E-Mail: board.public.comments@fire.ca.gov

State Agencies:

The State Board of Forestry and Fire Protection (Board) will be the Lead Agency and will prepare an environmental impact report (EIR) for the project identified above. The Board needs to know the views of your agency as to the scope and content of the environmental information that is germane to your agency's statutory responsibilities in connection with the proposed project. Your agency will need to use the EIR prepared by the Board when considering your permit or other approval for the project. The project description, location, and the probable environmental effects are provided below. Due to the time limits mandated by State law, your response must be sent at the earliest possible date but not later than the date listed above.

The Board of Forestry and Fire Protection (Board) is a Governor-appointed body within the Department of Forestry and Fire Protection (CDF). It is responsible for developing the general forest policy of the state, for the adoption of regulations pertaining to forest management and the fire protective system for the prevention and suppression of forest fires, for determining the guidance policies of CDF , and for representing the state's interest in federal forestland in California.

The Board is charged by Public Resources Code § 4645 with the responsibility to approve a Forest Management Plan (Plan) for the Jackson Demonstration State Forest (JDSF). The purpose of the Plan is to establish management goals and a management direction for the Forest. A management plan currently in effect was adopted in 1983. The Board’s current proposed action is an update of that plan. Some of the more important aspects of the Plan will address balancing and prioritizing management activities for the coming decade. In addition, the Plan will address general levels of management for forest management demonstration, recreational activities, timber harvest, and fish and wildlife habitats. In that the Plan sets forth general guidance for the management of JDSF, it is in some aspects a programmatic Plan; when further approvals are required for activities a more specific detail and environmental analysis will be developed at the project level.

Prior to Board approval of the Plan, the Board must disclose the potential environmental impacts of that action in accordance with the California Environmental Quality Act (CEQA). Therefore, the Board will prepare an Environmental Impact Report in compliance with CEQA. The EIR will describe and analyze the environmental impacts of the Plan and compare and contrast those impacts with alternatives to the Plan.

The EIR will analyze the potential direct, indirect and cumulative impacts of the management plan. The plan will contain a series of contemplated actions that are related geographically, having similar potential impacts and mitigation measures. The EIR and the Plan will have some programmatic aspects. Program EIRs are advantageous because they may provide for an earlier and more comprehensive analysis of potential effects, alternatives and cumulative effects than would be possible project-by-project. Additional analysis will occur prior to the approval of individual projects not analyzed at a project specific level in the EIR to determine if the proposed activity is within the scope of the analysis conducted in the programmatic EIR, identify potential impacts of the proposed project that were not identified earlier, and whether approval of the project may lead to cumulative effects. Much of this project level review will be facilitated through the use of a checklist developed as part of the programmatic EIR.

The Board may delegate specific CEQA administrative functions to others and has selected the CDF to prepare the EIR on its behalf. The Board shall retain responsibility for reviewing the draft, certifying the final EIR, and making CEQA findings.

The draft EIR is expected to be available for public review by approximately spring 2004, with the final EIR completed and project approval occurring by approximately summer of 2004.

On July 30, 2003, the Superior Court of California, Mendocino County, ruled that the 2002 EIR for the JDSF Plan, prepared by the CDF and its consultants and certified by the CDF director, was flawed on several counts. First, the court found that the Board, not CDF, was the appropriate lead agency for preparing and certifying the EIR, making findings per the CEQA Guidelines § 15091, and adopting a mitigation monitoring program. Second, the court ruled that the EIR itself was deficient due to an inadequate discussion of the environmental setting and inadequate assessment of potential cumulative effects. The court directed the Board to rescind its November 2002 approval of the JDSF Management Plan. The Board took this action on October 9, 2003. The court has retained jurisdiction in the matter until the Board has fully complied with CEQA in its approval of the proposed update of the JDSF Management Plan.

The Board intends to consider for approval a management plan for Jackson Demonstration State Forest. Public Resources Code (PRC) §4645 provides that state forests will be managed by CDF in accordance to plans approved by the Board. PRC §4639 defines "management" 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. The Board provides further direction through its regulations and policies related to the State forest system. California Code of Regulations (CCR) §1510 states that the harvesting of forest products from State forests and management of State forests shall follow management plans developed for each forest by the Director, and approved by the Board.

