Letter from botanist & coastal ecologist Peter Baye on the recirculated “Dogwood” logging plan in the floodplain of the Gualala River (December, 2015):
Conclusions and Recommendations
Despite recirculation and ample opportunity to correct deep flaws in the THP identified in public and expert comments, the Dogwood THP persistently retains both careless errors and apparently willful non-compliance with both the spirit and letter of Forest Practice Rules regarding alternatives, riparian/flood prone area forest protections, cumulative impacts, wetlands, special-status species, and archaeological resources. The THP with few exceptions fails to provide basic sound biological baseline survey data, and relies almost exclusively on detection of difficult-to-detect or difficult-to-identify plant and wildlife species by non-expert timber operators, or through surveys lacking any enforceable conditions for methods or expertise. In addition, the THP ignores the need to identify, map, and protect wetlands in over 400 acres of floodplain rich in wetlands. All this would be unimaginable and unacceptable in even rudimentary CEQA professional practice, and should be shocking that it is apparently routine in THP review. The THP at this stage should be either suspended and recirculated with corrections, or denied because it still contains impermissibly incomplete, incorrect, or materially misleading essential information and assessments. I recommend that CAL FIRE assist the applicant with development of an adequate alternatives analysis, without prejudice to any feasible alternative, by facilitating discussions among Sonoma County Regional Parks, Sonoma County Agricultural and Open Space District, interested non-profit forest conservation organizations, and State Sen. Mike McGuire’s office.
Read the complete Comments by Peter Baye on THP-01-15-042SON-Dogwood.