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Regarding the even-aged management update and the new rules for
variable harvest unit sizes: even 50 BA can be considered a
shelterwood in most of our temperate forest ecosystems.
Shelterwoods tend to promote shade tolerant, 'climax' species-like
hemlock and cedar and discriminate against the early seral
species-like Douglas-fir and redwood. Climax species are not as
resilient as early seral species and with climate change becoming a
more critical variable, this is an important distinction that needs
to be recognized. There needs to be more distinct guidelines and
differentiation between regeneration and stand improvement
treatments with even-aged silviculture. Not all treatments are
regeneration.

Secondly, there is an absence of guidelines for uneven-aged
management and specifically patch size for regeneration in this
silviculture system. The three Indian Tribes I have worked for in
the Pacific northwest dictate that patch size is not to exceed 3-5
acres with certain exceptions made for particular forest types-
like lodgepole pine and upper elevation forest types.