California Department of Forestry and Fire Protection
State Forest Program
Attn: Christopher Rowney
1416 9^th Street, 15^th 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 sector.

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.

Sincerely,

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

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 made.

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 programs.

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.

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,

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?

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 exist here.

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, and reasonably

foreseeable future actions.

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 Drummond (1996).

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 important questions?

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.

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 platform.

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 1988).

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 it best,

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 2001).

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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