Comment from CAMPBELL, BRUCE

Please reject this insufficient Draft HCP & ITP application since the planned management will worsen rather than improve murrelet habitat during its proposed term. Nest fidelity – yet sounds like even trees with murrelet nests can be logged as long as it is not during breeding season. “Passive Take Avoidance” is considered impractical to assure enough profit to keep the timber operation going, yet the USFWS must act not only to protect some critical habitat for the murrelet but also to help guarantee that the “fog lark” will recover viable population numbers. Under 2.4.3 Control of Competing Vegetation, the final sentence of the first paragraph reads: “Green Diamond is not seeking coverage of herbicide use for control of competing vegetation as a part of the Take Permit.” Does this rather sly and vague wording indicate that Green Diamond plans to use herbicides on various parts of their holdings in Humboldt and Del Norte Counties, but do not want to bother to analyze impacts of herbicides not only on some murrelet individuals but also impact of such use on habitat characteristics considered essential for the marbled murrelet life cycle? What herbicides have you used in the 2020s, and what kind of herbicides are likely to be used in the vicinity of some noted marbled murrelet critical habitat or areas with essential primary habitat characteristics? The definition of “take” is pretty weak under CESA. There can be widespread destruction of marginal murrelet habitat and even some crucial critical habitat. One part of the draft HCP glows about increased employment prospects if the supposed “certainty” involved with blanket permits for logging across vast acreage. Yet in a paragraph discussing precommercial thinning, it reads: “Although chainsaws are used to cut the noncrop trees, progress in the development of feller-bunchers may eventually lead to machines capable of executing this operation more efficiently”. This reminds one of the common “blame the enviros” for job loss as the timber industry has been automating and concentrating in fewer hands for several decades – including under the proposed plan for marbled murrelet habitat. It sort of sounds – under D.2.1.3 Forest Regeneration – that essentially conifer plantations will be allowed in areas buffering murrelet critical habitat (is what is sounds like from mention of various “regen” activities which can sound friendlier than it works out in the watersheds. I only read one of the linked documents, but you should have had more specific maps on murrelet habitat areas. I’ve done lots of studying historically in regards to the best habitat sites for the murrelet in California. It used to be that the greater Prairie Creek Redwoods State Park / lower Redwood Creek of Redwood Nat’l Park area has the most. It used to be a tie for 2nd between the greater Headwaters Forest area and in MM Conservation Zone 6 in the greater Big Basin Redwoods State Park area of the Santa Cruz Mtns. But the Cruz Mtns. fire sadly seriously impacted murrelet populations. Also I will note that all 3 of the main forest area habitat for murrelets in CA have intensive GD practice occuring next to them. Now tied for 3rd for best murrelet habitat is Jedediah Smith RSP and the greater Headwaters area -- neighbors to GD! Please do a full EIS on this serious matter for carbon storage and species survival.