Green Diamond relies heavily on voluntary measures such as its terrestrial deadwood management plan, which is supposed to leave remnant habitat structural elements to support species such as NSO and Pacific Fisher. However there are no enforceable standards associated with this plan that the Department of Forestry can gauge and measure during site inspections.
Green Diamond does not actively survey for species such as Pacific Fisher, relying instead on track-plate detections, which is a poor method for determining location, status, and habitat use for this species. Other non-covered species such as the Red and Sonoma Tree vole, which are a regular part of the diet of NSO, are generally unprotected by Green Diamond during logging operations.
In terms of aquatic species, even though Green Diamond has an AHCP with prescribed mitigation measures to avoid impacts to aquatic wildlife, these measures are generally inadequate. Protections such as so-called “equipment exclusion zones”(EEZ) associated with watercourses are misleading and inadequate to prevent sediment and temperature impacts. In truth, the EEZs are not EEZs at all, but rather are more accurately “equipment limitation zones”, and there are barely any restrictions for which there are not exceptions. Green Diamond regularly conducts ground-based yarding operations in riparian management zones (RMZs), even where steep-streamside slopes exist.
The result is that incidental take of aquatic wildlife such as salmonids and amphibians does occur, and habitat for these species continues to be degraded. Green Diamonds aggressive logging approach, even where selection in RMZs occurs, can and does affect sediment levels and stream temperatures.
Finally, Green Diamond does not consider or address the potentially significant impacts of its intensive and wide-spread herbicide use, particularly on aquatic species. Green Diamond’s own research suggests that herbicides can and do persist on the landscape and in affected watercourses, and research suggests that herbicides can and do affect critical life history stages in some aquatic species. The impacts of herbicide use on terrestrial species is not really understood at all, and Green Diamond does not conduct research on the impacts of herbicides on terrestrial species.
In sum, while Green Diamond’s HCPs regulate to some extent the methods and manners of logging operations on its lands, covered as well as non-covered species remain subject to significant habitat destruction as a result of intensive clearcutting that continues virtually unabated.
In this regard, the California Forest Practice Rules are vastly inadequate to protect threatened species and species of concern as the emphasis in the rules is not on wildlife protection, but rather on cutting as much as possible, as fast as possible. The Department of Forestry largely ignores the paltry provisions of the FPRs that vaguely state that sufficient habitat for resident wildlife be preserved.
The rub is that this provision targets habitat retention for within watercourse zones, and provides no particular standards or targets for habitat retention as a general part of planning of logging operations. Thus Green Diamond and its liquidation of suitable habitat for threatened species and species of concern is enabled by a Department of Forestry that is driven by the charge to approve THPs, rather than protect wildlife.