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I would also like to come talk to you with several members of the community. The community here, as you must know, is exceedingly unhappy with the way CDF has handled THP 352. We believe that the health and future of our watershed are at very great risk from Louisiana Pacific's long term management plans, as well as from THP 352. We would like the opportunity to explain our views, which we feel was denied to us in Second Review, and to discuss the new information which we have developed about THP 352 and its ridgetop environment.
In this letter, I would like to discuss these four additional topics: 1) new information
regarding the Cliff Ridge wildlife corridor; 2) new historical information - timber harvest plan
1-79-62M; 3) new information - cumulative effects; 4) new information - lack of public
access to information about THP 352; 5) an outline of our recommendations for THP 352.
1. New information: the photographs and the Cliff Ridge wildlife corridor
Mr. Petty's photographs establish that THP 352 is in error on a number of points regarding
its description of the late seral forest in the plan area, and its assessment of suitable wildlife
habitat for endangered species in the plan areas of THP 352 and the adjacent plan, THP 1
96-042 MEN. THP 352 is also in error in its cumulative impacts assessment section,
which fails to take into account the cumulative impact of THP 352 and THP 042 in
fragmenting a continous wild life habitat corridor that stretches for several miles along the
top of Cliff Ridge, and straddles two watersheds.
We have previously noted that the old growth Douglas Fir portion of THP 352 Unit 6 is designated as a late seral area in Map 15 of L-P's Sustained Yield Plan for Greenwood Creek, in contradiction of THP 352 which states that it is not so designated. We have recently discovered in Map 15 of the adjacent Elk Creek watershed (to the south) that the late seral portion of THP 352 Unit 6 is connected to, and contiguous with, a much larger SYP late seral designation area south of THP 352 Unit 6 just over the ridge in Elk Creek watershed. This late seral forest not only extends along Cliff Ridge to the east outside the Unit 6 area, but also it crosses the ridge from one watershed to the other. If you look at these two SYP watershed maps together--upper Greenwood Creek and upper Elk Creek- you see that the late seral forest in question is clearly much larger than 20 acres in size, and is clearly connected to, and contiguous with, the THP 352 Unit 6 old growth area.
Please see Map Atlas, Sustained Yield Plan for Coastal Mendocino County, Vol. 5,
Greenwood Creek (Louisiana Pacific). We are told that this Map Atlas is available at CDF
offices. We will bring a copy of the Map Atlas with us. These maps and Mr. Petty's
photographs corroborate that THP 352 is in error, and that what THP 352 proposes is to
clearcut a portion of one of the last late seral forests in this region.
Mr. Petty's photographs also show a significant area of tall, straight, perfectly formed, old
growth Douglas Fir that are part of a multi-storied, continous canopy, with a thick understory,
and with the forest floor covered with large down woody debris, within THP 352 Unit 6. The
photographs directly contradict the description of Unit 6 given in THP 352. This area of Unit
6 furthermore contains at least one old growth Redwood tree of 5 feet in diameter.
The reason that this beautiful and significant old growth Douglas Fir forest was not
previously logged is that it was not part of the industrial ownership in 1979, when the
previous industrial owner, Masonite, took virtually every living tree of 16" DBH and above
over an area of 1,337 acres--the entire Big Tree Creek drainage. Unit 6, with its old
growth, was not included in the Masonite ownership, or they surely would have hammered
it as well. Which brings me to the logging history of Big Tree Creek and why, today, the
Big Tree Creek drainage mostly consists of 18 year old tanoak.
2. New historical information: THP 1-79-62M
I refer you to THP 1-79-62M, the Masonite timber harvest plan in 1979, which was the
subject of extensive public controversy, and which, as I understand it, is only available
now on microfiche. We believe that this timber harvest plan, and the plan that preceeded it,
by Crofoot in the mid-1960s, are critical to an understanding of what is occurring now in
the Big Tree Creek drainage.
In 1979, Masonite Corporation, the previous owner of the Greenwood Creek timber lands now owned by L-P, filed a timber harvest plan of 1,337 acres covering the entire Big Tree Creek drainage, and proposing what was then called "overstory removal," and what we might now call "high-grading." "Overstory removal" consisted of cutting everything larger than 16" DBH. Please read this plan, and pay particular attention to the part where then CDF Resource Manager Ross Johnson states the following:
There was a big public outcry over the Masonite logging plan in 1979, which caused the Regional Water Quality Control Board, the Department of Fish and Game, and what was then called the Department of Conservation: Division of Mines and Geology, to take a look at the plan. Virtually everyone who did visit the plan area (except CDF) commented at length on the hammering that this area had taken prior to Masonite--from the Crofoot logging in the mid-1960s and earlier--and on the numerous erosion problems that had been caused by roads and skid trails in and around the Big Tree Creek stream system.
