BLM Resource Management Plan 2026 Revision

Submit comments online:
https://eplanning.blm.gov (Search for the DOI-BLM-ORWA-0000-2026-0001-RMP-EIS page)

Key talking points to include:

• Protect older and mature forests. Ask BLM to exclude mature and older stands from logging and prioritize conservation of climate-resilient forests.

• Honor sustained yield. Oppose quadrupling harvest levels that risk repeating boom-and-bust cycles and undermining long-term community stability.

• Analyze watershed and climate impacts. Request full evaluation of effects on drinking water, wildfire risk, carbon storage, and wildlife habitat.

• Consider a conservation alternative. Ask BLM to study an option that emphasizes restoration, thinning in plantations, and protection of structurally complex forests.

Personal comments matter. Share why these forests are important to you — your water, your work, your recreation, your family.

Deadline: March 23. Let your voice be part of the record.

Oregon Wild has a nice fact sheet for more information.

What does it all mean? Here is more for context.

What “Sustained Yield” Meant in 1937

When Congress wrote the O&C Act in 1937, forestry science was heavily influenced by early European sustained-yield forestry. The concept was simple:

Harvest timber at a rate that the forest can regenerate indefinitely without depletion.

The law itself states that O&C forests shall be managed:

“…for permanent forest production, and the timber thereon shall be sold, cut, and removed in conformity with the principle of sustained yield…”

In the 1930s context, this meant:

• Maintaining continuous forest cover
• Harvesting no more wood than grows back over time (consider climate change today)
• Avoiding boom-and-bust logging cycles (quadrupling harvest is a boom senario)
• Providing stable timber supply and jobs for local communities

It was both an ecological and economic stability principle.

Sustained Yield Was Based on Forest Growth — Not Logging Capacity

In 1937, timber harvest capability was limited by:

• Chainsaws (The portable chainsaw became commercially available in the late 1940s to early 1950s in the United States).
• Small logging equipment
• Limited road networks
• Horse and cable logging
• Sawmill capacity

Because of these limits, harvest levels roughly matched forest growth rates.

But the legal definition did not say: “Harvest as much as possible using the best technology.” Instead it meant: Harvest only what the forest can replace through natural growth over time.

3. Why the Meaning Became Distorted Later

Beginning in the 1950s–1980s, several major technological changes occurred:

• High-lead and skyline logging
• Bulldozer road building
• Clearcutting systems
• Helicopter logging
• Massive expansion of timber road networks

These innovations allowed logging companies to harvest vastly more timber than before, far faster than forests could naturally regenerate.

In many areas of the O&C lands, harvest levels exceeded natural growth for decades.

This led to:

• Younger forests
• Loss of old growth
• Declining habitat for species like the Northern Spotted Owl
• Major ecological conflicts that culminated in the Northwest Forest Plan in 1994

The Original Intent: Stability for Communities

Congress was reacting to a timber boom-and-bust cycle in the early 1900s.

Private companies had:

• Clearcut huge areas
• Abandoned lands
• Left counties without long-term economic stability

The O&C Act tried to prevent that.

The idea was: A steady harvest every year, forever. Creating artificially high harvest rates leads to the need to curtail harvest in the future to compensate for the overharvest in the short term.

The biological productivity of the forest. Not the industrial capacity to cut it.

Summary: When the O&C Act was written in 1937, “sustained yield” meant harvesting timber at a rate that the forest itself could regenerate indefinitely, ensuring permanent forest production and stable rural economies.

It did not mean maximizing harvest based on improving logging technology.

Legal aspects: How the courts (especially the 9th Circuit) later interpreted sustained yield and how that interpretation shaped modern O&C management.

The legal interpretation of “sustained yield” under the Oregon and California Lands Act of 1937 has evolved significantly through court decisions and federal policy over the last 40 years. These rulings are extremely important because they clarified that the O&C Act does not require maximizing timber harvest, and that other environmental laws must also be followed.

1. The Key Court Ruling: Seattle Audubon Society v. Evans (1991)

Environmental groups, including the Seattle Audubon Society, challenged federal logging practices.

The courts ultimately ruled that:

• Federal agencies must comply with the Endangered Species Act, even on O&C lands.
• The O&C Act does not override environmental protection laws.

In other words:

Sustained yield cannot be interpreted in a way that violates other federal laws.

2. Ninth Circuit Clarifies the O&C Act (Headwaters v. BLM, 1990s)

In several cases, the United States Court of Appeals for the Ninth Circuit addressed whether the O&C Act required maximizing timber harvest.

The court clarified something extremely important:

The O&C Act requires permanent forest production under sustained yield, but it does not mandate a specific volume of timber harvest.

In practice, this means:

• Timber harvest must be sustainable.
• Environmental laws still apply.
• Agencies have discretion to protect ecosystems.

 

3. Modern Interpretation of Sustained Yield

Today, sustained yield on O&C lands is understood as balancing:

• Forest growth
• Ecologic integrity
• Legal obligations
• Long-term timber supply

The BLM must consider:

• Endangered species protection
• Water quality laws
• Habitat conservation
• Public land planning requirements

This interpretation reflects the broader shift in federal land policy toward ecosystem management rather than purely commodity production.

But…

• Timber production must remain consistent with species protection and ecosystem health.
• Sustained yield is interpreted through modern ecological science, not just industrial forestry.

