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L-P Forests Destroyed Using Board of Forestry's "Sustained Yield" Rules

-- Albion River old growth targeted by the Gap investors --

by Mary Pjerrou

The Tree Size Chart ("Status of L-P/MRC forests in 1995"), which contains statistics taken from Louisiana Pacific Corporation’s proposed "Sustained Yield" Plan (SYP) for coastal Mendocino, reveals conditions on L-P forest lands, as follows: 97% of L-P forest lands are in 1-21 inch diameter trees. Of that 97%, 51% are in 11-16 inch diameter trees, 20% are in 16-21 inch diameter trees, and 25% are in saplings and pole trees. Only 3% contain trees of 24->32 inch diameter or greater (decent wildlife habitat). There are apparently no trees on L-P lands in the 21-24 inch diameter class–the critical link to future old growth.* Half of L-P watersheds contain no old growth at all. The other half share out that meager portion of old, big trees (3%) among them, with the Albion River watershed apparently having the best portion of decent-sized trees (16% of the L-P acreage in the 24->32 inch diameter class).

Those sobering and, indeed, catastrophic numbers from L-P's own "Sustained Yield" Plan (SYP) tell the very tragic tale of the failure of the Forest Practice Rules–and the failure of our government–to insure sustainable logging. The people in the logging community know this, deep in their hearts. They know the timber is gone, and they know the profits have gone elsewhere. The fisherfolk surely know it. There are no more fish. Commercial salmon fishing is finished.

It is now 1998, and L-P was not idle during that 3-year period before they sold out their Redwood business. L-P filed at least 132 new logging plans, in Mendocino County alone, during that period. That 3% of old growth in the L-P SYP tables is likely down to 1-2% by now.

The Fisher family, founders of the Gap clothing store chain, and their Mendocino Redwood Company, purchased these 231,000 acres of raked over L-P forest lands on July 1, 1998, in order to complete the liquidation of that last pathetic 1 to 2% of old, big trees on L-P forest lands in Mendocino County.


The timber harvest plans that the Gap investors purchased from L-P, and the ones that MRC is now filing, target the 14 coastal watersheds with any remaining old growth, especially the Albion River, with its relatively fat statistic of 15-16% big trees. The seven current timber harvest plans in the Albion River watershed illustrate what the Gap investors are up to.

These Albion River logging plans total about 1,400 acres of logging.** Every one of these plans contains "selection" logging, which means that the plan contains significant-sized trees that will be "high-graded" (taking the biggest trees–that is, the old growth). All of them contain winter operations, which means that the Gap investors are in a great big hurry to log them–despite the high impact of winter operations on the endangered fishery and on the already impaired water quality of the Albion River.

The Albion River logging plans furthermore include 233 acres of clearcutting and seed tree removal (high impact methods), and extensive road building on steep and unstable slopes, tractor yarding on steep slopes, operations on highly damaged roads with numerous landslides, fill failures, bank slumps and gullying, haul roads within the stream protection zones of Class I fish-bearing streams, and extremely inadequate cumulative effects assessments.

The Kaisen Gulch plan (THP 1-97-380 MEN) has already been the subject of litigation and of recent logging protests by the local community. The Kaisen Gulch plan contains old growth trees marked to be cut. (For further information on the on-going effort to stop this plan, call the Kaisen Gulch group at (707) 937-5703.)

The Redwood Coast Watersheds Alliance tried to stop THP 1-98-047 MEN, a logging plan in the south fork of the Albion that includes 112 acres of clearcutting (176 ac. total). RCWA filed suit on this plan in May while L-P lands were in escrow. The judges took twelve days to rule on RCWA’s request for an emergency stay of logging, while L-P hurriedly logged the three plans in that lawsuit, making the lawsuit moot.

In the last ten years, 61% of the Albion River south fork has been cut using mostly evenaged (clearcutting-type) cuts. This didn’t matter, of course, to CDF or L-P. CDF has never disapproved a logging plan because of cumulative effects.

The litany of Albion River logging plans by Mendocino Redwood Company (the Gap investors) tells a horrifying tale of maximum impact on the highly endangered Coho salmon, and a greedy stripping off of any remaining big trees. Plan after plan contains old growth logging and extensive road construction that will exacerbate the already high sedimentation in the Albion River drainage.

The plan numbers are as follows: THP 1-97-380 MEN, Kaisen Gulch, middle Albion, 325 acres. THP 1-98-047 MEN, Little Bull, south fork of the Albion, 176 acres. THP 1-98-059 MEN, Melbourne West, middle Albion, 70 acres. THP 1-98-199 MEN, J-Road East, lower Albion estuary, 233 acres. THP 1-98-202 MEN, Tilley Road, south fork of the Albion, 168 acres. THP 1-98-282, Norden Gulch, south fork of the Albion, 223 acres. And a new as yet unnumbered plan for 200 more acres, Clearbrook Creek, middle Albion, adjacent to Kaisen Gulch.

There are only about 200 Coho salmon left in the entire Albion River stream system (43 square miles). Every one of the above logging plans ought to be stopped until that number improves. That is what the Endangered Species Act is about. If what you are doing is killing an endangered species, then you must stop what you are doing.

