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Conservation Issues of the Ventana Chapter | santa cruz county

Forestry Updates

by Jodi Frediani
August 2010

1. San Vicente Creek remains on 303(d) List
2. SDSF Fern Gulch THP – challenges agency recommendations
3. SDSF Rim THP – Green House Gas Calculator?
4. Grizzly Flat NTMP - CAL FIRE is not pleased
5. Grizzly Flat Public Hearing coming up
6. August 17 talk on Lompico Forest Carbon Project - free
7. Forest Stewardship Council and Marine Stewardship Council

1. San Vicente Creek remains on 303(d) List

On August 4 the State Water Quality Control Board heard testimony from two Big Creek RPFs, Cemex' PR spokesman and their RPF, as well as the President of the California Forester's Association all in support of delisting San Vicente Creek for sediment impairment. These speakers also cried crocodile tears with claims that having the sediment source listed as 'silviculture' tarnished Cemex' pristine environmental record, that it would create problems for industry in the cumulative impact assessment for THPs, as well as forcing stronger restrictions on logging under the Forest Practice Rules. Judge for yourself whether these claims hold muddy water.

The staff recommendation was to keep San Vicente Creek listed. They were supported by the EPA, Heal the Bay and Coastkeepers Alliance. I spoke on behalf of CCFW and Sierra Club reminding the Board that residents of Davenport were under a 'boil water order' each winter when the listing was enacted. I also reiterated comments made by NMFS in their letter that 1) coho are listed as endangered, 2) San Vicente Creek is a key recovery watershed for coho, and 3) NMFS has begun restoration activities including dredging sediment from the off-channel ag pond which currently serves as good rearing habitat for coho.

I let the Board know that NMFS just completed a habitat assessment in July on San Vicente Creek, but the results have not yet been compiled. Oh, and I reminded them that the public review process had been violated when Regional Board staff felt compelled to review the delisting request that had come in months after the deadline for such submissions.

After much discussion, the Board voted unanimously to keep San Vicente Creek listed as impaired for sedimentation, but in a nod to their timber industry friends, they removed 'silviculture' as the source and changed the source to 'unknown'.

In their continuing attempt to get this waterbody delisted, Redwood Empire has already submitted additional turbidity data (including summer months) for the next round, the 2012 303(d) list. The deadline for submission of proposals is August 30. We are curious about Redwood Empire's interest, since they have never logged this watershed. The timberland is largely in Cemex' ownership. Forested portions of upper San Vicente Creek were burned in the Lockheed Fire last summer and are being extensively salvage logged under an Emergency Exemption operated by Big Creek. Normal rainfall this coming winter could send a deluge of sediment into the creek. And while turbidity readings during the past dry years have been low, low rainfall will have done little to move existing sediment through the system.

2. SDSF Fern Gulch THP – Challenges agency recommendations

The RPF for the state's Fern Gulch THP recently submitted a 140-page response to the second PHI comments. That brings the number of pages submitted to date (including hundreds of 'change pages') to something like 900. I was recently offered a complete set of documents from CAL FIRE for only $90. But I was also informed that, "We normally don’t pull together a complete “as is” document with all duplicate pages pulled prior to the completion of 2nd Review."

What this means is that CAL FIRE is not working from the latest revised version of a THP when attempting to ascertain if it is compliant with the Forest Practice Rules. In this case, CAL FIRE notes that there are 575 pages in the original submitted THP and estimates there are 300 revised pages. How can anyone keep track of completeness, contradictory statements, etc.? I'm guessing they can't.

In this latest submission, the RPF has rejected some of California Geological Survey's (CGS) mitigations for hauling logs over a section of the main haul road with a bank failure. A previous CGS report noted that the road prism at the site of the failure is just 9 feet. The plan proposes to haul somewhere between 585 and 2000 log loads. (Yes, one of the little contradictions.)

DFG and the County have insisted the failure should be repaired. CGS has allowed that trucks can pass as long as they come to a complete stop, cross the section in question at no more than 5 miles per hour, and 'Full time monitoring of the road surface opposite the stream bank failure shall be required. Monitoring shall be conducted by a licensed forester, engineer, or geologist."

