EIR 2006 Comments
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Senators' Letter
Ft. Bragg City Council
Mendocino Supervisors
Kathy Bailey
Kathy Bailey Supplement
Peter Baye, Ph.D.
Native Plant Society
Paul Carroll
EPIC
Richard Grassetti
Pat Higgins
Salmon Restoration Coalition
James Strittholt, Ph.D.
Vince Taylor, Ph.D.
Inventory Deflated
Fish and Game
Water Quality Board

 Comments on the 2006 Draft Environmental Impact Report (DEIR)

Elected Officials and Bodies
State Senators Don Perata, Wesley Chesbro, Joe Simitian, Debra Bowen, Gilbert Sedillo Urges management for habitat and enhancement of public trust resources, and calls for "reasonable and secure funding" for Jackson Forest operations.
Mendocino County Board of Supervisors   Endorses Alternative D of the Environmental Impact Report, rather than the state's proposed management plan. Urges sustainable funding for forest management
Fort Bragg City Council   Endorses Alternative D of the Environmental Impact Report, rather than the state's proposed management plan. Also recommends longer growing cycles ( 80-120 years) for timber management. Urges sustainable funding for forest management.
Individuals and Organizations
Kathy Bailey
Kathy Bailey - supplemental
Kathy Bailey has lived in Anderson Valley, Mendocino County, since 1971 and has been active in forest-related issues since 1976.  She was California Sierra Club's principal spokesperson on state-regulated forest issues for around ten years until her "retirement" from that volunteer position in 2003.  She intends to work on Jackson Forest until real progress has been achieved. Bailey finds that significant information about the extent and location of existing old forest stands at Jackson is completely absent making planning for habitat and analysis of alternatives impossible.  A habitat map that is provided is so muddled that it has caused CDF to conclude there is marbled murrelet habitat where there is not.  Also, at least two significantly  contradictory sets of habitat information are used in the EIR. 
Peter Baye, Ph.D.

Peter Baye is a professional plant ecologist and botanist (Ph.D., University of Western Ontario, Canada), specializing in the study and conservation of terrestrial and wetland coastal plant species, communities, and their ecosystems, for over 27 years.

 Baye found the DEIR was extremely difficult to read even for professional reviewers. The body of the DEIR was similar to a technical appendix, and lacked plain-language discussion of impacts supported by specific information about Jackson State Forest itself. Instead, the DEIR substituted highly technical background discussions, general in scope (like review of scientific literature) for an actual, specific assessment of impacts. The DEIR obscured more than it assessed.
California Native Plant Society
Paul Carroll Paul Carroll has won all five legal motions filed against the Department of Forestry and the Board of Forestry in the Campaign's legal actions to reform management of Jackson Forest. Carroll finds the EIR to err fundamentally in important ways.
Environmental Protection Information Center (EPIC) Lindsey Holm reviews Timber Harvest Plans for EPIC. Holm finds that the EIR does not adequately describe marbled murrelet habitat and the definition for late seral forest is too unclear to be meaningful. Lack of precision leads to the inability to plan for retaining and developing late seral habitat in general and marbled murrelet recovery habitat in particular.
Richard Grassetti Mr. Grassetti is an environmental planner with over 22 years of experience in environmental impact analysis, hydrologic and geologic assessment, project management, and regulatory compliance.  He has managed the preparation of over 50 CEQA and NEPA documents, as well as numerous local agency planning and permitting documents.  In addition to his consulting practice, Mr. Grassetti is an adjunct professor at California State University, East Bay, where he teaches courses on environmental impact assessment and urban planning. Grassetti finds  that the DEIR is a nearly unreadable and often incomprehensible mélange of data and information that has been neither synthesized nor arranged in such a way as to provide an analytical trail from the project description to impacts to mitigation.  As such, it fails to achieve the CEQA mandates of clear impartial analysis and full disclosure to the public and decision-makers.  In addition, the deficiencies in project/alternatives description, baseline, impacts assessment, and factual errors/contradictions result in a document that fails entirely to fulfill its required purpose of identifying potentially significant environmental impacts and mitigating them. 
Pat Higgins

Salmon And Steelhead Recovery Coalition

California Council Trout Unlimited, California Trout, Inc., Coast Action Group, Environmental Protection Information Center, Northcoast Environmental Center, Pacific Coast Federation of Fishermen's Associations,
Salmonid Restoration Federation, Smith River Alliance
The coalition finds that the aquatic protection measures in the Jackson management plan as described in the Draft Environmental Impact Report are insufficient to provide adequate protection for listed salmonid species based on their own knowledge and the sworn declaration of California National Marine Fisheries Service (NMFS) representative, the late Joe Blum, about the insufficiency of the California Forest Practice Rules. They propose use of the NMFS Guidelines or the federal Forest Ecosystem Management Assessment Team (FEMAT) standards instead.
Jim Strittholt, Ph.D. Executive Director of the Conservation Biology Institute. Dr. Strittholt holds a Masters in population genetics and a Ph.D. in landscape ecology and conservation planning. He has authored numerous reports and peer reviewed papers on various topics including forest conservation planning using GIS, late seral forest mapping, and forest fragmentation.  
Vince Taylor, Ph.D.
Related Paper
Founder and Executive Director of the Campaign to Restore Jackson State Redwood Forest. He holds a BS in physics from the California Institute of Technology and a Ph.D. in Economics from the Massachusetts Institute of Technology. He consulted on policy economics for 20 years. He founded and led a successful computer software development company. For the last 10 years he has worked to have Jackson Forest managed for restoration, research, and recreation. Taylor finds serious deficiencies and errors in the forest inventory and growth estimates used in the draft management plan and relied upon by the EIR. Using his own recent analysis of Jackson inventory data, he shows conclusively that the estimates are greatly in error -- perhaps by 40-50%. The errors are so great that the harvest levels proposed in the management plan would exceed forest growth. Harvest in excess of growth violates the law. The management plan is, therefore, legally invalid.
Government Agencies
California Department of Fish and Game
California Regional Water Quality Board

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