July 18, 2002

Christopher P. Rowney, Program Manager
Demonstration State Forests
California Department of Forestry and Fire Protection
Post Office Box 944246
Sacramento, CA 94244-2460

Jackson Demonstration State Forest Draft Management Plan and DEIR

Dear Mr. Rowney:

On behalf of Sierra Club’s members in California, I thank you for the opportunity to comment on the Jackson Demonstration State Forest (JDSF) Management Plan (FMP) and the draft Environmental Impact Report (DEIR) on the Plan. We congratulate you on reaching this milestone. The FMP is a significant improvement over the 1983 Plan that it replaces.

These comments are made from the backdrop of my experience in Mendocino County where Jackson Forest is located. I have lived here since 1971 and have been active on forest related issues off and on since 1976. In response to my concern about the unsustainable pace of logging in my area, in 1988 I helped found the organization Forests Forever. In 1990 I was on the state steering committee for Proposition 130, the Forests Forever voter initiative, which proposed a major reform of forest practice rules to provide sustained production of timber while protecting the environment. The Initiative also proposed a multi-million dollar bond for purchase of Headwaters Forest and other ancient forests throughout California. Unfortunately, in the face of a $13 million campaign by the timber industry, the measure failed with a 48.7% yes vote.

In 1992, I began representing Sierra Club California regarding state-regulated forestry issues, and was until my "retirement" last year, the Forest Conservation Chair for California. In that position I was Sierra Club California’s principle spokesperson regarding Headwaters Forest. I also represented Sierra Club in relation to the Board of Forestry regarding Forest Practice Rules and other matters, and was appointed by former Resources Secretary Douglas Wheeler to the Coastal Salmon Initiative Policy Panel. I have presented testimony to the California Legislature on a number of occasions and have been the Sierra Club liaison regarding forest-related litigation. I have reviewed and commented on numerous Timber Harvest Plans (THPs), including the two JDSF plans that are currently enjoined from operation by the court pending approval of the new FMP, and the other Jackson THP that has completed the review process but has not yet been approved.

In 1996, I began following management at Jackson when a series of protests and arrests brought the public’s concerns to my attention. I advocated with former CDF Director Richard Wilson for the creation of the Citizens Advisory Committee that ultimately met for more than a year and produced a report and recommendations that are now being considered as Alternative D in the DEIR, an alternative that is not the preferred alternative. I was not a member of the CAC, but did attend a number of its meetings. After the new administration failed to implement those recommendations and additional THPs continued to be proposed, in 1999 I sent a letter to CDF Director Andrea Tuttle on behalf of Sierra Club asking that THP approval be put on hold until a new management plan update was completed. I also raised this issue with the Board of Forestry. Director Tuttle created a State Forest Advisory Committee and appointed me as a member. However it was not until the newly formed Campaign to Restore Jackson Redwood Forest took CDF to court in 2001 that the draft Management Plan was released. The Campaign subsequently won an injunction prohibiting operation of any THP prior to approval of the new FMP. Although Sierra Club is not active with the Campaign, I believe their litigation was a key factor in CDF releasing the FMP. Even so, it has taken another year to reach the point of this DEIR review.

Throughout the course of my forest conservation activities I have been, and remain, a volunteer.

It was a relief to see the statement on page 3 of the Forest Management Plan:

This statement provides a context that makes progress possible and resolution of many conflicts achievable.

Decisions about management at Jackson must take into account several important factors that have not been adequately considered by the DEIR. Central among these is Jackson’s unique ecological importance within the redwood region. It is by far the largest bloc of public coast redwood forestland north of San Francisco and south of Humboldt County. It also contains much of the remaining significant stands of mature second growth forest in that same region. It is by far the largest single block of public land in the redwood region of Mendocino County and all of Sonoma County, an area of burgeoning population growth.

There is a good map in the FMP, Figure 2, Regional Forestland Ownership, illustrating the lack of public land in the redwood region. It shows the huge imbalance in public land ownership among the various regions of California north of Monterey Bay. Beginning on the eastern fringe of Mendocino County, in the hot, high, and dry Douglas fir forests stretching north into Humboldt, Trinity, and Del Norte Counties are large swaths of US Forest Service land. Even in the north, it is not until around Eureka that these Forest Service lands extend to within 50 miles of the coast into the range of the redwood forest. On the Sierra side of the state, large tracts of US Forest Service lands provide a range of protection for the Sierran Pine and Fir forests ranging from wilderness to commercial timber production. These Forest Service lands are also among the most heavily used recreation areas in California, if not the nation.

Yet looking toward the redwood region north of San Francisco, there is only one public forest of any size south of Humboldt County, and that is Jackson Demonstration State Forest. Even in Humboldt County there are only two public forests of similar size in the redwood forest type, the King Range National Conservation Area (which is actually dominated by Douglas fir, not redwood) and Humboldt Redwoods State Park. Thus, Jackson is one of only three large public forests in the redwood region south of Eureka and north of San Francisco. All three of these forests combined are something less than 150,000 acres total embedded in millions of acres of industrial timberlands in the redwood region.

The DEIR acknowledges on page 36 that:

However, the DEIR should have included the Figure 2 map from the FMP to illustrate the regional imbalance of private and public lands. The DEIR does not discuss the ecological implications of this imbalance. It focuses solely on the aspect of research opportunities. Failure to consider the full range of implications is a significant omission of the DEIR.

Large industrial timber companies dominate coastal forestland ownership in Mendocino County, and smaller private timber owners, many of whom engage in commercial logging, dominate the forested area of Sonoma County. Timber operations in these counties have eliminated almost all old growth forest, and in the past decade have dramatically reduced stands of mature second growth forest. Old growth and mature first or second growth forest stands are collectively referred to in the DEIR as late successional (or late seral) forest.

Although the DEIR does not disclose this at all, the older second growth forest stands at Jackson are highly likely to be among the largest blocs of such forest in Mendocino County. This is important environmental information that should have been included in the "Surrounding Land Use" section of the Setting information (DEIR page 54). One of the key areas of concern about Jackson has been and continues to be the fate of the oldest second growth redwood stands. According to JDSF Manager Marc Jameson, there are 10-12,000 acres of 80-110 year old second growth forest mostly on the west side of Jackson.

Additionally, the previous elimination by logging of most late successional forest and older second growth stands in the region should have been considered as one of the known significant adverse impacts from past projects when conducting a cumulative impacts analysis. Logging is a "project" under the California Environmental Quality Act (CEQA). Timber Harvest Plans (THPs) are logging permits that are certified by the Resources Secretary as functionally equivalent to an EIR. These THPs are reviewed and approved by the CDF, so these past projects are well known to the Department. Amazingly, no cumulative impact analysis has been done for the Jackson DEIR. As the guidelines for the California Environmental Quality Act (CEQA) encourage cumulative impact analysis as appropriate at the programmatic EIR stage, the lack of this analysis is a significant shortcoming in the DEIR.

