CONCERNS ABOUT FISHER FAMILY LOGGING IN MENDOCINO COUNTY

INTRODUCTION

The memo and tables below provide details of the history and facts of Fisher family logging, owners of the Gap. Since this memo was written the Fishers' logging company has increased the annual acreage of logging plans by one third over former owner Louisiana Pacific, a notorious forest liquidator in northern California. They purchased 104 logging plans from L.P. and have filed numerous new logging plans in 1999 and 2000. They have defended the worst of the L.P. plans in court for two years, since they bought the lands - in a lawsuit that the Save The Redwoods/Boycott The Gap and other groups recently won. The Fishers are engaged in the final liquidation of these redwood forests. Here is how it unfolded. (Note: Regarding the logging plan tables below, the total acreage figure for 1999 was approximately 7,000 acres.)

CONCERNS ABOUT FISHER FAMILY LOGGING IN MENDOCINO COUNTY

The Fisher family purchased 235,000 acres of cutover Louisiana Pacific forest lands (mostly in Mendocino County), several L-P mills and L-P’s logging program, on July 1, 1998, and set up the Mendocino Redwood Company (MRC) to log the lands. The facts at that time were these:

• L-P had been engaged in "liquidation logging" of these forests for two decades. Almost all merchantable timber was gone. There was almost no old growth left. Wildlife habitat had been decimated. The Coho salmon was on the verge of extinction.

- According to L-P’s own statistics, in 1996, 97% of L-P forest acreage was in 1-21 inch diameter trees. The bulk of this acreage was in 11-16 diameter trees and smaller. Only 3% contained trees of 24+ inch diameter or greater–the only decent wildlife habitat. (See WHR Tables.) L-P has had some fifty Timber Harvest Plans approved since that time.

- According to L-P fish distribution surveys in 1994-1996, Coho salmon were absent in 19 of 27 watersheds in the L-P ownership. Of those 8 watersheds with any Coho at all, Coho were absent in 75% of the streams. Overall, Coho salmon were absent in 90% of the streams on L-P property. (See attached L-P fish data summary, and data sheet for Elk Creek.) Despite hundreds of samplings, over 3 years, the numbers in those 8 (of 27) watersheds are dismal (examples - Albion R., 200 coho, Navarro R. , 100, Big R., 120, Elk Cr., 5-10.) Historical and fishing records indicate a once-abundant Coho fishery on the Mendocino coast.

• L-P lands still don’t have an approved and viable "Sustained Yield" Plan. The SYP that L-P wrote contains egregiously inadequate protections for wild life, fish and other resources. It is clearly a plan for further depletion of all resources. (Drs. Fred Euphrat, Allen Cooperrider and Edmund Smith provided expert public comment on the SYP to this effect, in letters that are now part of the public record.)

• CDF continued to approve numerous high-impact Timber Harvest Plans for L-P, under the notorious "Option C" rules (which do not require an approved SYP), up to the moment of the change of ownership. These THPs have implemented the industry-devised standards of the as yet unapproved SYP (f.i., standards for stream protection, downed woody debris, monitoring, etc.). THPs have a life of 3 to 5 years.

• When L-P announced its intention to sell out in fall 1997, CDF’s Richard Wilson said, "It’s sad but it really should be no huge surprise. Everybody knew they were cutting themselves out of business." After years of delay, CDF and L-P finally released L-P’s "Sustained Yield" Plan for public comment several weeks after L-P announced that it was selling out (one of the bitterer ironies of the Mendocino logging story). Between that time and the beginning of escrow (May 1998), CDF approved 17 additional logging plans for L-P–still with no approved SYP.

Enter the Fisher family of the Gap and their logging company, Mendocino Redwood (MRC). The reasons that the Redwood Coast Watersheds Alliance and other groups, including Forests Forever, Bay Area Action, Rain Forest Action Network, the Sierra Club , the Christian Environmental Council, and the Mendocino Environmental Center are so concerned about Fisher family logging are as follows:

• The Fishers’s logging company, Mendocino Redwood Company (MRC) has continued to implement L-P’s unsustainable logging program, including the use of clearcutting in almost 50% of their plans, and the use of "even-aged" methods including clearcutting in over 70% of their plans–the same percentages as L-P. (See attached THP Tables.) These practices also include extensive use of herbicides, road construction in steep and unstable areas, and logging of the very last old growth and the last big trees in these forests. The THP tables combined with our study of individual THPs show us that the Fishers are logging no differently than L-P. The Fishers bought the L-P logging program along with the land and mills, and are engaged in the final liquidation of these forests.

