Sierra Club

July 29, 2009

Bob Simpson (CEO)
Freshwater Tissue Company
P.O. Box 248
Samoa, CA 95564

Dear Mr. Simpson:

This letter is written on behalf of the Redwood Chapter of the Sierra Club, which has more than 10,000 members spread across northwestern California from north of San Francisco Bay to the Oregon Border. The Redwood Chapter, and the North Group of the Chapter, have been asked to comment on a pulp mill manufacturing facility proposed for Humboldt Bay. The Freshwater Tissue Company (FTC) has a plan to re‐tool a closed pulp mill in order to produce “eco‐friendly” toilet tissue. We will comment on FTC’s goals of environmental stewardship, as these are stated in the current FTC Business Plan. Specifically, we remark as follows.

Using Forest Stewardship Council (FSC)‐certified wood to manufacture the product. The Sierra Club is one of many organizations that have publicly expressed a preference for FSC‐certified wood over that of the competing industry‐run certification group, the Sustainable Forestry Initiative (SFI). Until now, local timber companies such as the former Pacific Lumber (now Humboldt Lumber Company), Green Diamond, and Sierra Pacific were certified by SFI.

On the other hand, the bankrupt Pacific Lumber has now been acquired by Mendocino Redwood Company, which is one of a handful of timber companies certified by FSC for Redwood production. The renamed Humboldt Redwood Company is well into the process of obtaining FSC certification on its lands in Humboldt County.

While SFI certification allows timber companies to continue clear‐cutting, applying herbicides, and logging old growth, the environmentally superior FSC certification assures that wood and paper products come from forests that exhibit better environmental practices. The FTC Business Plan proposes to provide financial incentives for landowners to obtain FSC certification by paying a higher price for FSC‐certified pulp chips. The toilet tissue manufacturing process, for example, would use “waste” from lumber milling operations (approximately 50% of the log volume), rather than harvest virgin trees to make the product. We support the goal of obtaining FSC, rather than SFI, certification.

Providing a market for tanoak. Suppressing growth of the hardwood “weed” tree tanoak in Redwood and Douglas‐fir forests is a major reason that timber companies use herbicides. The FTC Plan would provide a market for tanoak logs (50% of tissue recipe), turning this currently noncommercial hardwood species into a valuable commodity while reducing the need for herbicide application. This represents responsible land management practices that allow such a use of biomass, which is a stated goal of the Sierra Club’s “Clean Energy Solutions Program.”

Continuing a chlorine‐free manufacturing process. Pulp and paper manufacturing processes that involve chlorine produce dioxin. Humboldt Bay is already listed as impaired for that chemical. The former pulp mill, under Mr. Simpson’s guidance, became the only totally chlorine‐free pulp mill in the United States. We support this goal.

Reducing greenhouse gas emissions, foul odors, and water pollution. An immediate goal of the Business Plan is to comply with all state and federal waste water discharge and clean air emission requirements. The Plan expresses the long‐term goals of going beyond these to eliminate odors and greenhouse gases from its manufacturing processes and to return process water to the Pacific Ocean with no additional pollutants. The Plan also notes the potential carbon sequestration from older coastal Redwood forests that are managed for preservation. Reduction in greenhouse gas generation is a major goal of the Sierra Club’s Climate Campaign, and improving air and water quality are major goals of the Sierra Club. We support such objectives.

Introducing transparency of operations and consulting with environmental advocates. The Plan proposes to create an advisory board of environmental advocates focused on clean air and water and preserving the redwood forest. This board would review FTC monthly environmental performance reports and have access to all company environmental records. We encourage this effort.

Creating American jobs with lower environmental impact and avoiding export of polluting industry. The FTC Business Plan claims that manufacturing “eco‐friendly” toilet tissue will directly create 425 family‐wage jobs and would have a multiplier effect in the Humboldt economy. This is a different model from most American tissue producers, who have disposed of US pulp mill assets and are instead relying on pulp producers in developing countries (e.g., China), where inexpensive plantation timber is abundant, cheap labor is available, and where pollution often goes unchecked. We support such environmentally and socially responsible practices as these which FTC proposes.

Other potentially positive aspects not specifically mentioned in the FTC Business Plan are:

Increasing use of renewable energy. Pacific Gas & Electric has obtained permits to conduct wave energy power generation tests off the Humboldt Coast. FTC has spoken to PG&E about purchasing electricity resulting from these demonstration projects or future commercial‐scale operations. While North Group and Redwood Chapter have not taken a position on this specific wave energy project, the national Club does encourage development of renewable energy sources.

No reliance on railroad. The FTC Business Plan does not rely on resurrection of the railroad through the Eel River Canyon to Eureka, a project that would have hugely detrimental engineering and environmental challenges.

In our opinion, guaranteeing a sufficient supply of FSC‐certified Redwood chips is the largest hurdle to realization of the FTC Business Plan. It remains to be seen whether the financial incentives that FTC plans to offer are sufficient to move local timber companies to change their practices re: herbicides and clear‐cutting, and to obtain the more‐stringent FSC certification, but these are goals we wish to encourage. Therefore, Redwood Chapter wishes to express conditional support of the goals of the planned FTC operations, as stated in the company’s Business Plan, pending full environmental review of the proposed operations. We do this with the following caveats: that the company remains in compliance with its business plan and that it is held accountable to its vision and goals. Given those caveats, the Redwood Chapter Sierra Club commends the goals expressed in the FTC Business Plan. We strongly hope that a plant can be put in operation that proves to be model of good environmental stewardship for both the region and the industry.

Sincerely yours,

Gregg Gold, Chair, North Group
on behalf of the Redwood Chapter Sierra Club

Diane Beck, Conservation Chair of the Redwood Chapter