To Bruce Halstead, Micheal Spear, William Hogarth and VP Gore. 
Dear

        The Habitat Conservation Plan (HCP) for Headwaters Forest is now released for public comment, and we want to take this opportunity to express our deep concern.  This document is far from desirable, even far from adequate and needs major changing.  The HCP and Sustained Yield Plan (SYP) lack hard scientific evidence and strong legal backing and should not be approved as they now stand.
        To begin with, the HCP would grant Incidental Take Permits for thirty-six species of fish and wildlife.  It is true that only a few of these species are currently listed as threatened or endangered, but all are rare, and if Pacific Lumber continues as it is going, they all may become threatened.  The focus of the HCP is almost solely on the marbled murrelet, the coho salmon, and the northern spotted owl, even thought there are 33 other species that deserve study.
        The northern spotted owl lays its eggs in the branches of the canopy of old growth forests.  It needs this thick canopy covering as protection to survive.  To protect this bird, Pacific Lumber has =93set aside=94 some of its holdings of old growth forest.  But only for fifty years.  This is NOT permanent protection, especially since the land will stay in Pacific Lumber=92s hands and a special amendment could allow logging in as soon as ten years.  Since it has not happened already, the majority of the potential murrelet habitat needs to be surveyed by a trained, unbiased specialist.
        The northern spotted owl needs the protection of older, interior forests for protection and it also needs to be close to open areas, like prairies, where it can find prey more easily.  A survey monitoring the owls needs to be conducted in a scientifically credible way.  Currently, the plan will leave standing all of the owl=92s active nesting areas for the first five years.  Five years does not ensure species protection, and just saving their nesting sites does not ensure their survival.
        Now we come to the coho salmon.  These fish were once abundant in California with population numbers between 125,000 and 400,000.  Now the population has dropped to approximately 10,000.  This drop in population has also resulted in the loss of about 35,000 to 40,000 fishing jobs.  A federal recovery team needs to be established to evaluate the condition of the coho salmon.  An independent group of experts need to be allowed to review the plan and asses the damage that will be done to the fish.
        Coho salmon need freshwater for spawning and for the development of the young fish.  They are extremely sensitive to high temperatures and sediment.  A stream above seventy degrees is lethal to the fish.  Since the temperature in northern California can reach 100 degrees during the summer months, dense forests are necessary around the salmon streams to keep it shady and the stream temperatures low.  Thus, buffer zones are vital.  Pacific Lumber=92s plan would leave zones of 100 feet from Class I, fish-bearing streams and would only restrict all logging within 30 feet of the stream.  Their plan would also allow for limited logging every twenty years.  No logging should be allowed in the buffer zones.  The Federal Ecosystem Management Team (FEMAT) is largely regarded as some of the best science on salmon protection available.  Their research shows that in a predominantly redwood forest, the buffer zone for class I streams should be 300 feet.  This is three times what Pacific Lumber is proposing.  The provisions of the HCP need to be strengthened and the buffer zones extended.    Pacific Lumber also offers no restrictions on Class III streams, although these are the streams that carry sediment to the Class I and II streams.  Hence buffer zones for the Class III streams also need to be instigated. 
        Pacific Lumber should not be given take permits to log in Headwaters Forest when they have continually violated the California Forest Practice Rules and the federal Endangered Species Act.  They should be denied per 50 CFR 13.21(b)(1).  How can we expect this company to log responsibly with such a poor record?
        
        The watershed assessment process needs to be redefined.  Currently, it caps the no-cut buffers at 170 feet.  The purpose of the assessment is for biologists to determine these buffers by evaluating the unique conditions of each stream.  Having predetermined buffer zones completely defeats the point of having the assessment process.
        The stream surveys in the plan do not account for recent landslides and storm damage.  The data is incomplete, outdated and often misleading.  This needs to be changed. 
        For example, Bear Creek has been heavily logged the past few years and with the massive rainfall in 1997,  a huge landslide down the creek buried almost four miles of recovering salmon habitat.  From 84 habitat reconstruction structures put in place, all but one were buried or washed away.  After this storm Bear Creek was almost a gravel flat with a small, shallow stream exposed to full sunlight.  This condition is lethal for the salmon.  However, the SYP ignores this incident and the stream survey data is several years old.  It says that the stream has lots of pools and shade, which do not exist now.  The 1997 data is curiously missing.  The restoration structures are described as =93functioning=94 when all but one are not.  This must be changed.
        The slopes in the area Pacific Lumber is logging can be very steep and unstable with shallow soil.  These slopes errode easily and can lead to massive landslides as logging increases and more roads are built.  On extremely steep slopes (greater than 45%) logging and roadbuilding should be prohibited.  Sediment from erosion and landslides will also destroy living conditions in the streams, further leading to the destruction of critical salmon habitat.
        The =93disturbance index=94 provided in the plan, assumes that the affects of heavy logging will be gone in ten years when this is not the case.  The U.S. Forest Service analyzes erosion from logging related roads over a thirty year period.  Pacific Lumber should at least follow this example. 
        The plan allows for Pacific Lumber to log at a rate 32% higher than growth the first four year =93decade=94 and then continue logging at a rate 5% higher than growth during the second =93decade=94.  Pacific lumber should not be allowed to cut at a rate higher then the trees can grow back ever.  This logging would call for 150 miles of new road during the first decade alone.  This would again increase erosion, slides and sediment flows. 
        Intensive logging in the first =93decade=94 could lead to lay offs at the start of the next =93decade.=94  Not as many people are needed to log less land and also there would be no need for skilled wood jobs in young forests.  This plan does not lead to =93sustained production of high quality timber products. . .while giving consideration to the environmental and economic values=94 as called for under 14CCR 1091.1(b) and should, therefore, be denied.
        Pacific Lumber is planning on replacing the redwood forests with Douglas fir on 40-60 year rotations.  However, due to the resilience of the redwoods, Pacific Lumber will need to use intensive herbicide treatments.  This will contaminate groundwater, run off into streams and otherwise threaten and destroy the natural environment.  And when these chemicals are mixed with gasoline, as Pacific Lumber has been doing and spraying, the effects are even more harmful.  Even now, residents in the area can smell the gasoline in nearby streams.  This practice must be stopped immediately.
        Replacing forests with monocultures of Douglas fir would kill off all the species that inhabit the forest.  Biodiversity is essential for the continuation of forest species, and ourselves.
        Finally, the =93no surprises=94 guarantee needs to be deleted.  Pacific Lumber needs to be able to take measures to improve the HCP over time.  Especially for, say, unlisted species protection.  If new data becomes available, improvements need to able to be made.

        All of this should make it clear that the HCP and SYP are not adequate as they now stand and need serious revision.

Thank you,
Carolyn