We have commissioned a map to illustrate the proximity and extent of industrial timberland ownership in the vicinity of Jackson Forest and in Mendocino County. (Exhibit A) It shows that JDSF is bounded on both north and south almost exclusively by two large industrial timberland owners, Hawthorne Timber LLC (Hawthorne) on the west end of JDSF, and Mendocino Redwood Company (MRC) on the east. Their ownerships extend far to the north and south of Jackson. Both of these companies are relatively new owners, being successors to two large companies that operate internationally: Georgia-Pacific (now Hawthorne) and Louisiana Pacific (now MRC). G-P and LP mercilessly over-logged their lands, culminating in the 1990s with the virtual elimination of older second growth redwoods (stands exceeding 60 years of age in a region where trees will live to be 2000 years old) on their lands. During this now infamous period, CDF approved thousands of Timber Harvest Plans and concluded that each individually and cumulatively resulted in no significant adverse impact to the environment. Yet during this same period, ever increasing numbers of species such as coho salmon, marbled murrelets, and steelhead trout were listed as threatened or endangered by both the state and federal governments and most of the streams in the area were listed as impaired under Section 303d of the Clean Water Act including both the Big River and the Noyo River, major watersheds in JDSF. Each of these listings cited poor California Forest Practice Rules and effects of logging as either primary or significant factors in the listing. The absence of information regarding this environmental setting is a significant omission of the DEIR.

Attached are excerpts from the Hawthorne Option A [Exhibit B] and the MRC Option A [Exhibit C] that verify the loss of older forests in the County. The Option A is a document that complies with California Forest Practice Rules requiring demonstration of sustained timber production. According to the Hawthorne Option A, they had a standing inventory of 2.1 billion board feet (bbf) with 191,581 acres considered as the "timber management" area. This calculates to an average stocking volume of 10,900 board feet per acre.

According to the California Forestry Handbook (page 215)) [Exhibit D] a low site class II (site index 160) fully stocked redwood stand at 20 years of age would have 7000 board feet per acre, not much less than the Hawthorne average. At 30 years it would be expected to have 19,600 board feet. Obviously, the Hawthorne age estimate is an average--some of their acreage would have a higher level of stocking and an older stand age, but some would be even younger.

The former LP lands are generally considered to have lower timber volumes than the former G-P lands and this is born out by the MRC Option A, submitted February 29, 2000. With 232,000 acres, they had a standing conifer inventory of 2,264,700 mbf (ie ~2.27 billion bf) which comes to an average conifer volume per acre of 9,762 board feet. Again, according to the California Forestry Handbook, Lindquist and Palley (1963) yield table, a Site Index 160 stand, similar to what would be expected in the coastal areas of MRC holdings, would have 152,300 board feet per acre at 100 years. These figures demonstrate that the forests surrounding JDSF are very young and are likely to provide, in abundance, the sort of habitat typical of young forests. They are not at all likely to provide older second growth habitat, not to mention either the mature or old growth components of late successional forest.

The FMP indicates: "Some of the densest and highest volume stands of second-growth timber in the redwood region can be observed on JDSF." (FMP page 1) According to the DEIR the standing timber volume is roughly 2 billion board feet on the ~ 50,000 acres. (DEIR page 31) Without accounting for constrained areas, this calculates to an average ~ 40,000 board feet per acre, more than four times the stocking volume on the former LP lands. Using the same Site Index 160 as was used for the preceding analysis, the average age is somewhat older than 40 years. These numbers provide a very coarse grained analysis. We do not mean to indicate that this methodology provides a clear picture of specific stand ages on these forest ownerships, only the relative age of their stand averages.

Also attached as Exhibits E and F are two 2001 Landsat images. One is tightly focused on JDSF, and the other expands the view to include adjacent industrial timberlands directly to the north and south. The second clearly shows the general absence on neighboring forestlands of the dark green that indicates an older, more dense forest. The areas to the north and south corresponding to the former G-P lands show a vast network of white clearcut areas in an expanse of very light green young trees. The areas more to the east show the different approach generally taken by LP: rather than clearcuts, even-aged management was used to remove the large trees, leaving the younger ones in place. We note a disturbing similarity to some of the G-P lands on JDSF north of Parlin Fork. The network of clearcuts and heavy canopy removals are a striking image of the sort of logging the public has long been asking JDSF to discontinue.

On one hand, all of this indicates that JDSF has obviously been doing better than its industrial neighbors. On the other, it demonstrates that JDSF’s older forest stands are unique to the region. If we are to have older forests here, and the plants, fish, birds, wildlife, and other forms of life these forests support, we are going to have to have them at Jackson because they are already gone on the industrial lands.

These are the sort of issues the DEIR should have discussed when describing the JDSF setting and the environmental context of the project. The DEIR should have provided the images that would help the public to understand the context of the project. The DEIR should have, but didn’t, consider that by logging most of the existing older stands as proposed, the FMP project is likely to combine with past, present, and foreseeable future projects on adjacent timberlands to create an adverse cumulative impact on older second growth forests, late successional forests, and the species of flora and fauna that depend on these forests. These adverse impacts also extend to the aesthetic and recreation interests of the public.

What is meant by the term late successional forest (synonymous with late seral forest) is a key concept for the JDSF FMP and DEIR. It is imperative to recognize that this term is NOT synonymous with "old growth" forest. Rather, "old growth" is a subset of late succession. "Mature forest" is the second component. Collectively, these two stages in forest development are called late successional forest. The DEIR Glossary (Appendix) correctly recognizes this when it defines this term: "The stage in forest development that includes mature and old-growth forest." Neither the FMP nor the DEIR ever refers to the DEIR Glossary definition. Rather a number of surrogates are used. None of the surrogates are as accurate as the Glossary definition. As these surrogates are used throughout both documents, however, it will be necessary to refer to them and discuss the documents in those terms.

The DEIR does not adequately explain the importance of late successional forest. What discussion there is centers around the "old growth" component.

Without understanding the ecological importance of the "mature forest" component of late successional forest, the public’s concern for Jackson’s older second growth stands will be wrongly relegated to the spheres of aesthetics and recreation. Older forests younger than-old growth are a crucial biological resource well prior to their attaining true old-growth characteristics.

The federal FEMAT Report, which is specifically about the Pacific Coast region says: [page IV-20]

Other than in relation to old growth, no specific information is provided in the FMP, DEIR, or the maps regarding the total acreage or location of forest stands that are non-old-growth, but nevertheless, late successional stands. This is a significant omission.

The DEIR acknowledges that the California Wildlife Habitat Relationship (CWHR) system is not an adequate descriptor for late successional forest: "Old-growth forests and late successional forest as defined by the FPR [Forest Practice Rules] are not well represented by the CWHR classification system." (DEIR page 217) We agree. Nevertheless, the CWHR system is one of the late successional surrogates used by the DEIR. According to DEIR page 218:

Table 32 on DEIR page 216 indicates that Jackson has the following acreage in redwood forest type CWHR categories:

5M = 5,989 acres

5D = 627

6. = 9,444

TOTAL = 16,060 acres

As the DEIR says, this figure represents "the maximum availability of late successional forest habitat on JDSF." Even if one or more late successional characteristics are absent from these stands, they are nevertheless going to represent the closest to late successional forest structure available at JDSF. With the exception of the 459 acres of old growth (DEIR page 218), the location of these stands as categorized by the CWHR system, are not mapped in either the FMP or the DEIR. This is a significant omission. Without this information we cannot tell how much of this important habitat will be retained and how much will be logged over the life of the FMP. Based on the analysis to follow, it appears that most of this acreage is designated for logging.

There is a mind-numbing explanation in Appendix 8A 2-6 of the relationship between the CWHR system and the JDSF Vegetation Classification System. This is important to understand because the vegetation maps in the FMP and DEIR are both derived from the JDSF Vegetation System. The first time I attempted to understand this "crosswalk" between the two systems, I concluded I must have misunderstood something because it seemed so unwise to take a well-known system like CWHR and convert CWHR Size Class 5, with trees greater than 24" diameter at breast height (dbh) and call it Size Class 6 in the relatively obscure JDSF system. Doing such a thing would be an open invitation to absolute confusion. I asked a Registered Professional Forester to review the crosswalk and assist me with understanding it. He characterized the crosswalk as confusing.

