Jackson Demonstration State Forest Management Plan Comments
November 20, 2025
Department of Forestry and Fire Protection
Jackson Demonstration State Forest
802 North Main Street
Fort Bragg, California 95437
To whom it may concern:
Reference: Jackson Demonstration State Forest draft Management Plan
CalFire has released Jackson Demonstration State Forest (JDSF) draft management plan for public review. We understand your intention is to finalize a new Forest Management Plan (FMP) in early 2026. The following comments address a number of inadequacies in that draft plan.
Environmental Impact Report
The last full Environmental Impact Report (EIR) by CalFire was in 2007 which was used for 2016
FMP update. This means CalFire is relying on a nearly two decades-old environmental analysis
for this management plan update.
Furthermore, any new FMP will likely have significant impact on the environment. This impact
would cross the CEQA threshold that triggers the need for a new EIR. This updated EIR is
essential because it requires CalFire to respond to comments and questions, and to analyze
alternatives and mitigation options.
California Environmental Quality Act
The Board of Forestry (BoF) has attempted to exempt itself from CEQA in a 2020 rule change to Title 14 of the California Code of Regulations. This rule change wrongly categorizes Forest Management Plans (FMP) as merely “information collection.” (Cal Code Regs. Title 14 § 1153(b)). The FMP should not merely collect information. CalFire needs to recognize climate considerations, tribal involvement and realities of 2025 and institute restoration forestry, which means significant changes to the existing 2007 CEQA document.
There is also a lack of community outreach. This non-community involvement and subsequent drafting of the new Forest Management Plan is in violation of the California Environmental Quality Act (CEQA).
Tribal Governance Agreement
A new Management Plan should not move forward until a framework for tribal co-governance agreements is in place. As presented, this process as put forth by CalFire is entirely backwards.
AB 1284 encourages all Calif. Natural Resources Agency (CNRA) agencies to develop co-governance agreements with tribes and allow tribes to initiate government-to-government consultation regarding co-governance and ancestral land returns.
The CNRA Tribal Stewardship Toolkit is in the process of being finalized. This guiding document should be used for all co-governance and land returns in California.
The current Tribal Advisory Council established by CalFire is just that advisory. The Tribes should be shown the true respect they deserve as sovereign nations as equal governance partners with California on their traditional lands!
Government to Government Consultation
AB 52 government-to-government consultation and cultural landscape protections must be incorporated into the new Forest Management Plan. AB 52 was enacted in 2015 and has not been fully incorporated into the JDSF management plan.
Timber Harvest Plans
No timber harvest plans (THP) should be approved until the new Management Plan is in place. A Notice of Intent for AMEX THP has been issued. In fact, the AMEX THP was out for final public comment in which 425 acres are slated for logging. Those AMEX comments were due into CalFire by November 17, 2025. Any approval of this THP needs to be suspended until its impacts by the FMP can be fully evaluated and revisions made accordingly.
Another THP (Camp 8) is currently being prepared for release. Here, the Camp 8 THP proposes building roads in areas of JDSF that have never seen roads and would destroy one of the last second growth mixed stands of redwoods in JDSF.
Conclusion
This Forest Management Plan should not be approved until a new EIR analysis has been completed and all the above issues have been addressed and incorporated into that EIR. It also is especially important that community coordination and fire management under indigenous leadership, for forest health be included in this EIR.
Finally, any further logging in the Jackson Demonstration Forest must be stopped and/or approvals of future THP’s be suspended until a revised FMP is in place.
Thank you for your consideration,
Perry Metzger, President
Ebbetts Pass Forest Watch
Copies furnished:
Secretary Wade Crowfoot, California Natural Resources Agency
