July 16, 2007
Board of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244-2460
Re: Recirculated Draft Environmental Impact Report
Sch # 2004022025 – JDSF
Dear Members of the Board of Forestry:
I want to take this opportunity to address you
frankly. Alternative G represents a great stride forward towards resolving
the controversy that has shut down operations in Jackson State Forest
since 2001. But, as published, it fails in important respects to provide a
workable solution to restoring operations in the forest. I believe that
the board and the department share my desire to see operations resume. My
comments are aimed at assisting the board to make the modifications
necessary to allow all parties to move forward cooperatively.
Incorporating the Recommendations of the Mendocino Working Group in
The Mendocino Working Group provided a set of
consensus recommendations to the Board of Forestry on November 30, 2006.
The group re-emphasized certain points relating to the advisory committee,
evenage management, and review of interim harvest plans in its letters of
February 28, 2007 and June 20, 2007, but all of the recommendations in
its November 30, 2006 statement of principles constitute an inseparable
whole of the group’s consensus agreement. It is the consensus as a whole
that provides the basis for avoiding further conflicts and delays in the
resumption of operations in Jackson Forest. All parties compromised to
reach a workable agreement. Deviating from this agreement risks a
breakdown of the entire agreement. As issued, Alternative G fails to
fully reflect the working group’s consensus recommendations. Alternative G
should be revised include all of the group’s
I note that Mendocino Board of Supervisors
unanimously voted to support Alternative G, with the modifications
recommended by the Mendocino Working Group.
Research and Future Conditions
I concur with listing research and demonstration as
the first goal for the forest. However, it needs to be clearly stated that
R&D activities will be chosen and implemented in the context of the second
and third goals for the forest: Forest Restoration and Ecological and
Do any of you doubt that the major research and
demonstration need is on how to restore the ecological health of cutover
We have had ample demonstrations of large-scale
clearcutting and evaluation of their impacts. We don’t need any more
demonstrations of evenage management in redwood forests. We need to
develop better understanding of how to manage forests in ways that are
economically viable and reverse the negative ecological and aesthetic
impacts of previous industrial logging on coastal redwood lands.
With the above in mind, the first Objective under
Goal #1 – Research and Demonstration should be:
of how to manage coastal redwood forests in ways that improve forest and
watershed ecological health and opportunities for human enjoyment, and
that are economically viable.
The current first “Objective” should be deleted:
Maintain a diverse,
dynamic matrix of forest habitats and seral stages to provide broad range
of forest conditions available for research and demonstration.
This is not an objective of the research and
demonstration program. Rather it relates to developing goals for future
conditions of the forest, and these goals for future conditions need to be
developed in the context of all of the goals for the forest: research,
restoration, ecological and watershed processes, timber management, and
recreation and human enjoyment. The inclusion of the above objective is
particularly objectionable because it is used, without any justification,
in the section on future conditions as the primary guiding principle.
The current fourth “Objective” should be modified:
Design a range of
demonstrations and comparisons on ecologically beneficial forest
management practices to serve a broad set of clients such as
conservation-oriented, restoration-oriented, small landowner, and
intensive production approaches to forest management industrial timber
All research and demonstrations should be done
within the context of improving understanding and adoption of ecologically
beneficial management practices. “Intensive production approaches” should
not be included for their own sake, but only if they serve the primary
purpose of furthering ecologically beneficial forest management.
Alternative G proposes performing substantial
even-age and group-selection management solely to provide “a broad range
of forest conditions for research and demonstration.” This is incompatible
with the goals of restoration and ecological and watershed processes,
unnecessary, and illogical.
There is no role for evenage management in
ecologically beneficial management of redwood forests; thus there should
be no need to do any research involving this management method. If
research requires evenage stands as controls, there are plenty already
available in Jackson Forest and even more on lands now under the control
of conservation organizations.
In its letter of June 20, 2007 to the Board of
Forestry, the Mendocino Working Group recommended a process for
determining the extent of evenage management that could be justified for
future research. This recommendation should be incorporated in Alternative
Group selection may have a role in ecological
forest management, but it should not simply be used as a matter of course
to create “future research opportunities.” The Mendocino Working Group
Group selection plots
will be the minimum size consistent with wildlife concerns and obtaining
regeneration, they will only be used when justified as the most
ecologically beneficial way to obtain needed regeneration and or habitat.
