Smart & Wright
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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.

  1. 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 policies nationwide.
  2. 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.
  3. 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.
  4. 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.
  5. The plan does not prohibit use of herbicides in these important watersheds. We find this a glaring omission.
  6. 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.
  7. 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 misleading.
  8. This plan defends and projects increasing harvest levels while providing no data on the potential consequences of reducing the total biomass of the forest.
  9. 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.
  10. No provision in this plan increases staffing needed to prevent dangerous illegal activities or vandalism which currently occur frequently in the forest.
  11. 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.
  12. 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 important issues.
  13. 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.
  14. 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.
  15. 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.
  16. 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 rules.
  17. 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.
  18. 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.


Tanya Smart
Brent Wright
17660 Redwood Springs Drive
Fort Bragg, CA 95437

cc/ Assemblymember Virginia Strom-Martin
Senator Wes Chesbro
Supervisor Patty Campbell
Governor Gray Davis