Another review on my part has led me to conclude that the JDSF Vegetation Type does, indeed, take CWHR size class 4 (18-24" dbh) and call it JDSF Size Class 5; WHR Size 5 (over 24"dbh) and call it JDSF size 6; and does not crosswalk with CWHR Size 6. Perhaps in some belated effort at clarity, the FMP and DEIR maps abandon the numerical JDSF categories (ie size 5) and express vegetation as either "less than 18 inch dbh" or "greater than 18 inch dbh." Considering the FMP and DEIR indicate that JDSF is planning on retaining old growth trees defined as 48" dbh and greater, using 18" trees as the largest vegetation size mapped provides only the most minimal information about the forest stands that the public has consistently expressed the most concern about--the oldest, largest trees. Information in my library suggests that an 18" tree on Site II (the majority of JDSF) would be around 45 years of age. Additionally, DEIR page 216 clearly indicates that JDSF knows where its CWHR size 6 (greater than 24" dbh) is located, because they have told us they have 9,444 acres of it. Why the DEIR does not provide a map that would inform the public where larger, older trees are will remain in the realm of speculation. Nevertheless, the absence of this information is a significant omission of the DEIR that makes it very difficult for the public to assess how much of the oldest, largest second growth forest stands will be protected and how much will be logged.

Nevertheless, the public has made the attempt to figure this out. We have done this by consulting DEIR Figure F, the Vegetation Management Class Map, and comparing it with Figure H, the Special Concern Areas Map. Using the tried and true, if old-fashioned, tracing method, we have transferred the outlines of the Late Succession Management Areas associated with the old growth groves and the Woodland Special Treatment Area (WSTA) (from Map H) onto the Vegetation Map (Map F). Other than the Watercourse and Lake Protection Zones (WLPZs), these are the only blocks of Jackson that are designated specifically for late successional forest development.

As noted above, the Vegetation Management Class Map F categorizes conifer timber as either "less than 18" dbh" (< 18") or "greater than 18" dbh" (> 18"), and further indicates by shading of color, whether these stands are Dense (D), Medium (M) or Sparse (S). For the sake of the analysis, we have assumed that "greater than 18" Dense" would include the oldest, largest second-growth trees at Jackson in the stands that have been logged least recently. We have also assumed that "greater than 18" Medium" would include stands of older, larger trees, that may have been entered for logging in the past 80 years-110 years. We acknowledge that both of these mapped categories may include younger stands, but believe there are no other mapped categories that are likely to include the oldest, largest second growth.

Comparing the information from Map F, the Vegetation Map, with Map H, the Special Concern Areas Map, in this way indicates that, with the exception of the old growth itself (459 acres), the overwhelming majority of the "greater than 18" Dense" stands are not designated as Late Successional development. Further, the largest Late Successional Development Area, part of the Woodlands Special Treatment Area, has only a very few acres of "greater than 18" Dense" timber, although it does contain quite a bit of the "greater than 18" Medium" timber. Left outside the Late Successional Development Areas are the largest blocks of "greater than 18" Dense" timber, which are located in approximate order of size at: South Fork Hare Creek, South Caspar Creek, Camp One Complex, West of Road 500 near South Fork Hare Creek, headwaters of Russian Gulch, and north and south of, but not included in the Camp 20 old growth grove. Not a single one of the large blocks of "greater than 18" Dense" has been included in a Late Successional Development Area.

At significant expense, we are providing a map for the record that uses your data but compiles the information into a single map to demonstrate our analysis. We appreciate that you allowed us access in a timely fashion to the public data from which the DEIR maps were created, so we could illustrate our analysis. (Exhibit G)

According to DEIR page 179:

We find it unlikely that developing "structural characteristics similar to old-growth trees" will happen in "as short a time frame as possible" unless one starts with the oldest second growth available. The FMP does not propose to do so and the DEIR has failed to identify this failure as a significant adverse impact.

The Thornburgh Analysis

Appendix 8A, pages 26-39 is entitled "Evaluation of Late Successional Forest Development for Alternatives B, C, D and E as Presented in the DEIR for the JDSF Forest Management Plan" by Dale A. Thornburgh, PhD. Dr. Thornburgh is a well-respected forestry professor at Humboldt State University.

Having looked at this over and over I am only now beginning to have a glimmer of understanding about what the Thornburgh Analysis may be about. It is very confusing because of the context in which it is presented in the main body of the DEIR at Page 178-181 where the segment of the Analysis pertaining to the FMP is also reproduced. In the main body of the DEIR, this is a section that purports to identify impacts. The top of page 178 says, "Impact: Old Growth Forest (Less than Significant and Beneficial)." The next category beginning at the bottom of the same page says, "Impact: Protection of Late Seral/Successional Forest Characteristics (Less than Significant and Beneficial)." That paragraph begins with a review of information about preservation of the Old Growth Groves, the Late Seral Management Areas, and the Woodlands STA, as well as the WLPZs that are to be managed as late successional development. All of these have been the featured core of the supposed late successional development on JDSF throughout the DEIR.

The next paragraph begins: "JDSF intends to recruit trees with late successional characteristics in areas that enhance the ecological effects of forests with these structural characteristics….The JDSF Management Plan makes a commitment to manage identified forest areas to achieve that goal in as short a time frame as possible." It has taken me many, many readings to begin to realize that the discussion in this paragraph has shifted and the DEIR is apparently now talking about areas other than the special Late Seral Development Areas. The "identified forest areas" of this paragraph are apparently not the same areas as those identified in the previous paragraphs.

Then the Thornburgh Analysis is introduced saying: "The following discussion is based on the conceptual changes that will occur following the selective harvest of an even-aged timber stand as found on JDSF." Because this section is introduced so poorly, I had been assuming this hypothetical stand was meant to be in the Late Seral Development Areas. I now can see that it is at least possible that this analysis is meant to pertain to stands within the uneven-aged management component of the timber program.

This interpretation does seem to fit in with the introductory Note in Appendix 8A. This note, that appears not to have been written by Dr. Thornburgh, says:

If all of this put together is meant to tell us that JDSF plans to manage its uneven-aged management areas in the timber program to become late successional forest stands, that is a goal that we could support. This is an extremely obscure way of announcing this, if it is true. We do note that it would seem to be very unlikely that the Small Group Selection component of the forest’s uneven-aged management program would be likely to achieve late successional status because the openings are so large.

We are skeptical, however, that the FMP does intend to develop the uneven-aged management areas as late successional stands. In an attempt to understand the Thornburgh Analysis, a consulting forester who reviewed the documents asked JDSF personnel whether that was the intent, and he understood them to reply that it was not. So I continue to wonder exactly what the point is of Dr. Thornburgh’s analysis. The DEIR is very confusing in this matter.

A crucial paragraph that would lead the reader to hope that indeed the uneven-aged management compartments (although certainly not the group selection areas) will be managed to achieve late successional status is located at FMP page 47. It says:

An initial impression from reading the only reference in the DEIR on this subject (based on an Adobe search of the term "uneven-aged management") seems to indicate that all uneven-aged management will lead to late successional status. According to DEIR page 203:

A more careful read discloses that there is a distinction between full late successional status, and the development of "characteristics" typical of late successional forest. It appears that the uneven-aged management areas will have some "characteristics" of this older forest type, not necessarily the full range of these characteristics in each stand that would allow them to truly be identified as late successional stands. This is a significant distinction that the DEIR makes no attempt to clarify.

