The high rate and intensity of logging on Green Diamond/Simpson lands is visible from space. GIS credit Lindsey Holm

You are invited to join EPIC’s staff to discuss the impacts of industrial logging operations in the watersheds surrounding our towns in Humboldt County. Please join us at the Trinidad Town Hall on Wednesday July 13 at 6 pm for a Community Forum.

Simpson Timber, the parent company of California Redwood Company and Green Diamond Resource Company, owns roughly 400,000 acres of some of the highest producing lands in the redwood region. There is very little older forest on these lands, and forest resources on Simpson lands are in various states of recovery from past logging and current Simpson activities.

The rate and intensity of logging on Simpson lands is high and very disturbing. High intensity management practices which rely heavily on clearcuts, chemical herbicides, extensive roads, short rotations and plantation forestry betray a flaw in the paradigm of industrial forestry practices, as well as a pervasive lack of government regulatory control.

EPIC wants to hear your vision for a better future on forests and lands in our region. We advocate for the restoration of our forests and watersheds. Intensive industrial forestland management which relies heavily on clearcuts, chemical herbicides, extensive road systems and sterile plantations should be a relic of the past.

EPIC seeks to encourage a discussion around the principles of ecological restoration forestry, and seeks alternatives to the dominant management regime found on many private industrial forest landscapes. EPIC wishes to engage with the community and neighbors of these industrial logging giants to develop a new and more ecologically centered forestry for the future. Come join us on July 13 at 6PM at the Trinidad Town Hall.

THP 1-08-098 lies in Maple Creek proper.  It covers 131 acres, 90.7 clearcutting, and 22.4 selection. The plan area contains suitable habitat for Northern Spotted Owls, and Pacific Fisher, both of which are known to occur in the THP area. This plan will conduct cable selection logging on steep streamside slopes on Class II (non-fish bearing, but amphibian bearing stream) watercourses.  As with most Green Diamond THPs, this plan has adjacency constraints. This means that operations were restricted from occurring before now because adjacent stands were not either five years old or five feet tall at the time of plan approval.  The forest to be clearcut is extremely young, 50-55yrs old. The plan area drains downslope into Maple Creek, a stream that provides habitat for threatened anadramous fish.

THP 1-09-059 lies in Pitcher Creek and Mc Donald Creek. THP area covers 96 acres, 71 acres clearcutting, and 25 selection. The THP area contains suitable habit for Northern Spotted Owl, Pacific Fisher, Osprey, Southern torrent salamander, tailed frog and red-legged frog, all of which are known to occur in the THP area.  The plan proposes potentially damaging ground based yarding in Class II Riparian Management Zones (RMZs) in some areas. Units A,B,C are oversized, meaning units greater than 20 acres for ground based yarding, or 30 acres for cable yarding.  This plan was also constrained from immediate logging due to adjacent previous clearcutting operations. The forest to be clearcut under this THP averages 60 years old, also representing a very young forest, subject to very fast and intensive rotation.

These THPs represent the Green Diamond pattern of clearcutting, burning, spraying herbicides, and then quickly re-entering stands before any true ecological value to species can accrue.  Species such as Northern Spotted Owl and Pacific Fisher are systematically being forced to abandon suitable habitats for younger and younger forests, forests that do not generally provide the kind of structure and ecological value that would facilitate the survival, and ultimate recovery of these species.

A bird's eye view of the Maple Creek watershed.

Green Diamond Resource Company (GDR) has been intensively working to churn out dozen of new logging plans for 2010.  Thus far in 2010, GDR has filed 37 THPs covering thousands of acres.  Nearly all of these plans call for a vast majority of logging operations to be conducted by clearcut.

Most of these proposed new logging plans are concentrated in a few, heavily impacted watersheds.  For example, six of these new THPs are slated to conduct clearcut logging in Little River, four of which are proposed in the Headwaters region, a watershed area that has been heavily impacted by past and current clearcutting. Little River Still provides habitat for salmon and steelhead populations.

