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Conservation Issues of the Ventana Chapter | santa cruz county

Forestry Updates

by Jodi Frediani
October 2009

1. CBD takes on Lagomarsino THP
2. Lockheed Fire Emergency Exemptions
3. AB 1066 Signed by Governor
4. New THPs
5. NMFS Coho Recovery Plan
6. 10,000 acre Timber Management Plans
7. Clearcut Nation
8. The Story of Stuff
9. The Tree

1. CBD takes on Lagomarsino THP 1-08-063 SCR

The Lagomarsino THP in San Mateo County is just 35 acres, yet it has stirred controversy. The plan contains 10 acres of old growth redwoods, plus residual scattered old growth trees. As recently as 2005, DFG said there were 30 acres of late seral forest (LSF) in the vicinity, including the old growth on the Lagomarsino property. Originally submitted in 2004, the plan was withdrawn so that a 2-year marbled murrelet survey could be conducted. No murrelets were found and now, for some unknown or undisclosed reason, the 30 acres of late seral seem to have vanished. (The FPRs only require mitigation for 20 or more acres of LSF.) The plan was resubmitted in 2008 and now proposes to harvest 32% of the old growth stems, many over 60" DBH. DFG wants all the old growth trees retained. According to DFG, "The THP provides no mitigation for the loss of these late seral habitat elements and high quality wildlife trees." In addition, "At a minimum to protect LSF habitat on-site and comply with FPR §§ 913.8(a) and 897(b)(1), the THP should be revised to include language stating that no trees exhibiting old-growth characteristics shall be harvested, no large woody debris shall be harvested and no snags shall be harvested (Recommendation 5)."

The DFG PHI reports are excellent resources on late seral forest habitat values:

Until August 2009, the plan neglected to mention that there were even any old growth trees on site, in spite of the fact that a murrelet survey had been conducted. There was a single mention in the murrelet survey prepared by the consultant.

The Center for Biological Diversity (CBD) has also taken notice. In a 31 page letter, CBD reminds CAL FIRE that the intent of the Forest Practice regulation can't be overlooked simply because one implementing rule is too specific to protect resources under CEQA, CESA and/or the ESA: "It should also be emphasized, as recently put by the Attorney General’s Office, that “the plain intent of the Legislature in enacting the [Forest Practice Act] was to require the Board to view the forests of the state as a complete working ecosystem, and not only as a producer of high quality timber, but also as forestlands valuable in their own right as a public resource."

"However, the FPA does not require that this balance be affirmatively struck in favor of timber production . . . . [B]oth CEQA and CESA assure that forest resources . . . be protected during timber operations and thus balance the Board’s authority to weigh too heavily in favor of timber production." Id. at 8 “The requirements of CEQA, CESA, and the functional equivalent certification of the THP review process all require that the Board consider and mitigate for adverse environmental impacts when making its decisions."

The bottom line as laid out by CBD is, "The Lagomarsino THP fails to meet the requirements of the FPA, CEQA, CESA, and ESA because it fails to adequately address the project’s impacts on late seral forest habitat and wildlife in the area."

CBD also points out the following from a DFG PHI letter for THP 1-08-116 MEN: "Trees in all size classes up to the maximum management diameter are normally retained in selection silviculture. Through successive harvest entries, trees specified for retention during prior harvests may be harvested in subsequent harvests. This approach does not ensure that retained trees and trees in the larger diameter classes will be allowed to eventually develop into snags or green wildlife trees. This allows depletion of late seral habitat elements over time as existing snags and senescing trees deteriorate or are lost to windthrow (Chen et al., 1995, Reid and Hilton 1988)."

CBD concludes, among other things, "Cal Fire must disapprove a plan that could jeopardize the continued existence of any endangered species (14CCR 898.2) and must make “mandatory Findings of Significance [when the] project has the potential to substantially degrade the quality of the environment; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below self-sustaining levels; threaten to eliminate a plant or animal community; substantially reduce the number or restrict the range of an endangered, rare or threatened species; or eliminate important examples of the major periods of California history or prehistory." 14 CCR 15065.

While addressing murrelets and other OG dependant species, including bats, spiders and other arthropods, CBD also points out the elephant in the room: carbon emissions.

