July 17, 2002
California Department of Forestry and Fire Protection
State Forest Program
Attn: Christopher Rowney
1416 9th Street, 15th Floor
P.O. Box 944246
Sacramento, CA 94244-2460
Dear Mr. Rowney:
After reading the Draft Environmental Impact Report (DEIR) for the
Comprehensive Update to the Jackson Demonstration State Forest Draft
Management Plan and most recent version of the Jackson Demonstration
State Forest Management Plan Draft (dated May 17, 2002), I wish to submit
these review comments for the public record.
My name is James R. Strittholt and I am director of the Conservation
Biology Institute (founded in 1997) located in Corvallis, OR with a
satellite office in San Diego, CA. Our institute is a science-based
non-profit organization whose mission is to conduct applied conservation
biology research and provide a variety of education and science services
to the greater conservation community. We do not engage in advocacy;
however, we routinely conduct studies and reviews from a conservation
biology perspective. Our clients consist of equal proportions of
government agencies and groups (including the federal, state, and local
levels), other non-profit conservation organizations (e.g., World
Resources Institute, World Wildlife Fund, and The Nature Conservancy),
and the foundation community. We also occasionally work for the private
I have enclosed my most recent curriculum vitae for the record, which
outlines my professional credentials. In short, I hold undergraduate
degrees in Botany (forest ecology emphasis), Zoology (wildlife biology
emphasis), Science Secondary Education, and a Masters of Science in
population genetics. In 1994, I earned a Ph.D. from Ohio State University
in a self-designed multi-disciplinary program emphasizing landscape
ecology, conservation planning, and computer mapping technologies. While
a truly multi-disciplinary degree, I conducted most of my research and
developed most of my technical skills from the Center for Mapping – a
NASA Center of Excellence. While at Ohio State, I received numerous
academic achievement awards including being chosen as a University
Presidential Fellow during my final year. I have been involved in
conservation biology research and planning since 1988 with a strong
emphasis on forest ecosystems. Pertinent to the Jackson Demonstration
State Forest, our institute published a book entitled, The Redwood
Forest: History, Ecology, and Conservation of the Coastal Redwoods with
support from Save-the Redwoods League in 2000 (Noss 2000), which included
sections written by the leading redwood ecologists.
The following comments are directed at those parts of the DEIR and
preferred alternative management plan where I have specific expertise. I
assume that all comments, citation materials, and enclosures be made part
of the administrative record.
James R. Strittholt, Ph.D.
Conservation Biology Institute
Issues and Omissions in the DEIR
Before addressing specific issues, I wanted to begin by reviewing the
management goals and objectives as outlined in the DEIR and draft forest
management plan (DFMP). Defining management goals and objectives, which
the draft plan does well, is an important step in resource planning, and
I want to be clear that my comments are being made in full recognition of
these stated goals. Board policy regarding demonstration forests is
listed on pp. 26-31 in the DEIR. The major goal headings include: (1)
research and demonstration, (2) timber management, (3) watershed and
ecological processes, (4) forest restoration, (5) recreation and
aesthetic enjoyment, (6) information and planning, (7) protection, (8)
minor forest products, and (9) property configuration. It is clear that
timber production is the primary designated land use for Jackson
Demonstration State Forest (JDSF) with recreation recognized as a
secondary but compatible land use. Management has been further defined by
the California legislature as "…the handling of forest crop and forest
soil so as to achieve maximum sustained production of high quality forest
products while giving consideration to values relating to recreation,
watershed, wildlife, range and forage, fisheries, and aesthetic
enjoyment" (PRC 4639). On page 3 of the DFMP, the following statement is
This plan builds on the 1983 plan by elevating wildlife,
watersheds, and ecosystem processes to a level of importance equivalent
to the timber management and the research, demonstration and education
Based on these disclosures, it is clear JDSF wishes to make its forest
management practices more ecologically sustainable. With these
observations in mind, I offer the following comments.