In addition, GDR is proposing 12 new clearcutting THPs within the Maple Creek watershed. Maple Creek is a refugia for salmon and steelhead, which drains to Big Lagoon.  Many of the newly proposed logging operations in Maple Creek are in the lower part of the watershed where the potential to impact salmonids and the lagoon is highest.

This large-scale intensive logging strategy will impact critical habitat for imperiled species such as salmon, steelhead, Northern Spotted Owl, Pacific Fisher as well as various amphibians.  For example, a review of these newly proposed THPs indicates that Northern Spotted Owls are present either in or adjacent to a THP in 27 of the 37 cases.  Furthermore, 15 of these newly proposed THPs indicate that Pacific Fisher are present either in or adjacent to the plans.

While GDR proposes some no-harvest within some riparian management zones and habitat retention areas, the vast majority of the logging to be carried out under these plans is clearcutting.  Some of this clearcutting is proposed in and around wet areas, areas of disturbed ground, and potentially unstable areas.  Ground based selection logging is proposed within riparian management zones in many cases.

The 2010 GDR THPs also reveal a few other trends.  For example, 21 of the 37 new plans contain clearcut units that are constrained by lack of completion and stocking in adjacent THP clearcut units.  This means that trees in adjacent units are neither old enough nor tall enough to meet Forest Practice Rules tree stocking constraints required prior to clearcutting adjacent to regenerating units.

Furthermore, 23 of the 37 newly proposed THPs contain what is considered “oversized” clearcutting units.  This means that units contain greater than 20 acres of ground based clearcutting or greater than 30 acres of cable based clearcutting.  These extra large clearcut units are constrained by the Forest Practice Rules in order to protect natural resources such as soil, water, forest health, and wildlife.  Event though Cal Fire routinely approves the execution of these oversized clearcuts, the intent of the rules is to constrain the size and scope of clearcut logging to protect critical natural resources.

Sol Simpson descendant and current Chairman of Green Diamond Resource Company, Colin Moseley (the crown is fake).

Since the fall of the Maxxam/Pacific Lumber Company, Green Diamond Resource Company has become the king of clearcuts in Humboldt County.  The famed timber giant is proud of their aggressive ‘even-aged’ i.e. clearcutting policy. In addition, they seriously assert that redwoods are a shade intolerant tree, and thus must grow in the full sun, i.e. plantation clearcuts.

So-called even-aged management is a euphemism for intensive clearcutting, burning, and herbicide use across Green Diamond’s vast landscape.  The trees and all vegetation are stripped bare, leaving exposed soils on the hillsides.

Clearcutting increases the risk of soil and debris transmission to watercourses, and increases the risk of significant earth movements when storm conditions are at their most intense.  Intensive clearcutting and extensive rains make for a dangerous mix of overland flow, flooding, and landslide activity.

Green Diamond’s method of two-species monoculture depends on clearcutting, broadcast burning, and the use of herbicides to allow its plantation style management to take hold. Thus the natural species diversity within the forest is compromised, and the habitat once present for threatened and endangered species is demolished. The habitat remaining is restricted almost entirely to slim watercourse buffers and serve as the last vestiges of safety and biodiversity on the landscape.

Intensive clearcut logging as practiced by Green Diamond leaves little but barren moonscapes where vibrant, recovering forests once grew.  In their place, Green Diamond intends to embark on an endless tree farm.  The needs of the species living in these watersheds are relegated to secondary status in the face of Green Diamond’s idea of maximum sustained production; clearcut, burn, herbicide, repeat every 45 years.  Under this regime, forests will not recover, species will continue to disappear, and our streams will continue to suffer.

Now is the time for Green Diamond to take actions to protect these important mammals, by improving their practices across the forests within their ownership.

Thanks for reading!