In summary

Court rulings and federal policy since the 1990s established that:

• The O&C Act requires sustained forest production, not maximum logging.
• Other federal laws like the Endangered Species Act must still be followed.
• Timber harvest levels must reflect ecological sustainability and legal protections, not just technological logging capacity.

Let’s break it down on what this looks like on the ground.

Starting land base: 

BLM manages roughly 2.1 million acres of O&C lands. If all federal lands were harvested on a 144-year rotation, the sustainable rate would be about 11,600 acres per year — roughly 80 acres per township, or 18 square miles across western Oregon. This calculation includes all O&C lands, but in reality, Riparian Reserves are protected and would not be available for harvest, which would further reduce the sustainable harvest base. By contrast, the BLM proposal to quadruple harvest levels implies cutting roughly 40,000–45,000 acres per year — about 60–70 square miles annually, or 2–3 entire townships of forest each year. At that pace, the BLM could harvest the entire upland O&C landscape in just 4 decades, far faster than the 144 years needed for sustainable management, and leaving little time for forests to mature, store carbon, or provide stable wildlife habitat.

At the proposed pace, BLM could cut the equivalent of 2–3 townships of forest every year — the whole landscape in just 4 decades — compared with a sustainable rotation that spreads the harvest evenly over 144 years.

1. Full O&C landbase

• Total O&C acres: 2,100,000
• Number of townships (36 sq miles = 23,040 acres each): ~ 91 townships total
• Federal O&C land in a township is roughly half → ~11,520 acres per township

2. Sustainable harvest calculation

• 144-year rotation
• Annual harvest across full upland base: 2,100,000 ÷ 144 ≈ 14,600 acres/year
• Divide per township (federal land only, 11,520 acres/township):
  14,600 ÷ 91 ≈ 160 acres per township, but wait — remember only half of each township is federal land.
• So federal O&C land per township: 11,520 acres
• Harvest per township: (14,600 ÷ 91 townships) ÷ 2 = ~80 acres per township

Bottom Line:

• 80 acres per township/year is roughly the sustainable harvest under a 144-year rotation, whether or not you explicitly subtract Riparian Reserves or not.
• If you subtract Riparian Reserves, the real sustainable rate is slightly lower, making the quadrupled harvest even more unrealistic.

Let’s look at a more realistic sustainable harvest estimate that accounts for the constraints BLM must follow. Let’s break it down step by step.

1. Total O&C landbase

• Total BLM O&C lands: 2,100,000 acres

2. Subtract protected areas
3. a) Riparian Reserves

• ~425,000 acres

1. b) Late Successional Reserves (LSRs)

• LSRs on O&C lands are roughly 500,000–550,000 acres. Let’s take 525,000 acres as a midpoint.

1. c) Steep, off-limits slopes

• Rough estimate from BLM plans: ~150,000 acres

 

3. Remaining “harvestable” land

2,100,000 – 425,000 – 525,000 – 150,000 ≈ 1,000,000 acres

 

This is the realistic upland harvest base for long-term sustained yield without any withdrawals .

4. Sustainable harvest under a 144-year rotation

1,000,000 ÷ 144 ≈ 6,940 acres per year

• Round to ≈7,000 acres/year

 

5. Acres per township

• 1 township = 36 sq miles = 23,040 acres
• Half is federal O&C land = ~11,520 acres per township
• 7,000 ÷ 91 townships ≈ 77 acres per township per year

So, the per-township number is very similar to earlier simplified estimates, but the total landscape harvest is significantly lower, reflecting the protections.

6. Square miles per year

• 7,000 acres ÷ 640 acres per square mile ≈ 11 square miles/year

7. Compare to proposed quadruple harvest

• Quadrupled harvest = 40,000–45,000 acres/year
• Square miles = ~62–70 per year
• Harvest of the entire protected base (~1,000,000 acres) at quadrupled rate:

1,000,000 ÷ 40,000 ≈ 25 years
1,000,000 ÷ 45,000 ≈ 22 years

At the proposed pace, BLM could cut the entire harvestable upland base in just 2–2.5 decades, leaving protected areas as the only forested remnants.

Bottom Line:

• Sustainable rotation (144 years) → ≈7,000 acres/year, 11 sq miles/year, ~77 acres per township.
• Quadrupled proposal → 40–45,000 acres/year, 60–70 sq miles/year, cutting the harvestable landscape in ~25 years

Even after accounting for Riparian Reserves, LSRs, and steep slopes, the BLM proposal far exceeds what is sustainable and protective of long-term forest and community values.

And that does not even account for the high severity burn landscapes where the trees are at their infancy.

If we include severely burned areas, BLM could cut all remaining harvestable forests in just 2 decades, leaving only protected reserves and severely burned young forests for the next century.

• Sustainable harvest (144-year rotation, minus reserves, slopes, and burned areas) → ≈6,000 acres/year, ≈66 acres per township/year, ~9–10 sq miles/year
• Proposed quadrupled harvest → 40–45,000 acres/year, 60–70 sq miles/year, cutting all harvestable forests in ~2 decades
• Including fire losses emphasizes that the actual productive timber base is smaller than even the conservative estimates, making the quadrupling plan highly unsustainable and ecologically risky.