 80%. Clearcutting inside historic Cow Creek NSO Circle. Pre-roads into Areas 5 and 6 are already slumping. Area 5 has "many characteristics of LYR stand structure" (Clint Smith's draft Comments of FY 2003 sales) but will be a 83 acres clearcut. Northrup Basin has reached and exceeded REG %. Recommendations: All cedar, maple, should be reserved from harvest in all operations. See comments by Marcia Humes Wildlife Biologists Nov. 9, 2001. | 4 | O | N | N | N | N | N | A balance prescription will be employed -- balancing economics and wildlife issues. Some larger conifers and hardwoods will be left. | ||
| AST | Back Break Ridge -- Comments: Area 2 will clearcut around American Bald Eagle's Nest. When combined with Gnat Creek Comb, clearcut acres total would exceed those called for in the Draft IP for the Davis Basin. IP states 200-250 acres of REG in first 10 years; combined these two sales would clearcut 260 acres in two years. Recommendations: Drop Area 2. | 4 | O | N | N | N | N | N | The FMP recognizes clearcutting as a viable silvicultural prescription. The Astoria District's IP includes goals & objectives for a level of clearcutting. This sale prescription is in alignment with the FMP and IP. Therefore, this presciption does not merit changing. In addition, the anticipated level of clearcutting in the Davis Basin will be re-examined, and the upper level of potential clearcut opportunities will not be exceeded. | ||
| AST | Back Break Ridge -- Comments: Area 2 will clearcut around American Bald Eagle's Nest. When combined with Gnat Creek Comb, clearcut acres total would exceed those called for in the Draft IP for the Davis Basin. IP states 200-250 acres of REG in first 10 years; combined these two sales would clearcut 260 acres in two years. Recommendations: Change Area 1 to a thin and retain biggest and best trees, regardless of species. | 4 | O | N | N | N | N | N | The FMP recognizes clearcutting as a viable silvicultural prescription. The Astoria District's IP includes goals & objectives for a level of clearcutting. This sale prescription is in alignment with the FMP and IP. Therefore, this presciption does not merit changing. | ||
| AST | West Creek Comb -- Comments: Many stands moved from more to less complex stand structure including OFS and LYR stands. West Creek Community Watershed. Minimal clearcutting! Recommendations: Drop Areas 2, 6. These have been reclassified from OFS to LYR. | 4 | O | N | N | N | N | N | Areas 2 and 6 are prescribed to be partial cut, not clearcut. SLI plots revealed that Area 2 is indeed LYR and partial cutting to move to OFS; and, Area 6 is UDS and partial cutting to move to LYR. | ||
| AST | Astoria Basin Thinning -- Comments: Need more sales like this. No new roads, no large clearcutting of older stands! Recommendations: Area 1 should be less than 40 acres. | 4 | O | N | N | N | N | N | Area 1 is 16 acres. All planned clearcut areas are less than 40 acres. | ||
| AST | Northrup Quarry -- Comments: Areas 3 and 5 will clearcut 139 acres of older forest. Recommendations: See comments by Marcia Humes Wildlife Biologist Nov 9th 2001. Change clearcuts to thins and retain biggest and best trees regardless of species. | 4 | O | N | N | N | N | N | The FMP recognizes clearcutting as a viable silvicultural prescription. The Astoria District's IP includes goals & objectives for a level of clearcutting. This sale prescription is in alignment with the FMP and IP. Therefore, this presciption does not merit changing. | ||
| CM | ODF should hold off on all regeneration harvests of forest over 60 years old, and focus on thinning younger stand with the DFC of Layered or Older Forest Structure. (since targets aren't met yet) | 4 | a | n | n | n | n | n | In order to achieve the Desired Future Condition described within the Forest Management Plan and the Clackamas-Marion District Implementation Plan, active management will need to occur in most stand types. | ||
| CM | Science is very clear that active management in younger stands (<40) provides the greatest benefit when the goal is to bring about older forest characteristics. ODF should be front-loading thinning in younger stands using methods similar to federal lands to achieve these characteristics versus heavy thinning in mature stands. | 4 | a | y | y | n | n | y | Given the current stand structure of the Santiam State Forest, active management will need to occur in most stands to achieve the desired future condition in a timely manner. | ||
| CM | In the Rock Creek Basin, regeneration harvests within this watershed are not warranted at this point. ODF should wait until the Watershed Assessment commissioned by the N. Santiam Watershed Council is completed. ODF should then meet the restoration needs identified within the assessment. | 4 | a | n | n | n | n | n | ODF is committed to developing its own watershed assessment that will be coordinated with adjoining private and federal landowners, as well as with the broader public. The District has a representative that has been working with the N. Santiam Watershed Council on the Watershed Assessment and other issues. | ||