~Kerul Dyer

Green Diamond Stop Clearcutting Campaign

Green Diamond and the Pacific Fisher

by Rob Diperna

The Fish and Game Commission is on the verge of deciding on the listing petition to protect the Pacific Fisher as “threatened” under the California Endangered Species Act. This action is urgently needed as Pacific Fisher populations decline and there is currently no regulatory mechanism to protect them.  The fisher is a specialized forest carnivore related to weasels and otters inhabiting mature and old-growth forests. They are arboreal hunters and are associated with dense canopy areas.

Pacific Fisher populations have been found throughout lands owned by Green Diamond.  In the past, Green Diamond has taken no measures to protect Pacific Fisher habitat other than to protect nests if discovered during logging.  Green Diamond does not survey for Pacific Fisher other than the use of track plates.  This method does not provide an adequate mechanism to determine population size and trends. This method also does not suffice to protect Pacific Fisher in the absence of Timber Harvest Plan level surveys.

Clearcutting and roads have been found to be a significant threat to the survival of the Pacific Fisher. Studies in the coastal and interior of the Northwest California have documented that the majority of moralities are due to predation events, and these predation events on fishers occurred in or closely associated with regenerating clearcuts and roads.

Green Diamond is of course claiming that the fisher population is not declining, and that Pacific Fisher will thrive on intensively logged lands.  The truth is however, that The Pacific fisher now occupies less than half the range it occupied in California 75 years ago.

Green Diamond also claims that the protection measures in its Northern Spotted Owl Habitat Conservation Plan, its voluntary deadwood management plan, and its Aquatics Habitat Conservation Plan are sufficient to protect fisher. However recent science suggests that there is not enough overlap between NSO and Pacific Fisher habitat and occurrences to ensure that protection for owls will be enough for the fisher.

The fact remains that on Green Diamond lands, large clearcuts and an extensive and ever-growing road system will continue to destroy fisher habitat and expose them to predators.

The Department of Fish and Game had issued an emergency regulation to protect landowners such as Green Diamond against take of Pacific Fisher, but these regulations have now expired.  Thus Green Diamond no longer has protection against take of Pacific Fisher until the Fish and Game Commission decides on the petition.

Green Diamond may add the Pacific Fisher to its newly proposed Northern Spotted Owl Habitat Conservation Plan.  This would mean that Green Diamond would acquire an Incidental Take Permit for Pacific Fisher.

Green Diamond’s standard logging practices of extensive clearcutting and endless road building pose a significant threat to the survival of the Pacific Fisher.  At present, the populations are too small, too isolated and not genetically diverse enough to withstand much more pressure.

Atrazine applied on clearcut near Korbell. Photo by Jen Kalt.

Many of us are aware of the dangers of herbicides and pesticides in our food and water. But can we trust Green Diamond to take precautionary measures when it comes to our health and the health of the fish, amphibians, and birds?

Green Diamond claims that these pesticides and herbicides are relatively harmless. With a little research, however, EPIC staff questions these conclusions. As one step in their controversial plantation forestry model, Green Diamond plans to use Triclopyr in combination with 2,4-D, Imazapyr, and Oust in 2010 in many sites along the Klamath River. In addition to these chemicals, they commonly use Atrazine.

To view a map of 12 sites Green Diamond plans to spray this year along the Klamath River within Yurok Reservation boundaries, click here.

Green Diamond lists many reasons to apply herbicides after logging, but often they cite the need to protect tree seedlings from competitive, faster growing shrubs, grasses and trees. To illustrate, one need only look to CalFire’s website and find the list of Timber Harvest Plans for the Northcoast region. In the lengthy section on Chemical Contaminants, found in subsection a 2d. under Section 4: is a section titled Cumulative Impacts of Timber Harvest Plans. In this section, they disclose a wide variety of chemical herbicides they may choose to use post-harvest. Application of chemical herbicides and pesticides are regulated by the California Department of Pesticide Regulation and the Northcoast Regional Water Quality Control Board (NCRWQCB).

But Green Diamond is not held accountable for conducting any investigation into the harm that these chemicals cause.