However, SDSF's RPF says it is 'not practical' and instead proposes to have the road subgrade inspected only twice weekly by a licensed forester, engineer or geologist, and that the LTO will "designate someone" to inspect the site twice daily looking for evidence of tension cracks, etc. He also proposes, "installing a low-tech visual indicator such as a fiberglass rod with a flag into the bank's edge. This indicator flag would project out from the bank for at least 6 feet at no more than a 45-degree angle. This flag would exaggerate and display any ground vibration or movement." And when the truck driver sees the flag moving too much (?) as his 80,000 lb. load traverses the narrow 'bank failure' road segment on the edge of Soquel Creek, what then?

SDSF continues to refuse to repair the bank failure or install a permanent bridge across Soquel Creek, or agree to DFG's request to stop using the wet ford crossing of the creek. The RPF is also argumentative regarding the County's comments on Cumulative Impacts and complains that SDSF is being singled out. Well, if the State can't follow their own rules, then who else can be expected to?


3. SDSF Rim THP – Green House Gas Calculator?

In response to AB32, CAL FIRE has finally prepared a Green House Gas Calculator, which is currently available for public comment, but is also available for use by RPFs in THPs. Helge Eng, CAL FIRE head of State Forests, recently submitted a Green House Gas Analysis for the SDSF Rim THP, after Sierra Club and CCFW submitted a comment letter that no GHG calculations had been included in the plan, as required by law.

Unfortunately, CAL FIRE has provided no guidelines for interpreting or even understanding the Calculator. We have no idea how the data that is input is compiled, nor are the end results comprehensible. Hardwoods have not been included in the calculation, though we understand that some hardwoods will be managed. Soil carbon loses have not been tallied either, even though scientists claim that carbon loss from soil disturbance can be significant. They do not seem to be part of the Calculator. The Rim THP refuses to designate tractor trails, allowing for tractors to traverse the whole forest 'as necessary'.

The take home message we got from the narrative accompanying the Calculator was this comment:

"Since the net amount of carbon that would be sequestered under the project is greatly higher than the amount of carbon that will be released by management activities, there are no potential significant adverse environmental impacts, single or cumulative."

And I thought you were supposed to compare the carbon lost to the original amount of carbon sequestered before harvest.....


4. Grizzly Flat NTMP– CAL FIRE is not pleased

In a very technical review of the stand structure on the City of Watsonville's NTMP (dubbed the Eureka Canyon Forest NTMP) on their Grizzly Flat watershed lands, CAL FIRE's Sustained Yield Forester essentially takes the plan RPF to task. This NTMP was submitted in 2008 and the RPF is still arguing with CAL FIRE about some of the basics of stand structure required to be identified by the NTMP rules for long-term forest management.

Here are a few quotes from CAL FIRE:

"The RPF's reply is viewed as non-responsive as the amended information does not comply with the rules as statements and the limited amended information continues to be based on unsupported representations by the RPF."

"The RPF's reply is viewed as non-responsive as direct responses to the original February 12, 2009 question and the June 18, 2009 follow-up question appear to have been avoided."

"The RPF's reply is viewed as non-responsive. An evaluation of the pre- and post-harvest stand tables indicate that the post-harvest basal area density would be reduced to roughly 130 sq. ft./acre. As currently written, Section II would permit harvesting to reduce stocking across the plan area to 75 sq.ft./acre."

"After further consideration following our discussion during the PHI, I remain skeptical that harvest activity as described by the RPFs and LTO will prevent Group B species from increasing density representation in the stand."

"...confounding the inventory data in this NTMP is that the data represents unique stands that vary significantly by density, composition, and site productivity which have been homogenized together to represent that the NTMP is characterized by a single stand type." Me thinks this may be related to the fact that according to the current RPF, there is no Late Seral Forest (LSF), though we were assured that after the last harvest, LSF would still remain.

We think the City of Watsonville may not be getting their money's worth. They certainly aren't likely to begin harvest any time soon. 20100802_1-08NTMP-010SCR_ADD-PHI-CDF-1.pdf


5. August 17 talk on Lompico Forest Carbon Project - free

Tuesday 8/17 7 PM at Peninsula Conservation Center (PCC), 3921
East Bayshore Road, Palo Alto, CA

Laura McLendon, Sempervirens Fund, will give a presentation on "Sempervirens Fund's Lompico Forest Carbon Project".