The task that Dr. Thornburgh has been given—to demonstrate that certain sorts of uneven-aged management can lead toward late successional forest characteristics is relevant only to stands that are actually managed in the way Dr. Thornburgh describes. This is painfully clear from the conclusions he reached in relation to the Late Seral Emphasis Alternative E, which used an uneven-aged management scenario that did not achieve a significant level of late successional characteristics. There is no information in the FMP or DEIR regarding actual silviculture treatments proposed, so there is no level of assurance that late successional characteristics will develop, not to mention actual late successional stands.

It is also unclear why in the analysis of each alternative, the initial stand type chosen was a "40-60 year old 2^nd growth stand…even aged stand with a mixture of redwood, Douglas fir and other more tolerant conifers." [sic: presumably, shade tolerant] As noted above, according to manager Marc Jameson, JDSF has 10-12,000 acres of 80-110 year old second growth. What was the point of starting Dr. Thornburgh’s analysis of how to develop late successional characteristics with trees as much as 70 years younger than the oldest available? This was not explained in the DEIR and is a significant omission.

Perhaps the stands that are to be managed under uneven-aged management and will achieve late successional characteristics mostly consist of 40-60 year old stands? If this is true, using these younger stands to mitigate for logging the much older 80-110 year old second growth would not be appropriate, because as the Thornburgh analysis demonstrates, it’s going to be a very long time indeed, almost 100 years, until the 40-60 year old stands, even under optimal management, begin to develop late successional characteristics.

Before leaving Dr. Thornburgh’s analysis we have to point out something that raises an issue of good faith. In the analysis for Alternative C, the preferred alternative, ie the FMP, the analysis determined that after 100 years: "The development of late successional forest conditions will be progressing towards the optimum conditions that are found in late successional forests." In this alternative, the silvicultural system used starts: "[O]n a irregular [sic] basis each stand will be entered every 25 years to harvest 50% of the growth since the last entry." When we turn to the analysis of Alternative E, the Late Seral Emphasis alternative, the silvicultural system begins: "Uniform selection cut: 1/3 of the trees, 60-70 trees, are removed uniformly through the stand, leaving the remaining trees equally spaced." The resulting stand after a 100 years is indicated to be: "In general the development of late seral structural characteristics will be very slow in this 100 year time period following the crown closure at age 10-15 years following the initial uniform selection cuts."

In other words, the analysis for the Late Seral Emphasis Alternative was set up so that it performed less well at late seral development than did the preferred alternative C, the FMP. Isn’t it a bit much to set up the scenario in such a way as to assure the Late Seral Emphasis alternative fails at its primary purpose? Lest there be confusion, we presume that Dr. Thornburgh was presented with the silvicultural systems that were supposed to be plugged into the analysis and proceeded from there. We have no reason to believe that he would set out to create a failing sequence. While we recognize that CDF does not like the idea of the Late Seral Emphasis alternative, doesn’t this amount to an exercise in nose thumbing at the proponents of the Late Seral Emphasis that someone at CDF or NRM (the DEIR contractor) should have recognized as inappropriate? For the record, I make these remarks as someone who has been trying to find a middle ground between the FMP as proposed and the Late Seral Emphasis alternative. I am not its proponent.

The Thornburgh analysis was very helpful in some respects. It clearly demonstrates that whether or not one develops late successional forest or some of its characteristics is not a function simply of uneven-aged management, but rather depends on the specifics of how one applies that management and to the initial stand characteristics. In the course of the DEIR review we asked consulting forester Roger Sternberg to review the FMP and DEIR. Among his recommendations are that the FMP and DEIR should include information about both current stand characteristics and proposed management activities that would allow the public to better understand what Jackson will actually look like over time. He points out that this sort of information is required by the CA Forest Practice Rules for approval of a Non-Industrial Timber Management Plan (NTMP FPR Section 1090.5) [Exhibit H]. Without more specific information of this sort, it is impossible for the public to determine when and where stands at Jackson will develop late successional characteristics.

My review of the Thornburgh analysis, which I happened to have read first, has led me to approach cautiously the preceding segment of Appendix 8A, pages 19-25, entitled "Some Comments on the Effects of Silvicultural Options on Forest Structure" by James L. Lindquist, another eminent expert, discussing several forest structure development demonstrations. The message I take home from these remarks is that there is a wrong way to do just about anything. That certain uneven-aged management demonstrations have resulted in poor stand volume increases does not invalidate uneven-aged management. It has been and is still being used successfully by many non-industrial timber managers. On industrial lands, Big Creek Lumber, the largest private timberland owner south of San Francisco, manages their land that way. And one of the largest industrial owners in the area, Mendocino Redwood Company, is now managing the ownership it purchased a few years ago from Louisiana Pacific increasingly through the use of uneven-aged management. It may take a little more care, but it is a feasible way to manage timberlands for sustained production of timber.

• The DEIR should provide the information indicated in the text to enable the public to adequately assess current conditions, proposed management activities, and future outcomes.

• JDSF should review forest stand information and designate all the 80-110 year-old unentered second-growth as late successional development areas. These areas should be mapped prior to approval of the FMP.

• JDSF should review forest stand information and designate more recently managed 80-110 year old, and other appropriate forest stands as buffers and connectors for the unentered second-growth late successional development areas.

• JDSF should review managed stands to determine which are developing in a direction that appears to be leading toward late successional characteristics over time. Stand management records should be consulted to determine the management activities that led to that development. A report should be written with the findings.

• JDSF should manage a significant part of its timber program across the forest to become late successional stands over time.

• JDSF should eliminate even-aged management and other timber management techniques that preclude management for late successional characteristics over time.

• As a demonstration, develop a vegetation classification system that more closely represents the full range of forest stand types in the redwood region than do currently available systems. Use peer review to validate.

The FMP relies to a very great extent on developing late successional forest in the Watercourse and Lake Protection Zones (WLPZs). With the exception of the ~2500 acre Woodlands Special Treatment Area (which itself has a 270 acre patch in the middle that is slated for logging) and the few much smaller Old-Growth Groves and Late Seral Management Areas totaling 1239 acres spread across seven locations, all the other areas designated for late successional development are thin ribbons of riparian habitat along streams that appear to total 5930 acres spread across the ~50,000 acre forest. The overwhelming proportion of acreage dedicated to late successional forest development will occur in the Class I and II WLPZs. We completely agree that developing this type of forest stand within the WLPZs is appropriate. However, we do not believe the FMP or the DEIR have adequately identified the limitations in how narrow bands rather than large blocks of this habitat are likely to function for species that are dependent on older forests for important life functions.

The importance of forest patch size and the problem of edge effect are well-known issues that are mentioned in the DEIR on page 224, but not in relation to how WLPZs will function:

The California Department of Fish and Game (CDFG) also commented on this problem and suggested that you not count WLPZs adjacent to even-aged management blocks as acres of late successional forest. The DEIR does not address their concern. Later we will suggest much wider WLPZs, to partially mitigate this potential impact.

