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Certified Redwood Forests and Public Trust Resources

by Tomas DiFiore
The importance of fog, and fog drip to regrowth of the forest within the range of coastal influence is not discussed in Chapter 8.4.3.4, of MRC's draft HCP. What management options (silvicultural prescriptions over the duration of the HCP) would achieve a positive increased input to forest hydrology, redwood ecology, and overstory interception? This would have been a much more useful discussion in THPs Section under CEQA “Alternatives Considered.” How is the role of fog (including fog drip as throughfall, stemflow, infiltration) to redwood ecology enhanced by silvicultural proposals over the term of the HCP? Industrialized cut-over watershed studies do not suffice for supportive documentation in MRC forest restoration management under it's Option A Planning Documents. MRC's draft HCP only address the impacts of silvicultural prescription on forest hydrology in terms of the soil water balance and swales, landslides, mass movement, soil pipes, flow, pore size, saturation, and peak flows.
certified_redwood_forests_and_public_trust_resources.pdf_600_.jpg
Certified Redwood Forests and Public Trust Resources

In the FSC Certification of Mendocino Redwood Company, often times throughout the 2010 “Forest Management And Stump‐To‐Forest Gate Chain‐Of‐Custody Certification Evaluation Report” and yearly audits, the Certifying Bodies and Accreditation Services quote phrasings right out of the Forest Landscape Management documents of MRC. My favorite is “... to return the forest to desired future conditions.”

Herbicides and Dead Standing Trees

Tanoak suppression, fire dangers, fuel loading.... the forest is no longer seen as an ecosystem. MRC management documents speak of “legacy operations” that have resulted in the depleted forest landscape today. And some forests are of particular concern because past management practices, namely fire exclusion and timber harvesting, have already increased the likelihood of uncharacteristic impacts from fire and insects. Segmented scientific studies support forest resource extraction and transfer of forest carbon to consumer outlets. I have not found the words “Public Trust” in any associated MRC document. Neither the Forest Stewardship Council (FSC) nor Sustainable Forestry Initiative (SFI) certification or their respective audits mention the “Public Trust”.

Hence the focus is not forest management plans and operations designed to meet species’ recovery goals, as well as landscape level biodiversity conservation goals. The FME (Forest Management Enterprise or MRC in this case) sees tanoak removal as a forest restoration to redwoods and Douglas fir. “The auditors confirmed that tanoak has historically been a rather small component of the forest in region. Last, not all tanoak is being eliminated from the forest. It is scattered throughout the property, and included in RSAs and tribal areas of concern to name a few. In conclusion, it was the auditors’ opinion that MRC is in overall conformance to the FSC‐US Standard for chemical use.”

Fire Ecology - Balancing Wildlife Needs and Fire Hazard Reduction in the Central Sierra Nevada - An Ecosystem Management Strategy for Sierran Mixed-conifer Forests is a technical study that attempts to move the discussion beyond limited choices between fuels management and wildlife needs. A 49-page synthesis of current research. An Ecosystem Management Strategy for Sierran Mixed-conifer Forests. Malcolm North et al. 2009. Gen. Tech. Rep. PSW-GTR-220, USDA Forest Service, PSW Research Station
http://www.fs.fed.us/psw/publications/documents/psw_gtr220/psw_gtr220.pdf

But this is an article on Coastal Redwood Forests and the Public Trust Resources which flow through public and privately owned forested landscapes. The coastal influence of the ocean, the marine layer, fog and rain, on the streams, lakes, rivers, the watershed water balance, the full hydrologic cycle of forested slopes, tree growth, soil moisture levels, aquifers, groundwater recharge, thermal ecology and ecological energetics of species, nutrient cycling. I have submitted most of this information in the form of public comments and will continue to do so. Please download the 22 page PDF and help open the discussion on the role of fog and fog drip to coastal influenced watersheds.

These comments address the “Cumulative Impacts and Climate Change” Section 4 of Mendocino Redwood Company Timber Harvest Plans. (Which references another document explicitly by chapter: “Fog Drip - Chapter 8.4.3.4, of MRC's draft Habitat Conservation Plan”).

The section referred to above, in Mendocino Redwood Company's Draft Habitat Conservation Plan (HCP), provides sources of inconclusive research data, and at that, is selective at best. The discussion and resources cited in the Draft Habitat Conservation Plan regarding the role of fog and fog drip are incomplete. The suggested HCP Chapter provides no discussion of the role of fog and fog drip over the larger time-scale of the watershed hydrologic cycle. Neither is there a Risk Assessment evaluation of climate change quantifiers beyond the Harvest Block, (including but not limited to the landscape of the Sustainability Unit, Watershed Assessment Area or Biological Assessment Area - CA DFWS, DFG, CDF, CALFIRE, and the draft HCP area). Natural replenishment to the hydrologic cycle is separated from larger watershed dynamics of a healthy functioning forest ecosystem and filtered out through immediate response criteria in a metric of (temporary) increases to streamflows. MRC timberland management (silvicultural regimes) forces juvenile conifer regeneration employing methods that continue the desertification and depletion of Mendocino County redwood forests.

Why is MRC still working from a “draft” Habitat Conservation Plan? Even the FSC Certifying Bodies and Auditors have stated that there are problems with this arrangement.

What does and audit look like? This is a Public document....
"Forest Management And Stump‐To‐Forest Gate Chain‐Of‐Custody Certification Evaluation Report 2011"
http://www.mrc.com.php5-19.dfw1-2.websitetestlink.com/wp-content/uploads/2012/01/SCS_FM_Public_Summary_2011.pdf

CERTIFIED 30/Nov/2010
EXPIRATION 30/Nov/2015
Comments, concerns, complaints are due now, send to:
sgrado (at) hotmail.com


Respectfully Concerned,
Tomas DiFiore
Coast Resident
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