Bob MacMullin

MacMullin Forestry and Logging
944 Hidden Pond Lane
McKinleyville, CA 95519
(707) 839-4751
(707)839-4761 FAX

October 30, 2009

Robert M. Simpson

President-Freshwater Tissue Company
One TFC Drive P.O. Box 248
Samoa, CA 95564

RE: Freshwater Tissue Company Fiber Supply

Dear Robert Simpson,

As you know, I am a California licensed, Registered Professional Forester, working in Humboldt County since 1977.

Per your recent request I have analyzed your Freshwater Tissue Company Business Plan Fiber Supply Summary, Forest Economics and Pulp Chip Analysis.

After a careful review I believe these segments ofyour business plan are realistic and practical. Within the Pulp Chip Analysis it is stated, “The conservative estimate of harvestable tanoak inventory in the region is 2.6 billion board feet (1.3 million acres commercial acres x 2,000 bf)”. It is my belief the actual hardwood volume is considerably higher.

Most timber volume evaluations (cruises) do not adequately measure hardwood because the focus is on the more valuable conifer species.

Typically when hardwoods are present and/or harvested in conjunction with conifers, the landowner’s hardwood yields are greater than anticipated. Forest landowners and managers consider conifers to be assets and hardwoods are seen as obstacles.

Additionally, the plan indicated sourcing one halfofthe mill’s needed fiber, 18,350 loads annually, from tanoak trees. I agree that FTC should be able to operate at their sustained desired level of 18,350 truckloads of hardwood per year indefinitely, because of significant existing volumes of hardwoods, proven hardwood growth expectations, and the existing economic infrastructure offorest landowners in the Redwood Region.

In short, I agree with the initial volume estimates presented in the Pulp Chip Analysis and Forest Economics section ofthe Business Plan.

If the Freshwater Tissue Company pulp mill becomes operational, the increased hardwood log price will encourage landowners and managers to convert hardwood stands to conifer forests by logging, thereby utilizing the fiber rather than killing the hardwoods with herbicides. Instead of wasting the fiber and increasing fuel loading and wildfire potential, a valuable paper product can be made by harvesting and trucking it to the pulp mill. Additionally, in areas infected with sudden oak death, the disease can be effectively treated by profitably harvesting and trucking the diseased vegetation to the pulp mill.

Over the past 32 years on the north coast, as a consulting forester and timber operator, I have been actively engaged in forest management and daily forest operations ofprivate industrial and non industrial forest lands. I served as President ofthe Redwood Region Logging Conference in 1991. I have provided testimony to the House of Representatives Committee on Agriculture in Washington D.C .regarding timber legislation. I recently served for three years on the BLM Northwest California Resource Advisory Committee (RAC). I have also provided expert testimony in several local municipal and superior court hearing regarding timber harvesting violations and worker compensation issues.

I admire your efforts to bring this pulp mill back on line. As you certainly know an operating pulp mill provides timber land owners opportunity to better manage their forests by profitably harvesting low value tanoak trees and other hardwoods. These hardwoods are increasingly crowding our redwood and Douglas-fir forests ofnorthwest California, reducing future conifer growth and increasing the potential for catastrophic fire.

The economic benefit will greatly enhance employment in all of our north coast communities.

Removal ofsignificant amounts ofhardwood trees in our Redwood Region will be economical only ifthis pulp mill is operational.

Best regards,

Robert MacMullin
RPF #2072