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June 20, 2007
Board of Forestry and Fire Protection
PO Box 944246
Sacramento, Ca. 94244-2460
Attention: George Gentry, Executive Director
Re: Jackson Demonstration State Forest Management
Plan (Alternative G)
Dear Members of the Board,
The Mendocino Working Group (MWG) has been reviewing
and discussing Alternative G. Subsequent to our MWG meeting on Tuesday,
June 12, we decided it was appropriate to clarify our position on a few
issues.
As we stated in our
February letter we feel strongly the proposed Jackson Advisory Group (JAG)
is essential to the long term success of this Management Plan. For the
sake of transparency, credibility and effectiveness one advisory body
needs to be in a leadership role during the interim period. Our group
feels strongly this lead advisory body needs to be the JAG, in
consultation with the other groups. In addition, as the MWG suggested in
our February letter, we feel that the authority and effectiveness of the
JAG would be strengthened by being appointed by the Director and ratified
by the Board of Forestry. To maximize the effectiveness of the JAG, it
should report to the Director on forest management implementation issues
and to the Board on management policy issues.
Evenage management has always been a controversial
subject and we feel some clarification is warranted here also. A goal of
our recommendations is to provide the necessary flexibility for all
research projects. Nothing in our principle statements was meant to
preclude meaningful, scientifically designed evenage research projects
during the interim period or into the future, with the important condition
that the projects be of the minimum size required for scientific validity.
Some evenage management projects may conflict with
some of Alternative G's stated goals, such as promoting forest health and
ecological processes and providing enhanced opportunities for recreation
and aesthetic enjoyment. Further, evenage management is extremely
controversial within Mendocino County and the environmental community at
large.
We recommend that great care be exercised before
approving evenage management projects not directly tied to a specific
research project or justified for forest health. We recognize that not all
future research needs can be foreseen, but we feel that a workable
planning process is needed to assure that stand manipulation for future
research is appropriately balanced against the other goals for future
conditions. Therefore, we recommend that decisions on stand structure for
future unspecified research projects should be developed by JDSF staff in
cooperation with researchers, the Demonstration State Forest Advisory
Group (DSFAG) and, when functioning, the JAG. The amount of evenage
management should be the minimum that reasonably can be justified for
future research projects that can't presently be anticipated.
We note there has been no revision of Jackson’s
residual old growth harvesting policy, which differs in significant ways
from our recommendation. We believe review of this issue by the JAG is
necessary to minimize potential future controversy.
The last issue the MWG would like to address is the
short-term harvest proposal. We understood that the Board’s EIR
subcommittee accepted the MWG's concern that interim harvesting should not
preclude future planning options and agreed to our recommendations for
achieving this objective. We recommended that if THPs were to be proposed
for sensitive areas in the interim period that they should both 1)
meet the interim harvest restrictions, and 2) be submitted to the DSFAG
or, when operational, the JAG for review. CDF developed a map that shows
sensitive areas in purple (Alternative G Map Figure 2).
We are concerned that although the THPs in Section 1
of Table II.3 conform to the interim harvest restrictions recommended by
the MWG, they are listed as not being subject to DSFAG or JAG
review.
We believe that everyone’s interests are in resuming
operations in Jackson in a way that minimizes the chances for reigniting
controversy. DSFAG or JAG review of sensitive THPs will significantly
reduce the chances of a misstep. Such review will provide a forum for the
public and provide the public with greater assurance that the THPs
implemented in the interim period are chosen and designed so as to keep
open future options for restoration, habitat, and recreation to the
maximum extent feasible, consistent with the need to generate revenue to
fund interim operations of the forest.
The MWG recommends that all interim-period THPs
proposed for sensitive areas be reviewed by the DSFAG or JAG, provided the
review does not unnecessarily impact JDSF staff’s ability to move forward
with the 2008 sale program.
We recognize the importance of resuming operations in
Jackson Forest in 2008. The MWG does not want the recommended advisory
committee review to disrupt the 2008 JDSF Timber Sales Program. At the
same time, we would like to have as effective as possible review of
proposed THPs consistent with this desire. To achieve these twin goals, we
ask the department to 1) identify those THPs that are prime candidates for
2008 harvests and to have the DSFAG review these plans as soon as possible
so that preparation of approved plans can proceed with assurance of
acceptability, and 2) to expedite formation of the JAG so that it can take
over the review process as soon as practicable.
The MWG would especially hope that the JAG could
review the North Fork Spur and the West Chamberlain THPs, because both of
these contain some unentered stands of old second growth and are in an
area of high recreation potential.
One issue that still needs deliberation as this
process moves forward is the final resolution of the two enjoined plans.
Nothing in any of our correspondence is meant to state or imply that the
contract holders of the two enjoined timber sales relinquish any right or
expectations that their agreements will be fulfilled.
We are very appreciative of the Board’s previous
willingness to accept many of our recommendations. We hope that you will
consider modification of Alternative G to conform to the aspects of our
original recommendations that we highlight in this letter. We believe that
these changes are important to our shared goal of operating Jackson Forest
in the public interest and without further conflict.
Sincerely,
Bruce Burton
Kathy Bailey Art Harwood
Vince Taylor
Mike Jani Mike
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