Campaign To Restore Jackson State Redwood Forest
100 Manzanita Street
Fort Bragg, CA 95460
October 30, 2002
Members of the Board of Forestry
Fax: 916 653-0989
Dear Board Member,
I am the Executive Director of the Campaign to Restore Jackson State
Redwood Forest. I am writing to request your help. I, along with many
other well-informed people both private and within agencies, believe that
the proposed management plan for Jackson State Demonstration Forest
proposes timber operations that are needlessly destructive of rare
ecological and recreational values:
- CDF has refused to refrain from logging in the remaining unentered
stands of second growth, even though these have enormous potential
value as the core of a future sanctuary for species dependent on
old-growth redwood forest. The timber in these stands will continue to
grow and appreciate in value, thus there would be no economic loss in
deferring timber harvest in them until a later date. But there will be
a substantial, irreparable ecological loss from harvesting them.
- CDF has refused to budge from its historic emphasis on even-age
management and its ecologically destructive variant, group selection.
CDF proposes to apply these two silvicultural practices to one-half of
the forest. This is bad forestry that has no justification, other than
reducing the cost of operations and increasing profit. As a member of
the Board of Forestry you have both the opportunity and the
responsibility to prevent it.
On November 6, you will consider whether or not to approve the
proposed forest management plan (FMP) for Jackson Demonstration State
Forest (JDSF). There are several grounds for delaying approval of the
management plan and asking CDF to make further revisions in it:
- Four thousand people wrote to CDF during the EIR comment period
opposing continued large-scale commercial timber harvesting and
supporting restoration to old growth as the primary goal for forest
management. Less than fifty people wrote to support the CDF management
plan. You are being asked to approve a plan that is overwhelmingly
opposed by the public. The public has sent a strong message to those of
you who are on the board to represent them.
- There is substantial evidence that the estimates of inventory,
growth, and allowable cut contained in the draft management plan are
seriously in error. My comments on the Draft EIR presented this
evidence. In its responses, CDF failed completely to provide a factual
rebuttal to my evidence and contentions.
This is no small matter: If I am right, the inventory and growth
estimates are 50% greater than the actual forest numbers, and the
allowable cut seems likely to also exceed harvestable growth by 50%.
If I am correct, the proposed timber operations will greatly
decrease the timber inventories within the areas where unrestricted
harvesting is permitted. This would be directly contrary to state law
and Board policy.
I beg of you to take a look at the evidence that I presented in my
comments and judge for yourself whether or not there are serious
questions that need to be definitively resolved before approving the
CDF management plan. I have a Ph.D. in Economics from MIT, and I
performed complex empirical, mathematical and statistical analyses over
a period of twenty years. All of my experience cries out that the
inventory estimates in the management plan are seriously in error. You
can easily understand the reasons yourself by looking at my comments on
the EIR. A copy of my comments in PDF format is available at
They are also in the final EIR, Section IV, p. 265ff. I will be happy
to answer any questions about them.
Approval of the management plan should be delayed until the controversy
over the correct inventory estimates are resolved by an independent,
unbiased third party.
- A legal challenge against the EIR has been filed. This challenge is
well founded, as you will be able to determine yourself by reviewing
the comments on the EIR submitted to CDF. The EIR is most certainly
illegal in its failure to address cumulative impacts in a coherent,
organized fashion, as required by CEQA (see the EIRcomments by Paul
Carroll). Additionally, though, the DEIR failed to properly evaluate
the potential impact of timber operations on a variety of endangered
animal, fish, and botanical species. It also failed to evaluate the
management plan in the context of the landscape within and surrounding
Jackson State Forest.
To approve the management plan when the EIR on which it depends is
clearly legally flawed would reflect badly on the Board.
- In the opinion of our lawyer, Paul Carroll, the Board of Forestry
has the legal responsibility for certifying the EIR, a responsibility
that cannot be legally delegated to CDF. As a Board member, you
therefore have a special responsibility to make your own determination
about the adequacy and legality of the final EIR.
Experts submitted to CDF nearly a thousand pages of comments on the
DEIR, together with many more pages of supporting documentation. Most
of these comments were highly critical of the adequacy of the DEIR and
the management plan. Although CDF rejected almost all of the critical
comments in its final EIR, this does not mean that it did so on
adequate grounds. As you know, a suit has now been filed alleging that
the EIR is legally deficient. In your position as a Board member, you
have an obligation to form your own independent opinion about the
validity of the expert comments, the adequacy of CDF’s responses, and
the legality of the EIR.
Before making this decision, please make yourself fully aware of
information presented to CDF as part of the Draft Environmental Impact
Review (DEIR) and FMP review. Because CDF assumed the responsibility
for preparing and certifying the EIR, you may not have seen information
that is critical to your ability to make an informed decision.
Reviewing the EIR material will obviously take considerable time. The
Board does have the time to consider this matter deliberately. Logging
cannot begin in Jackson State until April 15. Delaying a decision until
Board members perform an independent review should not cause any delay
in the resumption of timber operations in Jackson State.
Separately, I want to bring to your attention an important omission in
the new management plan: the lack of any definition of allowable cut over
a multi-year period. The 1983 Management Plan stated that average
harvests within a five-year period would not exceed five times the annual
allowable cut. This rolling average provided an important constraint on
timber harvests in the late 1990’s, after several years in a row where
actual harvests exceeded the allowable cut by 50%. The new plan is silent
on this subject. Does this mean CDF will not exceed the allowable cut in
any year, regardless of harvest levels in preceding years? Or what does
The Board should ask CDF to put into the management plan a specific
method of calculating the allowable cut over a period of years. This is
especially important, given the reduced timber harvesting in the last two