Little North Fork Big River:

Additional Comments Can Be Filed:

it has come to our attention that two more THPs are planned for higher up in the Big River Watershed.

The Soda Gulch THP 1-20-00041 MEN was approved last Summer. It will be 445 acres, with 5 miles of roads to be constructed, much on steep and erosion-prone slopes. The other plan is Wheel Gulch 1-20-00115 MEN on Conservation Fund land and is slated for almost-sure approval shortly. This plan will be 386 acres. Together these total 831 acres, nearly one and a quarter square miles. This will add substantial sediment to Big River.

This could lead to an illegal take of endangered salmonid runs.

In light of this the LNF Big River Plan must be reconsidered and denied.

How to submit comments:

Send your email to:

SantaRosaPublicComment@fire.ca.gov

cc: Registered Professional Forester Lee Susan summit@mcn.org

California Department of Fish and Wildlife: Jon.Hendrix@wildlife.ca.gov

California Coastal Commission (if your comments include items that could affect land, aquifers, or watercourses

within the Coastal Zone): Bob.Merrill@coastal.ca.gov

bcc: mendocinotrailstewards@gmail.com

For your comment to be put into the record, the following MUST be in the subject line:

Little North Fork Big River 1-20-00173-MEN

~Cal-Fire has filed a 484-acre timber harvest plan (THP) for areas in the Little North Fork of Big River, directly adjacent to the Mendocino Woodlands State Park. Operations dates have not yet been announced.

~The entire THP is single tree selection, with approximately 30% of the tree basal area to be harvested.

~Because of the probable presence of endangered bird species, this THP does include Winter operations.

~Over three miles (18,517') of seasonal road will be constructed as part of the plan, as well as the reconstruction of another 7,810' feet of older road. 1,770' feet of this road will be on slopes over 65%, and 2,284' more on slopes over 50% in what is known to be a Coho salmon and steelhead bearing watershed.

~This road construction will require the removal of 30,000 cubic yards of soil, which will require 3,000 dump truck trips to an off site location. This soil is contaminated with Phytophthora ramorum—sudden oak death—spores.

~Yarding methods are listed as tractor, rubber tire skidder, ground, cable, and skyline yarder. Logs will be hauled North over Conservation Fund property to Highway 20.

~The THP is in proximity to Marbeled Murrelet-an endangered seabird species--habitat and nesting sites, so Summer operations during nesting season will be limited.

~Most of the area is listed as having moderate to high erosion hazard, which poses the risk of increased siltation into Big River (all of this information is from the THP).

~Jackson, as a forest whose mandate is demonstration of silvicultural methods, has not made clear what research purpose is served by this THP. Is it just for the sake of revenue? These 484 acres have not been logged in 90 years. It is all approaching late successional status. Jackson's management plan states on page 3 that:

….efforts will be made to limit the extent of harvest in areas that have had little or no harvest entry since 1925 (or that currently have at least 10 trees/acre greater than 30” in diameter).

The area of the plan almost entirely falls under the second set of criteria, and some of it falls under the first. In acknowledgment of this apparent disregard of Jackson's own guidelines, the plan states that the cut is being undertaken in order to aid the forest in its progression to late seral development (late successional). Whether this is actually true can only be determined by an inventory of the trees that will be cut: will they be the small ones or the big ones? What percentage of older trees are being left? How does one balance the damage caused by these forest incursions—including the construction and/or reconstruction of over four and a half miles of roads in an area of less than one square mile—against the need to bring in revenue?

In any case, the entire plan is in close proximity to the Mendocino Woodlands National Historic Landmark State Park, constructed in the late 1930s by the WPA and the CCC. This iconic campground has been in continuous operation since then until the start of the Covid pandemic—over 80 years. It is a magical and unique place that hosts music, dance, spiritual, and artistic camps every Summer. The Little North Fork THP is the first of three THPs being planned directly adjacent to the historic camp areas, which will substantially change the aesthetic and natural environment of the area, as well as affect the general peace of the valley.