• This winter (1999), the Fishers rushed a full crew of fallers into the Albion River Kaisen Gulch area–in February, in the rain–to log residual old growth and second growth trees for ten days, in an apparent attempt to beat the startup date for Spotted Owl surveys (March 1). People in the community hadn’t yet received the notice from CDF that the plan (THP 1-98-350 MEN) had been approved. The same week, the Fishers hastily amended an old 1995 plan in the Barn Gulch area of Greenwood Creek (THP 1-95-315 MEN Amendment no. 10), changing the plan from low-impact "commercial thinning" to high-impact strip clearcuts that will fragment and destroy the last old growth forest in Greenwood Creek, including extremely rare old growth trees estimated to be 200 to 600 years of age.

• The Fishers have furthermore begun an intense "green-washing" campaign–the likes of which we have never seen in Mendocino County (5 full page ads in one local paper). They are attempting to "sell" clearcutting as some sort of restoration program (!), and have created phony "stewardship" policies, such as their "old growth policy" (they won’t log trees of 250+ years of age and 48+ inches diameter, of which they have almost none), and their "variable retention" policy (clearcutting 90% of the trees instead of 100%).

- Re: MRC’s "variable retention"policy, see http://www.elksoft.com/gwa/ — the Flynn Creek clearcut — what "variable retention" looks like - 90% of the vegetation removed on a steep ridgeside, leaving small patches of scraggly trees that will blow down in the next wind.

- Re: MRC’s "old growth policy", see http://www.mendocinoredwoodco.com — the details of this "policy" are ridiculous. They say they will not cut trees of 250+ years and 48+ inches diameter when found in unentered stands of 20+ acres, but admit to having only one unentered stand — of 18 acres (by their reckoning). They also say they protect trees in 5+ acre stands with 6 or more such trees per acre — also virtually non-existent on L-P lands. Then they leave themselves a big loophole. Virtually the only old growth left on L-P lands is in "scattered residual" trees. As to these, they say they will "evaluate" their "importance" to wildlife!

- The Fishers have attempted to put "spin" on the L-P SYP tree size statistics and the L-P fish data — in effect, saying that these statistics are useless for determining conditions on these former L-P lands. This is their "line"–nothing more. The statistics speak for themselves. They have been reviewed by our experts (Dr. Fred Euphrat, Dr. Allen Cooperrider and Dr. Edmund Smith), who consider them to be meaningful. They are consistent with everything else that is known about the condition of L-P forests and fisheries.

• The Redwood Coast Watersheds Alliance filed suit on four of those 17 last-minute L-P plan approvals–the worst of the lot. When the Fishers became the owners, they hired L-P’s attorney Jared Carter to gain them the right to implement these "worst of L-P" plans.

- THP 1-97-445 MEN — a plan for clearcutting 418 acres (total 606 acres of logging), and 7 miles of road construction, directly upstream from the only Coho salmon found in Elk Creek and, indeed, the only Coho found in a 150 square mile region–a population sampling of "10 or fewer" fish--discovered in L-P fish surveys in 1994-96.

- THP 1-97-352 MEN — a clearcutting plan upstream from a town water well, that announces itself as the first plan of L-P’s as yet unapproved "Sustained Yield" Plan for Greenwood Creek (ten more years of clearcutting).

- THPs 1-89-100 and 1-89-145 MEN —the "Enchanted Meadow" area of the Albion River, a local recreational area — very old (1989) plans that the local community has been fighting for ten years (the logging plans that were the cause of the "Albion Uprising" in the mid-1990s--and the occasion for several previous lawsuits, including Schoen v. CDF.)

- RCWA tried to stop three other L-P plans, midway through escrow. One of them–THP 1-98-047 MEN, in the Albion River–can be viewed at http://www.elksoft.com/gwa. It is horrendous. (We ran into a politicized Appellate Court, which took 9 days to rule on our request for an emergency stay. L-P meanwhile started logging–and the Fishers then finished it.)

Additional reasons for serious concern about the Fishers and their logging practices:

• THP 1-97-445 MEN (Elk Creek clearcut) is one of the worst, most illegal plans we have ever seen. Not only does it threaten the last Coho salmon in an entire region, the forester originally claimed there were no fish in the stream at all (the same forester is now working for MRC). Local fisherkids then went up there and found and photographed numerous steelhead. Later, it came out that CDF and L-P had withheld L-P fish data from the public, which showed the presence of Coho and steelhead (in alarmingly small numbers).

