The Oregon Department of Forestry (ODF) is on a mission to lock up over 250,000 acres of public state forest, preventing harvesting and active forest management on about 40% of Oregon's state forest. The Habitat Conservation Plan, or HCP, has been identified as the desired strategy to meet the requirements of the Federal Endangered Species Act (ESA).
The ODF believes that the HCP will increase the populations of certain species listed under the ESA, such as the Northern spotted owl, marbled murrelet, and the Oregon Coast and Lower Columbia River coho. ODF hopes that the HCP will achieve ESA compliance over the next 70 years.
Last week I testified in opposition to the HCP.
Click the image below to view my full testimony on X
 Doubling down on failed forest policies
In my opinion, the HCP is doubling down on failed forest policies of the last 30 years. Two guiding goals of our current forest policy are increasing spotted owl populations and reducing global carbon emissions. The theory is that we can achieve these goals by increasing forest habitat and curtailing timber harvesting, the two guiding policies that continue with the HCP. The evidence shows that these goals have not, and will not, be achieved with these policies. And what is indisputable is that these policies have devastated the communities that live, work, hunt, and recreate in these forests. I’ve seen it first-hand in my district; the loss of jobs, the loss of revenue to these once-thriving rural communities, and the raging wildfires. These policies have robbed people of their livelihoods and their dignity. These policies have cost the state billions in revenue and turned our forests from an asset into a liability.
The HCP will continue these failures, reducing annual timber harvests by about 40% of current levels for the next several decades. The heart of the HCP is establishing Habitat Conservation Areas, and as the report highlights, after 30 years, no harvesting inside the Habitat Conservation Areas is assumed in some of the model scenarios.
Billions in lost state and county revenue
As a legislator, one of my duties is to pass a balanced budget, and the fiscal impact of the HCP to the state must be considered. The reduced harvests called for by the HCP models result in about a $60 million dollar revenue loss to the state in the first biennium and increasing for every biennium thereafter. That’s a $5.4 Billion revenue hit to the state over the model’s timespan. Most of this revenue is transferred to the counties for essential services. So, what is the ODF expecting the state legislature to do to make up for this loss? Raise taxes? Short the counties of essential funding? Pull even more money out of the state’s General Fund to prop up the ODF? And if we pull more money from the General Fund, what state programs should we cut? Housing infrastructure? Drug addiction treatment? Youth mental health services?
Fails to achieve environmental goals
The recently revised HCP model was designed to increase the habitat for 3 species, including the Northern Spotted Owl. Also, the report highlights as an added benefit an increase in carbon storage. In my opinion we are taking valuable forest lands out of sustainable production, costing the state and counties tens of millions in revenue every year, based on flawed assumptions. The theory is that we can achieve our environmental goals by increasing forest habitat and curtailing timber harvesting. There is mounting evidence, however, that shows we won’t.
Let’s start with the Northern Spotted Owl. Currently we have over 9 million federal acres designated as critical habitat for this bird. And despite all the habitat efforts over the last 30 years, despite all the job losses and the economic and social devastation this has caused, the spotted owl population in the Northwest has declined in every forest service study area. The primary reason is straightforward - the critical habitat for this bird is also the desired habitat for its apex predator, the barred owl. Barred owls are larger, more aggressive, and more adaptable than northern spotted owls. They displace spotted owls, disrupt their nesting, and compete with them for food. Researchers also have seen instances of barred owls interbreeding with or killing spotted owls. As we’ve witnessed over the last 30 years, locking up more state forests via the HCP will do nothing to increase the spotted owl population. There are other, less economically devastating approaches to increasing the spotted owl population. And the story is the similar with the other two species modelled, the marbled murrelet and red tree vole.
One other metric in the analysis is carbon storage. Carbon storage and/or carbon sequestration is mentioned multiple times in the report, and described as an important environmental outcome. The underlying assumption in the model is that locking up Oregon state forest lands in Harvest Conservation Areas, and stretching out harvest cycles to 90 plus years in other areas, are important strategies for carbon storage. I would argue that these strategies do the opposite. Forestry researchers at the U.S. Department of Agriculture Pacific Northwest Research Station have consistently found that locking up forests ends up emitting more CO2 than sustainable harvests. The science shows that a 45-50 year timber harvest cycle is optimal for carbon storage – you grow a tree through its highest carbon storing years, harvest and ‘sequester’ that carbon in lumber to build homes, and plant another tree to repeat the cycle.
Implicit in the HCP model is that this carbon storage policy provides a net global benefit. The opposite is true, however. Whether Oregon cuts another tree down or not, the United States will continue to utilize wood products to meet growing demand for homes, paper products, and packaging. In fact, the US is a net importer of softwood lumber. And as imports from Canada continue to decline, we are left importing lumber from overseas. What this means is simple: Every tree that Oregon takes out of a sustainable harvest cycle is one more tree that must be processed overseas and transported on a diesel guzzling, carbon spewing freight ship halfway around the world. Or, homes will be built with more steel and concrete, two building products that are extremely carbon intensive. In other words, every tree that Oregon takes out of a harvest cycle is, in fact, increasing the global carbon footprint.
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Our state forests are the gem of the Northwest. Not only are they a beautiful resource for recreation when actively and sustainably managed, they provide jobs and generate much-needed revenue for our state and our counties. The HCP doubles-down on turning our state forests from an asset into a liability. What’s worse, it will not achieve the environmental and species population growth goals that it claims to support. I urge the Oregon Department of Forestry to rethink the HCP, and engage your local communities in this decision-making process.
You can help by making your voice heard. Write to the ODF to express your concerns.
Testimony on the HCP can be submitted until January 17th, click here.
You can also email the Board of Forestry and the State Forester:
Jim.Kelly@odf.oregon.gov, Karla.S.Chambers@odf.oregon.gov, Brenda.McComb@odf.oregon.gov,Chandra.Ferrari@odf.oregon.go,Joe.Justice@odf.oregon.gov,Ben.Deumling@odf.oregon.gov, Liz.Agpaoa@odf.oregon.gov,boardofforestry@odf.oregon.gov,Cal.T.Mukumoto@odf.oregon.gov
You can also join Oregon Natural Resource Industries (ONRI), who has taken the lead against the HCP. Check out their membership site here.
Reference information
Oregon Department of Forestry HCP website
Additional information on the HCP from Oregon Stronger Together
Yours truly,
 Representative Ed Diehl
House District 17
Capitol Phone: 503-986-1417
Capitol Address: 900 Court St. NE, H-378, Salem, Oregon 97301
Email: Rep.EdDiehl@oregonlegislature.gov
Website: https://www.oregonlegislature.gov/diehl
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