Posted 3/5/98


March 4, 1998

Joint Legislative Committee on Headwaters Forest and Ecosystem Management
State Capitol
Sacramento, CA


Dear Senator Sher and Assemblywoman Migden,

We are calling on you to convene a review committee to evaluate the aquatic strategy of the draft Habitat Conservation Plan (HCP) of Pacific Lumber/MAXXAM. The proposed aquatic strategy outlined in the pre-permit application "agreement in principle" falls far short of the standards considered essential by the Forest Ecosystem Management Assessment Team to provide an 80% likelihood of survival over a 100-year period for Coho salmon. Similar federal standards have since been proposed outside the Pacific Northwest by another team for federally managed lands in the Sierra Nevada.

The disparity between what is considered necessary to protect salmon on Pacific Lumber's lands and on public lands in California's watersheds is astounding: the best available science indicates that salmon on public lands require a two-tree-height no-cut buffer, while salmon on Pacific Lumber/MAXXAM lands are apparently expected to be sustained with only a 30-foot restricted harvest zone. It appears that this disparity results from the narrow focus of the team that designed the proposed HCP. None of the agency personnel responsible appear to have expertise in fields concerned with stream channel morphology, channel processes, physical and riparian processes, geological hillslope processes, or cumulative watershed effects. Unfortunately, the ultimate survival of the Coho depends most heavily on these dynamic aspects of habitat. We therefore believe it is essential to convene an independent review committee comprised of knowledgeable experts in these fields.

This review must be accomplished as soon as possible, before the state commits to the plan. The review team must be comprised of recognized scientific authorities– experts from the disciplines of stream channel morphology, hillslope geological processes, cumulative effects and ecosystem function. People with the necessary expertise should include those who participated in the Forest Ecosystem Management Assessment Team.

We appreciate your concerns for the natural heritage of California and the future of our commercial and sport fisheries. We also believe that an informed legislative process is a product of expert advice. Before requiring California taxpayers to invest $130 million in this plan, which could set a questionable precedent throughout the range of salmon in California, we ask the Joint Legislative Headwaters oversight committee to convene a qualified team of scientists to formally examine the aquatic strategy component of the Pacific Lumber/MAXXAM HCP and provide their opinion regarding the adequacy of the aquatic strategy. Prior to any hearing to fund the Pacific Lumber/MAXXAM HCP, the review teams comments should be heard in open committee hearings and made part of the official record so that decision makers can make an informed decision.

Sincerely,

Jesse Noell, President, SALMON FOREVER

Paul Hughes, Executive Director, FORESTS FOREVER

Zeke Grader, Executive Director, PACIFIC COAST FEDERATION of FISHERMEN'S ASSOCIATION

Jud Ellinwood, Executive Director, SALMONID RESTORATION FEDERATION