| CM | In the Santiam, all older timber stands, including stands over 60 years old, should be retained until the desired future condition is achieved. | 4 | a | n | n | n | n | n | In order to achieve the Desired Future Condition described within the Forest Management Plan and the Clackamas-Marion District Implementation Plan, active management will need to occur in most stand types. | ||
| CM | Green Keel: none of the Crabtree Area is in the older forest structure category. All active management in this basin should focus on bringing about older forest structure in younger stands where thinning may be appropriate, not clearcutting stands over 60 years old. | 4 | o | n | n | n | n | n | The District is currently thinning younger stands available in areas that are slated for complex structure within this basin. | ||
| CM | The Soggy Bottom plan states that most of the area has been previously thinned 3 times and is classified as Understory stands. This stand would easily develop into OFS given time. The proposed 4 acres of clearcut would actually be good candidates for thinning. | 4 | o | n | n | y | n | n | The FY 2003 AOP will be clarified to show that three different areas within the operation were thinned one time each, occurring during separate years. The stand will achieve its desired future condition quicker with active management and is aligned with the FMP. The clearcut area is not a good thinning candidate due to the poor height to diameter ratio and the small crowns within the stand. | ||
| CM | Strongly recommend that all older stands in areas like the Fractured Rock Combo be protected from significant intensive logging, both clearcutting and partial harvests. These stands are good candidates for ecosystem restoration. | 4 | o | n | n | n | n | n | Given the current stand structure of the Santiam State Forest, active management will need to occur in most stands to achieve the desired future condition in a timely manner. | ||
| Coos | 1k: "More careful prescriptions are needed for thinning operations in the Elliott to better protect and restore forest structure and ecological components.: | 4 | A | Y | NA | Y | N | Y | The timber sale contracts have very specific language and specifications that require the logger to produce the target stand. The target stand specifications include minimum DBH and basal area range in the stand after thinning. Detailed information on these requirements will be added to the AOP in the section titled: Commercial Forest Management | ||
| FG | No clearcutting of naturally regenerated stands >50 years old, > 40 acres, on slopes > 50%, or within 350 feet of salmon streams. | 4 | M | N | N | N | N | N | The FMP strategies are based on stand structure, not stand agre or origin. | ||
| FG | Coffee Bean sale targets oldest stands in this basin which is inappropriate. | 4 | O | N | N | N | N | N | FMP landscape and stand level strategies are based on stand structues, not stand age or origin. Sale is aligned with DFC landscape design. | ||
| FG | Coffee Bean: This sale should be delayed 10 years. | 4 | O | N | N | N | N | N | Sale is aligned with the landscape design and stand type targets in order to achieve the DFC in a timely manner. | ||
| FG | Coffee Bean: No clearcutting layered stands. | 4 | O | N | N | Y | N | N | There are no layered stands within this sale as indicated on FG current condition map. SLI plots will be run to confirm stand type designation. | ||
| FG | In Sein Combo targets older trees in area (76 years); adjacent private land clearcut. | 4 | O | N | N | N | N | N | Stands in clearcut area are consistent with IP and landscape design. Age is not a criteria. SLI plots will be run to confirm stand type designation. | ||
| FG | Alotta Falinus: Leaving extra snags on Raven Ridge is no replacement for less snags in this sale. | 4 | O | N | N | Y | N | N | Snag strategy for this sale is in alignment with FMP and IP. Root rot minimizes the opportunity for creating snags. | ||
| FG | Raven Ridge - justification for clearcut (big game habitat) not valid due to nearyb reprod stand (5 yrs old) | 4 | O | N | N | N | N | N | The sale prescription is aligned with IP and DFC landscape design stand type targets which sets RGN %'s, objectives and location options. Current stand condition matches presciption parameters descibed in IP. | ||
| FG | Sappington Creek: Drop clearcut unit; adjacent private land provides RGN | 4 | O | N | N | N | N | N | Sale prescription is aligned with IP and DFC landscape design and matches clearcut presciption parameters described in IP. | ||
