MRC — Same Old Same Old

The Fisher family of San Francisco owns the Mendocino Redwood Company and the Humboldt Redwood Company. They've made pots of dough in the garment industry and, it almost goes without saying, are politically well-connected to the Feinstein-Pelosi-Willie Brown Axis that dominates Northern California. The Fishers own Old Navy and The Gap, among other interests, retail super stores made wildly profitable by sweat shop labor.

The Fisher's takeover of L-P, much of G-P, and almost all of Charles Hurwitz's Pacific Lumber in Humboldt County in 1998, made them the largest private landholders in Northern California, maybe in the state.

They got off to a pretty good public relations start here in Mendocino County with promises to log sustainably and responsibly. Unlike L-P and G-P, Mendocino Redwoods managers were and are accessible, although the new guy in charge for this area of MRC is already quite unpopular.

MRC'S charm offensive continues with television ads (played often during Giants baseball games) about how Home Depot and other giant lumber outlets only buy MRC lumber because MRC takes good care of the wild places where the lumber comes from.

There were, however, immediate grumbles from local gyppo loggers that MRC wasn't walking any more lightly on the land than the cash-in logging  by L-P and G-P that ignited the protests of the 1990s had been. "They're worse," a Boonville logger said of MRC, "worse than L-P ever was."

And there were scattered complaints when MRC sprayed the garlon-like herbicide, imazapr, on junk trees, a hard-labor practice carried out, predictably, by immigrant Mexican crews not resident in Mendocino County. Of course poisoning unwanted swathes of forest is faster and cheaper than having crews cut the unmarketable trees down and remove them. But the chemical practice imperils water supplies, nearby streams, the workers applying it, and creates a fire hazard with acres of poisoned, dead trees waiting to fall in already drought-dry forests.

MRC now has unprecedentedly large timber harvest plans ready for what's left of the healthy forest lying between Albion and Comptche, areas L-P somehow didn't get to. We're all accustomed to cuts of 50 to 150 acres, but  758 acres (Railroad Gulch), 838 acres (Comptche) with 50 to 76 percent cuts?

"You know why these THP's are so big?" a logger asks. "They've got to be big because there aren't enough trees left out there for a regular-size timber harvest plan."

Log prices are up, the Mendocino Redwood Company is a business. The Fisher family isn't running a charity up here, but you'd have to go back to the 19th century for logging on the scale about to commence in the area of the "wild and scenic" Albion River.

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MRC FACT SHEET

-Herbicide Use-

MRC hack-and-squirts imazapyr into the trunks of hardwood trees, and foliar (leaf) sprays triclopyr and glyphosate on brush. Previous to 2008, their herbicide use was predominately imazapyr, but because lots of brush sprouted back after the 2008 lightning fires, they’ve been doing a lot more of the foliar sprays the past few years. Here’s the percentages used for 2011:

imazapyr 57%
triclopyr 37%
glyphosate 6%

-Amounts of Poison Used-

MRC reports on their website pounds of “active ingredient” used each year, which is approximately half the total weight of poison product used (50% active, 50% inert). One gallon weighs about 8.34 pounds. Over the past 15 years of MRC ownership, the following averages of self-reported poison use are:

5,689 forested acres poisoned per year
4,202 pounds (active ingredient) used per year
8,405 pounds total poison (including inerts) used per year
1,008 gallons total poison used per year

This stuff is highly toxic, it only takes a few milliliters to kill a big tree. MRC’s standard prescription is one milliliter imazapyr per three inches diameter. To approximate how many trees would be in each poisoned acre, MRC foresters guessed 227 (9″ diameter trees). If you take the yearly average of acres poisoned (5,689) and multiply that by 227 (trees per acre) you get well over a million trees (1,291,403) poisoned every year.

-Catastrophic Waste-

One cord of tanoak yields 27.5 million carbon-neutral BTUs, equivalent to the energy in 300 gallons of propane (madrone performs even better at 337). Those million-plus poisoned trees per year represent approximately 220,000 cords of hardwood, containing over six trillion BTU’s, or the energy produced by over 65 million gallons of propane.