Throughout, the FMP and DEIR appear to count Class I WLPZ as 150 feet, and Class II as 100 feet when calculating how much late successional forest they will provide. This is in spite of the fact that the Class II zone is a variable zone that can be 50 feet or 100 feet, or presumably something in between. No clear standards are articulated about when the Class II zone is larger or smaller. DEIR page 107 says there are 186 miles of Class II streams on Jackson, so this lack of clarity represents a significant discrepancy that the DEIR has failed to identify or resolve.

Considering how important this late successional issue has been to the public and how much ink is used regarding it in the DEIR, we find it perplexing that there are significantly different acreage figures provided for it in the DEIR:

Arithmetic, mine not the DEIR’s, yields: Total non-WLPZ LSS acres = 3750 acres. This is not very much for the entire 50,000 acre forest!

Using the FMP’s late successional figure of 9,680 acres total and subtracting the 3,750 acres of non-WLPZ late successional yields a total of 5,930 acres of WLPZ that is being counted as late successional.

Of course if you use the DEIR’s 11,190 figure and subtract the 3,750 acres of non-WLPZ late successional, you come up with 7,440 acres of WLPZ.

Unfortunately adding to the confusion, DEIR page 109 says there are 7,753 acres of WLPZ. This page specifically notes that this calculation is based on a 150 foot Class I WLPZ and a 100 foot Class II WLPZ.

These are pretty substantial discrepancies that have not been identified by the DEIR. In fact, it is the DEIR that has provided these confusing figures. I make the assumption that the FMP acreage figures for the non-WLPZ late successional management areas are highly likely to be correct, given the relatively discrete area the numbers describe.

Finally, how much of the WLPZ currently meets any of the various surrogates or definitions for late successional forest? We are told quite a bit of the WLPZs have a high level of "shade value." This is illustrated in DEIR Map E. But an examination of the map I have provided [Exhibit G] that overlays DEIR Map H (Special Concern Areas, including the WLPZs) onto DEIR Map F (the vegetation map) indicates that large stretches of stream reaches in most, if not all, watersheds do not show as the "greater than 18 inch Dense" type of vegetation. Thus the WLPZ as late successional forest is largely speculative and somewhere in the future. It does not seem particularly fair to count it as currently available habitat. None of these matters were brought to our attention by the DEIR.

• The DEIR should clarify all information as noted in the text and provide the information requested.

• JDSF should not count WLPZs as late successional forest development areas unless the stream buffers are substantial enough to avoid edge effect within a significant proportion of the WLPZ.

• WLPZs should not be used as a substitute for maintaining and creating large blocks of late successional forest in all parts of JDSF.

In the six years during which I have been actively engaged in issues relating to Jackson Forest, it has often been difficult to discern much response on the part of the Department to the concerns expressed by the public. The most obvious exception has been in relation to Jackson’s old growth. We are very happy to see the FMP clearly delineates the major old growth groves, prohibits logging in them, and provides a late successional management area around three aggregations of them. Provisions are made for aggregations of scattered old growth residuals. Additionally, the FMP indicates that under most circumstances individual old growth trees will not be felled. These are all very important steps that will certainly help address one of the more persistent and emotional sources of conflict regarding JDSF management.

However, old growth trees are unique and irreplaceable, even when smaller than average, or isolated. The removal of any such irreplaceable resource would be a significant adverse effect of the FMP that has not been identified by the FMP and for which no mitigation is proposed.

• Retention standards: A review of presumed old growth trees should be undertaken to determine whether the 48" dbh default standard is appropriate, particularly for Douglas fir old growth, and particularly on the east side, in the higher elevations, or on poorer soil sites on the forest. The point should be to determine a standard that is the most inclusive practicable, even if it is necessary to distinguish standards among species or sites. The 48" standard may be too high in some common circumstances.

• Aggregations: If taken literally, the aggregation policy would exclude the aggregation of scattered residual old growth because the standard requires "an obvious, intact, undisturbed remnant of the original stand…." By far and away the most common occurrence of scattered old growth for potential aggregation is among residual trees that were left after a stand was logged. These would not be either "intact" or "undisturbed." For instance there are many scattered residual old growth trees along West Chamberlain Creek, but the stand has obviously been logged in its history. Besides changing the language of the aggregation policy, I strongly suggest that specifically you designate the West Chamberlain area as an old growth aggregation. There are, no doubt, many other areas of scattered residuals that should be aggregated as well. These should be designated as soon as possible, and mapped.

• Old Growth Groves: We are pleased to see these groves designated, but have also noticed that in several instances there is vegetation mapped adjacent or very nearby to either the groves themselves or the designated Late Seral Management Areas that would seem to be reasonable candidates for inclusion in an LS Management Area because they are "greater than 18" Dense" stands. Specifically these include: Stands north and south of the Camp 20 Old Growth Grove; stands to the east of the Lower James Creek Grove; older fir south of the Chamberlain Creek Complex and dense habitat to the north and north east; and dense stands both south and southwest of the North Fork of South Fork Noyo Complex. While some of these lines may have been drawn at watershed breaks, it could be a plus to extend the protection across the watershed into the adjacent drainage when the available habitat is dense there.

• Single Old Growth Trees: They aren’t making any more of them, at least not in our lifetimes. They are irreplaceable, non-renewable resources. Roads can be realigned, yarding corridors can be reconfigured. Except for imminent threat to human life that cannot be mitigated, every single old growth tree should be retained.

One of the positive aspects of reviewing the FMP and DEIR has been the opportunity to acquaint myself with the most recent information regarding marbled murrelets in this region. Having spent more than 10 years trying to get Headwaters Forest in Humboldt County protected so that the murrelets there would not be eliminated, I have a particular interest in making sure that our efforts there are not undermined by actions, or failures to act, elsewhere. Marbled murrelets are listed as endangered under the California Endangered Species Act (CESA), and as threatened under the federal Endangered Species Act (ESA). The marbled murrelets known to be nesting on state parkland adjacent to Jackson must be protected from any potential impairment of their breeding success. The DEIR seems to cast doubt on the presence of these marbled murrelets and on murrelets in general in Mendocino County. Nevertheless, a simple phone call to Russian Gulch State Park confirms that protocol surveys have detected nesting behavior in Russian Gulch for at least the past four years. (Personal communication with State Parks biologist Renee Pasquinelli). The DEIR also failed to mention the well-known presence of nesting marbled murrelets in Alder Creek near Pt. Arena on lands owned by the Mendocino Redwood Company.

We asked noted marbled murrelet expert S. Kim Nelson to review the JDSF FMP and DEIR in relation to murrelets and she has submitted her comments directly to the Department. Based on her recommendations and on our knowledge of Jackson from review of maps, Landsat imagery, and personal familiarity with the forest, Sierra Club make the following recommendations:

First, a very large no-logging buffer must be established in the contiguous and nearby forest stands in Jackson to protect these endangered nesting birds in Russian Gulch. The DEIR Map F, when watercourses from Map H are traced onto it (see Exhibit G) indicates blocks of the largest tree size class and most dense habitat mapped along both branches of Russian Gulch where they extend into Jackson, directly upstream from the known murrelets. These forest stands, currently slated for logging, must be completely protected. Failure to do so would be a significant adverse impact on a species listed by both the state and federal government.

Second, in the older second growth forest beyond the no-logging buffer, new marbled murrelet habitat should be developed. To accomplish this, marbled murrelet experts should identify significant, well placed high quality habitat and implement controlled experiments to determine how best to create suitable nesting habitat for murrelets over time. Although the relatively nearby Woodlands Special Treatment Area is designated for late successional forest development, it should not automatically be assumed that this is the best location to develop murrelet habitat. The high use road, the Helms experimental plot that fragments this area, and the Woodlands group camps used throughout the year by thousands of people, may not be the best location for developing murrelet nesting habitat. Murrelet experts should determine whether it is suitable.

