California Board of Forestry
Policy and Management Committee
P.O. Box 944246
Sacramento, CA 94244 -2460
April 9, 2003

Committee Members:

The Gualala River and its tributaries have suffered for years from excessive and extreme logging. "The damage done [to the Wheatfield fork of the Gualala] by logging was huge and it will take decades more to approach the pre-harvest conditions we would like to see. The stream canopy on the Wheatfield is generally poor... " -- from a CDF Pre-harvest Inspection, 1999. How will the Gualala, the Buckeye and the Wheatfield ever be restored?

Salmonids were once abundant in the Gualala basins. But California chinook salmon, coho salmon, steelhead trout and coastal cutthroat trout are all Pacific salmon species which require cold water -- "The National Marine Fisheries Service (1996) characterized salmonid habitat as 'at risk' when spawning temperatures exceeded 15.5^o C and rearing temperatures exceed 17.8^o." (Source: KRIS Gualala). And water temperatures in the Gualala today are commonly hovering at or over these 'at risk' values at critical times during the life cycles of salmonids (ibid -- Stream Temperature). As a result, for example, CDFG (2002) noted that coho salmon, were "extirpated or nearly extirpated" in the Gualala (ibid).

It is also the case that the most important factor affecting water temperature is ambient air temperature. "Bartholow (1989) describes the physical factors affecting stream temperatures as used in the Instream Water Temperature Model (SNTEMP) (Theurer and others 1984), and reports the results of a sensitivity analysis of the SNTEMP. When predicting mean daily water temperature, air temperature is the most sensitive input variable." -- from Essig (1998): The Dilemma of Applying Uniform Temperature Criteria in a Diverse Environment: An Issue Analysis.

Consider, then, the effect on ambient temperature of extensive surrounding vegetation loss (see photograph below).We believe this picture and the others you have seen today vividly illustrate the necessity for the Board to consider imposing watershed wide planning limits on logging.The report of Scientific Review Panel (June, 1999) stated that: "... the FPRs, including their implementation ('the THP process ' do not ensure protection of anadromous salmonid populations. The primary deficiency is the lack of a watershed analysis capable of assessing cumulative effects attributable to timber harvesting and other non-forestry activities on a watershed scale."

Sincerely,

Jay Halcomb

RRRAUL