• Jared Carter, on behalf of the Fishers, engineered an abberrant legal manuever, to re-circulate THP 445 for public comment, in order to perform a minor "fix it" of the plan and get it RE-approved. A local judge okayed this maneuver and mooted the entirety of THP 445–telling the Fishers and CDF, in effect, that they can do whatever they want with THP 445, with no court review. (They waited until we had filed our trial brief to do this — costing us a whole lot of money.)

• The National Marine Fisheries Service wrote two very strong letters to CDF about THP 445, when L-P was the owner. Now that the Fishers are the owners, NMFS has completely reversed itself and has okayed the plan, with only minor and cosmetic mitigations, with no fish surveys required, with no risk analysis, with completely inadequate cumulative effects assessment (the plan doesn’t even mention the "10 or fewer" coho or where they were found)–and with the intention (on NMFS’ part) that this plan will be precedent for the Fishers’ Habitat Conservation Plan. NMFS in other words has okayed massive clearcutting upstream from a dying fishery–an horrendous precedent for coastal Coho. The Fishers’ power and influence, and their "green-washing" of L-P’s logging program, has served the timber industry well.

• Garlon spraying (associated with clearcutting): The Fishers’ logging company has lifted L-P’s partial moratorium, and will only notify the immediate adjacent property owners within 300 feet. Garlon spraying is of great concern here — potential effects on public water supplies and swimming holes, on children, workers, wildlife, fish, live stock and pets. Garlon is known to cause disorientation in juvenile salmonids.

• "Winter operations": The Fishers are adding "winter operations" to almost all of their logging plans. Big impact on fish — from muddy roads, landslides.

• Targeting the last remaining old growth and big trees. The clearcutting areas in the Fishers’ plans generally include 50% or more redwood and Douglas fir. (They are not just removing tanoak!) Their "selection" plans are generally "high-grading" (taking the biggest trees). The Albion River watershed has the most big trees left. (See WHR Tables.) The Fishers currently have eight logging plans on the Albion, all with "winter operations."

Note on the Fisher family: The Fishers control both Gap, Inc., and the Mendocino Redwood Company. Donald Fisher is Chair of the Board of Gap, Inc. His son Bob is Exec. V-P and C.O.O. of Gap, Inc. The Mendocino Redwood Company, at their web site, states that the Fisher family is the "primary investor" in the logging venture. Bob Fisher discusses this logging venture as "our investment" in a letter to local activists (see www.elksoft.com/gwa — the "Picket Packet" section). All news releases and articles describe it as "a Fisher family investment." Gap, Inc., has recently tried to confuse people by saying that John Fisher (Bob’s brother) is the only family member with an "operational" connection to Mendocino Redwood Company. However, the Fishers’ profit expectations are certainly the key factor driving decisions at the logging company.