The legal standards that regulate the use of these chemicals cannot be relied upon for upholding ecosystem or human health. The standards are often established through the use of flawed, industry tested datasets and then formulated into standards, and codified by the Environmental Protection Agency. EPA regulations are unreliable by their own standards, as indicated by this quote on their website:

“Note! There are significant gaps in U.S. EPA’s current pesticide product data. Errors in the raw data include close to 13,000 missing product records, over 40,000 secondary products with no primary product record, missing formula data and other errors. US EPA is aware of this and working on fixing the problems.” ( http://www.epa.gov/pesticides/ )

2,4-D is the common brand name for Frontline manufactured by Dow. 2,4-D is listed by the Pesticide Action Network (PAN) as a PAN bad actor chemical, these are one or more of the following: highly acutely toxic, cholinesterase inhibitor, known/probable carcinogen, known groundwater pollutant or known reproductive or developmental toxicant. ( ). In laboratory animals, human cells, and exposed people 2,4-D causes genetic damage. 2,4-D affects hormones in exposed people. It is classified as a possible carcinogenic by the International Agency for Research on Cancer. Studies of exposed farmers support this classification. 2,4-D exposure is associated with low sperm counts and damaged sperm and male sex organs. More EPA studies and reports available from pesticide.org. Even moderate exposure of 2,4-D severely impairs reproduction of honeybees and it has been found to be toxic to birds.

Triclopyr, whose common brand names are Garlon3A and Garlon 4, are manufactured by Dow AgroSciences. They are corrosive to eyes and can cause allergic skin reactions. But this is just the tip of the iceberg. In laboratory tests, tricolopyr caused an increase in the incidence of breast cancer as well as an increase in a type of genetic damage called dominant lethal mutations. It is damaging to kidneys and causes a variety of reproductive problems. For example, in laboratory tests, it accumulates in fetal brains when pregnant animals are exposed. Tricolopyr is highly toxic to fish and inhibits behaviors in frogs that help them avoid predators. Feeding triclopyr to birds decreases the survival of their nestlings. Triclopyr is mobile in soil and has contaminated wells, streams, and rivers.

Oust is manufactured by DuPont. Its chemical name is sulfometuron methyl. This herbicide causes eye discomfort, tearing, and blurred vision. In laboratory tests, it caused anemia, atrophied testicles and testicular lesions, and increased the incidence of fetal loss. This product causes DNA damage in the colon of laboratory animals. Because of limited monitoring, little is known about how often sulfometuron methyl contaminates rivers and streams. Enough sulfometuron methyl to kill desirable vegetation can persist in soil for a year or more after application. Minute amounts can disrupt plant reproduction. ( .)

Imazapyr called by either Chopper or Arsenal and manufactured by BASF Corporation is another chemical listed by PAN as a bad actor chemical. Imazapyr is corrosive to eyes causing irreversible damage. Adverse effects found in laboratory animals after chronic exposure to imazapyr include: fluid accumulation in the lungs of female mice, kidney cysts in male mice, abnormal blood formation in the spleen of female rats, an increase in the number of brain and thyroid cancers in male rats, and an increase in the number of tumors and cancers of the adrenal gland in female rats. Imazapyr moves readily in soil and can persistent in the soil for over a year. Persistence studies also suggest that imazapyr residues damage plants at concentrations that are not detectable by laboratory analysis thus having the potential to seriously impact rare plant species. Meanwhile over a half-dozen weedy plant species have developed resistance to this herbicide.

And in addition there are the hazards of “inert” ingredients in these pesticides. This particular example shows the inert ingredients associated with 2,4-D but some or all are in all of the chemicals Green Diamond uses. Inert ingredients are neither identified on pesticide labels nor included in most of the health and safety testing required to register.

Redwood tree within McKay Tract. Photo courtesty Humboldt Earth First.