The primary purpose of JDSF, as stated by the Legislature, is the demonstration of economical forest management (PRC §4631 (d)). Management is defined to mean the handling of forest crop and forest soil 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). Board policy describes JDSF as a commercial timberland area managed by professional foresters who conduct programs in timber management, recreation, demonstration, and investigation in conformance with detailed management plans (Board Policy §351.1).

The Board’s policy states that to attain proper management of private timberlands in California, there is a need to investigate, develop, and demonstrate new and improved forest management methods to timberland owners and the public. The State forests serve this purpose while contributing to the economic stability of local communities by providing high yields of forest products that sustain local employment and tax basis. Outdoor recreation, aesthetic enjoyment, and wildlife, watershed and fishery protection are also important public benefits of the state forests.

The primary purpose of the State forest program is to conduct innovative demonstrations, experiments, and education in forest management. Timber production is the primary land use on JDSF. (Board Policy §351.2).

JDSF has had a long history of providing a demonstration and education function to a broad range of audiences. CDF, in cooperation with the USDA Forest Service, UC Berkeley, Cal Poly San Luis Obispo, and Humboldt State University, has embarked on development of a network of forest learning centers, including a site on JDSF, which will be available to students, educators, scientists, and the public where forest ecology, management principles, and forest watershed sciences can be taught, studied, and monitored. JDSF is open to requests for field trips and provides field trips regularly to all levels of educational institutions, groups of natural resource professionals, and other groups such as California Native Plant Society (CNPS), industrial landowners, and mycological collectors. Also, JDSF has been the source of many research reports that are used throughout the North Coast.

Silviculture—the management of forest stands using treatments such as harvesting, site preparation, and tree planting—is an important tool to meeting multiple objectives of the proposed management plan. JDSF has an estimated timber inventory of more than 2 billion board feet, with an annual growth level estimated at well over 40 million board feet. JDSF currently produces an annual timber harvest of approximately 29 million board feet of redwood, Douglas-fir, and whitewood logs. This timber is sold annually to bidders, harvested by local logging contractors, and is shipped to a number of sawmills throughout the redwood region and California. Substantial numbers of jobs are produced by this timber management activity, as well as tax revenues.

This publicly owned forest also is utilized as an important recreational resource by local citizens, travelers, and vacationers from throughout the County, State, and country. There are over 60 individual campsites, many miles of riding and hiking trails, and over 200 miles of forest road utilized by the public for casual driving, walking, bicycling, and horseback riding. Other common recreational activities conducted on JDSF include picnicking, hunting, swimming, wildlife viewing, and target shooting. JDSF is also an important local source of firewood and other minor forest products such as mushrooms and greenery for both personal and commercial use.

JDSF is home to a number of sensitive fish and wildlife species, including the northern spotted owl, coho salmon, and steelhead. There are over 90 miles of fish stream. The Forest provides habitat for a large number of species and habitat protection is an important element of forest management activities. For the past several years, JDSF staff has monitored the population of northern spotted owls that lives within the Forest. In cooperation with the California Department of Fish and Game, and National Oceanic and Atmospheric Agency (NOAA) Fisheries, several aspects of anadromous fish populations and habitats are being monitored on an annual basis.

The proposed JDSF management plan seeks to establish a desired future condition or target for management. It further seeks to establish a direction for management that utilizes a wide range of silvicultural systems; to further the goal of creating a diverse and healthy distribution of forest structures and habitats, ranging from disturbance related early seral stages to late seral/old growth. This approach is intended to provide an opportunity to demonstrate sustainable forest management, while also providing a diverse forest system available for research and demonstration, which are key components of the established purpose of JDSF. The proposed plan allocates desired forest structure types to specific areas of the forest, as well as guiding and constraining forest treatment options; this should allow for the enabling of future monitoring and research of the relationships between forest structure, watershed processes, and wildlife habitat. Some management areas would be subject to uneven-aged management systems such as selection and group selection, while others would be subject to even-aged systems such as variable retention, two-age, and clearcut. The forest structure within the management units would change over time, as portions of the areas are harvested and grown.

The proposed management plan establishes restoration and recovery of functioning ecosystems as a high priority, and recognizes the need for research and demonstration to help determine how best to manage forests to achieve high levels of timber production while maintaining or restoring functional ecosystem processes. The proposed management plan presents an approach to create and maintain multiple seral stages of forest, along with important structural habitat elements.