In 1979, CDF and Masonite treat with contempt the effort by the Regional Water Quality Control Board to get a handle on the cumulative impacts on water quality of 1,337 acres of tractor logging in an already heavily hammered watershed. Frank Reichmuth of the RWQCB makes the noble gesture of non-concurrence. He is ignored by CDF--just as, today, with regard to THP 352, CDF's Jack Marshall largely ignored the recommendations of Water Quality's Andy Baker including Baker's request to be present during Second Review. Also note, in the old THP record, the plaintive cry of Dick Moore who tries to get a word in edgewise for the Department of Fish and Game.
In a curious replay of recent history, the public interest group, which was called the Greewood Creek Watershed Association, represented by Richard Kossow, complains bitterly about the lack of public notice and the inability of the public to get hold of the fast moving timber harvest plan review process, for a plan that they fear will devastate Big Tree Creek. Kossow writes, as one of his reasons for opposing the plan, his fear of the "diminution of the water quality and fish habitat of Greenwood creek." He was also concerned "That operations under THP 1-79-62M will result in extensive soil erosion, soil nutrient loss and regeneration problems in barely recovering timberland, leading to a reduction in its "sustained' ability to produce timber in the future."
Mr. Kossow, Joe Citizen, was right. Ross Johnson of CDF was wrong. None of the hand
wringing of Water Quality or Fish and Game had any affect. The decline of the Coho Salmon
was accelerated at that time, and continued unabated to its near extincton today, in 1997. Big
Tree Creek was hammered once again. All of its big trees were taken--except those up on Cliff
Ridge which were not yet part of the industrial ownerhip. Now they are. And Big Tree Creek
is about to lose not only its fragile covering of young tanoak, but also its very last big trees.
Please review this old history. It is critical to an understanding of current conditions. In
the current logging plan, THP 352, RPF Gerald Garvey mentions this old timber harvest
plan, THP 1-79-62, but he does not tell you what happened as a result. He does not
provide you with clear, detailed stand information on any of the five clearcutting units in
the current plan, because, if he did, you would have to deny this plan. He furthermore
says that L-P intends to re-plant with conifers after the clearcutting. Masonite also tried re
planting. It's mentioned in THP 1-79-62. What happened to those conifers?
3. New information: cumulative effects
Another fact emerging from Mr. Petty's study of this ridgetop ecosystem is that the old
growth trees in both THP 1-97-352 MEN and THP 1-96-042 MEN have suffered a drastic
reduction in growth since the mid-1960s. The rings of an old stump in THP 352 and of a
freshly cut stump in THP 042 reveal that soil and moisture conditions have dramatically
changed in the last 30 years. All of the early rings, to about 1965, are a quarter inch thick;
all of the later rings are very thin. What this may mean is that the ecology of this ridgetop
forest has been unalterably changed, and will never again grow trees of this girth and
height. Is this not a cumulative effect?
When do cumulative effects kick in, do you think? At the point at which there are no more old
growth trees in the watershed? No more second growth trees? No more multi-storied canopy?
All thirty-year old trees? All tanoak? Fifty Coho Salmon in the stream system? Twenty? Ten?
All that we have ever asked of CDF, and of L-P, is that the cumulative effects of logging in
Greenwood Creek watershed be adequately assessed and mitigated. This is why we
submitted to you the court records of Superior Court case no. 60728, in regard to the
current THP 352. We feel that the questions raised by our 1990 lawsuit on previous timber
harvest plans have not been answered, and it appears to us that CDF has no memory--no
sense of the true history of this watershed.
CDF is the agency that approved the 1979 timber harvest plan that left the Big Tree Creek drainage unloggable by 1997 rules. Indeed, the 1979 plan was applauded by Ross Johnson who now holds a very high position within the agency. And now we have to listen to this again--that they're going to re-plant conifers and "enhance" the area.
In the "alternatives" section of THP 352, L-P states very plainly that their one and only purpose in clearcutting this area is economic--to supply logs to the mills. They have no other purpose. To do it, they have to average the old growth on top of the ridge with the young tanoak in separate stands below--a clear subversion of the rules.
4. New information: public access to records and documents
We have two new questions for you regarding the public process for review of THP 352.
Our review of the public record so far for THP 352 indicates that there is no document in
the record stating what occurred during First Review, which presumbly took place between
August 25, 1997, when the plan was accepted for filing, and--coming very quickly upon
that--the Pre-Harvest Inspection on the day after Labor Day, September 4. Very important
decisions were made during First Review, regarding what questions should be asked
during the Pre-Harvest Inspection and who should attend. How can the public review
those decisions with no written record of that proceeding?