Prepared by Mary Pjerrou

Redwood Coast Watersheds Alliance

Table 1: TREE FARMING ON THE MENDOCINO COAST

Tree Sizes in Louisiana Pacific/Mendocino Redwood Co. forests as of 1995-96

- 97% in very small trees (1 to 21 inch diameter) —

- only 3% in larger trees (decent wildlife habitat) -

	Size 2	Size 3	Size 4.1	Size 4.2	TOTAL Acreage	Size 4.3	Size 5	Size 6	TOTAL Acreage
PERCENTAGE OF ACREAGE IN TREE SIZE CLASS	1-5.9 inch diameter trees	6-10.9 inch diameter trees	11-15.9 inch diameter trees	16-20.9 inch diameter trees	% 1 inch to 20.9 inch diameter trees	21-23.9 inch diameter trees	24->32 inch diameter trees	best wildlife habitat	% larger trees
SYP NO./WATERSHED
41. Hollow Tree Creek	0	22.5	68.5	8.7	99.7	0	0	00.3	= 0.3
47. Cottaneva Creek	0	8.0	65.0	19.0	92.0	0	0	08.0	= 8.0
55. Jack of Hearts Crk	0	15.3	84.0	0.5	99.8	0	0	00.2	= 0.2
70. Noyo River	1.0	19.0	29.0	51.0	100	0	0	0	= 0
71. McDonnell Ranch	0	14.0	01.0	85.0	100	0	0	0	= 0
72. Caspar Creek	37.0	0	63.0	0	100	0	0	0	= 0
74. Upper Big River	27.4	11.5	37.6	23.5	100	0	0	0	= 0
75. No. Fork Big River	34.6	12.8	38.3	14.3	100	0	0	0	= 0
79. So. Fork Big River	22.0	14.0	46.0	18.0	100	0	0	0	= 0
76. Two Log Creek	28.5	11.0	41.6	18.3	99.4	0	0	0.6	= 0.6
77. Reeves Canyon	16.0	2.0	48.0	34.0	100	0	0	0	= 0
78. Albion River	3.0	7.5	49.0	24.5	84.0	0	1.0	15.0	= 16.0
81. No. Branch Navarro	19.2	28.3	40.2	12.3	100	0	0	0	= 0
82. Navarro River	3.5	6.7	67.1	16.5	93.8	0	2.1	4.1	= 6.2
85. So. Branch Navarro	32.0	6.8	46.3	14.9	100	0	0	0	= 0
83. Ackerman Creek	14.3	3.2	50.3	32.2	100	0	0	0	= 0
84. Greenwood Creek	1.0	3.5	81.0	9.0	94.5	0	0.1	5.4	= 5.5*
86. Indian Creek	20.6	1.3	41.1	37.0	100	0	0	0	= 0
87. Elk Creek	6.4	3.6	73.0	8.6	91.6	0	0	8.4	= 8.4
88. Rancheria Creek	0	11.4	83.4	3.2	98.0	0	0	2.0	= 2.0
89. Alder Creek	1.3	5.4	73.5	11.5	91.7	0	0.3	8.0	= 8.3
91. Brush Creek	2.0	7.0	67.0	14.0	90.0	0	0	10.0	= 10.0
92. Zeni Ridge	20.0	06.6	65.0	4.8	96.4	0	0	3.6	= 3.6
93. Garcia River	13.4	31.8	42.7	7.8	95.7	0	4.1	0.2	= 4.3
94. Schooner Gulch	30.9	13.1	43.4	9.6	97.0	0	3.0	0	= 3.0
96. No Frk Gualala R.	0	59.0	32.0	9.0	100	0	0	0	= 0
97. Wheatfield Fork	1.0	32.0	35.0	32.0	100	0	0	0	= 0
98. Willow Creek	7.0	13.0	25.0	55.0	100	0	0	0	= 0

tot. of %’s	342.1	370.3	1437	574.2			10.6	65.8	76.4
div. by 28 =
AVERAGE %	12.21	13.22	51.32	20.50	97%	0	00.37	02.35	3%

These statistics are taken from Louisiana Pacific "Sustained Yield" Plan (SYP 95-003), "Wildlife Habitat Relationship" tables, current period (table generally appears on or near p. 20 in each watershed section). Tree sizes are in "diameter at breast height" (DBH) inches. The above table combines all trees in one size class regardless of canopy density. Note: Big River has at least one unentered old growth stand (Russell Brook) which doesn’t show up in the WHR tables.

Table 2: LIQUIDATION LOGGING ON THE MENDOCINO COAST

Logging since 1995 by L-P and current logging by MRC

is eliminating the meager portion of old, big trees (3%) reflected in columns 3 and 5

(statistics taken from L-P’s 1995 "Sustained Yield" Plan)

Fifty percent of the L-P/MRC logging plans for 1997-1998 target the areas that contain the last 3% of big trees.