Regardless of whether the Woodlands STA is suitable for murrelet habitat, we do support its designation as a late successional forest development area.

Murrelet experts should be consulted to determine locations on the west side of the forest where development of murrelet nesting habitat should be demonstrated.

Specifically, the following areas should be designated as buffer or for consideration as areas for habitat development and demonstrations:

• the entire Russian Gulch watershed, including previously logged lands
• all areas of mature second growth forest south and west of the Woodlands Special Treatment Area
• the mature second growth forest roughly west of Road 408 and south of Road 630
• The mature second growth forest in the Jug Handle Creek watershed
• At the west end of the forest, the mature second growth remaining on either side of Road 500
• The south fork of Hare Creek and the older stands on the mainstem of Hare Creek
• Pygmy forest and other habitat unsuited to murrelets within these areas should be managed to avoid impeding murrelet habitat recovery
• To avoid edge effect, the Railroad Gulch experimental area (Helms Plot) slated for logging within the 2500 acres you have already proposed as a Late Seral Development Area should not be logged except as advisable to accelerate late succession characteristics.
• Any project undertaken in the Woodlands STA should be done with the written agreement of the Mendocino Woodlands.

We believe these actions are necessary for the following reasons:

The marbled murrelet (Brachyramphus marmoratus) is a small diving seabird that nests on the limbs of old-growth trees within, in California, approximately 25 miles of the sea. In early 1992, it was listed as endangered by the California Fish and Game Commission pursuant to the California Endangered Species Act (CESA). In late 1992 it was listed as threatened by the U.S. Fish and Wildlife Service in pursuant to the federal Endangered Species Act (ESA). Federal Critical Habitat was designated in 1996. The final federal Recovery Plan was published in 1997. Under the federal listing, Jackson Demonstration State Forest is designated as critical habitat for the marbled murrelet. Litigation was instrumental in achieving the state and federal listing.

According to the federal Recovery Plan: "The weight of evidence indicates that the major factors in marbled murrelet decline from historical levels in the early 1800s (or earlier) are (1) loss of nesting habitat and (2) poor reproductive success in the habitat that does remain, a phenomenon that appears due in large part to increased vulnerability of nests to predators in highly fragmented landscapes." (page 10)

According to State Parks biologist Renee Pasquinelli, marbled murrelets have been detected in Russian Gulch State Park, adjacent to Jackson, for at least the last four years. Surveys have been conducted to protocol every year during that time and have detected breeding behavior up the Russian Gulch drainage. The headwaters are located on Jackson in an area designated for commercial timber harvest under the draft Plan.

The DEIR made no mention of the information in and recommendations of the federal Recovery Plan for marbled murrelets. It should have. According to the Recovery Plan:

The federal Recovery Plan is the best available scientific information about the status of marbled murrelets. The information in the Recovery Plan indicates that it is reasonable to believe the very existence of marbled murrelets in the region, and perhaps beyond, may depend on actions taken at Jackson. Murrelets’ status as endangered under the California ESA makes it incumbent on Jackson to implement the federal recovery plan strategy. Under CESA, state agencies have a duty to help recover endangered species as per Fish and Game Code sections 2053, 2055, and 2061:

The federal Recovery Plan is the best available science regarding how best to conserve marbled murrelets. Its recommendations must be applied at Jackson.

Because the region’s forestland is overwhelmingly held as private property, Jackson Demonstration State Forest is the only opportunity available in the region where it would be possible to develop marbled murrelet habitat on a large scale. This should be done. Finally, research on how best to accomplish this is needed and doing so is completely within Jackson’s "demonstration" mission. The FMP as proposed fails to make a substantial contribution to recovery of marbled murrelets and this is a significant adverse effect of the plan that the DEIR has not identified and for which no mitigation is currently proposed by the Department. The FMP as proposed also violates CESA. We have herein proposed mitigation and ask that you incorporate that mitigation into the Forest Management Plan.

A disappointing aspect of Jackson’s Management Plan is the statement of Riparian Management prescriptions. The prescriptions are only somewhat more protective than the Forest Practice Rules required for approval of a Timber Harvest Plan (THP) in California. These prescriptions do not constitute a riparian management strategy. They are not nearly as comprehensive as the federal standards for riparian management adopted as the Standards and Guidelines for Management of Habitat for Late Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl (Standards and Guidelines) adopted more than eight years ago, after rigorous scientific review, for federal forests in the same ecosystem as Jackson. The Forest Ecosystem Management Assessment Team (FEMAT) Report detailing the science supporting adoption of the Standards and Guidelines, states there are 199 species of plants and animals associated with late-successional and old growth riparian areas in this region, including 38 species of birds, 18 species of mammals, and 11 species of bats. Among the objectives of the federal Aquatic Conservation Strategy is to: "Maintain and restore habitat to support well-distributed populations of native plant, invertebrate, and vertebrate riparian-dependent species." A similar goal, with a similar strategy, should be established for Jackson. The FMP fails to adopt such a goal and strategy. That failure constitutes a significant adverse effect on the environment that is not fully identified by the DEIR and for which incomplete mitigation is offered in the DEIR.

According to Standards and Guidelines:

For comparison with the draft Jackson Plan described later, the following is excerpted from the federal Standards and Guidelines for Riparian Reserves. The system is based on the concept of "site-potential tree height." "A site potential tree height is the average maximum height of the tallest dominant trees (200 years or older) for a given site class"

Although the major features have been reproduced above, please refer to Standards and Guidelines for additional details of the federal Riparian Management Strategy.

Although riparian management is sometimes mistakenly considered to be limited in importance to fish and aquatic organisms, the State of California has correctly recognized the importance of riparian areas for avian species. The Riparian Bird Conservation Plan is a collaborative effort of the Riparian Habitat Joint Venture (Joint Venture) made up of numerous federal and California state agencies and non-profits including the CA Department of Fish and Game, the US Fish and Wildlife Service, Point Reyes Bird Observatory, and Audubon Society. According to the Joint Venture’s August 2000 Conservation Plan, "due to their biological wealth and severe degradation, riparian areas are the most critical habitat for conservation of Neotropical migrants and resident birds in the West…. The loss of riparian habitats may be the most important cause of population decline among landbird species in western North America." The Jackson DEIR notes that "133 species of neotropical birds have the potential to occur on JDSF." The DEIR does not appear to provide information regarding how many species are known to currently use JDSF.

The DEIR does correctly point out that forest patch size, habitat fragmentation, and resulting predation are major concerns in nesting success for Neotropical bird species. The following was excerpted previously but is reproduced here for convenience.

Yet, with the exception of the 2500 acre Woodlands Special Treatment Area (which itself has a 270 acre patch in the middle that is slated for logging) and the few much smaller Old-Growth Groves and Development Areas totaling 1239 acres spread across seven locations, all the other areas designated for Late Succession Development are thin ribbons of riparian habitat along streams that appear to total 5930 acres spread across the ~50,000 acre forest. It is highly likely that much of these narrow riparian corridors will not provide adequate habitat for many riparian dependent species.

