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Neighbors, Recreation, and the Woodlands |
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The information here is in addition to
General Information on the Management Plan and
EIR. We recommend that you review at least the
items in Basic Information and Comments Received
contained therein before writing your comment. Index The Draft Management Plan has scheduled logging plans for Hare Creek, Mitchell Creek, East Caspar (2 plans). If you live near Jackson State, your neighborhood is threatened. Although your area may not be scheduled for logging now, you can be sure it will in the future, because CDF intends to log it all. If you live near Jackson State Forest, please write and voice your concerns about logging next to your home. Concerns include visual degradation, destruction of recreation potentials, fire hazards, water quality and availability, and property values. In terms of the EIR, object to the lack of a specific procedures for taking into account your concerns when harvests are planned for your neighborhood. The EIR says only that CDF has historically "discussed" harvest operations within 200 feet of neighbors. A mitigation that might apply to neighbors is discussed on page 91 of the EIR, but it is unclear whether or not it does apply. In any event, the mitigation does not guarantee any influence by the affected neighbors nor specify the minimum width of the buffer, which needs to be at least 500' to provide any degree of real protection.. As stated, it would allow "single-tree selection" without any limit on the percentage of trees that could be removed and says nothing about the treatment of slash, preservation of existing recreation trails, or treatment of logging roads. No mention is made in the EIR of recreation values of forest adjacent to neighborhoods. Therefore, there is no consideration of the tradeoff between recreation values and timber values. There is no consideration of restrictions on harvest to protect existing or potential recreation values. The lack of meaningful detail in discussing recreation in neighborhood forests precludes informed decisionmaking and public participation. In commenting on the EIR, you should voice your objections and wishes, but be sure to include the following: With respect to the EIR treatment of harvest operations adjoining forest neighbors, informed decisionmaking and public participation are impossible because there is no clear description of proposed administrative procedures for consulting with neighbors, quantitative minimums or ranges for buffer size, types of allowable harvest operations and allowable percentages of single-tree tree removal within buffer zones, or provisions for protecting recreation values. If you use Jackson State Forest for recreation, you will want to express your views on the lack of protection for existing trails and campgrounds and the lack of any plan for recreation development. The Draft Management Plan contains no recreation plan. Development of a recreation plan is deferred. No baseline data is presented on potentials for hiking, biking, and equestrian trails or campsite development. No information is given on public desires for different types of recreation. The last recreational use survey way conducted in 1988. Given the high potential recreational values in the Forest, the lack of a recreation plan is a major defect. The lack of a plan makes impossible informed decisionmaking and public participation in planning for recreation. The Draft Management Plan lists only the16 miles of trails "managed, maintained, and sanctioned" by the State Forest. No inventory has been made of the trails "that have been developed by users without participation of the Forest." (Draft Management Plan, Appendix 7, p. 192.) These "user developed" trails are an important aspect of recreation in the forest and should be considered in the EIR. No protection for recreation trails is specified in the Management Plan or EIR. In recent years, several trails, including the Bob Woods Trail and Trestle Trail have been negatively impacted by timber operations. Because no protection measures are specified, informed decisionmaking and public participation in developing such measures is impossible. A 300 foot buffer is specified around campgrounds and day-use areas. Within the buffer, logging activities will be restricted in as-yet-unspecified manner "with the site use in mind." (Draft EIR, Volume 1, p.90.) Three hundred feet is a short distance that can be walked in less than one-minute. The proposed buffer would not protect recreation values around campsites. The lack of meaningful detail in describing the harvest methods to used within the buffers precludes meaningful decisionmaking and public participation in their development. In commenting on the EIR, you should voice your objections and wishes, but be sure to include the following: With respect to the EIR treatment of recreation in Jackson State Forest, informed decisionmaking and public participation are impossible because no recreation plan is discussed and protection for existing campgrounds and trails is not discussed