1. Planning Context and Scale
Consideration of spatial context is one of the most important
conservation planning principles (see Noss 2002) and one of only two
basic principles of forest management that applies to all forest types
(Perry 1994). Recognition of this has been made at very high levels
within the U.S. Forest Service and other agencies. A noteworthy example
can be found in an international agreement the U.S. signed striving for
forest sustainability as part of the Montréal Process Criteria and
Indicators (see Montréal Process Working Group 1998). Forest management
researchers and practitioners, at a recent meeting of the National
Commission of Science and Sustainable Forestry in Portland, OR in May
2002, highlighted the recognition and endorsement of the importance of
context regardless of ownership. It is no longer acceptable to conduct
planning in a geographic vacuum yet it continues in many places and is
demonstrated in the DFMP and DEIR. The lack of regional context in the
DEIR and DFMP is a very serious omission and will result in poor
assumptions and flawed judgments. Some are already obvious in the
existing DFMP. For example, all of the goals of maximizing habitat
diversity (and therefore biological diversity) through forest management
practices proposed by the DFMP make little sense when the context of the
region is considered. Attempting to replicate a microcosm of all possible
habitat types in a small area like JDSF does little to promote, and in
some cases even damages, regional biological diversity. Another example
is found in the Table 13 (p. 127) under the question, "Cause a fish
population to drop below self-sustaining levels or threaten to eliminate
an aquatic community?" The rationale given as to why all alternatives are
scored as beneficial is ludicrous and demonstrates what happens when the
context is not considered. The DEIR states,
Nearly two-thirds of the entire land base within the JDSF was
clear-cut and burned prior to the introduction of the FPRs. Historic
activities included massive broadcast burning, road construction and log
skidding in watercourses, splash damming, stream clearing, and complete
removal of riparian canopy. No effort was made to protect fish
populations at that time. Fish populations were able to maintain
themselves through this period. The potential effects to fish populations
and aquatic communities from each alternative are orders of magnitude
less than pre-FPR operations.
What this quote demonstrates is a lack of understanding of context
over both time and space. Is it possible that fish populations were
maintained elsewhere in the bioregion at the time of this widespread
destructive period, and returned after conditions improved over time
albeit to lower population levels? Are many salmonid and other native
resident fish populations at risk currently throughout most of its range
including the JDSF? The answer to this second question is a resounding
"yes" (see Moyle et al. 1996 and Welsh et al. 2000) and phenomenal levels
of time and resources are being applied to solve the problem throughout
the greater Pacific Northwest. To say that future management, because it
is less destructive than historic land uses, will not lead to further
fish declines has absolutely no scientific basis.
The spatial and temporal context of the surrounding region adjacent to
JDSF, and for particular issues the entire redwood ecoregion, cannot be
overlooked and still produce an effective forest management plan that
addresses the stated goals and objectives by JDSF.
The issue of scale is also important in resource planning, and
although the DFMP recognizes the importance of planning at multiple
scales, it appears from the rest of the document that the land managers
are still far more comfortable with the stand level than any of the
others listed on pp. 43-45 including Table 4 (p. 45). What is not clear
is what forest managers intend to do with their findings, particularly
the landscape level and watershed scale measurements. The DFMP is far
more specific about its silvicultural goals and objectives (notably the
stand level ones) as exemplified in the desired future conditions section
on pp. 46-49, which focuses primarily on issues such as forest structure
and forest growth and yield targets. There is absolutely nothing in the
desired future condition section regarding the other aspects of forest
management that is stated as being of "equivalent importance" to JDSF —
namely wildlife, watersheds, and ecosystem processes. Even the objectives
listed under goal #3 in the DEIR lacks any clear direction. How will the
agency know how to adaptively manage if they do not have a clear idea of
what is desired with regard to these other values?
2. Cumulative Effects
The California Environmental Quality Act (CEQA) requires an
examination of cumulative effects. Page 79 of the DEIR states, "These
[cumulative and growth-inducing effects] have little or no applicability
to the JDSF Management Plan project." The DEIR discusses cumulative
effects in very general terms in section VIII and supposedly is
considered within each resource section in the document. Based on the
three paragraphs on pp. 429 & 430 pertaining to cumulative effects,
cumulative impact assessments are, "inherent in the programmatic approach
to development of the JDSF Management Plan EIR." A number of concerns
First, there is no way to know what the authors mean by "inherent in
the programmatic approach" based on the information provided. More
importantly, the DEIR completely leaves out entire sections of what is
meant by cumulative effects. A cumulative effect is an
environmental change influenced by multiple, progressive, or repeated
activities (Reid 1993). The key component completely missing from the
DEIR is any recognition that multiple activities could be working
together over time resulting in ecological degradation to some degree.
Tracking a single activity over time (e.g., road building) is
insufficient. To fully understand the ecological impacts on ecosystems
from human activities, one needs to consider factors such as road
building, logging practices, and recreational impacts together over time
and space to adequately predict risk to different resource values. An
important aspect of the cumulative effects is that many activities have
minimal negative impacts on natural ecosystems when considered alone;
however, when many of these individual activities are added together, a
much greater response is realized. From what little is written about
cumulative effects in the DEIR, I can only assume this important point
has been dismissed altogether.