| FG | Noble Prize - clearcut 60 acres adjacent to private lands. | 4 | O | N | N | N | N | N | The sale prescription is aligned with IP and DFC landscape design stand type targets which sets RGN %'s, objectives and location options. Current stand condition matches presciption parameters descibed in IP. | ||
| FG | Noble Prize: Drop sale or thin from existing roads. | 4 | O | N | N | N | N | N | Roads planned for this sale are predominitly ridge-top and are necessary for low impact yarding operations. | ||
| FG | Xantippie - change to thin or drop. Willark basin has 44% RGN. | 4 | O | N | N | N | N | N | Stand has significant level of Phellinus; prescription is aligned with FMP and IP disease strategies and DFC landscape design. | ||
| FG | Porcupine Climb - 90 acres clearcut to diversify landscape, change clearcut to thin. | 4 | O | N | N | N | N | N | The district is exploring modifications that may result in additional thinning and less acres of clearcut that better matches current stand conditions. | ||
| K-L | I support the use of all silvicultural tools, including both uneven-age and even-age management. In areas of even-age stands, the use of seed tree and clear cut are warranted. | 4 | D | N | N | Y | N | N | Add information to the AOP about LRP strategy for even-age vs uneven-age management. | ||
| K-L | I urge the discrimination against lodgepole pine in the understory in uneven-age or older even-aged stands. | 4 | D | N | N | Y | N | N | Discrimination against lodgepole in mixed conifer and ponderosa stands is a standard part of our prescription. Check AOP to make sure this is clearly stated. | ||
| K-L | Silvicultural burning has its place, but it should be limited in all age management. | 4 | D | N | N | Y | N | N | The district does make limited use of fire as a silvicultural tool, prefering to use mechanical tools to accomplish goals typically associated with fire. Check AOP to make sure this is clearly stated. | ||
| K-L | Your proposed harvest prescriptions will ensure that your forest health goals are met and that fire hazard will be reduced. We appreciate the reduced opportunity for spread of fire and I&D onto our adjacent lands. | 4 | D | N | N | N | N | N | No action or changes necessary. | ||
| K-L | In lodgepole stands we have had very satisfactory results removing lodgepole overstory in 2 or 3 harvests rather than all at once. | 4 | D | N | N | N | Y | N | District has had satisfactory results with a single entry. Multiple entries would result in decreased efficiency. | ||
| K-L | I endorse your efforts to to retain multi aged stands throughout the state lands. Harvesting should occur over the entire range of diameters while paying attention to BA, crown condition, and stand density index. | 4 | D | N | N | N | N | N | No action or changes necessary | ||
| K-L | In reference to Guiding Principle # 3 (the plan will recognize that the forest is intended to be an important contributor to timber supply for present and future generations), your operations plan has incorporated the urgent need for thinning of trees thr | 4 | D | Y | N | N | N | N | No action or changes necessary | ||
| K-L | We applaud you on the very balanced, prudent, and sensitive harvest prescriptions. They are consistent with your long-range goals for forest health and comprehensive resource protection. | 4 | D | Y | N | N | N | N | No action or changes necessary | ||
| K-L | The only way to create a diverse forest for a multitude of species is to use timber harvesting as a tool to manipulate the stand structures. I commend you for implementing stand treatments to ensure the health of the forest ecosystem. | 4 | D | N | N | N | N | N | No action or changes necessary | ||
| K-L | The reason for the Sun Pass forest's good health is because you continue to harvest the timber and manage the stands. I believe that you are doing the right thing to use uneven-age silvicultural systems to drive these stands towards optimal stand density | 4 | D | N | N | N | N | N | No action or changes necessary | ||
| K-L | On the Huckleberry Hound Sale, are we trying to force ponderosa pine into a lodgepole site. | 4 | O | N | N | N | Y | N | Change document for this sale to clarify our approach. We do not plan to force a species composition change if it is not appropriate. | ||
| K-L | The AOP for Stand 245 in Hole in One calls for a 10 acre leave clump. While we support this for wildlife considerations, we request that this clump not border our adjacent property. | 4 | O | N | N | N | Y | N | District will work with ODFW and landowner rep to determine best location and change the AOP accordingly. | ||