in meaningful detail. Mendocino Woodlands Camp and Surrounding Forest Users of the Mendocino Woodlands Camp may want to express their concern about two planned timber harvests adjacent to the Camp. These plans are in the so-called 2,550-acre "Special Treatment Area" that surrounds the Camp and is managed by CDF. Background: The Mendocino Woodlands Area The Mendocino Woodlands Camp is leased from California State Parks. The Camp is part of the Mendocino Woodlands Recreational Demonstration Area (Woodlands Area), an area of 5,426 acres transferred by the federal government to the state of California in 1947. Originally, the Woodlands Camp comprised the entire 5,426 acres. The Woodlands Area (see Woodlands Map) now consists of three parts: the Woodlands Camp (780 Acres), a Special Treatment Area or STA in Jackson State Forest (2,550 acres), and the remaining part of the transfer, which is managed as a regular part of Jackson State Forest (2,155 acres). All parts of the Woodlands area are of great ecological importance. With two exceptions, no logging has occurred in this area in eighty years, making it one of the two large areas of undisturbed, mature second growth in Jackson State Forest. These areas of mature second growth have great potential for providing habitat to endangered species, especially the Marbled Murrelet, dependent on old-growth type habitat. The Woodlands Area was transferred to the state of California explicitly for park, recreation, and conservation purposes. The act of Congress authorizing the transfer stated in part: "Every such deed or lease shall contain the express condition that the grantee or lessee shall use the property exclusively for public park, recreational, and conservation purposes. …" {Act of Congress of June 6, 1942[56 Stats. 326: 16 U.S.C. 459t].} The state expressly agreed to these terms in accepting the transfer. Under any reasonable interpretation of the purposes for which the Woodlands Area must be used, timber operations that do not directly contribute to recreation and conservation are prohibited. Harvest Plans The Draft Management Plan specifies two timber harvests within the next five years in the Special Treatment Area of the Woodlands. (See Woodlands Logging Map) Both of these timber plans will detract from the recreational values of the Mendocino Woodlands Camp, which is located within the Woodlands Area. Railroad Gulch: The largest plan is 270 acres in Railroad Gulch, which borders on the west side of Woodlands Camp and spans one of the recreation trails most used by Woodlands Camp visitors, the Forest History Trail. (See Woodlands Logging Map). To allow logging in this protected area, the state in 1981 designated the 270 acres a Demonstration and Research Project of the University of California. It was logged initially in 1984 under this justification. The planned logging is also being justified as a continuation of this "research project." You may wish to point out that such a use is directly contrary to the clear legislative purposes of the entire Woodlands area. Even the research justification for the new plan is questionable. The original research design called for a second harvest in 1990, 12 years ago. This harvest was never done, thus the original hypotheses can no longer be tested. CDF has entered into a Memorandum of Understanding with State Parks that allows it to conduct logging operations within Railroad Gulch right up to the edge of Woodlands Camp (DEIR, p. 85). This is the sole exception to a 200-foot harvest-exclusion buffer from all camp areas administered by State Parks. You may wish to object to the lack of any exclusion buffer between the Woodlands Camp and the planned Railroad Gulch Harvest. Thompson Gulch: The second harvest plan is in the north end of the Special Treatment Area. (See Woodlands Logging Map.) An old road that is often used for hiking crosses it. The stated purpose of the harvest plan is to accelerate the development of "late-seral characteristics," which describe the forest structures found in old-growth forests. There are no specifics given for the Thompson Gulch plan, precluding making a informed judgments about the environmental effects of the plan. Because this plan is stated to be a demonstration and model for future timber operations throughout the Special Treatment Area, and because of the great ecological value of the Special Treatment Area, detailed specifications for the plan need to be a part of the EIR. In commenting on the EIR, you should voice your objections and wishes, but be sure to include the following: With respect to the EIR treatment of harvest operations in the Woodlands Special Treatment area, informed decisionmaking and public participation are impossible because the plans are not described in meaningful detail and there is no consideration given to the recreational and wildlife benefits of undisturbed forest. Moreover, the original deed transfer of this land precludes any timber operations that don't contribute to recreation, park, or conservation use. The Railroad Gulch plan clearly violates this clause. When you are finished
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