CBD does a nice job of addressing industry's myths about old growth and carbon storage and sequestration. We learn (all with literature citations) that "older forests store the most amount of carbon and therefore their loss is significant", "[O]ld growth forests have an especially vast amount of live vegetation including huge trees, large downed logs, a healthy understory and a rich ground layer. Each of these elements stores considerable amounts of carbon and so it follows that ancient forests and trees are the 'banks' holding the most carbon." "'The theoretical maximum carbon storage (saturation) in a forested landscape is attained when all stands are in old-growth state (Nabuurs et al. 2007).'"

For a copy of CBD's letter, contact CAL FIRE or me. It's not posted on the ftp site.

Sierra Club and Central Coast Forest Watch have also submitted extensive comments. The plan is deficient in many, many ways. For instance, the Erosion Hazard Rating was miscalculated (four math errors) and should be High and Extreme instead of Medium and High. There is all kinds of conflicting information, slash will be burned or it won't, there are in-lieu practices or there are not, there are two watercourse crossings or there are three, there are slides or there are not, and there are archaeological sites or there are none, to name a few.

2. Lockheed Fire Emergency Exemptions

Cal Fire has prepared a Lockheed Fire Post Fire Risk Assessment with the help of Rich Casale of the NRCS, Nadia Hamey, Big Creek RPF, Grey Hayes, PhD, Ecological Consultant and Michael Huyette, CGS. Cal Poly and Big Creek helped with the extensive GIS mapping. 36% of the 19,001-acre Scott Creek Watershed was burned. Some of the subwatersheds, burned more extensively, like the Bettencourt Subwatershed with 99.8% area burned. 46.7% of Queseria Creek Watershed burned at High Severity, while 46.4% burned at Moderate Severity. This was probably the most severely burned watershed, though 31.8% of the Upper Scott Creek burned at High Severity with 52.2% burning at Moderate Severity.

Due to the significant area burned at either High or Moderate severity throughout the fire area, a good number of trees suffered scorched canopies (High) or some mortality (Moderate). As we learned in a Sentinel story during the recent early rains, some redwoods were falling down due to root fires still burning in the ground.

Now I have learned that Big Creek Lumber is intending to harvest 14 acres under an Emergency Exemption downstream from the Big Creek Hatchery. And they have even bigger plans. Big Creek will be submitting an Emergency Exemption in 2010, when such exemptions will be good for one year (they are currently only good for 120 days). Big Creek plans to do their harvest via helicopter. One can only imagine that this Exemption will cover significant acreage and steep slopes. Such Exemptions do not undergo the necessity of plan preparation and submission, or the scrutiny of Timber Harvest Review. The Emergency Exemption language (CCR 1052.1) says that the following constitutes an emergency, "Trees that are fallen, damaged, dead or dying as a result of wind, snow, freezing weather, fire, flood, landslide or earthquake." Talk about a loop hole.


3. AB 1066 Signed by Governor

Now that THPs can be extended for four years (past the initial three), we can expect to see more THP submittals and for larger plans at that.

The previous version of Section 4590 of the Public Resources Code allowed 3 yr THPs to be extended for two one-year extensions if operations could not be completed in a timely fashion. The new version will allow THPs to be extended for a maximum of 4 one-year extensions if two requirements are met and the plan expired in 2008 or 2009. The RPF must certify that 1) no listed species have been discovered in the logging area of the plan, and 2) significant physical changes have not occurred to the harvest area or adjacent areas since the original cumulative impacts assessment in the plan.

Plans that are approved in 2010 and 2011 may be extended for two two-year periods to complete operations. The RPF must certify the same two conditions apply as above.

There is no definition of 'significant physical changes.'

I understand that Duane Shintaku, Assistant Deputy Director, CAL FIRE, will be drafting a memo of clarification of the changes. Let's hope he helps us understand what significant physical changes look like.


4. New THPs

12 acre, Bushnell-Quigg Way, Gary Paul, RPF, Castle Rock Falls

Plan submission has been slow due to the economy and the low price for redwood. I do understand that the 2004 Dale Holderman NTMP has returned to active status, the 2004 SDSF plan may be resurrected, the YMCA Jones Gulch NTMP may also be coming back, and two new plans are slated for San Mateo County, one in Pescadero Creek watershed, one in Butano. Neither have been submitted to Cal Fire yet.