On Class I (fish-bearing) streams, the FMP-proposed Watercourse and Lake Protection Zone (WLPZ) is 150 feet wide divided into an Inner and Outer Band. These slender ribbons of habitat consist of a 25 foot Inner Band where logging is excluded except for "cable corridors where needed" and except "to improve salmonid habitat through use of selection or commercial thinning silvicultural methods." Straddling the bands, within 50 feet of the stream channel (i.e. including the 25 foot Inner Band), the largest 10 trees per 330 linear feet of stream (the Plan is unclear whether this is 10 trees per 330 feet on each side or both sides of stream) are to be kept. Adjacent to the 25 foot Inner Band, an additional 125 feet of WLPZ Outer Band allows significant logging within certain parameters: At least 70 percent overstory canopy must be maintained, 240 square feet of conifer basal area must be maintained, and re-entry is limited to every 20 years. Clarification is required regarding whether the 240 square foot basal area retention is to be measured across the entire 150 foot WLPZ or only in the outer 125 feet. The later would be preferable because otherwise it is impossible to determine what sort of forest structure might develop in the Outer Band. These are standards that have been developed from the perspective of fish rather than birds or mammals, but they are also not adequate for anadromous salmonids. Even a 150 foot no-cut zone adjacent to a logged stand will lose a very significant proportion of function to edge-effect. With a mere 25 foot no-cut zone as proposed by the plan, it is unlikely the habitat will be able to adequately function as secure nesting habitat for many riparian-dependent avian species. In addition to the problem with edge-effect, regular re-entries for logging, even limited to every 20 years, will be likely to damage the development of the complex riparian understory that provides important habitat for many species.

The DEIR, page 119 proposes mitigation if a Class I stream is deficient in large woody debris. This mitigation is to have either a 100 or a 150 foot no logging zone (no explanation of how to determine size of this zone) next to Class I streams that are deficient in wood. This is an improvement over the FMP. However, it is not comparable to the Standards and Guidelines and does not include Class II and Class III streams. Thus this mitigation for aquatic resources is not sufficient to mitigate the FMPs significant adverse effects on riparian dependent avian species, salmonids, and other wildlife dependent on complex late successional forest habitat.

• Regarding riparian-related avian issues, we recommend that the FMP help implement the goals developed by the Joint Venture’s Riparian Bird Conservation Plan.

• In general, the FMP should use the federal Standards and Guidelines Aquatic Conservation Strategy as the default riparian management regime. Note that while the initial prescriptions include no timber management, after completion of a watershed analysis, modifications such as management for stand development are allowed.

Planning for timber management is the central core of the FMP and has clearly been given careful consideration. The broad outlines of the timber management plan are well presented and clear. It is the strongest part of the FMP. While we admire the conceptualization and presentation, unfortunately we have a basic disagreement with CDF about the focus of the timber program.

Because Jackson is the only public forest in the region, it must function in many roles. We believe this could be done under the current legislative mandate if it was interpreted broadly. More of the forest should be off limits to commercial timber operations. This would not preclude stand management in some of these areas for late seral development or other demonstration purposes, but the timber inventory and the volume produced in the course of operations should be accounted for separate from the sustained yield calculations of the commercial timber production program.

The commercial timber production program should focus on becoming a showcase for producing a sustainable volume of timber in a way that does not offend the public. When Jackson was created, there was a serious question whether logging second-growth forest could be profitable. We know the answer, and have known it for some time.

Jackson is not industrial timberland. But most of the managers of the forest and most of the CDF management in Sacramento come from timber industry backgrounds. It is against that experience that decisions are being made about what is good management at Jackson. We have high regard for a number of these people. But we are not sure whether key decision-makers are fully up to date about how progressive non-industrial timber managers are implementing sustained yield and uneven-aged management.

Everyone knows about Masonite’s high-grading in the name of selection logging. Everyone has a story about un-evenaged management that has resulted in the take-over of shade tolerant non-commercial species. But have you been to Peter Parker’s property, managed under a Non-industrial Timber Management Plan? Have you looked at lands managed by RPFs Jim Grieg or Craig Blencoe? They are the ones demonstrating sustained yield logging without creating offensive conditions on the ground. The question is not whether Jackson can do better than LP or G-P. Of course you can, and you have been doing better. The question is, rather, can Jackson achieve sustained timber production using techniques that leave the landscape sufficiently like a natural forest that the public is comfortable with the management program?

• End Clearcutting

We applaud the Department’s recognition that certain modifications to silvicultural practices, like retaining legacy features, can provide important habitat at little cost to the landowner. Your adoption of standards for snag and down wood retention across the landscape is an important step in that regard. We concur with the comments included in the DEIR Appendix from the California Department of Fish and Game (CDFG) that called on Jackson to augment its goals for snags and large woody debris on the forest floor. The DEIR recommended mitigation to keep all existing snags is a good start, but does not fully address the concerns voiced by CDFG. Snags are a vital resource for many species.

The FMP’s decision to modify clearcutting by the use of variable retention of legacy components is a step in the direction that biologists and the public have long advocated. However, from the habitat protection perspective, a much better step would be to eliminate clearcutting altogether. While it is true that clearcutting creates habitat for some species, that habitat is already abundant in the region, whereas the species that prefer a more complex forested habitat are declining or already imperiled. Clearcutting, even with the addition of variable retention of legacy features, does not mimic any natural forest condition in this region. Therefore, forest-dependent species are not well adapted to the large openings created by clearcutting. Additionally, the use of herbicides that generally accompanies clearcutting, is well-known to be harmful to many species of fish, birds, and wildlife, not to mention the human population. Herbicides also harm many smaller forms of life (for instance, insects) that are part of the food chain for higher species. Jackson already has huge tracts of previously clear-cut land where research can proceed. And even if all of the above were not correct, the simple fact remains: The public hates clearcutting and Jackson is a public forest. We strongly urge you to eliminate clearcutting of any sort from the timber harvest program at Jackson.

• Invasive Plant Infestations Happen for a Reason

Jackson has a very significant invasive plant problem that is incompletely described in the DEIR. Pampas grass and other similar pest plant invasions are directly proportional to the amount of forest canopy that is removed from a stand in a single operation. The DEIR fails to disclose this. Certain kinds of even-aged management, particularly clearcuts (by any name), as well as Group Selection with openings of 2 ½ acres to 5 acres are highly likely to precipitate additional infestations of invasive plant species, including pampas grass. It is hard to go anywhere on the forest where there is a significant opening and not find pampas grass. With the increased emphasis in the FMP on Group Selection as an uneven-aged management technique, the DEIR provides no information about how you plan to avoid additional infestations. The DEIR claims that the general approach to potential adverse impacts is to avoid them rather than to mitigate them. But there is no explanation regarding how to avoid invasive plant infestations when the FMP proposes to deliberately create openings across the landscape. Lest one try to claim that the openings allowed under the Group Selection system are not large enough to trigger the problem, I suggest you visit any of the many landings that were used for previous operations, most of which are 2 ½ acres or less. You will find plenty of pampas grass there. The DEIR fails to disclose this significant adverse impact from certain types of logging operations or propose feasible mitigations.

• Herbicide Use Should be Avoided

The perceived need for herbicide use is directly proportional to the extent of invasive plant infestations and native brush growth that occurs after too much of the forest canopy is removed in a single operation. The DEIR fails to disclose the connection between choice of management techniques and herbicide use. Herbicide use should be eliminated by avoiding timber operations that result in invasive plant problems. Existing invasive infestations should be controlled using non-chemical means to the greatest extent feasible.

