March 8, 1999
Ms. Mary Bull
Mr. Robert Krebsbach
252/250 Frederick Street
San Francisco, CA 94117
Dear Mary and Robert,
Thank you for your letter regarding our Timber Harvest Plans, and your questions about old growth, Coho salmon, stream protection, and water quality. It gives us the chance to directly answer you and clear up any misconceptions about what our company is trying to achieve.
Before I respond to each of the specific issues your letter raised, let me alert you to the fact that we have a very complete Web site (www.mendocinoredwoodco.com) that talks about many of the issues you raised. In addition, our web site contains more general information about our company, our mission, and what we hope to accomplish in the coming years as we build a different kind of forest products company.
I want to respond to specific issues you raised with regard to THP 1-98-350 MEN and THP 1-95-315 MEN. To respond to your concerns most efficiently, I have simply quoted from your letter, and then followed this with the most relevant factual information we can provide at this time.
"... one of the few dwindling stands of old growth and mature second-growth redwood trees in the entire county...".
First let me begin by saying that neither one of these plans have any stands of old growth. Both harvest plan areas were clearcut and burned at or before the turn of this century. There is only an occasional residual older tree scattered throughout the landscape and we are retaining those trees that are at least 48" in diameter and 250 years old. The average age of the second growth trees in THP 350 ranges from 45 to 70 years old. THP 315 was logged a second time in the 1940's making the average stand age about 58 years old.
If these stands did contain any meaningful amount of old growth, they would be managed consistent with our stated policy on old growth, which you can read about on our web site.
As a matter of background, prior to harvesting in the area of either THP 315 or 350, wildlife surveys are conducted to establish the presence or absence of species that are federally or state-listed as Threatened, Endangered, or Sensitive ("TES species"). If TES species are located, appropriate protective measures are implemented. The protective measures, as established by The United States Fish and Wildlife Service, California Department of Fish and Game, and California Department of Forestry, are enacted so as to ensure that no harm is done to those species. The protective measures concentrate on habitat retention, with the purpose being to provide the needed habitat that will sustain the population of TES species.
The wildlife species that are found on MRC property represent a diverse group of animals, including species such as Marbled murrelets and Northern spotted owls. To maintain and promote biodiversity, our old growth policy and Federally mandated habitat retention measures are enacted. These and other actions will allow for the existence of a wide range of different types of animals and habitats on our ownership.
"... changes it from a Commercial Thinning plan to a Group Selection plan (1.5 - 2.5 acre clearcuts, having a significantly higher impact."
The type of harvest planned for THP 315 has been amended from a commercial thinning, to a group selection. This change was due to the change of timberland ownership and a change of philosophy. The change to group selection will in fact be a much lighter touch on the land than the previously proposed commercial thinning. As now proposed, only about 31 acres in group selection areas are scheduled to be logged out of a total plan area of 168 acres. Within the group selection areas, trees greater than 10" DBH are proposed for harvest with the exception of wildlife trees. These group selection areas will then be planted. The areas outside of the group selection strips will remain untouched.
THP 350 is proposed for selection and group selection with the goal of transferring the growth of the harvested trees onto the residual trees. The selection and group selection will result in less volume of trees being harvested than is retained in the stand. The goal of the group selection and selection is to maintain a multistoried, uneven-aged stand by thinning out crowded trees and removing the less thrifty and damaged trees.
"90% of the streams on MRC lands are no longer fish bearing".
MRC estimates that it has about 520 miles of Class I streams (streams that are fish bearing), and another 1180 miles of Class II and Class III streams (streams that are either flowing all the time or are intermittent, but not fish bearing).
Fish distribution surveys conducted in 1994-1996 on MRC's 350 square mile ownership in Mendocino and Sonoma Counties spanned 20 basins. Fish were present in all basins. The 90% estimate does not line up with current known and public information.
The streams in THP 315 are being protected beyond what is required by state regulations. There will be "no harvest" buffers on all watercourses, which includes 25' buffers on Class III watercourses, 75' buffers on Class II's, and 100' buffers on a Class I watercourse.
The increase in protection to the watercourse and reduction in plan size and actual harvest area are more than adequate protection measures to avoid a taking of Coho Salmon in THP 315.
"...one third of the creek in 315 is misclassified".
The classification of this stream was reviewed and accepted by Biologists from Natural Resources Management, Mendocino Redwood Co., and the California Department of Fish and Game. All were in agreement with the classification contained in the harvest plan.
Because of concern over this issue, MRC and a representative from the local water district will together review the stream area in the next week or two. MRC is committed to providing appropriate protections to all of its streams.
"There is also serious landslide potential and water quality issues, impacting a town water district in this plan".
There is no known "serious landslide potential" in Barn Gulch. While there are a few mapped unstable areas, there is no proposed harvesting in the mapped unstable areas. Most of the unstable areas are associated with watercourses and there are no proposed harvesting within the stream zone buffers for the Class I and II watercourses and no harvesting within 25 feet of Class III watercourses. There is a single domestic water source (a spring box) located uphill of the plan boundary and adjacent to the Greenwood-Philo Road. This spring box was given the same protection as a fish bearing stream. No operations will take place uphill of the spring box.
The plan area is approximately eight miles upstream from the mouth of Greenwood Creek on the ocean, just south of the town of Elk. The Elk County Water District operates two shallow wells adjacent to Greenwood Creek near the Highway 1 bridge, approximately eight miles downstream of the plan area. Because the Elk water system is not supplemented by deep wells, the system must rely on stored water during high turbidity periods, which occur under winter high flow conditions.
In addition, the majority of the proposed harvesting will be by cable yarder, thus limiting the potential for increased sediment inputs. The residual timber stand will contain sufficient trees on site to stabilize soils. To further reduce the potential for sediment inputs, approximately 1 mile of existing WLPZ road in and adjacent to Barn Gulch has been abandoned by removing culverts, pulling back perched material, installing drainage facilities, installing large rock (riprap) to control erosion, and seeding and mulching numerous areas.
Roads are the greatest source of sediment into streams and we have actively been making road improvements. A good example of this is near THP 350. In recent years, four bridges were put in to replace culverts and low water crossings. These permanent bridges greatly assist fish migration and reduce the sediment input into streams. In this same area we have been working with the California Conservation corps (CCC's) for stream enhancement projects. This includes building in-stream structures to improve fish habitat.
We have been working with a number of experts on the best way to manage these lands for the long term. We are actively pursuing Forest Stewardship Council certification of our lands (independent third party verification that the environmental practices employed on our lands are good). Certification takes time, and we are confident that we are making good progress in this important effort.
It is our intention to continue to provide information to you and others who have contacted us, those who have signed petitions, government officials, and others. Our Web site has lots more information. If you don't have access to the Internet, feel free to call our office, (707) 485-8731, and we would be happy to send you a full print out of our web site by mail. Whether we agree or disagree you are entitled to know what we're doing and have the opportunity to be heard. Thank you for writing.
Sandy Dean, President
Mendocino Redwood Co.