This week in EPIC’s Eye on Green Diamond dispatch, Amber Jamieson and Rob Diperna have combined efforts to look at both the proposed development Green Diamond has put on the table in Humboldt County, but also approved Timber Harvest Plans just east of Eureka, in the McKay Tract.

One could point to the president of Green Diamond, William R. Brown, former Chief Financial Officer for Plum Creek timber, for the direction in speculative development schemes that may have originated from his experience on the east coast. Last fall, conservation activists from Maine contacted EPIC and asked of Brown’s direction of the company. They specifically asked the question whether the company would be transforming their forests into residential developments, based on those that changed Maine’s forests forever, under Brown’s leadership at Plum Creek. Of course we at EPIC are unsure of the inner workings or strategic plans of Green Diamond’s corporate leadership. One could draw some parallels, however, based on the proposals on the table in Humboldt County.

It is also interesting to note that in a recent flight over the McKay Tract, I noticed the blue tarps sheltering a tree village! After the flight, I looked up the Humboldt Earth First! website and found that they had information about the McKay 09 THP, a threatened mature forest within the McKay Tract, in the Ryan Creek watershed and adjacent to Cutten (Eureka). These dedicated activists are likely the only reason why this grove of forest has not been liquidated into quick profits for Green Diamond. I hope to spread the word of the stand that they are taking, to illustrate how dedicated people will sacrifice so much, to stand up for what they believe in.

While EPIC doesn’t do our advocacy from atop redwood trees, we want to bring to you, our readers, the sixth Eye on Green Diamond, to provide information about this important area. Next week we will focus on what people can do to get involved in this campaign and outline our goals and objectives, as we launch the next phase of our Green Diamond Stop Clearcutting Campaign.

Thanks for reading!

Kerul Dyer, Green Diamond Stop Clearcutting Campaign coordinator

Development within the McKay Tract?

by Amber Jamieson

Green Diamond has numerous large pieces of land that are being considered for rezoning from Timber to Residential. But earlier this year they and two other timber companies sent a letter to the County proposing a voluntary program to keep “the bulk” of their lands in timber production in exchange for weakening Timber zoning regulations. The letter never made it to the Board of Supervisors agenda, but it remains a concern to the environmental and regulatory agencies because it involves the County’s three biggest timber companies working together in an attempt to modify the General Plan outside the of public process.

On February 18th Green Diamond, Humboldt Redwood Company, and Sierra Pacific Industries collectively presented the County with a Declaration of Intent to “maintain the bulk of [their] acreage as commercial forestland” in exchange for:

• removing any consideration of Industrial Timberland ‘IT’ zoning designation;
• removing Article II of the New Merger Ordinance [which would merge contiguous parcels];
• maintain ministerial permit for a residence on all legal parcels zoned TPZ; and
• for the “County to actively support increased regulatory efficiency to facilitate cost reduction for permits associated with timber harvesting.”

If the timber companies really wanted to “maintain the bulk of their acreage as commercial forest land” then they would not be opposed to “IT” zoning designations for lands that have high quality timber production possibilities. “IT” zoning would keep industrial timber land from being used for other non-timber related uses such as residential developments.

The “voluntary program” would replace definitive enforceable policies with a toothless promise from the timber companies. Overall, this proposal is a bad idea for timberland within Humboldt County as it would facilitate subdivision and residential construction on some of the County’s most productive timberlands.

One of the areas Green Diamond is considering for Residential zoning is in the McKay Tract, on the west side of the Ryan Creek Watershed. The County has been petitioned numerous times to rezone portions of the McKay Tract from Timber Production (T) to Residential Low Density (RL). The proposed rezone would facilitate residential development in forested areas that exist outside of district and city boundaries. Although the County has not approved any General Plan Amendment to rezone the large tracts of timberland, large portions of them are proposed to be changed from T to RL under General Plan Alternatives B and C. This area is of particular importance because it is adjacent to the Ryan Creek Watershed, which is habitat to the Northern Spotted Owl and Coho Salmon. The image below shows some of the parcels that are proposed to be rolled out of T and into RM, most of which are owned by Green Diamond (and some owned by the Arkley’s).