The road construction in these plans will cause much more sediment to enter the Albion River this winter–especially with winter operations on muddy roads and hillsides. CDF and MRC cannot tell you how much more sediment–because they don’t know. They are playing with the death of an entire species and have no facts to back up their repeated assertion of "no cumulative effects."


You might wonder, in all this, what ever happened to L-P’s proposed "Sustained Yield" Plan? Didn’t this corporation promise the Board of Forestry, and the people of Mendocino County, that they were now going to log sustainably–back in the early 1990s, after more than a decade of "liquidation logging" by Harry ("I want it!") Merlo?

Didn’t they also promise that they were in it for the long term–that they were here to stay–now that they were going to log sustainably?

Well, a funny thing happened to "sustained yield" plans on their way into the Forest Practice Rulebook. Somehow, the Board of Forestry forgot to put in a deadline for industry to have an approved Sustained Yield Plan. They also put in a set of rules, called "Option C"rules, by which industry could just keep right on logging at any rate they chose, while their so-called "Sustained Yield" Plans underwent three years of "sufficiency review" (out of the public eye) at the Department of Forestry.

L-P’s "Sustained Yield" Plan was released from "sufficiency review" (and put out for public comment) shortly after L-P announced that it was selling all of its Redwood forest lands, last November. There is still no approved SYP for L-P lands.

Mendocino Redwood Company, on behalf of the Gap investors, has extended the public comment period for the L-P/MRC "Sustained Yield" Plan through January 1999. The SYP is a seriously defective document in need of extensive revision. But the truth is that MRC doesn’t need the SYP. MRC is cleaning up after L-P--taking the last merchantible timber off L-P forest lands--using "Option C" rules.

This royal hoodwinking of the public was arranged by Governor Pete Wilson’s campaign manager, Terry Gorton, whom Wilson appointed as head of the Board of Forestry back during the Harry Merlo era "liquidation logging" crisis. Gorton worked closely with timber industry lawyers to write a set of bogus "sustained yield" rules by which industry could do anything it wished and call it "sustainable logging."

This is how you destroy a Redwood forest sustainably. You call whatever you are doing "sustainable," when, in truth, it is nothing of the kind. (My Dad used to call this "the Big Lie"–although he was referring to Joe Stalin.)


Linda Perkins, of the Albion River Watershed Protection Association/Friends of Salmon Creek (ARWP/FOSC) points out that, of four recent L-P/MRC logging plans in the Albion watershed--one each in the four watershed assessment areas of the Albion River drainage--not one of these four logging plans admits that there is "late successional" forest (old growth trees) in its watershed assessment area. And this is very strange because the statistics in L-P’s SYP for the current period indicate that 15% of the L-P acreage in Albion contains "late seral" forest (pretty much the same thing as "late successional" — meaning 24->32 inch diameter trees in a forest with 60% canopy closure and other decent wildlife characteristics).

If Albion does contain the total of 16% in big trees (indicated in the SYP tables), where is it, and why do the individual THPs state that it is not present? If Albion does not contain 16% of the L-P acreage in big trees, how many big trees, if any, does it contain? Are we looking at an overall L-P forest with no big trees at all, anywhere?

Well, we know that isn’t true, because local people have located some of the big trees. So, the answer is that the individual THPs are not telling the truth about what is present in the watershed assessment areas. L-P/MRC logging plans routinely deny that there is any old growth forest anywhere, because they might be restricted from logging it (if it is 20 acres or more), or, more likely, people might try to stop them from logging it, because there is so little left. L-P forests in Albion may have more than 16% of the acreage in big trees; it may have less. You can’t really tell for sure from L-P documents. But with overall statistics and many indicators showing an almost complete loss of old growth in coastal Redwood forests owned by industry, how is it that CDF is allowing any logging of old, big trees without knowing what is left? How can they say that this is "sustainable"?

Perkins reports that she asked this question about Albion old growth in her public comment on a recent timber harvest plan: Where is this 15% of "late succession" forest in the Albion (as stated in the "Sustained Yield" Plan), if recent timber harvest plans in the four Albion River assessment areas state that it is not present in any of those assessment areas?

The answer she got is typical of CDF. First of all, they didn’t answer her question during the public comment period. They answered it in the Official Response to Public Comment after the plan was approved. They said that the 15% of "late succession" forest was a future figure--predicted for a later period of the SYP.

However, the 15% statistic that Linda quoted was not from a future period. It was from the SYP’s "current period" table.

CDF was just plain wrong about this--but, as usual, there is nothing that can be done about CDF being wrong, except to sue them (if you can afford the expense and the grief). The public has no chance to refute such false statements, because the THP is already approved at that point.

They never answered Linda’s question.

It is difficult to know which is worse–that the 15% of Albion River old growth is in the future (that all the old growth is gone in the Albion), or that CDF and MRC are lying about it.


The Gap investors’ Mendocino Redwood Company is certainly better at public relations than L-P ever was. You won’t find MRC President Sandy Dean saying, "I want it!" But their excellent P.R. skills don’t change what is actually happening on the ground and in the forest, where "liquidation logging" continues unchecked.