Under this proposal, existing old-growth groves that remain on the Forest would be preserved, and a substantial acreage of young forest area would be dedicated to the long-term development of late-seral habitat conditions suitable for use by listed species. The major fish-bearing streams would be managed to maintain a recovery trajectory, and active restoration would be considered and implemented where appropriate. A high level of shade canopy would be maintained adjacent to these streams, and provision made to manage riparian zones for their contribution to a functional aquatic and near-water ecosystem.

Protection of listed species is designed for in both habitat enhancement and species recovery. This element of forest management would be balanced with timber production consistent with legislative mandates. Substantial core areas would be established to preserve old-growth forest stands and to provide for the development of late-seral habitat conditions. The proposed management plan would set standards for the retention and recruitment of essential habitat elements within forest stands, such as snags, large green trees, and large woody debris.

An important element of the proposed plan to protect and enhance the resources of the forest involves the effective management of the road system. This road system serves as the main point of public contact with the forest, and also serves as the conduit for management activities, including the transportation of forest products. Important elements of the proposed plan include a road inventory, maintenance provisions, construction standards, and a decommissioning schedule for roads in poor locations that result in ecological damage.

The proposed management plan proposes to maintain a rustic outdoor recreational experience for the thousands of annual visitors. A moderate expansion of the trail system is proposed. The current rate of recreational use is substantially below the capacity of the current facilities. Some improvement in both the condition of access roads and camping facilities is proposed.

As a part of the proposed management plan, a detailed research and monitoring plan would be implemented. It is of vital importance that the effects of forest management upon watersheds, aquatic systems, and terrestrial plants and animals be monitored and compared to desired outcomes. An adaptive management program would be implemented in order to provide an opportunity for the effects of management activities to be analyzed, and management adjusted accordingly to achieve the desired management objectives. Research has long been a significant activity on JDSF and would continue to be so under the proposed plan. Knowledge gained will be continually re-evaluated, and management actions will be modified as necessary in response to the results that are observed. This would help to keep the plan up-to-date and in step with new science and management techniques.

 PROBABLE Environmental EFFECTS OF THE PROJECT

Forest management and timber harvesting activities, recreational activities, forest management demonstrations, and collection of minor forest products, unless mitigated, may cause environmental effects, such as noise, traffic, aesthetic degradation, changes in fish and wildlife habitat, soil disturbance, reduction in water quality, and interruption of recreational opportunities. The potential effects of these activities may be limited to the project site itself, areas immediately adjacent to the project, other areas within JDSF or to areas outside of JDSF and at a considerable distance. Measures to avoid, minimize, or otherwise mitigate potential significant impacts will be incorporated into the proposed Plan. This EIR for the Plan will identify any additional project impacts, both individually and cumulatively, and will develop measures to reduce those potential impacts to a level considered less than significant. Given the programmatic aspects of the Management Plan and this EIR, additional CEQA-based environmental assessment and impact mitigation, including cumulative effects assessment, will be done at the project level for many actions described in the plan. Other actions will be analyzed in this EIR at the project-specific level.

The impact categories listed below have been preliminarily identified for analysis in the Draft EIR, along with examples of such effects:

1. Aesthetic: Disruption of scenic integrity by harvesting, infrastructure development, road building.
2. Agricultural Resources: Conversion or conflicts with existing zoning as a result of management activities.
3. Air Quality: Emissions from slash burning, fugitive particulate matter from road construction and road use.
4. Biological: Impacts to species, either directly from activities in the forest, or indirectly through habitat modification.
5. Botanical: Impacts to species, either directly from activities in the forest, or indirectly through habitat modification.
6. Forest Protection: Introduction of non-native species transported by vehicle activity; introduction of disease or pests, via injury to trees during management activities or transport by vehicle activity.
7. Geology: Increased landsliding triggered by management activities such as harvest and road building.
8. Hazardous Materials: transport of fuels or chemicals through forested areas.
9. Heritage and Cultural Resources: Ground disturbance via heavy equipment operations disrupting or damaging sites.
10. Hydrology and Water Quality: Alteration of drainage patterns, introduction of sediment to watercourses, increased runoff related to heavy equipment use or vegetation modifications.
11. Land Use: Conflicts with policies, zoning or other ordinances of proposed activities.
12. Noise: Increases in ambient noise related to permanent installations or periodic increases related to harvesting activities.
13. Recreation: Use or improvement of facilities, curtailment of use during other management functions.
14. Timber: Modifications in quantity or quality of later seral forest or old growth types through management activities. Loss of maximum sustained production through misapplied harvesting regimes.
15. Transportation: Increases beyond normal usage due to management activities.

