Letter to CDF on Austin Creek THPs

Rodger Thompson
Deputy Chief of Forest Practice
Coast Cascade Region
California Department of Forestry
135 Ridgeway Ave.
Santa Rosa, CA 95402

April 25, 2000

Re: THP 1-00-101 MEN ("Cassidy THP")

Dear Mr. Thompson,

An ounce of prevention is worth a pound of cure. THP 101 proposes to log by selection 181 acres in 17 harvest units directly adjacent to tributaries of the Gualala River, including 3 planning watersheds (Little North Fork, Stewart, and Dry Creek). The Gualala is a 303d listed river.

Among other significant issues, the following points are mentioned in this THP:

1) That these 3 watersheds have already been extensively logged in the last ten years by Gualala Redwoods, Inc.: from 54% (LNF) to 64% (Stewart). They have been logged, largely, by the aggressive methods which GRI favors: clearcutting, shelterwood removal, and seedtree removal. A little while back, though, GRI was promising (THP 1-99-460 MEN) that "the Class I watercourse associated with this THP wil not have harvest activities". Or was that misleading information (and thus grounds for denial)?

2) That these rivers are presently suffering from: stream aggradation and pool filling, downcutting and mass wasting;

3) That the THP proposes in-lieu practices -- exceptions to the standard rule requiring directional tree felling away from a WLPZ. The boilerplate justification for this which the RPF gives would apply in almost any circumstance and so would obviate the rule. Will Water Quality go on the PHI and determine the necessity for this deviation?

4) That a skid trail, and a landing lie within WLPZs. That main hauling roads run through WLPZs in "numerous" places.

5) That there are continuing and significant adverse impacts from past timber harvesting in these watersheds.

6) That 60 landslides exist within the 3 watersheds, of which 21 are active.

7) That a pumping station for the North Gualala Water Company is located near by the Little North Fork.

8) That much of the logging area lies within the floodplain of the rivers.

Yet, in spite of this, this THP proclaims that there this latest logging proposal will result in "no significant impacts". How can this be possible? Is it possible?

Among the remarks and conclusions of the Scientific Review Panel of the Watershed Protection and Restoration Council were the following:

1) That the Forest Practice Rules do not ensure sufficient protection of salmonid habitat. (Exec. Summary, SRP)

2) That floodplains "provide winter refuge habitat for juvenile anadromous salmonid" and are "extremely important as habitat to other riparian-dependent species" (P. 46, SRP).

3) That the MWAT (mean weekly average temperature) methodology, cited in GRI's monitoring data, is inadequate and "needs to be replaced." (P. 15)

4) That, to maintain adequate riparian and salmonid habitat, an 85% canopy cover is recommended in the first 75 feet of a Class 1 WLPZ, and 65% for the next 75 feet. This THP proposes only 70% retention for the first 75 feet. The SRP also recommended retention, for Class Is, of the ten largest trees per 100 meters of channel, within 50 feet of the watercourse transition line, and permanent designation, prior to PHI, of Large Woody Debris recruitment trees. (P. 37) Will this standard be achieved? Who will know what level of LWD recruitment will be attained?

5) That "excessive time and money are devoted to RPFs writing and agencies reviewing long THPs that do little more than restate forest practice rules or attempt to protect the THP from procedural changes." (P. 21) This THP, which is 142 pages long, is an excellent example.

Respectfully,

Jay Halcomb
Chair, RRRAUL

Russian River Residents Against Unsafe Logging
P.O. Box 2030, Guerneville, CA 95446
Tel: 707.869.3302 Fax: 707.869.3602
E-mail: rrraul@sonic.net Http://www.rrraul.org