Regarding the notorious THP 1-97-445 MEN in Elk Creek (where a tiny population of 10 or fewer Coho salmon is at risk of extinction), Mr. Dean recently stated in the Ukiah Daily Journal that "the areas slated for clearcuts are largely populated by tan oaks, which often take over when conifer forests are over cut."

Mr. Dean’s assertion is directly contradicted by the THP itself, which states the following: "The tree species composition is composed primarily of second growth Redwood (Sequoia sempervirens), and Douglas-fir (Pseudotsuga menziesii)....Also, where Doug-fir is occurring it tends to occur in small concentrations along with the hardwood component. Madrone, chinkapin, and other hardwoods make up a much smaller percentage of the area." (THP 97-445, p. 21)

The THP also gives pre-harvest species percentages, specifically for the clearcutting areas, as follows: "Redwood and Douglas-fir 58%, All hardwoods 42%." (THP p. 28.) No tanoak percentage is given, but it should be noted that the Forester, in his general description above, doesn’t even mention tanoak. Presumably tanoak comprises some portion of this 42% hardwood component (it has been locally verified). But it is just plain wrong of Mr. Dean to say that the clearcutting areas are "largely populated by tan oaks." The truth of the matter is that they are "largely populated" by Redwood and Douglas-fir.

This is an old L-P line–that they have to clearcut the tanoak in order to grow conifers (Redwood and Douglas fir). It was baloney then. It’s baloney now. Clearcutting causes tanoak to grow. Tanoak is a quick-growing, healing species--Nature's way of providing ground cover and wildlife habitat. To remove the tanoak again, by wholesale clearcutting, is to compound the problem. That’s one of the reasons L-P lands are such a mess and have so little timber left on them (not to mention forest).

The lies of CDF, the lies of foresters in timber harvest plans, the lies of L-P and the Board of Forestry and Terry Gorton, are why L-P Redwood forests are in their present condition, with a vast landscape of small trees, no wildlife habitat left and a dying fishery. Mendocino Redwood Company and the Gap investors are no better, and they might even be considered worse, since this ancient Redwood forest ecology is going to collapse on their watch, and with their assistance, and all we get from them are P.R. statements, such as this, from John Fisher: "Fisher said the family — which has a history of donating to and being involved in environmental organizations — is interested in changing the way logging is done and setting an example, a good one. ‘We think we can make a difference,’ he said." (UDJ, by Glenda Anderson, 9/6/98)

The Fishers can, indeed, make a difference. They can save the coast Redwood forest, or not. They can save the Coho salmon fishery, or not. They have the money–a fortune reported to be somewhere between eight and eleven billion dollars–to do anything they want. Instead of defending L-P’s failed program, they ought to place the entire ownership into a conservation land trust, and employ loggers, fisherfolk and others to restore these battered forests. Squeezing the last bit of profit out of L-P’s extremely overcut and damaged forest lands--and seeing the Coho salmon go down forever--is not something the Fisher family will want to be known for.




*Note: This statistic on the 21-24 inch diameter class–0% of such trees on L-P lands–could be an artifact of the sampling system used by L-P for the SYP data. For instance, it could mean that the number of such trees were so few they didn’t show up in samples. Also, at least 300 acres of old growth is known to exist in Big River in the Russell Brook plan, but these L-P tables say that Big River has no old growth.

**Note: In addition, Georgia Pacific has a total of 367 acres of high-impact logging in the Albion, including about a 100 acres of clearcutting and clearcutting-type logging, and winter operations in extremely steep and unstable areas (THP 1-97-051 in Kaisen Gulch, and THP 1-98-256 in Portuguese Gulch).



Please sign and help circulate the Petition to the Fisher family that is enclosed with this Environmentalist. (The Petition is also available on-line, for signing and downloading, at: , and at the San Francisco Bay Guardian web site, at: ).

Letters of public comment should be sent to: California Department of Forestry & Fire Protection, attn. Forest Practice, 135 Ridgway/P.O. Box 670, Santa Rosa, CA 95402, fax (707) 576-2608, tel. (707) 576-2959.


Letters to the Fisher family about their L-P forest land investment should go to:

The Fisher family c/o Bob Fisher, Gap, Inc., 900 Cherry Ave., San Bruno, CA 94066.



THP 1-98-266 MEN, a Roger Burch/Cloverdale mill logging plan for 402 acres of high-impact logging in Elk Creek has been re-opened for public comment through September 29. THP 266 together with the Gap investors’ plan, THP 1-97-445 MEN, comprise over a thousand acres of logging surrounding the only known population of Coho salmon in Elk Creek. The National Marine Fisheries Service has stated that THPs 98-266 and 97-445 have inadequate cumulative effects assessments and will likely harm Coho salmon. Write to: California Department of Forestry & Fire Protection, attn. Forest Practice, 135 Ridgway/P.O. Box 670, Santa Rosa, CA 95402, fax (707) 576-2608, tel. (707) 576-2959. And sign the Petition!



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Green Party of Mendocino County, Alliance for Human Rights,

P.O. Box 533, Talmage, CA 95481 * (707) 459-5490 ext 501 fax 468-1009.

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