Comments of Tanya
Smart and Brent Wright
July 1, 2002
To: Christopher Rowney, Deputy Chief for State Forests
California Department of Forestry and Fire Protection
PO Box 944246
Sacramento, CA 94244-2460
Re: Draft Jackson Demonstration State Forest EIR
Dear Deputy Chief Rowney,
We have the following comments to make on the Draft EIR for the
proposed management plan for Jackson Demonstration State Forest:
We strongly oppose the Draft Management Plan for Jackson State. Some
of our reasons are listed below.
- This plan is not based on recent science. Statements asserting a
lack of evidence regarding the effect of disturbance events or the
value of corridors in forested environments ignores and contradicts
extensive literature on both subjects. There are many published studies
scientifically demonstrating the value of habitat corridors and the
effects of disturbance on ecosystems that guide resource management
- We are neighbors of the forest who have already endured one THP
with operations occuring just outside our property line. Past
procedures for consulting with neighbors adjacent to harvest operations
have been inadequate to say the least. This plan provides no clear
description of proposed procedures for consulting with neighbors
adjoining harvest operations, no quantitative minimums or ranges for
buffer size, types of allowable harvest operations and allowable
percentages of single-tree tree removal within buffer zones.
- Jackson Demonstration State Forest has the potential to demonstrate
whether old growth characteristics can be re-gown, yet the proposed
management plan proposes to cut the oldest second-growth stands.
- The plan is misleading. Despite comments of areas "set aside" and
"restricted from harvest", the only areas protected in this plan are
those excluded from operations by outside constraints imposed on CDF.
- The plan does not prohibit use of herbicides in these important
watersheds. We find this a glaring omission.
- The plan focuses on efforts to grow trees faster to produce lumber
more quickly. This philosophy ignores recent market trends. Lumber from
second or third growth areas grown in the10-25 year cycles proposed by
the plan, is poor quality and provides a poor price/value ratio.
Consumers are rejecting such material, as evidenced by overstocked
inventories and low demand for this product.
- The total inventory of JDSF and claims that yield is increasing are
difficult to analyze given the changing measurement methodology
described. As a result, the data supporting projections appears
- This plan defends and projects increasing harvest levels while
providing no data on the potential consequences of reducing the total
biomass of the forest.
- Claims that Jackson State has increased productivity and timber
stand defines "sustainable" as merely board feet grown vs. board feet
cut. This narrow definition is outdated. A sustainable forest is a
healthy ecosystem that provides lumber as well as healthy wildlife
habitat while remaining reasonably secure from fire.
- No provision in this plan increases staffing needed to prevent
dangerous illegal activities or vandalism which currently occur
frequently in the forest.
- The plan claims that JDSF has habitat for a potential of 325
species, but there is no data to determine how much of that potential
is realized. Actual species surveys are missing. Observations from
local ecologists, birders and hikers indicate that Jackson
Demonstration State Forest has very low diversity and poor abundance of
wildlife for a forest of its size.
- Despite statements that the plan will elevate wildlife, watersheds
and ecosystem processes to a level of importance equivalent to timber
management and the research, demonstration and education programs, it
is apparent that producing revenue from selling timber is the primary
objective from the budgets outlined. The substance of the plan itself
is all about logging and the revenue to be generated with little
financial or administrative support devoted to the other equally
- There is no provision for law enforcement, improving the forest, or
restoring logged areas. Currently, recently logged areas are filled
with debris, piles of slash, and rapidly invading exotics (and
vandals). The increased fire danger from this dry and piled debris is
apparent. The plan outlines issues such as exotic weed invasion and
illegal activities but provides no corrective measures.
- The community has strongly expressed the mandate that a significant
portion of the revenue generated from timber sales in JDSF must be
dedicated to wildlife habitat and watershed protection, as well as
research and education programs in JDSF. This is ignored in the plan.
- Group selection (clear-cutting) any grove of trees without taking
into account the effects of changing micro-climates in pocket groves or
the overall effect of global climate change on the modern regenerative
potential of this ancient ecosystem is unacceptable. Yield tables from
1930 and 1963 that were developed from data of previous clear cuts are
not reliable today.
- This plan does not provide for its own enforcement of timber
harvest rules. There is insufficient staff for monitoring and
enforcement. Licensed Timber Operators (LTOs) cannot be made to follow
Timber Harvest Plans (THPs) without staff dedicated to monitoring and
enforcement during operations. This plan invites THP violations in that
the LTO provisions almost ensure that the highest bidder for timber
will sell to the lowest bidding Operator. Clear provisions of THP's can
be disregarded and violated by the LTO with no consequence to the
operator, but grave consequence to the forest. CDF loses credibility
when it does not provide staff and financial support to enforce its
- Statements such as "The variety and quality of habitats is expected
to increase through the planning period and beyond" have no actions or
measurable outcomes associated with them. Presumably this increase in
variety and quality of habitats occurs because of the plan's commitment
to the recruitment of "late seral stages", yet the statement that
"level of the annual harvest will increase over the coming decades"
contradicts this goal.
- Public input is noted in its section, but no financial or
administrative provision is described to act upon any suggestions, or
to enforce restrictions or rules already in place. The publics'
statements and desires are considered and good intentions are outlined,
but there is no administrative or financial support provided to carry
out these promises.
We strongly urge you to carefully review comments from the qualified
scientists who do not profit from the exploitation of the forest, and yet
are taking the time to review this plan. There is a strong community
feeling that only those who profit from this forest are having any real
say in its management. There is strong apprehension that the board of
Forestry is a rubber stamp for these interests and that political
contributions drive forest management policy. It is clear to long-sighted
leaders, legislators, agencies and citizens that our economy is changing
and tourism, not timber and lumber are Mendocino County's future.
Squandering the aesthetics and value of one of our largest tourist
assets, Jackson Demonstration State Forest, for short-term revenue to
fill the State's coffers, or to inflate political campaign war chests at
the expense of the local economy is reprehensible and unacceptable.
17660 Redwood Springs Drive
Fort Bragg, CA 95437
cc/ Assemblymember Virginia Strom-Martin
Senator Wes Chesbro
Supervisor Patty Campbell
Governor Gray Davis