What’s at Stake in Ryan Creek Watershed

by Rob Diperna

In addition to proposed rezoning from Timber to Residential, the McKay tact on Green Diamond ownership holds two timber harvest plans that threaten large, mature second growth forests that are currently providing habitat for Nothern Spotted Owls, Steelhead, and Cutthroat trout, and Coho and Chinook in the downstream area. Ryan Creek has been heavily and intensively logged in both the past and recent past. According to THP 1-08-102, 50% of Ryan Creek watershed was logged by clearcut or shelterwood removal between 1975 and 1989. The plan states that logging has been reduced in recent years. However, a look at past projects shows that a whopping 2,145 acres have been logged over last 10 yrs.

The two THP’s in question, 1-08-102 and 1-08-155, both propose clearcutting that will total 82 acres. Selection logging is proposed in riparian management zones. However selection is also proposed for unstable areas. THP 1-08-102 contains a Channel migration zone class I, slope management zones, and Steep streamside slopes. Salvage is allowed within outer zone of RMZ. Steelhead and Cutthroat trout are known to inhabit Ryan Creek adjacent to the logging area.

The forests in question in 1-08-102 range in age from 85-100 yrs, and have an average DBH of 40″. The THP contains NSO, and no HRA’s are proposed to protect them. For THP 1-08-155, forests age from 65-80 yrs, and have an average of 24″DBH and these stands currently have 85% overstory canopy closer. Here too, the THP contains an NSO site, and a few acres of HRA will result in a very small amount of trees that will be retained. Cutthroat trout exist within this reach of Ryan Creek. Steelhead, Coho, and Chinook exist downstream.

Both THP’s propose logging on unstable areas. THP 1-08-155 will clearcut a vegetated scarp adjacent to an active failing scarp (small unstable area). These logging practices threaten to result in considerable sediment generation and delivery to Ryan Creek, which is covered under the Freshwater Creek TMDL, and is considered a 303(d) listed watershed due to sediment.

In all, Green Diamond logging on these plans will result in the loss of vital dense, old, mature second growth that provides vital habitat for NSO, and trout and salmonid species in and downstream of the plan.

An Incidental Take Permit is like a hunting permit for endangered species. If granted, this new permit will offer Green Diamond the opportunity to “take” more owls, without fear of violating laws protecting threatened and endangered wildlife.  In addition to owls, the plan may attempt to get the green light on other wildlife species, like the Pacific fisher.

The documents can be daunting, and the process exhausting, for everyone involved.

Although Green Diamond uses antiquated logging practices like clearcutting, they work with credible, skilled biologists and other scientists in their planning processes. EPIC and our allies acknowledge that most of Green Diamond’s staff and contractors do cutting edge work in an attempt at understanding redwood forest ecology and to minimize impacts of logging operations.

Unfortunately, much of the conservation effort from within Green Diamond’s labyrinth of fish and wildlife research is overshadowed by the company’s continued dependence on liquidation logging practices, heavy use of herbicides and short rotation cycles. We at EPIC must hold the Washington state-based decision-makers (and profit-takers) at Green Diamond/California Redwood Company/Simpson Timber accountable for their irresponsible and destructive priorities,  but want to commend local workers, scientists and contractors for their ongoing efforts to perform responsible forestry.

Thanks for everyone’s comments on the Eye on Green Diamond dispatches. With diligence, communication and open-eyes, we can find common ground and solve the problems that plague our environment and our economy on the Northcoast.

Thanks for reading!

Kerul Dyer

Green Diamond Campaign Coordinator

Eye on Green Diamond: Week 5

by Rob Diperna

Green Diamond has applied to the Fish and Wildlife Service for a new Habitat Conservation Plan. According to the Federal Register notice dated April 16, 2010, the new HCP will cover Northern Spotted Owl and potentially Pacific Fisher. To read the documentation, click here.