-Poison Costs-

It costs MRC $180 to poison one acre, or $300 to cut it. Their toxin costs recently dropped as the patent on imazapyr ran out and cheaper generics became available. The brand of imazapyr they use now is called Polaris AC.

-How Quickly a Poisoned Tree Dies and Decomposes-

After poisoning, it takes about a month for the tree to die. Most of the leaf fall probably occurs within a year, but the limbs and trunk can remain standing for quite awhile. Depending on conditions, MRC guessed three to seven years before much of the poisoned tree hits the ground. Dead trunks have been seen standing ten years after receiving their lethal injection.

-Lack of Proper Testing-

MRC self-tests for herbicide runoff after the first big rains (what they call “first flush”). How careful and rigorous and well-placed these tests actually are, we don’t know, but MRC said they performed the run-off test at 17 different sites (downstream from poisoned areas) in the autumn of 2012 and detected no runoff. Which sounds good, until you start probing a little more…

One of the problems is they are only testing for the single active ingredient used at each site (imazapyr, triclopyr, or glyphosate) but not all their breakdown products (quinolinic acid being an example of a breakdown product of imazapyr). There is no testing for all the inert ingredients and surfactants, and all their breakdown products, that are included in these toxic applications. So this first flush testing is incomplete, as far as scope goes.

Additionally, MRC performs absolutely no testing (for all these myriad chemicals and their breakdowns) in the soil, groundwater, streams, plants, and wildlife (both aquatic and terrestrial).

Note: the European Union banned imazapyr in 2003. Their concerns seemed to be based on imazapyr’s persistence and mobility, its ability to get into the groundwater, and its extreme toxicity to aquatic plants and life. For this reason, extensive groundwater testing should be done wherever imazapyr is being used to such an extent.

No research has been found on air-contaminants when these poisoned trees burn.

-Poisoned Trees Burning-

The Mendocino Lightning Complex Fires of 2008 burned a total of 54,817 acres. MRC owns 10% of Mendocino County, so one would expect that approximately 10% of that total, or 5,482 MRC acres would have burned. However, MRC hosted an astounding 23,196 of those burned acres (42% of the total, or more than four times what the odds would expect). 26% of that MRC burned acreage was in deadzone areas, which works out to 6,031 poisoned acres burned during that summer of 2008.

Incidentally, the total cost of fighting that fire was upwards of 53 million dollars, whereas MRC’s CA Fire Prevention Fee for 2012 was a whopping $115 (for one habitable structure).

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MRC has filed unprecedentedly large-acreage timber harvest plans for their forests lying between Albion and Comptche. Sue Miller, as below, has objected to one of the most destructive plans…

To: Leslie A. Markham, Deputy Chief, Forest Practice, Cal Fire, 135 Ridgeway Avenue, Santa Rosa, CA

santarosapubliccomment@fire.ca.gov

From: Susan Miller, September 10, 2014

Dear Ms. Markham,

The following are my comments regarding the Railroad Gulch THP No. 1-14-080 MEN submitted by MRC.

The 758 acres of this plan with 76% tree removal is way too large and steep for governmental agencies to be able to monitor, oversee, or evaluate, and will result in deforesting the forest, will displace, damage and kill wildlife, cause soil loss which will end up in the creeks and streams, destabilize the existing slide areas, and effectively destroy the productivity and diversity of the forest land. It will result in the irreversible damage to and removal of resources from the public commons and create undesirable cumulative adverse environmental impacts.

The Albion River. the major water system in the THP area is a State of California Wild and Scenic River, designated in 2003. The adverse cumulative environmental impacts which will result from proceeding with this plan will degrade the anadromous fishery values, wildlife and their habitat. It will impair scenic and recreational qualities, degrade soil, water, and the natural character and free-flowing condition of the river. The plan makes a mistake on Page 41 where it states the Albion River and Railroad Gulch “are not ‘ “wild and scenic” ‘ rivers under state or federal law.”