WHERE IS THE OLD GROWTH?	tot MRC acreage	ac = 1 inch to 20.9 inch diameter trees	ac = larger trees (24->32 in.)	% = 1 inch to 20.9 inch trees	% = larger trees
41. Hollow Tree Creek	20,344	20,290	54	99.7%	0.3%
47. Cottaneva Creek	18,043	16,656	1,387	92.0%	8%
55. Jack of Hearts Crk	802	800	2	99.8%	0.2%
70. Noyo River	19,381	19,381	0	100%	0
71. McDonnell Ranch	627	627	0	100%	0
72. Caspar Creek**	297	297	0	100%	0
74. Upper Big River	6,888	6,888	0	100%	0
75. No. Fork Big River	4,697	4,697	0	100%	0
79. So. Fork Big River	18,113	18,113	0	100%	0
76. Two Log Creek	4,347	4,321	26	99.4%	0.6%
77. Reeves Canyon	1,782	1,782	0	100%	0
78. Albion River*	15,549	13,117	2,432	84%	16%
81. No. Branch Navarro	13,121	13,121	0	100%	0
82. Navarro River	23,073	21,635	1,438	93.8%	6.2%
85. So. Branch Navarro	14,890	14,890	0	100%	0
83. Ackerman Creek	3,898	3,898	0	100%	0
84. Greenwood Creek*	9,924	9,394	**550	94.5%	5.5%
86. Indian Creek	1,729	1,729	0	100%	0
87. Elk Creek*	14,022	12,839	1,183	91.6%	8.4%
88. Rancheria Creek	1,741	1,708	33	98.0%	2%
89. Alder Creek	10,472	9,601	871	91.7%	8.3%
91. Brush Creek	660	592	68	90.0%	10%
92. Zeni Ridge	328	316	12	96.4%	3.6%
93. Garcia River	11,508	11,015	493	95.7%	4.3%
94. Schooner Gulch	2,162	2,097	65	97.0%	3%
96. No. Fork Gualala River	946	946	0	100%	0
97. Wheatfield Fork	6,987	6,987	0	100%	0
98. Willow Creek	5,587	5,587	0	100%	0

	231,918	223,324	8,064	97%	3%

NOTE: 51% of the L-P acreage is in 11-16 in. trees; 25% smaller down to 1 inch, and 21% slightly bigger; with only 3% in trees in the large size class. * The Albion River, which contains the largest % of big trees (16%) had eight logging plans approved in the last two years alone. Elk Creek (8.4% of the big trees) has five clearcutting plans. Greenwood Creek (5.5%) lost 20% of its rare old growth in May 1998, with THP 98-042, despite a legal effort to save it. The Redwood Coast Watersheds Alliance filed suit on four Albion River, Elk Creek and Greenwood Creek logging plans in 1998.

* *Caspar Creek L-P forest is all 1 inch to 15.9 inch diameter trees.

MENDOCINO REDWOOD COMPANY

TIMBER HARVEST PLANS 1997

(all plans filed by Louisiana Pacific; uncompleted plans now belonging to MRC)

1997

DATE	THP	ACRES	SILVIC.	LOCATION	notes	cc	cc	high
							type	WHR
1/13	020	63	cc	Elk Cr	cc #1	X		X
2/7	068	212	sel, sts, cc, swr, str, ct	Big River		X	X
2/17	082	287	ct, cc, rehab	Ellison G (Big River)		X
2/26	101	375	str, ss, rehab	John Smith Cr (Navarro)			X	X
__/1	109	(290)	rehab, sel, cc	Hayworth Cr	withdrawn	(X)	(X)
4/11	134	382	sel	trib Salt Cr (T21 R12)
4/18	140	169	sel	Ackerman Cr
4/28	156	41	cc, ap	Sulphur Fk, Elk Creek	cc #2	X	X	X
5/13	186	321	cc, rehab, ap	MF/NF Noyo, Dewarren Cr		X	X
5/29	217	113	cc, str, sel, ap	Hayworth		X	X
7/7	271	197	cc, sel	Bull Cr (T16 R16, sc 14,15)		X
7/30	316	221	cc, sel	Elk Cr	cc #3	X		X
8/11	493	’94 - add 27 ac	swr, cc	Low Gap Cr		X	X
8/18	352	116	cc	Greenwood Cr	* 96 ac/cc	X		X
8/19	357	50	sel	Hardy Cr
8/25	372	147	cc, sel	Ray Gulch		X
8/28	380	325	ct, sel	Albion				X
8/28	381	22	cc	SF Big River		X
9/26	421	73	sel, cc	Tom Bell Cr (Albion)		X		X
10/2	430	65	ct, sel	Hollow Tree, Butler, Jack of Hearts Crs				X
10/2	431	90	ap, cc	Bear Wallow, Jack of Hearts		X	X	X
10/16	445	606	sel, cc	Elk Cr (cc=418 ac)	* cc #4	X		X
11/21	482	129	ct, str, rehab	Hollow Tree Cr			X	X

	subtotal	(4031)
		(-290)
		=
	TOT.	(3,741 ac)

cc = clearcutting. ap = alternative prescription. str — seed tree removal. sel = selection. ct = commercial thin. swr = shelterwood removal. sss — sanitation salvage. sps = shelterwood prep. sw2 = shelterwood, step 2 (cc). stst = seed tree seed step. trans = transition. rehab = rehabilitation (cc). [note: all but sel, ct, sss and trans, are cc-type cuts]

Summary: More than 50% of these plans include all or partial clearcutting (15 of 22 approved plans). More than 70% (17 of 22) include high-impact logging methods ("even-aged," clearcutting and clearcutting-type). 11 of the 22 plans (50%) are in areas with the largest % of the last remaining big trees and old growth (of overall ownership 3%), as revealed in L-P WHR tables.