This is a pioneeringinitiative that demonstrates the importance of forest preservation incontrolling climate change. Located on 425 acres in the Santa CruzMountains, the Lompico forest naturally sequesters massive amounts of carboneach year. Sempervirens Fund is ensuring the future of this forest's carbonbenefits to our earth and our atmosphere by purchasing property rights thatwill permanently prevent future subdivision or development of the property. To support this purchase, Sempervirens Fund is selling greenhouse gasemissions reductions, or carbon credits, on an annual basis as the treescontinue to grow. The project, which follows stringent standards of carbonaccounting set forth by the Climate Action Reserve, allows largeorganizations who buy the carbon credits from Sempervirens Fund to join thefight against climate change and reduce their carbon footprint." (Read more at

The Lompico Forest Carbon Project actually saves trees from being logged --- not just logged less - but logged at all. This project is one of the first ones to navigate the state's project to buy and sell carbon credits. Come hear Laura's experience with pioneering the state's new and developing process.

6. Grizzly Flat Public Hearing coming up

The County is requesting a Public Hearing for the City of Watsonville's Grizzly Flat NTMP. The Santa Cruz Sentinel plans to have a reporter on hand at the hearing. I will let people know when the date is set. PLEASE PLAN TO ATTEND.

7. Forest Stewardship Council and Marine Stewardship Council

The Forest Stewardship Council (FSC) and the Marine Stewardship Council (MSC) have much in common. Both are supposed to be independent certifiers, one of forest products, one of fish and ocean products. However, both have come under fire for certifying companies and practices that some of those in the environmental community do not consider sustainable.

Folks have criticized FSC for certifying forests that allow clear cutting and that harvest old growth trees, including old growth redwood. Other criticisms have to do with human rights issues in third world countries.;

You can check out info on the clear-cutting of Massachusetts public forests by an FSC certified timber company here:

" The more than half million acres of Massachusetts Public Forests, including the Savoy Forest, were certified by Scientific Certification Systems Inc, in August 2004. SCS evidently had difficulty in massaging the state public bodies through the certification process: of the 17 'conditions' which SCS had attached to the certificate between 2002, when assessment began, and 2004, only two conditions had been 'closed out' by the time the certificate was issued. SCS's Public Summary Report of the certificate reveals that, at the time of certification, the various public bodies responsible for managing forestlands had no landscape level forest management plan, very few actual forest management plans, no means of identifying or delimiting areas of High Conservation Value Forest, had no credible calculations of annual allowable harvest, and had failed to identify, designate, or map representative ecological reserves."

The Pew Environment Group criticized the decision by MSC to certify Antarctic krill. Krill is the critical food source for penguins, seals and many species of whales that feed in the Southern Ocean, surrounding Antartica.

Pew Faults Marine Stewardship Council's Decision

"Sustainable" label for Antarctic krill fishery is misleading

WASHINGTON, May 25 /PRNewswire-USNewswire/ -- The Pew Environment Group today criticized the decision by the Marine Stewardship Council (MSC) to certify Antarctic krill. The certification gives the false impression that the entire fishery for Antarctic krill is sustainable when in reality it is not.

Seafood with the MSC label implies that it has been caught in a sustainable manner and does not threaten the local marine ecosystem.

Krill are tiny shrimp-like crustaceans that serve as a critical food source for penguins, seals and many species of whales that feed in the Southern Ocean, the waters surrounding Antarctica. This new certification poses a serious threat to these and other Antarctic animals that depend on krill to survive.

Aker Biomarine, an integrated biotechnology company that catches and processes Antarctic krill, applied for the MSC label months ago. Fisheries seeking this distinction from the global seafood certifier undergo a review process. Aker operates only one krill fishing vessel in the Southern Ocean, but its certification by the MSC sets a dangerous precedent. While other companies operate krill fishing vessels around Antarctica, they have not yet approached the MSC for its sustainability label. This is the first time a krill fishery has been certified by the MSC.

"Unfortunately, perception is reality," said Gerald Leape, director of Pew's Antarctic Krill Conservation Project (AKCP). "The MSC's label falsely advertises the message that all krill are sustainably caught and that consuming krill-based omega 3 supplements or purchasing farmed salmon raised on krill meal is okay. Nothing could be further from the truth."

To date, there have been few studies on krill populations. However, the overlap between the fishery and krill predators is increasingly well documented.

"In its decision, the MSC ignored irrefutable evidence put forward by numerous stakeholders including prominent Antarctic scientists, climate change and forage fishery experts and environmental groups," said Leape.

I guess it pays to do your homework, rather than simply trust that certification systems are doing it for you.

Jodi Frediani
Central Coast Forest Watch
tel/fax 831-426-1697

Jodi Frediani
Chair, Forestry Task Force
Ventana Chapter, Sierra Club
tel/fax 831-426-1697

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