This letter concerns the close of public comment on timber harvest plan (THP) 1-97-352 MEN, a clearcutting plan by Louisiana Pacific Corporation in Greenwood Creek watershed, and a plan that poses serious jeopardy to our watershed, particularly given the plan's SYP implications.
Second review was Thursday, September 18. I, and three other Gap Boycott members, and one Elk water board member attended that review. We conducted ourselves in an orderly fashion and tried to follow the Review Team Chair's rules. We found, after sitting there for two hours, that the rules were not going to allow us to discuss this critical timber harvest plan with CDF with sufficient scope and detail to be called adequate review.
We had arrived at 1:00. NCRWQCB inspector Andy Baker requested of the CDF chair that our plan be moved up on the schedule, so that he would be present for the review of our plan. He had to leave at 3:00. CDF refused this request. Three o'clock came, and still our plan was not heard. Before Andy Baker and State Fish and Game's Rick Macedo (who also had to leave at 3:00) departed, we shared some of our concerns regarding the plan, in particular the salmonid crossings on the haul road and the classification of a fish bearing pond. Andy Baker wrote down recommendations for these problems. The CDF chair also wrote recommendations, eventually, when our plan began to be heard between 3:30 and 4:00.
There was discussion between that time and about 5:30, but much of the time was taken up with the CDF Review Team Chair reading from the record--the PHI, a letter of public concern, the geology report--and on writing out his recommendations during the meeting. He said that there was no other public comment in the record. However, we know that Charlie Acker, manager of the Elk County Water District, faxed a letter to both CDF Howard Forest and CDF-Santa Rosa on the morning of second review before 9:00, and that a Gap Boycott member wrote a letter of concern to CDF-Santa Rosa on September 15.
For these and other reasons we submitted a 15 page letter with 26 attachments detailing our concerns to CDF, on Friday, September 19, at about 3:00. Over the weekend, we discovered an important fact in the SYP maps that are referred to in this THP, a piece of information in the SYP that directly contradicts what the THP says about a Late Seral designation. We faxed this and other information to CDF on Monday, September 22.
We understand from the front office staff at CDF-Santa Rosa that CDF closed public comment for this THP on Friday, September 19, the day after second review, two hours after our first letter was submitted, and two days (over the weekend) before CDF-Santa Rosa received the CDF Review Team's recommendations.
We have several questions with regard to these procedures. One, how can public comment be closed before the receipt of the Review Team's recommendations? Two, how was the public to review the Review Team's recommendations and comment on them, if they hadn't been received by CDF-Santa Rosa on Friday? Three, why wasn't the ECWD letter considered at second review?
With this timber harvest plan, Louisiana Pacific announces its implementation of L-P's Sustained Yield Plan for Greenwood Creek without a public hearing and without approval of the SYP by CDF. The SYP implications of this timber harvest plan are profound. How can you close public comment so abruptly, with such irregular procedures and with so many important questions unanswered?
Please send us copies of the CDF Review Team Chair's and the NCRWQCB inspectors's recommendations, and please re-open the public comment period for this plan, so that we may comment upon those recommendations.
Norman de Vall, Co-Chair