This principle needs to be explicitly incorporated
in Alternative G.
Forest Structure Goals
The forest structure goals, as described on pages
II-6 through II-8, need to be revised to reflect the preceding discussion.
Even within the context of Alternative G as written, the operative
statement on page II-6 is clearly unsupportable:
The major purpose of the forest structure
condition goals is to provide forest stand conditions and management
histories in the Forest suitable to a wide range of research
investigations and demonstration opportunities, as well as a broad range
of valuable habitats.
The second and third goals listed are forest
restoration and ecological and watershed processes. These should be the
primary determining goals for future conditions. As argued above,
appropriate research and demonstration activities would be complementary
to and not antagonistic to these goals. Alternative G needs to be revised
to reflect these understandings. The above cited sentence should be
condition goals should be determined primarily by the goals for forest
restoration, ecological and watershed health, wildlife habitat, and
recreation and human enjoyment. Research and demonstration activities
should generally be complementary to these goals. Where research requires
activities that are antagonistic to these goals, these activities should
be explicitly justified, be of minimum size for scientific validity, and
be reviewed by the advisory committee.
Tables II.1 and II.2 need to be revised to reflect
the change in goals for future conditions. The best way to do this is to
provide the following footnote to each table:
The numbers in this
table are subject to review and revision in cooperation with the forest
advisory committee during the initial implementation period.
Initial Implementation Period
An initial implementation period is discussed
beginning on page II-12. Changes in this section are essential to bring
this in line with the consensus recommendations of the Mendocino Working
Group. I incorporate in my comments by reference the letters and
attachments from this group to the Board of Forestry, dated November 30,
2006, February 28, 2007, and June 20, 2007.
The group re-emphasized certain points relating to
the advisory committee, evenage management, and review of interim harvest
plans in its letters of February 28, 2007 and June 20, 2007, but all of
the recommendations in its November 30, 2006 statement of principles
constitute an inseparable whole of the group’s consensus agreement. It is
the consensus as a whole that provides the basis for avoiding further
conflicts and delays in the resumption of operations in Jackson Forest.
Alternative G should be revised include all of the group’s
Interim Period Length: An important
recommendation, emphasized in the letter of February 28, 2007, should not
The MWG is concerned
with the language suggesting the initial period will sunset no more than
36 months after approval of the Forest Management Plan by the Board. We
agree that 3 years should be more than adequate to bring this to
resolution, but we don't feel a specific ending time for the initial
period should be set. … The initial period should continue until the
revised plan is submitted to and approved by the Board of Forestry.
A fixed deadline could create perverse incentives
to delay the development of a revised management plan. Please amend
Alternative G as above.
Interim Period Harvest Limitations: The
Working Group proposed and reemphasized in its letter of February 28, 2007
that interim harvest should be limited to generating the amount of revenue
to restore and enhance
staffing, remedy the more significant environmental problems on the
forest, initiate a wildlife inventory, a botanical inventory and generate
a reviewed and verifiable forest inventory…
Alternative G does not contain any reference to
limiting harvest during the interim as recommended. This limitation on
harvest amount is a key part of the group’s consensus agreement and should
be explicitly stated within Alternative G.
Interim Harvests: The working group restated
its understanding of the kind of harvesting that should occur in the
interim period in its letter of February 28, 2007:
Our proposal for this
initial period envisioned low impact harvesting in non-controversial
Not all of the proposed harvest plans in Table II.3
are in non-controversial areas. All potentially controversial plans should
be mandated to be reviewed by an advisory entity, preferably the advisory
committee for Jackson Forest, as proposed by the working group in its
letter of June 20, 2007.
Jackson Forest has been subject to increasing
controversy for over a decade and had its timber operations shut down
since 2001. All parties are close to agreement on a plan and process for
resuming operations and minimizing controversy. I urge the board to use
its authority to make the few but essential changes needed to move forward
Vince Taylor, Ph.D.