The DEIR hints at the intensity of opposition to herbicides locally. Herbicide use has been among the most hotly contested features of management at JDSF. The mid-1990s plan to spray 70 miles of forest roads with herbicides was instrumental in galvanizing opposition to JDSF management.

In spite of that, the DEIR has not provided information about the location and extent of invasive plant infestations or the location and extent of likely use of herbicides even though herbicide use was identified as one of the three "most important" "areas of controversy" on DEIR page 6. This is a significant omission of information.

• Slash

Slash piles should be reduced across the forest and innovative methods of accomplishing this should be demonstrated. Jackson has a huge slash problem that the DEIR does not adequately identify. This is an adverse impact of timber operations from the point of view of fire danger, aesthetics, and recreation. Piles of logging debris 12 feet high and 20 feet long are not uncommon. The DEIR incorrectly assumes that slash piles are only a problem near main forest roads. The DEIR falls into the same mistake as the JDSF managers do when they assume that small campground and road buffers are adequate to avoid impacts. The public wants to hike or bike throughout the forest without being confronted with huge piles of debris, limbs, and other slash mixed with great quantities of dirt. These piles are noticeable features in the landscape for ten or more years. While it may not be feasible to reduce slash retroactively except in the most high profile locations, contracts for the future should specify how slash will be disposed. Failure to do so is a significant adverse impact to fire prevention and aesthetics that could easily be mitigated, but which has not been identified by the DEIR.

Some non-industrial timberland managers pack slash on skid roads to avoid run-off and prevent vehicular traffic. I personally remember when LP made its final cut along what became the Navarro River Redwoods State Park along Highway 128. They specified slash abatement that was far in excess of standard industry practice. The loggers complained, but the result is a strip of forest that does not shriek "logging" as one walks or drives through. Even if it is an extra expense, measures of this sort are appropriate in a publicly owned multi-use forest. "Humoring" the public about matters like this would be a feasible, small step toward repairing Jackson’s strained relations with the public.

• Salvage and LWD Recruitment

The DEIR has failed to explain and integrate the many strands of apparently contradictory information within the DEIR about salvage operations and terrestrial large woody debris recruitment. On one hand DEIR pages 163-4 clearly indicate that salvage operations are permitted under specific constraints.

But on page 180, Large Woody Debris (LWD) is identified as one of the "important attributes" of late successional forests. And Page 219 indicates that:

Further, pages 203-4 discuss the need to salvage diseased wood, while recognizing that diseased wood is often readily recruited into LWD.

Finally, on page 262 is the LWD recruitment policy:

Comments from CDFG in Appendix 6 indicate this policy is not strong enough.

According to JDSF annual reports, the salvage volume in 1996 was 5 million board feet of timber. This seems like a large amount of salvage logging to be coming from a forest that has an identified lack of terrestrial LWD. The DEIR does not explain how the salvage program will interact with the need to recruit LWD. This is a significant omission that may result in significant adverse impacts from salvage logging on LWD recruitment.

In general the DEIR takes the same approach to mitigations for recreation as one would expect to find in relation to private industrial timberlands: a small campground buffer where even-aged management is not practiced, for instance. There seems to be little recognition that campers and others have the right to traverse the public land beyond the campgrounds. Most non-industry people consider any form of logging to be an aesthetic impact.

Recreation corridors should be designated now. There is no need to wait for "visitor use surveys" as proposed by the DEIR. Jackson’s staff knows where the high use areas are. They would certainly include all the principle routes to and around the camping facilities, the Mendocino Woodlands, and the old growth groves. Future surveys can refine and add to these obvious high visitor-use areas.

The DEIR has identified various aesthetic and recreation-oriented adverse impacts (pages 87-91) and points to the mitigations that are planned once the recreation corridors are designated. Failure to designate these now would result in identified significant adverse impacts to aesthetic and recreation resources but proposed feasible mitigations would not be implemented at the time of plan approval.

There is a definite hesitancy about bringing this up, but it seems remiss not to. Although SHN is indicated as the principal contractor for preparing the DEIR "with" NRM being listed second, a review of Appendix 3, the list of Preparers and Contributors, shows that six are listed as SHN people, with another four listed as SHN Subconsultants, and fifteen are associated with NRM. Gary Rynearson is listed as President of NRM. He is also a member of the Board of Forestry as a timber industry representative appointed by Governor Gray Davis. Although we presume Mr. Rynearson will recuse himself from voting on the matter, we believe that his company’s strong presence in preparing the DEIR puts the members of the Board in an uncomfortable position. The members of the Board are ultimately responsible for approving the DEIR and the FMP.

Or is it that clear? Oddly enough, there are two versions of the DEIR and FMP approval process printed in the DEIR. The first version appears in the Executive Summary, page 4:

Then on page 18 in the main body of the DEIR it says:

Take your pick: In the Executive Summary version, who exactly approves the EIR is not really stated, but the Board gets to pick and choose among alternatives, so clearly the DEIR certification has not yet occurred. In the Page 18 version, the Director certifies the DEIR and the Board has the more or less ceremonial function of approving the FMP based on the approved DEIR.

This confusion should be clarified.

But getting to the point, with Gary Rynearson the Board of Forestry member being the President of the apparent, if not credited, lead contractor, how comfortable are other Board members going to be with expressing opinions that may differ from those expressed in the EIR? I have been on boards. I know how they work. With each major issue considered comes the calculus of whether it is worth causing trouble when it might affect an unrelated issue you care about. It causes a complication. And finally, how appropriate is it for one Davis political appointee (and timber industry representative) to be providing a supposedly "objective" CEQA review of the project of another Davis political appointee, the Director of CDF? I have no answers, but I do wish there were no issues here to raise.

We have identified many significant adverse impacts that would occur should the FMP be implemented as proposed. We have also identified many failures of the DEIR to provide information, identify impacts, and propose mitigations to avoid those impacts or reduce them to insignificance.

Many, if not most, of these issues have been raised repeatedly in the last decade. In the course of my trying to encourage people to comment on the DEIR there has been a very strong theme in reaction: Why should I bother to do this again? They haven’t paid any attention to the comments we already made. They are not going to pay any attention anyway.

Reactions of this sort came from a varied group of people including: the California Department of Fish and Game, the UC Forest Advisor for Mendocino and Lake County, a number of former Citizens Advisory Committee (CAC) members, a member of the State Forest Advisory Committee, the head of the Campaign to Restore Jackson Forest, and one of the reporters for a regional radio station. Perhaps the most poignant reaction along those lines came from former CAC member Jim Grieg, a Registered Professional Forester who has been managing timberlands across California during a long career. He point blank refused to review the documents even if I provided them for him saying he was tired of wasting his time. I was distressed to discover that he had been on not one, but two, Citizens Advisory Committees regarding JDSF. There had been one ten years prior to the CAC with which I was familiar. I had no idea. Unfortunately, in Grieg’s eyes the recommendations from the first committee had no more effect than the recommendations of the more recent one. What has been gained from all this stonewalling? Nothing positive for Mendocino County, I am sure of that.

We urge you to revise the FMP and the DEIR. Your attention to our concerns, and to those of so many who have come before us, would be greatly appreciated.

Sincerely,

Kathy Bailey

Forest Conservation Committee

List of Attached Exhibits:

1. Forestland Ownership Map
2. Hawthorne Option A, excerpt
3. MRC Option A, excerpt
4. CA Forestry Handbook, excerpt
5. Landsat close view
6. Landsat wider view
7. Combined Areas of Concern and Vegetation Map