5. NMFS Coho Recovery Plan

As some of you may know, in recent times, money for salmon recovery has been spent largely on barrier removal and/or replacement projects. Some of these have been exceedingly expensive, as undersized culverts have been replaced with bridges or mega-culverts, ostensibly opening up more upstream habitat. However, many of these projects have been tied to improving access for property owners. In the meantime, large instream logs have been removed for 'flood' protection, and sediment input, as well as low instream flows, have often been overlooked or under-rated.

The following indicates a change in policy that many of us look forward to:

"With the upcoming coho recovery plan the National Marine Fisheries Service (NMFS) will be encouraging a change of focus for restoration projects. NMFS believes more effort needs to be focused on increasing survival and de-emphasizing increasing capacity - across the range of CCC coho. This is a major paradigm shift for many in the restoration community. Coho can get to where they need to get to; we do not need more ladders or culvert upgrades to move them further upstream (for most streams within the extant range). As you all know the habitats where coho persist are not at a properly functioning condition and we need to increase instream wood (particularly for Santa Cruz County), protect and recreate overwintering habitats, and protect instream flows. I am working on a couple of LWD projects in Mendo County where the landowners are simply felling trees into the stream channels (at 1.5 to 2x bankfull). Many of these types of projects are much less expensive than barrier modification and produce instant results. It is imperative for coho survival that the fishery community speak with one voice regarding the importance of these types of projects for Santa Cruz." - Jonathan Ambrose, NMFS

6. 10,000 acre Timber Management Plans

Remember last year's 10,000-acre NTMP bill? It would have allowed large non-industrial landowners to receive in-perpetuity timber harvest permits. This was not well received by the environmental community here in the urbanized forestland of the Southern Subdistrict and the bill ultimately died. The current acreage ownership is limited to 2,500 acres of timberland. North Coast forest advocates favor the larger timber management vehicles as they would prohibit clearcutting and require, they hope, better long-term management of timberlands.

Well, the bill has resurfaced with new clothes as a 10,000-acre Timber Management Plan. This would encompass industrial lands as well as those owned by timberland owners who are not also mill owners. The current draft proposal would require:

"A description of the carbon sequestration, watershed protection and wildlife enhancement developed by the plan, with projected volumes of carbon, an erosion control plan and anticipated wildlife habitats to be created by the timber management plan over time." The plan would be restricted to uneven age management and would be available for public review in 15 years.

Keep your ears open and your pen ready as new developments arise on this front.

7. Clearcut Nation

Wow, and I thought I knew all about clearcut practices. Think again. Chains on tractor tires for traction in a timber harvest area?

From Marily Woodhouse:

My group, has a DVD/video presentation, "Clearcut Nation" that is posted on YouTube now (3 parts). There is a link to it on our site.

Marily Woodhouse
(530) 474-5803
Sierra Club Organizer for the campaign to Stop Clearcutting California

Battle Creek Alliance

PO Box 225
Montgomery Creek, CA 96065

8. The Story of Stuff

While this is not strictly about forestry, how we treat the world through our consumption practices, impacts not only the forests, but the planet as a whole. Annie Leonard, who has worked on international environmental health and sustainability issues for more than two decades, has put together an amazing video about the production, consumption and disposal of all the stuff we consume. The graphics are great and I encourage you to take 20 minutes and watch it. Then share with your friends and family.

9. The Story of Stuff

Dana Lyons, singer/songwriter, has majestically captured the voice of an old growth tree in this haunting song, "The Tree". I first heard Dana sing around a campfire at a Coho Confab somewhere up north, a forest and rushing river near by. In early October, I had the good fortune of hearing Dana again, at the Wildlife Conservation Network Expo in San Francisco singing this wonderful, poignant tribute to our ancestors, the ancient ones. Jane Goodall, the keynote speaker, was truly inspirational in her presentation and ended by bringing Dana onstage to sing for the full house. I doubt there was a dry eye by the end.

Check it out:

And for the child on your Holiday gift list, the book from the song: The Tree


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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