Secondly, we notice that RPF Gerald Garvey's signed response to CDF's Second Review recommendations is stamped as received by CDF-Santa Rosa on September 22, 1997. However, someone has written in, under the stamp, "Faxed 9-19-97." Other such notes are initialed in the record. Why is this handwritten amendment not initialed? Who did this?
CDF's Second Review recommendations, written by Jack Marshall, were not received by the CDF-Santa Rosa office until late in the afternoon of Monday, September 22, 1997. You will recall that Second Review occurred on Thursday, late afternoon, of September 18. Close of public comment occurred the next day, on Friday, September 19. We reviewed the public record that afternoon, Friday, September 19, about 3:30, one hour before the office closed. We have copies of what was in the record at that time. Gerald Garvey's signed response was not in the public record at 3:30 on the afternoon of close of public comment (9-19-97).
So, what is going on here? How can all this have occurred in such a short time? And, what is more important, how could the public review and comment on this critical document from Gerald Garvey, if he faxed it to CDF-Santa Rosa within the last hour before close of public comment, and if--as we are told repeatedly by the office staff in Santa Rosa--faxes are routinely put aside for later filing and are not placed into the public record in a timely manner? Furthermore, while public comment closes at 5:00 pm, the office closes at 4:30--meaning that this fax could have been received in the half hour during which the public is not admitted.
CDF Second Review recommendations were not received by CDF-Santa Rosa until late in the
afternoon of 9/22. Those recommendations contained significant changes in the
recommendations of Regional Water Quality's Andy Baker. Gerald Garvey responds to the
CDF recommendations on 9/19--three days prior. Very puzzling. And we, who sat through
four and a half hours of Second Review, have no chance to see or to comment on those
changes. Gerald Garvey responded to them before they were submitted into the record; neither
document was available to the public until the Monday after the close of public comment.
For the record, we would like to state that we strongly object to CDF's changes to Andy
Baker's recommendations. Baker wrote them down, and they stated that the entire haul
road should be included in the THP, to Signal Ridge Road, and that the fish-bearing pond
adjacent to clearcutting Unit 1 should be given Class I protection.
Please see attached Schoen v. CDF, Part 2 (11 pages), the result of a recent Appellate Court re-hearing on the issue of CDF's obligations under CEQA to provide the public with important timber harvest plan review information during an open public comment period.
5. Our recommendations for THP 352, THP 042 and the SYP
The truth is that THP 352 shouldn't be logged at all, and it most certainly should not be
clearcut. Re-planting of conifers didn't work in 1979, and it isn't going to work now. The
four units aside from Unit 6 do not have a stand age anywhere near 65 years old and do not
qualify as a clearcut under the Option C rules. The Unit 6 old growth Douglas Fir is part of
a larger and very significant and rare late seral forest and wildlife area, not to mention a
public viewshed. Big Tree Creek should be left alone to heal, and its only remaining old
growth on top of the ridge should not be clearcut.
This fragmentation of what has become extremely rare endangered species habitat in Greenwood Creek watershed is a violation of the federal Endangered Species Act. These timber harvest plans, 352 and 042, were not reviewed for wildlife habitat. The California Department of Fish and Game did not attend either Pre-Harvest Inspection. No Marbled Murrelet survey was done. No plant survey was done. A host of other sensitive species were ignored (such as the 50+ species of cavity nesters) or were given a slapdash, confusing and contradictory dismissal, such as the Northern Goshawk.
The plan-writer's consideration of wildlife species and habitat in the THP 352 and 042 documents is entirely inadequate, filled with boilerplate and sometimes just plain wrong. Read the Goshawk description and try to make sense of it.
The ESA is further violated, in both THP 352 and THP 042, by the inadequate protection that these plans afford to the newly listed Coho Salmon populations of Greenwood Creek and its tributary, Big Tree Creek. These two plans contain extensive road construction and reconstruction, with one part of the road system (Road 2, in THP 352) curving up an extremely steep slope for most of its length. The bottom part of this road has collapsed into Greenwood Creek, creating an open wound of sediment pouring into the Coho Salmon fishery. This slide is not mentioned in THP 352.
Last year, Water Quality's Christine Wright-Shacklett, during Second Review of THP 042, required a bridge for the crossing of Greenwood Creek to Road 2. She had not (and has not) visited the plan area. She spotted the wet crossing of this Class I salmonid stream in the written plan. That mitigation was well and good, but yet the re-opening of the road has apparently caused a major slide into the Creek. The road is very steep and crumbly. It should be shut down.