Among the entire range of cumulative effects that have been described,
cumulative watershed effects (CWEs) — impacts that involve the transport
of water, sediment, or woody debris through a watershed (Reid 1993) —
have gained the most attention throughout the Pacific Northwest including
the redwood region. The CEQA requires that CWEs be identified as part of
the timber harvest planning process. As pointed out by Dunne et al.
(2001), a survey of timber harvest plans (THP) in California showed that
applicants frequently acknowledged that past land use activities would
adversely impact the proposed project; however, none of the applicants
indicated that their project would negatively impact future conditions.
These survey results suggests that applicants acknowledge the existence
of past cumulative effects but believe future cumulative effects
resulting from their proposed activities would not occur. I believe this
DEIR reflects the same response pattern as observed in the survey, and
reflects a reluctance to address complex issues rather than a fair
assessment of possible cumulative effects.
Cumulative effects analysis is an emerging science and is therefore
more complex than more traditional resource analyses; however, that does
not justify their avoidance. According to Reid (1999) cumulative impacts
are responsible for much of the current damage to resources and values in
the Pacific Northwest forests. Therefore, without adequate cumulative
effects analyses, we will never gain the level of understanding necessary
to manage resources in an ecologically sustainable fashion — not in a
demonstration forest or anywhere else.
Although no universally accepted framework for evaluating CWEs exists
(which results in some administrative problems), any assessment should
generally include a description of undisturbed reference conditions,
evaluation of environmental changes from past land-use activities, and
prediction of the likely effects of present and future activities
examined together (Ligon et al. 1999). In a review of the scientific
literature, Ambrose et al. (2000) summarize the ten most important
principles that should be considered when conducting CWEs. They include —
1. Cumulative effects are caused by the aggregate of past, present,
foreseeable future actions.
2. Cumulative effects are the total effect, including both direct
and indirect effects, on a given resource, ecosystem, and human
community of all actions taken, no matter who (federal, nonfederal,
or private) has taken the actions.
3. Cumulative effects need to be analyzed in terms of the specific
resource, ecosystem, and human community being affected.
4. It is not practical to analyze the cumulative effects of an
action on the universe; the list of environmental effects must focus
on issues and resources of greatest concern.
5. Cumulative effects on a given resource, ecosystem, and human
community are rarely aligned with political or administrative
6. Cumulative effects may last for many years beyond the life of
the action that caused the effects.
7. Each affected resource, ecosystem, and human community must be
analyzed in terms of the capacity to accommodate additional effects,
based on its own time and space parameters.
8. Cumulative effects may result from the accumulation of similar
effects or the synergistic interaction of different effects.
9. The spatial scale of cumulative effects analysis should be
defined by the spatial scale of the processes that control the
impacts and the resources of concern.
10. Because of the numerous complicating factors involved with CWE
assessment, and uncertainty in our ability to adequately predict
cumulative effects, a cautious approach should be taken.
A combination of remote sensing and geographic information systems
(GIS) technologies are being used to conduct cumulative effects
assessments and significant progress is being made (see Dunne et al.
2001). These assessments need to be multi- and interdisciplinary and must
address multiple spatial and temporal scales (Beschta et al. 1995). These
analyses are expensive to carry out, but far more economical than is
often realized. Once a GIS model has been developed, it can drastically
reduce the effort needed to analyze various combinations of cumulative
effects and forest management scenarios. Dismissing the inclusion of
cumulative effects is a serious omission in the DEIR. I cannot think of a
better place than a demonstration forest to promote the use and
advancement of cumulative effects analyses in forest planning. As pointed
out in the DFMP, cumulative watershed effects was the #1 urgent research
need identified by the State Board of Forestry and Fire Protection’s
Committee on Research in 1987.
Monitoring is fundamentally important in adaptive forest management
and the DFMP recognizes its importance. In my opinion, monitoring is so
important it should be an integral part of any DEIR. The current DEIR
mentions monitoring here and there, but there was no effort to clearly
describe a strategy that would allow for adaptive management to occur.
The only detail is found in the DFMP itself (pp. 100-110), and based on
that description, I found the monitoring plan 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.
Keddy and Drummond (1996) provide a good foundation for the forest
properties that could be monitored to inform forest management decisions.