 ALTERNATIVES TO THE PROPOSED PROJECT

Lead agencies, when preparing an EIR, are required to evaluate a variety of feasible alternatives to the proposed project that both meet the objectives of the project proponent and serve to mitigate the proposed project’s potentially significant environmental impacts. The Board intends to analyze several alternatives by varying levels of commodity management, forest management demonstration, wildlife habitat protection and management, late seral management, restoration, and recreational use. The Board will consider the earlier Plan, dated May 17, 2002, (approval of which has since been rescinded), comments on that plan and all other relevant information, including alternatives from the previous Draft Environmental Impact Report (see below) and public and agency comments received during the scoping period in developing alternatives and mitigations. The number of alternatives and the levels of management intensity analyzed in the alternatives will be determined following scoping.

The following alternatives were set out in the previous EIR (since invalidated) for the plan. These alternatives may be modified, based on review of the comments received in the scoping period.

Alternative A describes the effects of only minimal maintenance and protection of JDSF lands. There would be no harvest of timber. Road maintenance would be limited to that necessary to maintain public access. Stand structure would change more slowly than in an active management strategy. The demonstration value of this alternative is limited to forest development that is not likely on most private lands in the state. The primary land uses on JDSF would be public recreation and monitoring or study of natural environmental processes.

Alternative B describes JDSF maintaining the current level of forest management demonstration,

This alternative places emphasis on development of late seral forests across the landscape. Restoration of the natural forest ecosystem and the protection of water quality, fish, and wildlife habitats at JDSF would be the primary management goals. There would be no even-aged management or harvest of old-growth trees. Timber harvesting, when it occurred, would be designed to advance timber stand development to late seral characteristics. Low impact recreational opportunities such as trails and hike-in campsites would be expanded where they did not pose significant risk to fish and wildlife resources. Research would no longer address questions on active forest management, but would shift to studying the existing vegetation types and watercourse conditions and how they change over time. A research, demonstration, and monitoring program would be implemented to gain and distribute knowledge on the restoration of old-growth and late-seral forests, natural watersheds, and associated resources.

With this Notice of Preparation the Board is soliciting public and agency comment on the scope of the analysis and issues to be considered, the potential environmental impacts of the draft Plan and alternatives to the draft Plan.

Facilitated Scoping: a scoping session facilitated by staff from the University of California Cooperative Extension will be held on February 27 in Fort Bragg, California. This session has been designed by the facilitators to seek the views of a diversity of stakeholders. These stakeholders will provide the Board with focused presentations on relevant issues to help inform the Board on the factors that are relevant to the preparation of the EIR and affect the management direction of JDSF. An opportunity for public comment will occur following the presentations.

Facilitated Scoping Session

February 27, 2004 at 1:00 PM
Town Hall
363 North Main Street
Fort Bragg, CA 95437

Field trip: On February 28, a field trip is planned on JDSF to allow for the Board to visit various places of interest. The itinerary has not been finalized. The public should expect to provide their personal transportation and food, and to carpool to minimize traffic.

Field Trip

February 28, 2004 at 8:00 AM
JDSF Headquarters
802 North Main Street
Fort Bragg, CA 95437

Public scoping: a public scoping session will be held on March 12, 2004 in Sacramento. This session will allow for additional public comment to be received.

Public Scoping Session

March 12, 2004 at 10:00 AM
Resources Auditorium
1416 Ninth Street
Sacramento, CA 94244

                                                                      Email: board.public.comments@fire.ca.gov

Copies of the draft Management Plan may be viewed at the following CDF Offices:

802 North Main Street. (Hwy. 1), Fort Bragg, CA 95437 (707) 964-5674

17501 Highway 101 North, Willits, CA 95490 (707) 459-7414

135 Ridgeway Ave, Santa Rosa, CA 95402 (707) 576-2275

1416 9^th Street, Rm. 1506-16, Sacramento, CA 95814 (916) 653-8007

Electronic copies of the draft Management Plan are also available on the CDF website at