Public
comments needed on Headwaters Habitat Conservation Plan
Posted 10/23/98
The
Pacific Lumber Co.'s (PL's) Habitat Conservation Plan (HCP)
covering its more than 200,000 acres of holdings has been released
for public comment. As part of its agreement to sell a portion of
Headwaters Forest to the public, PL has submitted the HCP to state
and federal agencies for approval.
Approval of
the HCP would give PL an "incidental take" permit allowing it to
kill endangered species and destroy habitat critical to the survival
of these species for 50 years. These permits would be unchangeable,
regardless of new science concerning the affected species.
Take
part in the public hearings on the HCP and submit written
comments to federal wildlife officials (see "Contacts" and "Hearings"
below) who are reviewing the plan. Tell them the HCP would further
endanger the Coho salmon, that PL is a criminal corporation with
over 300 forestry violations in the last three years and that agencies
must rely on real science– not corporate "tobacco science."
The deadline for comment is Nov. 16.
Background
and Additional Items:
The groves
of Headwaters Forest not acquired under PL's "deal," the numerous
streams essential to the survival of California's coastal salmon
and the salmon themselves hang in the balance. Extensive citizen
involvement at this point may be the only way to improve or negate
the flawed HCP. Mention the following points in your comments:
-
The
HCP is based on flawed analyses. The plan fails to recognize
existing science on species' conservation needs. Stream surveys
fail to account for recent storm damage and landslides. The
so-called Sustained Yield Plan (SYP) assumes that logging impacts
disappear after ten years. Surveys of Marbled murrelets–
federally-listed seabirds dependent upon old-growth habitat
for nesting– have not been conducted on much of the property.
Baseline habitat levels for Northern spotted owl would be identified
after nesting areas have been logged. Further, 36 other sensitive
species can also be killed without detailed analyses and species-specific
mitigation measures.
- The
plan fails to provide any mitigation for: clearcutting up
to 935 acres of old-growth redwood, 9,385 acres of residual old-growth
redwood, 8,323 acres of old-growth Douglas fir, and associated
habitats for Marbled murrelets and other old-growth species; killing
or harming 241 to 340 Marbled murrelets; logging 16 Northern spotted
owl nest sites while they are temporarily unused; killing or harming
33 percent of the local Northern spotted owl population; logging
along perennial and intermittent streams (while the plan's stream
buffers are better than current requirements, they fall far short
of those needed for the protection and recovery of salmon, amphibians,
and other species); clearcutting across the remainder of the over
200,000-acre area; converting redwood forest stands and habitats
to Douglas fir; impacting the 36 unlisted-yet-sensitive species
covered by the permit, as well as other species that rely on older
forests, riparian areas, or well-developed second growth, or species
which are highly sensitive to logging and other disturbances.
The plan also fails to provide permanent protection for "set aside"
areas not included in the acquisition package.
- The
plan allows destruction of coastal salmon habitat and "take"
of gravely imperiled Coho salmon prior to any federal recovery
planning process for the species. A federal recovery team has
yet to be established for coho, so there is no independent panel
of experts in place to review the plan.
- The
plan allows PL to log most of its forest within the first
few years, with the promise that second-growth forests will be
grown back later. Once the high value old-growth is logged, however,
PL will have little incentive to continue implementing the plan
and its mitigation measures. Mitigation should be provided and
demonstrated to work prior to logging.
- The
plan fails to provide a long-term supply of high-quality timber
and other opportunities for local jobs.
- PL
should not be given a permit to operate in threatened and endangered
species habitat. The company has repeatedly violated California
Forest Practice Rules and the federal Endangered Species Act and
cannot be expected to behave responsibly.
- PL
should not be given "No Surprises"-type guarantees that absolve
the company from making meaningful improvements to the HCP over
time. The plan's conservation measures for unlisted species, for
example, are woefully inadequate.
- The
proposed public acquisition of parts of Headwaters is significant,
but will be coming at too high a cost if the proposed HCP
is approved. The price of protecting parts of Headwaters should
not include the extinction of coastal salmon. We may also be paying
above-market prices for the land, thereby setting a poor precedent
and suggesting the public, not landowners, is responsible for
providing basic protections for endangered species on private
lands.
Contacts:
Michael
Spear
California/Nevada Operations Manager
U.S. Fish and Wildlife Service
2233 Watt Avenue, Suite 120
Sacramento, CA 95825-0509
916/979-2034 phone
916/979-2056 FAX
mike_spear@r1.fws.gov
Reference
the HCP as U.S. Fish and Wildlife Service permit request #PRT-828950.
Dr. William
Hogarth
Regional Administrator- SWR
National Marine Fisheries Service
501 West Ocean Blvd., Suite 4200
Long Beach, CA 90802
562/980-4000 phone
562/980-4018 FAX
William.Hogarth@noaa.gov
Reference
the HCP as National Marine Fisheries Service permit request
#1157.
Send a copy
of your letters to the elected official who is the Clinton Administration's
point person on the precedent-setting effect of this HCP on
Pacific Northwest salmon:
Vice President
Al Gore
c/o Council on Environmental Quality
Old Executive Office Building
Washington, DC 20501
Hearings:
- Culver
City / LA - Tue., Oct. 27 - Pacifica Ballroom, Radisson Hotel,
6161 W. Centinela
- Sacramento
- Thur., Oct. 29 - Convention Center, Rooms 307-308, 1030 15th
St.
- Oakland
- Thur., Nov. 5 - Marriott Convention Center, W. Hall, 550 10th
St.
- Eureka
- Tue., Nov. 10 - Franceshi Hall, Redwood Acres Fairground., 3750
Harris St.
Hearings
are from noon to 4 pm, and 5 pm to 9 pm each day.
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