The ten properties they introduce include are presented in Table 1.
Although this paper is focused on temperate deciduous forests, it
contains many properties equally important to western conifer forests. As
you can see, some of the properties are currently part of traditional
silvicultural monitoring (e.g., tree size), but many other important
indicators of ecological integrity are not (e.g., avian communities).
Table 1. Preliminary list of properties presented by Keddy and
||basal area per (m2) per
||proportion of shade tolerant tree
|Coarse woody debris
||megagrams per hectare
||number of ephemeral species
||number of bryophyte species
||number of snags per 10 ha
||fungi community assemblage
||number and abundances of forest interior
||number and abundances of species
Other possible properties that should at least be considered for
long-term monitoring include soil nutrients, aquatic macroinvertebrates,
exotic species, and forest fragmentation. All of these should be
monitored routinely using a mix of region-wide remotely sensed data,
permanent plots and points, and research project data (especially focused
on pre and post management treatments) into GIS.
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. For example, there is little or no energy being placed on
monitoring the ecological effects of even-aged management. With over 30
percent of the JDSF under even-aged management and with so much
controversy around this forest practice, I find it amazing there is not
an ambitious monitoring protocol established for this as well as other
practices. 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
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.
4. Ecological Considerations in Forest Management
Written by some of the nations leading forest researchers and
practitioners, the Ecological Society of America published a review of
ecological principles in forest management, which documents the most
important ecological considerations in forest management (Aber et al.
2000). In my opinion, the most important questions facing forest
management including the JDSF pertain to ecological integrity and forest
sustainability (see Karr and Dudley 1981, Rapport 1989 and Karr 1993).
Forest managers not only need to be concerned about growth and yield
projections, but also must be concerned about the ecological costs and
limits of their management. Forestry science has perfected the former,
but has much ground to gain in the later. Some important texts have been
written on the subject of sustainable forestry (e.g., Perry 1994, Maser
1994, and Hunter 1999), and I submit these for your consideration.
Land managers and the general public need to understand the ecological
costs of different types and levels of resource extraction upon which to
base consumption and use decisions. For example, if by supplying a
specific number of board feet of timber each year means certain
conservation values (e.g., salmon, healthy soils, or aesthetic quality)
are diminished or eliminated the land managers and the public need to
know in as much detail as possible. Only by examining the most important
ecological components can this be done. According a panel of 13
scientists (Aber et al. 2000), the five broad categories of ecological
considerations that should be explicitly part of any forest management
plan include: (1) soil and nutrient cycling, (2) hydrology, (3)
biodiversity, (4) landscape level issues, and (5) global climate change.
The DEIR and DFMP address some of these to varying degrees, but in my
opinion miss many of the most important considerations or remain unclear
as to how to apply the information obtained.
First, soil erosion is listed under the resource considerations in the
DEIR (pp. 291-313), but no consideration of soil fertility is mentioned.
The topic of nutrient cycling, which contains a large soil component, is
not addressed at all. The assumption by JDSF must be that forest
management practices are not impacting soil nutrient budgets in any
significant way in spite of the ever-growing body of scientific
literature that continues to show significant reductions in soil nitrogen
stocks, nitrogen availability, and productivity in association with
timber harvests. Other plant nutrients (e.g., phosphorus, calcium, and
magnesium) are impacted as well by forest harvesting practices (see
Kimmins 1977 and Smith et al. 1986).
The DEIR contains a section on hydrology (pp. 365-379), but I gain
little insight as to what evidence the DEIR has to explain its
conclusions. Upon reading Appendix 11, which explains the specifics of
the hydrologic analysis carried out, I find the conclusions difficult to
substantiate. From what I can tell, most if not all of the conclusions
are reached from a study on Casper Creek in 1988. The findings in that
study appear to have been extrapolated over the entire forest. A clear
methods section is lacking, so I have a difficult time ascertaining what
was done. With GIS already at JDSF, a spatially explicit hydrologic model
should be built with past and planned harvesting plans evaluated for the
DFMP (see Maidment and Djokic 2000). Sedimentation, erosion, and
landslide risk can all be evaluated from this spatially explicit
Biodiversity encompasses the full variety of life on earth, from genes
and species to ecosystems and landscapes, as well as the ecological
processes that both sustain and are sustained by living things (Aber et
al. 2000). The DEIR and DFMP focus almost entirely on the species and a
few rare plant communities (e.g., pygmy Cyprus) and ignore the other
equally important aspects of biodiversity.