The proposed HCP would cover Green Diamond lands in both Humboldt and Del Norte counties.  The purpose appears to be to obtain a new 50-year Incidental Take Permit (ITP) for the Northern Spotted Owl.  Just three years ago, Green Diamond received an extension on its existing NSO HCP, and was given authorization to take eight more owl pairs.

The proposed new HCP could open up areas set-aside for the Northern Spotted Owl in the original HCP.  Green Diamond is contending that some of these set-asides do not support active NSO sites, and that the development of suitable habitat in RMZ’s through it’s AHCP would help off-set logging in previously set-aside areas.

Green Diamond has been contending that the provisions of the existing NSO HCP along with its’ voluntary deadwood management plan would provide sufficient habitat and habitat structure for Pacific Fisher.  Now however, with the prospects of listing for Pacific Fisher growing, Green Diamond may also seek an ITP for Fisher as part of the new HCP.

There is no denying that the existing NSO HCP, which was issued in 1992, is inadequate, and scientifically and regulatory antiquated.  However many of these issues could have been addressed with the extension of the existing permits and HCP.  Instead, FWS and Green Diamond intend to start from scratch based on data that Green Diamond has been collecting throughout the life of the existing HCP.

The new Green Diamond HCP proposal is in the scoping stage.  Public scoping meetings will not be held, but public comment is being accepted by the FWS until May 17th.  To find out more about the project, call  Ray Bosch, Fish and Wildlife Biologist, at the Arcata Fish and Wildlife Office  at (707) 822-7201 or  e-mail at ray_bosch@fws.gov.

Public comment on the scoping documents may be submitted to the FWS at fw8_greendiamondeis@fws.gov.  A draft EIS is not expected to be available until at least November.

This week in our Eye on Green Diamond,  Rob Diperna has outdone himself again. He has identified patterns in their planning and listed out the vital statistics for the five Green Diamond plans announced through the Startup Notification I received Monday, April 12.   Now, as I publish this carefully edited (for accuracy) dispatch, I just received yet another Startup Notification from CalFire.  Green Diamond has announced that they plan to begin logging operations on two additional THPs. That’s seven,  just this week.

We will update the information in our post when time allows. To get involved in the Green Diamond Stop Clearcutting campaign, please contact us!

For the wilds,

Kerul Dyer

Green Diamond Stop Clearcutting Campaign

Eye on Green Diamond: Week 4

by Rob Diperna

This week Green Diamond filed for start-up on five THP’s on its property.  These plans are primarily set in drainages of the North Fork Mad River and Maple Creek.  These plans are characterized by the usual Green Diamond trademark of large, and in many cases oversized, clearcuts.

THP 1-08-052 comprises 161 total acres, of which 118 is clearcut.  Unit B alone of this plan comprises a whopping 34 acres of clearcutting, which exceeds the even-aged unit limitations by three acres for cable yarding. This THP lies in Canyon Creek, a fish-bearing tributary to the North Fork Mad River.  The plan acknowledges that both Steelhead and Cutthroat occur in the biological assessment area.  The plan also contains potential habitat for Pacific Fisher, but Green Diamond has stated that no ‘incidental’ sightings have occurred, so no assessment for the Pacific fisher is necessary.

THP 1-08-173 comprises 131 total acres, of which 107 will be clearcut.  Here too, Green Diamond proposes an oversized clearcut unit.  Unit B of the plan total 34 acres, again larger than the FPR’s allows for cable-based yarding.  Plan area contains rare plants and Pacific Giant Salamanders.  This plan lies in the Maple Creek watershed. The biological assessment area contains Northern Spotted Owls, Coho, Chinook, and Steelhead.  The plan also contains potential habitat for Pacific Fisher, but Green Diamond has stated that no ’incidental’ sightings have occurred, so no assessment for the Pacific Fisher is necessary.

