October 30, 2002

Members of the Board of Forestry
Sacramento, CA
Fax: 916 653-0989

Dear Board Member,

I am the Executive Director of the Campaign to Restore Jackson State Redwood Forest. I am writing to request your help. I, along with many other well-informed people both private and within agencies, believe that the proposed management plan for Jackson State Demonstration Forest proposes timber operations that are needlessly destructive of rare ecological and recreational values:

• CDF has refused to refrain from logging in the remaining unentered stands of second growth, even though these have enormous potential value as the core of a future sanctuary for species dependent on old-growth redwood forest. The timber in these stands will continue to grow and appreciate in value, thus there would be no economic loss in deferring timber harvest in them until a later date. But there will be a substantial, irreparable ecological loss from harvesting them.

• CDF has refused to budge from its historic emphasis on even-age management and its ecologically destructive variant, group selection. CDF proposes to apply these two silvicultural practices to one-half of the forest. This is bad forestry that has no justification, other than reducing the cost of operations and increasing profit. As a member of the Board of Forestry you have both the opportunity and the responsibility to prevent it.

On November 6, you will consider whether or not to approve the proposed forest management plan (FMP) for Jackson Demonstration State Forest (JDSF). There are several grounds for delaying approval of the management plan and asking CDF to make further revisions in it:

1. Four thousand people wrote to CDF during the EIR comment period opposing continued large-scale commercial timber harvesting and supporting restoration to old growth as the primary goal for forest management. Less than fifty people wrote to support the CDF management plan. You are being asked to approve a plan that is overwhelmingly opposed by the public. The public has sent a strong message to those of you who are on the board to represent them.
   
2. There is substantial evidence that the estimates of inventory, growth, and allowable cut contained in the draft management plan are seriously in error. My comments on the Draft EIR presented this evidence. In its responses, CDF failed completely to provide a factual rebuttal to my evidence and contentions.
   
   This is no small matter: If I am right, the inventory and growth estimates are 50% greater than the actual forest numbers, and the allowable cut seems likely to also exceed harvestable growth by 50%. If I am correct, the proposed timber operations will greatly decrease the timber inventories within the areas where unrestricted harvesting is permitted. This would be directly contrary to state law and Board policy.
   
   I beg of you to take a look at the evidence that I presented in my comments and judge for yourself whether or not there are serious questions that need to be definitively resolved before approving the CDF management plan. I have a Ph.D. in Economics from MIT, and I performed complex empirical, mathematical and statistical analyses over a period of twenty years. All of my experience cries out that the inventory estimates in the management plan are seriously in error. You can easily understand the reasons yourself by looking at my comments on the EIR. A copy of my comments in PDF format is available at http://www.jacksonforest.com/EIR/Comments/taylor_final.pdf .
   They are also in the final EIR, Section IV, p. 265ff. I will be happy to answer any questions about them.
   
   Approval of the management plan should be delayed until the controversy over the correct inventory estimates are resolved by an independent, unbiased third party.
   
   
3. A legal challenge against the EIR has been filed. This challenge is well founded, as you will be able to determine yourself by reviewing the comments on the EIR submitted to CDF. The EIR is most certainly illegal in its failure to address cumulative impacts in a coherent, organized fashion, as required by CEQA (see the EIRcomments by Paul Carroll). Additionally, though, the DEIR failed to properly evaluate the potential impact of timber operations on a variety of endangered animal, fish, and botanical species. It also failed to evaluate the management plan in the context of the landscape within and surrounding Jackson State Forest.
   
   To approve the management plan when the EIR on which it depends is clearly legally flawed would reflect badly on the Board.
   
4. In the opinion of our lawyer, Paul Carroll, the Board of Forestry has the legal responsibility for certifying the EIR, a responsibility that cannot be legally delegated to CDF. As a Board member, you therefore have a special responsibility to make your own determination about the adequacy and legality of the final EIR.
   
   Experts submitted to CDF nearly a thousand pages of comments on the DEIR, together with many more pages of supporting documentation. Most of these comments were highly critical of the adequacy of the DEIR and the management plan. Although CDF rejected almost all of the critical comments in its final EIR, this does not mean that it did so on adequate grounds. As you know, a suit has now been filed alleging that the EIR is legally deficient. In your position as a Board member, you have an obligation to form your own independent opinion about the validity of the expert comments, the adequacy of CDF’s responses, and the legality of the EIR.
   
   Before making this decision, please make yourself fully aware of information presented to CDF as part of the Draft Environmental Impact Review (DEIR) and FMP review. Because CDF assumed the responsibility for preparing and certifying the EIR, you may not have seen information that is critical to your ability to make an informed decision.
   
   Reviewing the EIR material will obviously take considerable time. The Board does have the time to consider this matter deliberately. Logging cannot begin in Jackson State until April 15. Delaying a decision until Board members perform an independent review should not cause any delay in the resumption of timber operations in Jackson State.

Separately, I want to bring to your attention an important omission in the new management plan: the lack of any definition of allowable cut over a multi-year period. The 1983 Management Plan stated that average harvests within a five-year period would not exceed five times the annual allowable cut. This rolling average provided an important constraint on timber harvests in the late 1990’s, after several years in a row where actual harvests exceeded the allowable cut by 50%. The new plan is silent on this subject. Does this mean CDF will not exceed the allowable cut in any year, regardless of harvest levels in preceding years? Or what does it mean?

The Board should ask CDF to put into the management plan a specific method of calculating the allowable cut over a period of years. This is especially important, given the reduced timber harvesting in the last two years.

Sincerely,