Without a doubt old growth is of primary concern in the redwood region
since so little of it remains (see Noss 2000). Most of the original
forests are gone and many species (mostly invertebrates, bryophytes, and
fungi) are either gone or made exceedingly rare because of the loss of
ancient forests. In addition, the function of the original forest flora
has been significantly altered. How the DFMP addresses old growth as well
as many of the conclusions reached in the DEIR are based on a flawed
understanding of what biodiversity is and how it is maintained. For
example, the DEIR concludes that the DFMP and the less timber aggressive
alternatives (D and E) will protect old growth in similar ways. How is
this possible? Nearly ¾ of the 9,680 ac of areas in late seral stage (or
old growth) is located along stream buffers throughout the forest. Only a
few small patches of old growth groves and old growth management areas
are found scattered throughout JDSF. The long linear stretches of old
growth are subject to many stresses that result in substantive changes in
the composition, structure, and function of these linear fragments. For
example, Chen et al. (1995) documented physical changes in microclimate
gradients reaching 30-240 m into a forest from the edge. Harvest
restrictions along linear strips along watercourses outlined in the DFMP
fall below this range, so they are functionally all edge habitat. Changes
in wildlife communities near edges are also well documented (see Yahner
Many edge and early seral species will do well under the DFMP, 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 relatively intact core
(or interior) areas and high quality aquatic habitat. The way the DFMP
includes some late seral forest enhancements will do little in promoting
the long-term survival of these species in these areas.
Often missed in the old growth debates is the importance of the
recovering segments of the forest. Forests of 80-150 yrs of age will not
posses all of the old-growth characteristics of older forests, but they
contain the best we have to work with as we strive for a more
ecologically sustainable forest management strategy. If these forests are
ignored in the planning with regard to their non-timber values, they will
be summarily harvested and we will loose our best building blocks for
short-term ecosystem recovery.
Before leaving the topic of forest age, I want to briefly state that I
find it 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 (specifically those that
closely approximate natural forest conditions) 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 ( I would recommend a much smaller
percent of the land base), 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. It appears to me that even-aged
forestry is still practiced for economic reasons exclusively, even though
those economic reasons are incomplete and do not include other values
expressed as important.
There is no landscape-level issues section in the DEIR, and I see this
as another serious omission. One of the major concerns with forest
management and biodiversity protection deals with forest fragmentation.
Two excellent reviews of the summarizing the impacts of forest
fragmentation on natural ecosystems can be found in Saunders et al.
(1991) and Trombulak and Frissell (2000). The DFMP mentions that forest
fragmentation is routinely monitored, but I was unable to find anything
about how that information will be used to adapt future management plans.
There is no discussion of a desired target fragmentation level listed
anywhere or how the impacts of the continuing fragmentation on various
species or processes will be evaluated.
The last recommended ecological consideration for forest management
deals with the issue of global climate change. Aber et al. (2000) state
Forestry has always had to plan for the long term against a
backdrop of rapidly changing social and physical environments. If forest
productivity and other forest values are to be sustained in the face of
global change, management policies must make unprecedented use of the
knowledge base that has been developed on forest ecosystem dynamics and
response to disturbance.
Forest landscapes are composed of three basic elements — composition,
structure, and function (Forman and Godron 1986 and Forman 1997). The
DFMP and the DEIR pay attention to different aspects of forest
composition and structure (particularly from a silvicultural perspective)
and little or no attention to ecological processes such as nutrient
cycling, species interactions, and disturbance. The section in the DEIS
on wildfire underscores my point. The DEIR includes wildfire under the
heading "Hazards and Hazardous Materials," instead of as an ecological
process that needs to be maintained. I also believe the finding in Table
41 (p. 328) about Alternative E in negatively impacting the JDSF to
conduct fire suppression as ill founded. A growing body of scientific
evidence is showing that increased roads and intensive forest management
(including fire suppression) exacerbates wildfire damage to human life
and property not alleviate it (see Dombeck 2001 and DellaSalla and Frost
5. Selection of a Preferred Alternative
As stated in the DEIS, the document is, "intended as a public
disclosure and decision-making tool for adoption of the JDSF Management
Plan." Later on page 23, the DEIS states, "Upon comparison of the
relative merits among each alternative, the ‘environmental superior
alternative’ is identified." If this is true, the DEIR clearly shows that
the DFMP is inferior to alternatives D and E in many of the comparisons
made. In my professional opinion the "environmental superior alternative"
was not chosen.
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