In addition, numerous of the beloved trails will be affected, with many closed for a period of one to three years during harvest. Steam Donkey, Big Dipper, Jeep Trail, Eagles' Roost, and Marsh Creek Trail will be closed by this harvest, hopefully to be reconstructed later. The ensuing harvests will affect Endo, Oh No, Boiler, Confusion Hill, More Confusion, Chuck Hinsch, and Arrow. These trails are known worldwide to mountain bikers, bringing tens of thousands of people from far and wide to visit our county.

Ironically, much of the area of these THPs used to be a part of the Woodlands itself. The Mendocino Woodlands originally consisted of 5,425 acres, but the state split it into two parcels in 1976, giving the substantially larger portion to Cal Fire to integrate into Jackson Demonstration State Forest, leaving only 700 acres as a State Park. This was a controversial move at the time, and a ‘Special Treatment Zone’ was established. Unfortunately, timber harvest is being planned anyway.

Further, there is little forest like this left in Mendocino County. Only two State Parks, a few private holdings, and 459 acres of JDSF have any old growth at all, and even second growth over 75 years old is rare. As stewards entrusted with the care of public lands, Cal Fire should ask the question: would it not be better to let the forest progress to maturity on its own, and leave the Mendocino Woodlands in peace?

The public comment period is open now and will close late January, 2021. If you have an opinion on this harvest, we encourage you to submit a comment soon. It is crucial that your comments be as well-informed as possible, though your own words and voice carry more weight than cut and pasted statements. If you can take the time to research and include citations, your comments will be more valuable, but even a simple statement of objection from the heart is better than no comment at all.

Some Additional Areas of Commentary:

~Three THPs are planned in the Big River Watershed for the coming years: Little North Fork Big River, Railroad Gulch, and Thompson/Berry Gulch. We don't know if they will overlap in operations dates, but it is possible.

~In addition, three more THPs are planned for just over the ridge in the Caspar, Mitchell Creek, Hare Creek, and Jughandle Watersheds, commencing in 2021. This is highly concerning for many reasons. Two contiguous plans being harvested at the same time create issues under the California Environmental Quality Act—an important body of regulatory law which unfortunately has no companion enforcement agency—as the cumulative impact of these harvests could be greater than the sum of their parts. The piecing out of so many adjoining plans makes them much more time consuming to analyze and contest. This large of an amount of logging activity will turn the Western end of Jackson Demonstration State Forest into an industrial zone for years to come.

~The greater area of Mitchell Creek, Hare Creek, Jughandle Creek, Caspar Creek, and Big River watersheds is used by tens of thousands of people every year and is a large draw for recreational tourism--bringing millions of dollars into the county economy every year. So much logging will likely discourage many people from visiting the Mendocino Coast.

~The undertaking of so many timber harvest plans at once brings up the question of whether these harvests are actually for research and demonstration—the prime stated mandate in the 2016 management plan—or whether they are just for generating revenue at the expense of another stated objective: the development of maturing second growth late succession forests.

~~All recent JDSF meetings have been closed to the public. However, according to the JAG Charter, and under the Brown Act of 1953 and the Bagley-Keene Open Meeting Act of 1967, these were under law supposed to be open or at least accessible to the public, but, due to the pandemic, were closed. This was in spite of Governor Newsom’s series of orders in March of 2020 that such meetings remain open, at least by teleconference.

Additional Comments can and should be filed:

It has come to our attention that two more THPs are planned for higher up in the Big River Watershed.

The Soda Gulch THP 1-20-00041 MEN was approved last Summer. It will be 445 acres, with 5 miles of roads to be constructed, much on steep and erosion-prone slopes. The other plan is Berry Gulch 1-20-00115 MEN (not to be confused with the Thompson/Berry Gulch THP that Cal Fire has in development) on Conservation Fund land and is slated for almost-sure approval shortly. This plan will be 386 acres. Together these total 831 acres, nearly one and a quarter square miles. This will add a substantial sediment load to Big River.

This could lead to an illegal take of endangered salmonid runs.

In light of this the LNF Big River Plan must be reconsidered and denied.