| K-L | Recommendation for all three sales: Do not remove any trees greater than 100 years old. | 4 | O | N | N | N | N | N | This recommendation is not in compliance with the FMP. In the uneven-age management system described in the FMP, cut/leave tree decisions are made based on individual tree characteristics such as species, quality, and vigor (see pages III-105, 106 in the | ||
| K-L | Recommendation for all three sales: Retain the biggest and the best trees, regardless of species. | 4 | O | N | N | N | N | N | This recommendation is not in compliance with the FMP. The District does retain most of the largest healthy ponderosa and sugar pines as well as the large, defective white firs. | ||
| K-L | Comment on all three sales: We appreciate that this is not a clearcut sale. | 4 | O | N | N | N | N | N | No action or changes necessary | ||
| SWO | Do not remove any trees greater than 100 years old whether the have mistletoe or not. | 4 | O | N | N | N | N | N | Age is not used to determine harvest in either the FMP or the IPs. | ||
| TL | There are 8 of 19 timber sales that have individual clearcut areas (13 total) greater than or equal to 100 acres. These 100 acres plus clearcuts should be broken down into areas less than 40 acres each with at least 300 foot buffers between individual units. | 4 | A | N | N | N | N | N | FMP and IP strategies will be followed. No justification provided for recommendation. | ||
| TL | Clearcutting of severely infected Swiss Needle cast plantations should be limited to less than 50 years old. | 4 | A | N | N | N | N | N | ODF Strategic Plan for management of SNC will be followed. Stand age is not used to determine severity of infection. | ||
| TL | The acreage on several of the sales seem to include clearcuts in Focused Stewardship, Riparian areas. It would be helpful to explain how these provide an effective outcome for riparian habitat. | 4 | A | N | N | Y | N | N | Will clarify in plan that FMP riparian strategy will be followed. | ||
| TL | Foss Alder - do not sell or cut. | 4 | O | N | N | N | N | N | See comment in source # 11 above | ||
| TL | Crymini; Foss Alder; Low Roller; Miami High; New Moon; North Fawcett - Change to thin and retain biggest and best of all trees regardless of species. | 4 | O | N | N | N | N | N | ODF Strategic Plan for management of severe infections of SNC will be followed. | ||
| TL | Crymini - Divide these into 2 different timber sales. | 4 | O | N | N | N | N | N | No justification provided. | ||
| TL | Foss Alder - In the proposed management prescription there is no indication of the amounts of down wood. Leaving additional trees for down wood recruitment will improve the effectiveness of the harvest in both Area 2 & 3. | 4 | O | N | N | Y | N | Y | FMP and IP down wood requirements will be followed. | ||
| TL | Foss Alder - Develop a management prescription that includes more partial cutting leaving some no harvest areas. | 4 | O | N | N | N | N | N | Plan is to partial cut in areas that will promote LYR or OFS structures. There will be some no harvest areas. | ||
| TL | Crymini - Retain all areas of large, older trees. | 4 | O | N | N | N | N | N | This sale is composed of stand with severe Swiss Needle cast that are less than 50 years old. No harvest of large trees is planned. | ||
| TL | Foss Alder - we recommend that you eliminate the sale. | 4 | O | N | N | N | N | N | See comment in source # 11 above | ||
| WL | Spine Thin. Heavy thinning and underplanting is a poor way to get LYR. Should use group selection.. | 4 | M | Y | Y | N | Y | Y | District will consider partial cut options to increase the number of open patches in the stand. | ||
| WO | Hatchery Combination - reduce net acres in Area II to 40 | 4 | O | N | N | N | N | N | Stands infected with Swiss needle cast are harvested in accordance with the "Strategic Plan for Managing State Forests in Northwest Oregon Affected by Swiss Needle Cast". There is not an acreage limit of 40 acres in the Plan. | ||
| Estimated Resource Output | |||||||||||
| ALL | I can understand that part of your role to assure the economic viability of these regions of the State and to provide needed revenue for these counties, but truly I feel your highest responsibility is to ensure the continued existence of these forests and the endangered animals who inhabit them. As an Oregonian and taxpayer, I strongly urge you to reconsider your decision regarding harvesting of large amounts of timber in these forests. | 5 | M | N | N | N | N | N | The forest management plan provides strategies that will provide for both timber harvest and the endangered species that inhabit them through active management. | ||
