Dear Vince:

After reading the draft management plan for the Jackson Demonstration State Forest (Dated April 13, 2001 [but nearly identical to the latest draft, dated May 17, 2002] ),  I wanted to write you a brief letter highlighting what I feel are some of the more serious shortcomings.

From the outset, I feel the management agency is trying to do and promise too much. Defining management goals, which the draft plan does well, is an important step in resource planning. But like so many resource agencies committed to multiple use, I believe the goals are too diverse and expansive to be sustainable, or even attainable. Which goals are likely to fall by the wayside depends upon the priorities of the particular agency or management agenda. Based on the history of the Jackson Demonstration State Forest (JDSF), which places a strong emphasis on timber production, it is most likely that the conservation, ecological integrity, or ecosystem function goals will be the ones that suffer most. Ecological conditions may be better within JDSF than observed throughout the surrounding private forest landscape as the result of implementing the draft management plan, but that does not mean the management plan will go far enough to attain ecological sustainability. In its present form, it is likely it will not.

Another common problem I see in management plans of all types (and I see it again here) is the lack of context by the planners. Concentrating inside ownership boundaries is understandable, but to do so without considering the current conditions outside the planning area as well as the landscape history of the entire region leads to poor assumptions and flawed judgments. For example, all of the goals of maximizing habitat diversity (and therefore biological diversity) through forest management practices proposed by the draft JDSF management plan make little sense when the context of the region is considered. The problem is one of scale and context. Attempting to replicate a microcosm of all possible habitat types in a small area like JDSF does little to promote, or even damages, regional biological diversity. For example, many edge and early seral species will do well in the current plan, but these species are doing well already throughout the entire redwood ecoregion. The species most at-risk are those dependent upon late seral conditions, especially those that require large intact core areas. The draft management plan includes late seral forest enhancements, but not over an area necessary to contribute to the long-term survival of these species. The lack of regional and landscape level considerations in Table 4 illustrates this point further. Too much emphasis is placed on the stand and species level actions making ecological sustainability difficult to plan, implement, and monitor.

It is also hard to justify 31 percent of JDSF in even-aged forest management on ecological grounds. Just because a large portion of the redwood ecoregion is managed this way, does not justify its use in JDSF. In my view, JDSF should use its unique position to pioneer and lead the region in ecologically sustainable forestry practices while being acutely sensitive to the role JDSF plays to redwood forests in the region. If the managers feel obliged to keep some component of JDSF in even-aged management for demonstration purposes, then they must at least be monitoring the activity as closely as other forest practices. None of the research topics covers even-aged management and little monitoring is planned in these regions from what I can tell.

The large commitment to group selection is also a little disturbing. According to Table 5, group selection is proposed to make up the majority of land treated (52%, or 3,303 ac). Combined with clearcuts (another 10%, or 667 ac), the total amount of forest soil disturbed and exposed is 62 percent of all treatments and 8 percent of the total area of JDSF, which is quite high (1.6% per year). Landscape change studies looking at forest loss from clearcut forestry and fire conducted in other regions including the Klamath-Siskiyou, northern Rocky Mountains, and mid-coast Oregon showed lower cutting rates (maximum was 1% per year). If we consider all forest practices, including thinning and selective harvest, about 2.5 percent of JDSF is impacted by forest cutting of some type each year. Again, this is large compared to many other regions dominated by coniferous forests.

The draft plan mentions repeatedly the negative impacts from invasive exotics. Control and, more importantly, prevention of exotics on the landscape should remain a high priority. In light of this, why does the plan still support many activities (e.g., even-aged management and road maintenance) that have been directly linked to invasive exotics penetrating native forests? Under the current management plan, the potential for exotic species expansion, or entrenchment in existing sites, is very high.

The monitoring component of the plan is perhaps the weakest overall. Monitoring is too focused on the micro-level and silvicultural characteristics. The overriding questions facing forest management deal with ecological integrity above everything else, and the proposed monitoring plan shows very little of that. This section reads like a wish list of many incompatible goals with monitoring proposed that will tell little about the overall ecological integrity of JDSF even if what is proposed in terms of monitoring is achieved. With limited resources (emphasized by the plan) for this critically important component, I suspect the items that finally get monitored will be those most important to maintaining a forestry operation (there seems to be the most experience here), not necessarily the ones that could provide insight into questions on ecological integrity. The link to GIS as mentioned in the plan is a critical component, but I doubt if an effective monitoring plan can be built around this powerful tool based on the descriptions provided. From my perspective, many of the important ecological questions are not even being asked.

Without an effective monitoring program in place, all of the planned activities will continue without any mechanism for evaluating the effects of the actions - many of the treatment areas fall outside the research zones. There are a few exceptions as described in the research section, but the lack of a thoughtful monitoring program forest wide is a serious shortcoming, especially for a "demonstration" forest. As the plan points out, monitoring is an expensive item, but how can the forest afford not to develop a monitoring program that answers the most important questions?

In short, I believe a management plan for an area as important as JDSF will require creativity and willingness to think outside the box, both figuratively and literally. Some of the assumptions presented (e.g., maintaining diverse seral habitats over the areal extent of JDSF is desirable; maintaining a large potion of JDSF in even-aged management is positive, and measuring silvicultural characteristics should be the primary focus of any monitoring) should be challenged. Above all, I would stress the need for a spatially explicit, comprehensive monitoring plan that focuses on the most important issues pertaining to ecological sustainability within a working forest. Without this critical component, the full contribution that JDSF could make to forestry in over the entire ecoregion will not be realized. Please feel free to contact me if you have any questions.

Sincerely,

James R. Strittholt, Ph.D.
Director, Landscape Ecologist
Conservation Biology Institute