Overall Message: We strongly support the Board of Forestry’s finding that Oregon’s current forest practices cause excess water pollution and logging rules need to be improved, but the proposed new streamside buffers are not enough to protect cold water for fish.
8 Key Points:
- Change is welcome. Wider, mandatory streamside buffers on Oregon’s private forestlands are needed and long overdue.
- The proposed buffers are too narrow. The proposed streamside buffers are not wide enough to prevent warming of streams used by salmon, steelhead and bull trout, as required by DEQ water quality standards.
- Upstream reaches need protection. The proposed rule does not protect salmon habitat because it does not extend the streamside buffers far enough upstream.
- Siskiyou Exemption Unjustified. The Siskiyou Region was left out of improved streamside buffers even though there is adequate information and urgency to protect fish in that region.
- Drop Variable Retention Option. The rule’s provision that will allow an experimental “variable retention alternative” will bring too much logging to close to streams (outside 20 feet) and should be dropped.
- Drop North-sided Option. The Board should also drop the experimental idea of allowing smaller streamside buffers on the streams that run east-west. Not only is the effectiveness of this option to prevent steam warming unproven, it won’t protect against sedimentation or prevent logging of trees that are needed to form healthy instream habitats, among other problems.
- Monitoring is Critical. The Board should closely monitor the effectiveness of the new rule because full compliance with the coldwater standard the new buffers are supposed to meet is legally required and extremely important to the survival of salmon and other freshwater species.
- Exemptions cause for concern. The proposed rules would allow some landowners to use smaller buffers, but logging should never be allowed to harm public waters and threatened and endangered species.