The State of California has initiated the first of three planning watershed-scale pilot studies to evaluate the adequacy utility, and methods of representation and assessment of information that informs the modern-day Timber Harvest Plan review process. The Campbell Creek Planning Watershed Pilot Project is a subsidiary to the larger Timber Regulation and Forest Restoration Program that was created in the wake of 2012’s Assembly Bill 1492, that calls for ensuring efficiency, accountability, and transparency in the THP process, and the eventual development of “Ecological Standards and Performance Measures,” to ensure the overall effectiveness of the THP administration program.
The concept behind the Planning Watershed Pilot Project study is to evaluate pre-existing information in Timber Harvest Plans over history in a specific planning watershed and to then “truth” the value, utility, clarity, and representation of the information against the physical on-the-ground conditions in the watershed via field examination. The study will evaluate the ability of the information as represented to accurately depict field conditions, identify and design mitigation measures, and to identify restoration opportunities and prioritization of restoration activities and funds. The Planning Watershed Pilot Project study is the brain-child of long-time EPIC associate, Richard Gienger.
The Planning Watershed Pilot Project study for Campbell Creek, a tributary to the Ten Mile River in Central Coastal Mendocino County, is being conducted by the Planning Watershed Pilot Project Working Group. The Working Group is comprised of an agency leadership team, a team of agency technical staff, and an appointed group of non-governmental stakeholders, including land owners, Registered Professional Foresters, scientists, fisheries restorationists, environmental non-profits including EPIC, and a tribal liaison from the Pomo tribe. The concept of having “multi-disciplinary” team and approach to evaluation is critical to the premise of the pilot project concept.
Another, though understated objective of the Planning Watershed Pilot Project study, is to evaluate the ability of existing information in the THP process to inform and guide methods of assessment and develop necessary mitigations to address cumulative environmental impacts of past and contemporary timber harvesting activities on private lands in the State.
The Pilot Project Working Group held its first meeting in Fort Bragg in December 2016. The location allows for easy access to field site visits in the Campbell Creek watershed on its timberlands. Timberlands in Campbell Creek are presently primarily under the ownership of Lyme Timber. Lyme is a Timber Investment Management Organization (TIMO), and is the successor to Campbell Global, itself a TIMO. Campbell Global acquired the property from Georgia-Pacific Corporation. The Ten Mile River in Central Coastal Mendocino County is one of the last vestiges of remaining native wild-run coho salmon in the Central California Coast, and is thus a critical watershed for study and assessment of restoration opportunities.
The Planning Watershed Pilot Project study concept has been subject of other legislative efforts in the past that subsequently failed, but is now built into the rubric of the larger Timber Regulation and Forest Restoration Program, with the hope that the study will contribute valuable information to the larger program, and aid in the development of Ecological Standards and Performance Measures. Ecological Standards and Performance Measures can be thought of as “Thresholds of Significance,” in the CEQA parlance, a set of objectives and measureable criteria to aid in the identification and avoidance of adverse cumulative environmental impacts from timber harvest and related activities on private lands in the State.
EPIC’s participation in the Planning Watershed Pilot Project Working Group is a circling back to the landmark 1986 court decision, EPIC v. Johnson, in which EPIC sued CAL FIRE for approving the logging of old-growth in the Sally Bell Grove in what is now the Sinkyone Wilderness State Park, without evaluating the cumulative impacts of successive harvests and the subsequent cumulative loss of old-growth forests.
While EPIC prevailed in forcing private forestry to be subject to evaluation of cumulative impacts via the creation of the modern-day cumulative impacts assessment process in the Forest Practice Rules, the requirements are weak at best, and in the present-day have resulted in little more than cut-and-paste boiler-plate conclusionary statements that are passed off as an “evaluation,” to support a finding of no cumulative impacts. In the 30 years since EPIC v. Johnson, CAL FIRE has never denied a Timber Harvest Plan on the basis of a finding of adverse cumulative impacts, despite the wide-spread loss of old-growth, continued declines in populations of threatened and endangered fish and wildlife, the listing of almost every major North Coast stream as water quality impaired, and now the advent of global climate change.
Long-time EPIC associate, Richard Gienger, has been advocating for a truly multi-disciplinary evaluation of the THP process and the information upon which is predicated for decades, and his vision and prints are all over the concept and structure of the Planning Watershed Pilot Project study and the Planning Watershed Pilot Project Working Group. The Pilot Project study is a foundational element to building an understanding and developing an information-based critique of the current process, identifying opportunities for much-needed reform.
40 years, and still going strong, EPIC is working as hard as ever to protect our forests, fish, air, water and wildlife against the damaging impacts of industrial-scale timber harvest on private forestlands in the State. Far from being finished, EPIC will hang tough and stay strong and vigilant in working for the place we love and call home.