Hello everyone,
THANK YOU for such a strong showing at the in-person sessions to give public comment on CalFire’s draft Forest Management Plan (FMP)!
Now is the time, by December 12th, to submit robust written comments.
Even though CalFire is not following CEQA, we can point to the fact that they should fully respond and address all written comments (which would be required if they were following CEQA). The longer, more specific comments with citations/links the better, influencing this management plan will give us a better footing from which to make additional changes in JDSF. We will have a shorter letter to sign on, but ask first for your original, individual comments to be submitted. Say what you want most for the forest- some ideas are still in the Coalition’s petition, there’s the protection of human rights that comes with protecting the cultural landscape, restoring the forest to old-growth conditions by ending the logging of any large trees, land return of the historic villages to local Tribes, creation of an Elders Council to advise on traditional land stewardship, more trails for hiking, more robust campground facilities, and protecting the beautiful large trees!
The draft FMP: https://drive.google.com/file/d/1uADggtRdF7nj5S0INsKFpkzXcgGi338R/view
Please submit public comments by Dec. 12th in 3 locations.
1. At this JDSF website, submit your comment and you can also attach a document.
2. Email to: JDSF@fire.ca.gov with “FMP public comment” in the subject line.
3. CC the Coalition at savejacksonforest@gmail.com in your reply, we’d like to put them on our website like a CEQA-compliant process would include.
Talking Points and citations you can include:
- Tribal Co-Governance should have been established BEFORE drafting this FMP, so Tribes can fully co-manage the forest. Since CalFire is forging ahead without that, we demand that the language from CNRA’s brand new (still draft) Tribal Stewardship Policy be written directly word for word into the Jackson Forest FMP as they reflect the current policy directives of Cal Fire’s boss, the California Natural Resources Agency. It almost looks as if CalFire is attempting to complete their new FMP before this draft Tribal Stewardship Policy is released in it’s final form…whereas we believe it should be fully incorporated into any JDSF Management Plan. This policy is the implementation of AB 1284 which was passed and encourages all CA. Natural Resources Agency (CNRA) agencies to develop co-governance agreements with tribes and allows tribes to initiate government-to-government consultation regarding co-governance and ancestral land returns. Please include this link to the Stewardship Policy in your comments:
- The Chumash Tribe has established a co-governance model that includes, in addition to Tribal Governments, a Tribal Elders/traditional practitioners group of advisors. Please comment that JDSF do the same, as this has been called for by local Indigenous Elders and we can amplify that call. It MUST happen! And we even got the Board of Forestry to bring representatives from that Chumash agreement to one of their meetings. Chumash summaries One and Two. The Thaidene Nene reserve in Canada is another strong example where the Feds, Tribes, and Territorial (State) governments all have co-equal power in a consensus format, with each party having veto power. This is a way to make true reconciliation with local Tribes and respect their knowledge of the forest. 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!
- AB52 Amendments to CEQA should be fully written into the new FMP for JDSF, word for word, so CalFire does not continue to ignore these important rights of Tribal people. Stress that modern archaeology sees Cultural Landscapes instead of smaller “sites” and CalFire must evolve to reflect this. Dr. Victoria Patterson has explained how this applies to JDSF.
AB 52 was a significant amendment to CEQA expanding the ability of Tribes to protect “cultural landscapes” not just individual archaeological sites. iI was already in place at the last redraft of the Management Plan and was not mentioned at all, it must be this time. This amendment to CEQA enables Tribes to protect large swathes of land at JDSF, such as the village sites and ancestral Pomo and Coast Yuki trails connecting inland with the Coast. AB 52 affords tribes, as mitigation for damages to their heritage landscapes, to obtain land back and place conservation easement on such land to protect them from further damage, such as the systematic destruction of village sites and ancestral trails at JDSF by road building and skid trails which historically has been a large part of logging operations at JDSF.
- JDSF should be fully conserved under the 30×30 statewide initiative. EPIC has made the case clearly (also here) and JDSF even made the list of ideal places to conserve according to the Power in Nature Coalition. Local scientists have explained numerous times that CalFire’s actions in JDSF are counter to our state’s carbon goals.
- The Trail Stewards released this wonderful list of talking points a month ago, complete with maps you can use at this link.
- Quote Tribal Elder Priscilla Hunter’s first public statement about this campaign because it still says it all!
- The last full EIR in 2007, was cited by CalFire and used for the 2016 FMP update, which means CalFire is relying on a nearly two decades-old environmental analysis for the management plan update. The Board of Forestry (BoF) erroneously 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)). We don’t want the FMP to merely collect information; we want the agency to recognize climate considerations, tribal involvement and realities of 2025 and institute restoration forestry, which means a significant change, which means following CEQA! State Senator Mike McGuire and State Assemblymember Chris Rogers agree. See their Sept. 5, 2025 letter.
- We call on California to fund Native training programs and build institutional infrastructure in order to build tribal capacity to realize the full scope of co-management. No timber harvest plans (THP)s should be approved until the new Management Plan is in place. And then, for fire management under indigenous leadership, for forest health, but not for commercial purposes.
If you’d like more documents to cite, here are two folders of documents the Coalition has presented to the Board of Forestry over the years. The first documents how we have tried working with CalFire, and shows the massive public support this forest has: via petitions, letters of support, including that of the CA Democratic Party: https://drive.google.com/drive/folders/163qKU8jDWYm1dSG0pTCI_h7gw7Y7H01k?usp=sharing
And this second folder has more examples of how Co-Governance can look, and why JDSF should be conserved: https://drive.google.com/drive/folders/1NcCXftYy8BDLVjAVSVSNN8zEvQLyygi6?usp=sharing
Here are some additional documents that can helpful in writing your comments on the draft 2026 Forest Management Plan.
Thank you all for your continued work to protect this Gem of a Forest!!
