EPIC's GIS expert created this map of Northern Spotted Owl habitat within the Green Mule Timber Harvest Plan.
EPIC comments to Cal Fire regarding SPI Timber Harvest Plan 1-10-025HUM “Green Mule” have forced the Department to reconsider the plan after the close in public comment. The new information and changes provided to the plan by SPI will likely require Cal Fire to recirculate the THP, allowing EPIC and the public the opportunity to analyze and comment on the newly submitted materials.
THP 1-10-025HUM, “Green Mule” proposes to log 92 acres, 89 via clearcut. The THP is within the 1.3mi home range of two Northern Spotted Owl centers. SPI intends to conduct clearcut logging within 1,000 feet of one of these activity centers. Clearcut logging within this distance of an NSO can result in significant habitat modification, alteration of home range micro climactic conditions, impair juvenile dispersal, and result in site abandonment.
Also at issue was SPI’s proposal to employ the U.S. Fish and Wildlife Service’s NSO take avoidance guidelines by utilizing interior region habitat definitions, but coastal region retention standards. The FWS has indicated to both EPIC and to Cal Fire that this approach was not scientifically defensible, nor consistent with the intent of the FWS guidance. In response to our comments on this matter, Cal Fire sent a letter to SPI requiring them to either employ the FWS guidance utilizing the interior region standards, or revamp the plan to comply with the sub-par California Forest Practice Rules NSO take avoidance option, called Option G.
SPI chose to revamp the plan to comply with option G. Option G allows landowners like SPI to employ sub-standard habitat protection and retention standards. Option G also allows SPI and others to employ antiquated, and inferior definitions for NSO habitat that represent the lowest possible denominator of what could be considered as NSO habitat. The FWS has indicated that the use of Option G will not likely avoid take of NSO in many situations. The “Green Mule” THP clearly represents one of these instances.
SPI has taken its opportunity to employ these sub-par standards, and now proposes to draw the critical area (core area) in such a way that it conveniently excludes the portion of the THP that would clearcut within 1,000 feet of the NSO center. SPI has reasoned that the THP area in question is not connected to the rest of the NSO core area because it is not typed as nesting/roosting habitat. However, EPIC’s review of the aerial photography and the THP habitat analysis maps suggests that the habitat typing provided by the RPF is questionable at best, particularly when the use of the sub-par FPR definitions is considered.
Thus EPIC’s comments have forced Cal Fire to reconsider the “Green Mule” THP, and will likely result in recirculation of the THP so that EPIC and the public can review and comment on the changes to the plan and the new information provided to the record. EPIC will continue to monitor the progress of this THP, and will likely submit further comments if and when the plan is recirculated.