JIB THP Comments
November 17, 2025
Forest Practice Program Manager
CAL FIRE
1234 East Shaw Avenue
Fresno, California 93710
The following comment concern Sustainable Harvests, THP 4-25-00159-TUO, JIB Timber Harvest Plan (THP)
To whom it may concern:
JIB THP consists of 747 harvest of which 476 acres are alternative prescription (the closest to a clearcut0, 66 acres of selection harvest and 172 acres of Fuel Breaks. This harvest is located on Beaver Creek, Little Beaver Creek, and Crane Creek just southeast of Dorrington and Calaveras Big Trees State Park. The post-harvest stocking for alternative prescription lands consist of even-aged management with a 125-point count within 5-year post-harvest.
Sustainable Harvests.
On page 149, it is stated that Sierra Pacific Industries (SPI) operates under third party certification as sustainable under the Sustainable Forestry Initiative. This sustainability certification is allowed because of SPI large scale ownership of forest lands. Thus, their annual acreage of proposed harvests is a small fraction of SPI’s lands.
Furthermore. on page 156 states, “Generally, SPI’s annual even-aged harvest rotation ages range from 60 to 80 years which equates to an annual harvest of 1.25% (80-year rotations) to 1.67% (60-year rotations) of the even-aged portion of the land base.”
Below (Figure 1) is the Google Earth map as prepared by Brian Baker, Director of Conservation and Research, Las Padres Forest Watch. This Google Earth view shows all the clearcut/commercial harvesting areas in the vicinity of Dorrington and Calaveras Big Trees State Park. The boundaries of Calaveras Big Trees State Park are outlined in green. Here, Brian has overlayed each logging and harvests that have happened in this area starting in 1985 and ending in 2020. Again, these are the same lands and areas proposed for harvest in the JIB THP.
Brian has completed similar clearcut/commercial harvesting Google Earth overlays of other SPI properties in El Dorado, Amador, Butte and Tehama Counties. These Google Earth maps in these other counties show almost identical levels of harvesting as has been done in Calaveras and Tuolumne Counties.
We understand that SPI does not need to prove to CAL FIRE the long-term sustainability of a harvest within a single or series of connecting watersheds. This determination was based upon an agreement the California Division of Forestry made as part of the approval of THP 2-97-00359-SHA on September 16, 2002 (over 20 years ago). Here, landowners that own more than 50,000 acres such as SPI can avoid showing sustainability within an individual watershed if the aggregate of their timber harvest lands in California show sustainability at the ownership level.
However, each landowner including SPI must provide CAL FIRE with a defined program of management at sufficient detail to allow for tracking of harvesting over time. CAL FIRE must be able to determine at any point in time whether actual harvesting is consistent with the demonstration of sustainability. Accordingly, SPI is required to provide annual reports to CAL FIRE and individual THP’s must also demonstrate consistency as part of their ongoing obligation to demonstrate consistency.
Based upon the above Google Earth visual harvesting impacts and similar other visuals of SPI forest properties located elsewhere in the Central Sierra, it does not appear that SPI’s harvesting practices are sustainable. In addition, we suspect their harvesting practices do not comply with their annual sustainability reporting for which has been provided CAL FIRE. As such, Ebbetts Pass Forest Watch again requests CAL FIRE provide EPFW with a copy of SPI’s most recent Annual Sustainability Report. This report is needed so we can verify as a community organization that the mountain communities that depend on recreation have a long-term future. This request is necessary to maintain transparency and long-term trust with our local forest community.
Finally, the above google Earth photo represents only that harvesting that has taken place in Calaveras and Tuolumne Counties in the last 35 years. What hasn’t been taken into consideration was the previous harvesting older than 35-years out. These lands were already degraded somewhat over logging that has taken place since late in the 19th century. Assuming a conservative 25 percent harvested area prior to 1985, imagine what these harvesting areas should really look like and would leave extraordinarily little of the harvest lands that have not been disturbed and subjected to logging.
Based solely upon the visual clearcut/harvesting impacts as shown on the Google Earth imagery, it is our strong belief that the JIB THP harvest is unsustainable and extremely likely flawed. Premised upon the unsustainability of the previously harvested SPI lands, it is our recommendation CAL FIRE deny approval of this plan pending further analysis of SPI forest sustainability harvests.
Should you have any questions regarding our concerns or comments, please feel free to either email or contact me at (916) 320-2657.
Thank you for your considerations,
Perry Metzger
President, Ebbetts Pass Forest Watch
Copy Furnished:
Central Sierra Environmental Resource Center, P.O. Box 396, Twain Harte, California 95383
Secretary Wade Crowfoot, California Natural Resources Agency
Senator Henry I. Stern, Chair, California Senate Natural Resources and Water Committee