THP 1-09-005 comprises 111.9 acres, of which 67.5 are slated for clearcut. These clearcuts pose a direct threat to Cutthroat trout populations immediately adjacent to the THP area.  Furthermore, these clearcuts may also threaten Coho and Chinook populations that occur downstream in the North Fork Maple Creek Watershed.  The plan area also provides potential habitat for Pacific Fisher and Northern Spotted Owl, both known to occur within the biological assessment area.

THP 1-09-011 comprises 134 total acres, of which 108 acres are to be clearcut.  The plan lies in the North Fork Mad River tributaries of Jiggs Creek, Bald Mountain Creek, and Pollack Creek.  The plan states that Cutthroat Trout and Steelhead Trout, as well as Pacific Fisher in the plan area.  Access for Chinook and Coho in these reaches is already blocked due to a land failure.

THP 1-09-065 lies in Denman Creek and Canyon Creek in the North Fork Mad River watershed.  The plan proposes to log 114 acres, 98 by clearcut, and 26.3 of these acres will be logged as one giant over-sized ground-based clearcut. These clearcuts pose a direct threat to Pacific fisher, which are known to occur in the THP area, as well as posing a threat to downstream populations of trout and salmonids.

These plans and the plans currently under review which propose more of the same will clearcut vast acreages, and threaten to destroy potential or actual habitat for numerous species.  Much of this destruction and actual take has been rubber-stamped under Green Diamond’s Aquatics and Spotted Owl HCP’s. However for species like the Pacific Fisher, a candidate for listing in California, the habitat destruction proposed under these THP’s will incrementally reduce the species’ range and impair essential life behaviors.  Unfortunately, a glance at potential future projects in these and other watersheds paints the same old picture of endless clearcuts, and endless habitat destruction.

Aerial photo above Maple Creek for EPIC by Kerul Dyer

Green Diamond Resource Company recently applied for a Master Agreement for Timber Operations and a programmatic Road Management Waste Discharge Requirements from the Department of Fish and Game and the Regional Water Quality Control Board.  At present, the Department of Fish and Game has prepared a draft Mitigated Negative Declaration regarding this project.The Department of Fish and Game is acting as the lead agency with the Regional Water Board playing the role of a responsible agency. The MATO is designed to create a programmatic basin-level approach to road maintenance, construction, and decommissioning. The project primarily will provide programmatic coverage under Section 1600 of the California Fish and Game Code pertaining to streambed alteration.

However, the MATO has further reaching implications than simply construction, decommissioning, and maintaining roads and stream crossings. The MATO also provides ‘coverage’ along with programmatic mutually agreed mitigations for biological resources.  For example, the MATO contains a programmatic consultation for Osprey that may be impacted via operations on roads and associated with road facilities.  Furthermore, the MATO also contains a programmatic agreement for the treatment of threatened and endangered or at risk species that may be encountered or impacted in the course of road or road facilities maintenance, construction, and mitigation.

The RMWDR’s would provide programmatic WDR’s for operations associated with roads and road facilities in order to protect the quality and beneficial uses of water.  As part of this process, GDR and the RWQCB will agree on programmatic mitigations, covered activities and prohibitions. The preparation of a Mitigated Negative Declaration by DFG signals that the Department does not believe that significant impacts will occur provided that the restrictions and mitigations are followed.  This virtually precludes the possibility of preparing an Environmental Impact Document under CEQA.

For the moment, it appears that the MATO and RMWDR will allow GDR to streamline both its road and road facilities construction, decommissioning, maintenance, and mitigation.  However there is a danger here that public review on a THP basis could be hindered.

The general purpose of these agreements is two-fold.  First, it will allow GDR to perform under its AHCP obligations and the obligations of the Road Maintenance and Inspection Program while providing established standards and mitigations. Secondly, it will allow GDR to perform road and road facilities maintenance on a programmatic, basin-wide level as opposed to filing for individual Section 1600 permits and WDR’s through the individual THP process.  Unfortunately, there do not appear to be any provision to include the specifics of each programmatic operations in THP’s.