Lost Coast League Responds to HRC's Denial of the High Conservation Values of Rainbow Ridge in their Assessment.
July 2020
The Following are excerpts from our Comments to Humboldt Redwood Company July 31, 2020
The Assessment has failed to identify the greater Rainbow Ridge area as HCVF. The ownership on Rainbow Ridge as an entity deserves HCVF status, as we have advocated in the past and to which we supplied an abundance of peer-reviewed literature and expert opinion. Please incorporate all the expert testimony found in those documents in this Review. Limiting HCVF status to a small 200+ acre plot fails to recognize the rare and valuable biodiversity of adjacent lands.
Remote Sensing confirms Rainbow Ridge area in Mattole merits HCVF Designation
Put simply, areas where the landscape has not been industrially managed is where you find the rare and important species – the high conservation values (also known as Public Trust Values as embodied in CEQA or the “beneficial uses of water” criteria employed by the California State Water Resources Control Board). An intact High Conservation Value landscape in the Mattole is nowhere more prevalent than in the Companies’ Upper and Lower North Forks lands. This was found to be true by the Mattole Restoration Council as early as 1988. This organization completed an aerial photograph analysis of the watershed. The area escaped the post WW2 logging boom, owing to its remoteness, steepness and mix of hardwoods and conifers (thus yielding less profit to the timber companies who held it and basically let it be). The 1988 analysis has been confirmed today using the latest USGS LiDAR data.
The following discussion is based upon analysis of that data. We focus on the Lower North Fork off Rainbow Ridge.
The images below feature the Mattole and Bear River Watersheds, outlined in orange.
As you zoom into the LiDAR maps, above, you see that the dark red areas are everywhere on this section of Rainbow Ridge. These are the oldest and tallest trees as sensed from the air. These are the areas that were never logged and where the wildlife and ecological integrity of the landscape abound. This is what HRC targets to remove. In the place of this High Conservation Value Forest, HRC promises to allow trees to grow old in the stream courses (above in white).
.However, you can see that the stream courses often do not have tall old trees. Past logging has caused landslides which have eroded those areas, well below the logging area, in places HRC foresters and California State Agencies never go. The Lost Coast League has requested they visit the sites so they can learn how logging has de-stabilized this steep, erodible ground. Perhaps they don't want to see for themselves what a mess they've made. Their claim is that they protect the "beneficial uses of water" as per the law, but they don't have to live in these streams like the endangered salmon.
Back in 2018, the Lost Coast League, along with leading conservation organizations, and over 100 of you, filed a Formal Complaint challenging Humboldt Redwood Company’s “Certified Sustainable” status, the ultimate stamp of approvals for logging companies. The Bear River Band of Rohnerville Rancheria and the WIyot Tribe have now joined in the effort to preserve sacred sites and the High Conservation Value Forests of Rainbow Ridge. The Forest Stewardship Council (FSC) certification (doled out by inspectors whose funding now comes from Big Timber,) allows Humboldt Redwood Company to market their products as sustainable and eco- friendly. After a dense legalistic procedure, the Investigation concluded that our concerns had “merit.” They required that HRC, before logging any more, come up with (1) a plan for designating areas of High Conservation Value Forest (parts of the forest with greater environmental importance that would be protected from the logging) and (2) a plan to phase out the use of herbicides. However, before completing any of those requirements, HRC began logging in mature forests which contained Northern spotted owls and other endangered wildlife species. The Forest Stewardship Council simply looked the other way.
The League demanded that Humboldt Redwood Company cease activity immediately until they fulfilled their obligations to FSC. Instead, HRC hired camo-clad, weapons equipped para-military personnel, veterans of the Mid-East wars, to harass and endanger forest defenders and tree sitters. The League appealed to FSC to issue an emergency halt until the dispute was adjudicated. They were deaf to those pleas. The logging went on despite violations of FSC rules and numerous injuries to forest defenders who were putting their lives on the line to protect the trees. The League lodged a Formal Complaint.
The Appeal process is yet another bureaucratic labyrinth, and it has taken FSC over a year to start looking into Humboldt Redwood Company’s violations. FSC also demanded that the League sign a confidentiality agreement with an indemnification clause. This would allow HRC to take us to court for revealing details of the Appeal, and sue for monetary damages, creating an Appeal process with no transparency and in which the complaining entity could be subject to financial ruin by the logging company as decided by FSC’s court in Germany! It would have been like putting one’s head in a noose for complaining about the brutality of the hangman.
The Appeal has dragged on with no investigation. Now, due to Covid concerns, the Appeal board cannot travel to the US to validate the facts that were already approved in our original Formal Complaint. Meanwhile HRC is logging rare, old forests.
Humboldt Redwood Company, along with companies such as the The Gap, Banana Republic, and the Oakland A’s, are owned by the Fisher Family, billionaires who, knowingly or not, have exploited the people around them, covering for the damage they cause with philanthropic ploys. Now they are acting to destroy the beautiful, irreplaceable forests of the Mattole.
At this critical juncture the forest needs your support.
Please write FSC at (d.brunelle@asi-assurance.org) and HRC (sbillig@mendoco.com) and cc to <lostcoastleague@gmail.com> Tell them to stop all logging on Rainbow Ridge until a valid, transparent Appeal from the Lost Coast League is heard. Remind them that the Indigenous Tribes of this land want those lands to remain mature forests and prairies for their critical cultural and wildlife values.
Unless FSC hears from you, they will never stand up to HRC. One of the planet’s premier carbon sequestering forests and its wildlife is at risk of being logged beyond recovery, by a company that proudly wears the badge of environmentally- friendly forestry. Petition to unmask HRC for what it really is: yet another example of a Green washing exploitation of everyone’s environment. This is not eco-friendly logging. This is not “sustainable”.
At the Madrid UN Climate Conference in 2019, a panel discussed this failure of FSC to uphold Sustainable standards on Rainbow Ridge. Watch the public presentation.