In addition, MRC is self monitoring their own activities. The California Public Resources Code states that the free-flowing condition and natural values of the river are not to be adversely impacted or degraded. It is simply not possible for this massive plan to be carried out without significant adverse and irreversible environmental impacts.

It is a conflict of interest to have MRC operate this massive timber operation (758 acres and 75% tree removal with winter time operations) with its potential to permanently and significantly damage the environment of the river ecosystem while also reporting on themselves if damage occurred or could have been prevented. MRC is not even marking setbacks but leaving setbacks up to the operators’ judgment and then evaluating and reporting on their own compliance. This plan cannot be carried out without permanent degradation of the ecosystem so it follows that it will be impossible for the same corporation that created this clearly destructive plan and who claim there will be no significant adverse environmental effects caused by the plan, to self monitor, self evaluate, and report on themselves.

According to MRC’s analysis, it will take about 135 years to grow back the mass of trees removed. That is beyond all of our lifetimes. MRC shouldn’t be allowed to cause such impacts so far into the future. The plan will have an adverse cumulative impact on climate change with depleted oxygen production and increased carbon dioxide concentration.

MRC should not allowed to do anything and everything they want to with “their land” whenever they want to because it will create cumulative adverse environmental impacts and adversely affect public common environmental resources inside and outside of the plan boundaries. These operations which will cause soil loss, siltation and loss of or adverse effects on endangered, rare, and special concern species including the Northern spotted owl and Coho Salmon, Steelhead Trout, rare and endangered plant species including the Bolander Pine and Pygmy Cypress (only 2000 acres are left in the entire world which contain these 2 species). Pages 36-7 state the endangered cypress and pine will be “avoided to the extent feasible”. Feasible for whom? That should not be allowed because they must be preserved and not impacted, whether MRC self reports it is feasible or not.

Wintertime timber operations only make this situation worse because on top of the adverse effects of dry weather activities, there will be further soil disturbance, soil loss, and road degradation.

MRC’s mission statement on Page 2 is in direct opposition to the activities listed in the plan. This plan fails to comply with all 4 of MRC’s stated mission objectives. The plan also fails to comply with CEQA because their mitigated negative declaration is insufficient and does not state the truth that there will be no significant adverse environmental effects. As a concerned citizen, I dispute MRC’s claim there will be no environmental impacts that they can’t mitigate and then to report on themselves whether or not they achieve mitigation. This plan requires an EIR, which would clearly outline the true effects of the planned operation.

This THP is too large in scope and too devastating to the forest ecosystem to simply state there will be no adverse impacts. For example, use of roads in unstable slide areas will result in significant adverse environmental impacts. Adverse effects increase in winter time operations. Many of the 41 reported shallow slide areas are just below existing roads. This problem will be exacerbated with reconstruction, new construction and use of roads, especially in the winter operations. I don’t believe MRC’s operators will have enough time to be able to properly and adequately prepare all the sites and roads for rain to prevent soil loss based on weather forecasts. In no way should this corporation be able to operate during the winter season.

Thousands of cubic yards of displaced soil will be created and it will be impossible to control. Mendocino County’s grading ordinance forbids allowance of any soil loss. On page 43 it states disturbed soil in areas of 100 square ft. or less will not be treated at all, leaving areas the size of bedrooms to lose soil which will end up in the waterways. What are the on the ground conditions and cumulative environmental impacts resulting from the conduct of and self monitoring of MRC’s previous THP’s in the coastal watersheds?

Anadromous fish bearing streams are within the borders and just outside the borders of the proposed operations and they will surely be impacted from this excessive “harvest”. These fish, including the Coho Salmon and Steelhead Trout, both listed as Federal National Marine Fisheries Service threatened species inhabiting Federally recognized Critical Habitat areas within and just outside of the plan boundaries. The impacts will include dewatering of anadromous fish bearing streams, higher stream temperatures due to dewatering and removal of at least 50% of shade canopy, stream bed disturbance from construction and use of stream crossings, and soil entering the streams which will silt over important fishery rearing areas.