| ALL | Today, on our way to the coast from Portland via Highway 26. I stopped counting the logging trucks I saw after 22! Unbelievable! Please stop this! | 5 | M | N | N | N | N | N | Active management and harvesting are important aspects of the Forest Management Plan. In addition, the "Greatest Permanent Value" Rule requires a sustainable and predictable production of Forest Products from state forest lands. | ||
| ALL | As you know, OFIC disagrees with both the harvest levels called for in the draft IPs and some of the planning methodologies contained in the IPs themselves…This makes it difficult for me to comment on the AOPs. On the one hand, I don’t support the draft IPs, so any AOP designed to implement them I too would not support. On the other hand, the AOP by definition can’t be tied up in endless planning. My initial reaction is to accept the AOPs as they are with the understanding that the Department would change the IPs and implement them correctly in the next year’s AOP. Unfortunately, there is no assurance that an AOP based on the wrong IP won’t simply become the template for future years. So I would suggest a very simple approach. The Department and the Board should publicly re-affirm that the Plan meets the Greatest Permanent Value (GPV) rule. It is very clear that the IPs and AOPs need to stay within the confines of the adopted Plan. Within those bounds, it is my opinion that the state is obligated to p | 5 | M | N | N | N | N | N | The FMP requires that the AOPs to be consistent with the most current version of the IPs. As IPs are revised, the following AOP will meet the new IP goals. | ||
| AST | Every timber sale in the Astoria District is located in MM critical habitat with the exception of: Saint Nik, Big Nic, Selders Cr, Luukinen Road, Fallcreek Ridge. Critical Habitat was designated by the US FWS as an area that should contain suitable habitat for the MM. ODF should explain how it is providing for the MM despite a majority of planned and accomplished timber sales in the Astoria District located in critical habitat as designated by the USFWS. | 5 | M | N | N | N | N | N | Our FMP and I.P.'s employed a different process for identifying important potential murrelet habitat. See Multi-District Item #5. | ||
| Coos | 9a:"The cost estimate should be refined. It does not include the cost the probable landslides will have on the soil, water, fish, and future tree-stocks since all 5 sales each have high probability of landslides." | 5 | D | Y | NA | Y | N | Y | All sales planned in the FY'03 AOP that contain high hazard (high probability of failure), high risk (likely to deliver to aquatic system) sites will be checked on the ground by a ODF geotech. The geotech will make recommendations regarding practices to achieve the best decision for the resource. | ||
| Coos | 9b: Commentor suggests ODF reduce estimates of timber revenue due to loss of tax revenue from fishing jobs due to increased landslides from planned sales. | 5 | D | Y | NA | Y | N | Y | An economic analysis that considers the risk of debris flows is not part of ODF's current sale appraisal. All sales planned in the FY'03 AOP that contain high hazard (high probability of failure), high risk (likely to deliver to aquatic system) sites will be checked on the ground by a ODF geotech. The geotech will make recommendations regarding practices to achieve the best decision for the resource. | ||
| K-L | I am pleased with ODF's attention to revenue generation. These sales reflect the goal of generating revenue and providing timber. This honorable outcome is not always sought in public forest management. It is significant that ODF notes financial and si | 5 | D | N | N | N | N | N | No action or changes necessary | ||
| K-L | As a side benefit to the projects you are proposing you will be generating many tons of bio-mass from the limbs, tops, and small sub-merchantable trees. We have used much of this material in the past for hogged fuel to generate electricity in our cogener | 5 | D | N | N | N | N | N | No action or changes necessary | ||
| K-L | I encourage continued efforts in the asset management for real returns to the Common School Fund and the State Treasury. | 5 | M | N | N | N | N | N | No action or changes necessary. | ||
| K-L | ODF should use recent average prices provided by State Land Board staff to estimate revenues. Question whether the high end of a fluctuating market is at all valid. | 5 | M | N | N | N | N | Y | ODF uses recent log prices to make revenue projections in the AOP. | ||
| TL | In order to improve clarity and effectiveness of the Plan include: a detailed summary of the operations you will undertake to improve wildlife habitat, particularly T & E species; how many acres of riparian buffer will be left in the harvest areas; how many cubic feet of down wood and scheduled culvert replacements which will improve fish passage or increase the amount of fish habitat. | 5 | A | N | N | Y | N | N | FMP riparian strategy will be followed. | ||