* Note: THPs in 1998 litigation: THP 445 — Elk Creek. THP 352 - Greenwood Creek (1 unit of cc removed, leaving 96 ac of cc.) THPs 89-100 & 145 - Enchanted Meadow (Albion River, tot. 56 ac.) - cum. effects amendments were approved - am.'s originally filed as "minor" resulted in Schoen v. CDF, requiring "major" am’s.)

Note: Big River has at least one unentered old growth stand (Russell Brook) which doesn’t show up in the WHR tables. Also, the column "high WHR" is not complete. Research has not been completed to determine the WHR category of several of the streams with THPs. The number of THPs in drainages with high %’s of big trees could be greater.

MENDOCINO REDWOOD COMPANY

TIMBER HARVEST PLANS 1998

(1/1/98 through 6/30/98 filed by Louisiana Pacific; 7/1/98 and beyond filed by MRC — all belonging to MRC)

1998

DATE	THP	ACRES	SILVIC.	LOCATION	notes	cc	cc	high
							type	WHR
1/14	019	113	cc	Elk Cr	cc #5	X		X
1/14	022	20	cc	Ackerman/Alder		X		X
1/26	031	68	ap	Mills Cr			X
2/6	042	192	sel	Greenwood Cr				X
2/11	047	176	cc, sel	SF Albion		X		X
2/20	059	70	sel	Tom Bell/Albion				X
2/24	065	61	cc, sel	SF Big River		X
2/26	069	95	sel, cc, ct	SF Big River		X
4/14	128	222	sel,cc, str	Marble Cr (Noyo)		X	X
5/19	186	132	cc, sel, ap	Hardy		X	X
5/29	193	572	str	SB NF Navarro			X
6/3	199	233	sel	Albion - J Rd-E				X
6/3	202	168	sel, str	SF Albion-Mack G			X	X
6/17	219	222	sel, ap	Flynn Cr (Navarro)			X	X
6/30	235	63	cc, str	Noyo		X	X
	subtot	(2407 ac)
(Note: change of ownership date 7/1)
7/8	249	266	cc, sel, ap, ct	Cotteneva Cr		X	X	X
7/31	282	223	sel	SF Albion				X
8/20	312	152	ap	Mallo Pass			X
8/28	320	131	sel, swr, sss, sps	Big River			X
9/4	329	138	cc, sel, sw2, str	NF Noyo		X	X
9/23	350	218	sel	Clearbrook (Albion)				X
10/13	372	57	cc	Redwood Cr		X
10/20	376	212	swr, ap	Slaughterhouse			X
10/20	377	100	cc	Redwood Cr		X
11/9	396	132	cc, str, trans	T19, R15 -22,27,28,33		X	X
12/__	404	125	sel, stst, trans	Big River (nr Russ. Br)			X

	subtot	(1,754 ac)
	TOT.	(4,161 ac)

Summary: 50% of these plans include all or partial clearcutting (13 of the 26 approved plans). Over 80% (22 of 26) include high-impact methods ("even-aged," clearcutting and clearcutting-type). 12 of the 26 plans (almost 50%) are in areas with the largest % of the last remaining big trees (of overall ownership 3%), as revealed in L-P WHR tables.

Notes: Flynn Creek "ap" (alternative prescription) THP 219 strongly resembles a clearcut (see www.elksoft.com/gwa), as do many of the non-cc plans. Big River has at least one unentered old growth stand (Russell Brook) which doesn’t show up in the WHR tables. Albion River (big trees 16%) had 8 logging plans approved in 2 years. Elk Creek (big trees 8.4%) had 5 clearcutting plans approved in 2 years. Greenwood Creek (big trees 5.5%) was stripped of 20% of its old growth, in THP 042, while the Appellate Court delayed ruling on a request for an emergency stay for nine days. (THPs 97-445, 97-352, & Enchanted Meadow amendments, are still in litigation.)