What will be the total number of gallons of water drafted from the streams? On page 87 it states there are 15 stream drafting sites. On page 42 it states 15,000 gallons will be drafted per day from just one site. From the map of the water drafting sites, it appears much water will be taken and the watercourses could be and will be dewatered. This huge amount of water drafting using 15 separate water drafting sites all along the Wild and Scenic River system will not protect the fishery and wildlife values. MRC is supposed to self monitor to prevent excessive take of water from watercourses. This is a conflict of interest.

The biological diversity in the plan area is rich. There are many endangered and rare species and species of special concern. Neither Cal Fire nor MRC can deny that the planned operations will have an irreversible adverse impact on these species. MRC states there will be no impacts on the endangered species living near the waterways. This can’t be true because of the plans for water drafting and reduction of free-flowing water and dewatering of the streams, operations very near and in streams, construction and use of stream crossings, cutting and removal of trees, large machinery use in and near streams, removal of much of the canopy, and increasing the water temperatures. This plan will take 758 acres of forest away with the 76% tree removal and 50% removal in unmarked stream protection zones and deep slide areas. The plan will remove the forest and animals and leave a dead area baking in the sun with ¾ of the trees gone.

Page 134 states MRC is leaving sufficient vegetation intact to minimize soil loss. How can this be true when only 1 in 4 trees is left? The 3 identified deep slide areas were last mapped in 1999. This needs to be updated to actual conditions in 2014. In this unstable area with steep slopes up to and over 70%, and 3 deep slides and 41 shallow slides, what is today’s ground truth? If the slopes are over 65% the hazards are extreme. This is not acknowledged.

This plan is grossly inadequate. There will be excessive water drafting and dewatering of streams, creation of thousands yards of sediment which can land in the waterways, 76% tree removal, disturbance, elimination and displacement of wildlife, sedimentation of watercourses on and off the plan area, and winter operations on these steep slopes subject the area to increasing the existing and creating new landslides. This plan will be devastating to the entire Railroad Gulch and Albion River area and it adversely affects the public good, public commons, and the diversity of natural resources. And, the plan does not protect the natural character of the wild and scenic river. The cumulative environmental impacts will be irreversible and devastating.

Please deny approval of this plan on the basis of irreversible adverse environmental impacts, reduction of natural diversity, cumulative impacts on the environment and misuse of resources contributing to the public commons and public good.

Here is a list of 5 THP’s from MRC that I know of for 2014 near Albion and Comptche and their acreage. As I mentioned, these plans are 3 or 4 times the size of average of plans for other areas:

1. 1-14-023 MEN 1417 acres !!! 10 miles W of Ukiah includes Daugherty, Johnson, Horsethief, Gates, Snuffins, and Bottom Creeks, and Little N Fork Navarro River. T15N R14W sec 3,4,5,9, T16N R14W Sec 29-35
2. 1-14-077 MEN 979 acres 2 miles E of Navarro includes S Branch N Fork Navarro River. T15N R14W 18,19, T15N R15W 13-16, 22-24
3. 1-14-089 MEN 835 acres called Big Gulp. 4.3 miles E of Navarro N. Fork Navarro River. T16N R15W sec 25,26,34,35,36
4. 1-14-080 MEN 758 acres called Railroad Gulch 3 miles E of Albion. Lower Albion Watershed, T16N R17W sec 23-26, T16N R14W sec 19, 30
5. 1-14-??? MEN 700++ acres will be submitted in 30 days. 2 miles W of Comptche. Middle Albion and South Fork Albion River Watersheds, Tom Bell Creek, N and S forks Albion River. T15N R17W sec 4, 8-11, 14-17, 23,26