Letter to BOF re Clearcutting Forest Practice Rules

California Board of Forestry
P.O. Box 944246
Sacramento, CA 94244 -2460
August 6, 2003 (revision)

Dear Board Members,

We are increasingly seeing new listings (by the EPA and the Boards of Water Quality) of waters in California for TMDL pollutants -- particularly, of late, listing of temperature impaired rivers. The Gualala and several other rivers have just been added to the State and Federal 303d lists of waters impaired for temperature. Anyone who views the slides (http://www.rrraul.org/BOF_8_6_03/BOF_8_6_03/MicroclimateBOF.html) we are exhibiting today of the Gualala River can see why this is: too many trees have been and are being removed too quickly from too many hillsides -- trees which would shade and cool the air, which in turn cools the stream below.

Water temperature is a critical limiting factor in the lives of many fish and amphibians. I.e., "Aquatic habitats critical to salmonids are the product of processes acting throughout watersheds and particularly within riparian areas along streams and rivers. This document depends on the premise that salmonid conservation can be achieved only by maintaining and restoring these processes and their natural rates." (Spence et al. 1996)

Consider these remarks from a Regional Water Quality Control Board North Coast Region Second Pre-harvest Inspection Report (Hope, D. 2001):

"The Gualala River has been listed by the U.S. Environmental Protection Agency as an impaired waterbody under Section 303 (d) of the Clean Water Act. High sediment loads in the Gualala River necessitated the impairment listing [the Gualala is now also listed as temperature impaired -- Ed.]. Both coho salmon and steelhead are listed as “Threatened” under the Endangered Species Act and are present in the Gualala River and have their last refuge in the streams covered by this THP. Coho salmon in particular are sensitive to temperature increases, and require large woody debris (LWD), deep pools and abundant shade to moderate this water quality issue. Stream Maximum Weekly Average Temperatures (MWAT) listed for 8 streams in this area show most streams have water temperatures that range above the preferred range for coho salmon. Given this data the NCRWQCB must consider temperatures as a limiting factor for salmonid survival and other beneficial uses in the Gualala River watershed. These documented elevated temperatures are due to removal of tree canopy that in turn increases solar exposure, increases air mixing and lowers humidity by reducing evapotransporation. Increased overall basin canopy has been shown to moderate local ambient air temperatures, which directly effects stream temperatures. " (Source: http://www.krisweb.com/krisgualala/krisdb/html/krisweb/biblio/gualala/swrcb/hopethprpt.pdf)

Although uncertainties remain in specialized areas, the science (see the Attachments and the Bibliography below) underlying these problems is generally well-known and well-established, Specifically, with respect to clearcutting (and other forms of even-aged management), it is clear to both science and common sense that air temperature is the most important factor in stream temperature.

The following is an excerpt from the introduction to Essig (1998): The Dilemma of Applying Uniform Temperature Criteria in a Diverse Environment: An Issue Analysis

"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. Relative humidity is the next most sensitive input variable, accounting for less than half as much change in stream temperature. Percent shade follows a close third to relative humidity. When predicting maximum daily water temperature, air temperature is just as important, but percent shade, which affects diurnal range, overtakes relative humidity as the second most sensitive variable. For both measures, stream flow is the fourth most sensitive variable and 'water temperature is very sensitive to changes in air temperature when stream flow is low'." (Source: http://www.krisweb.com/krisgualala/krisdb/html/krisweb/stream/tempkr_gualala.htm)

The following is an excerpt from Poole and Berman (1999): Pathways of Human Influence on Water Temperature Dynamics in Stream Channels.

"Stream characteristics that influence the rate of heat exchange with the atmosphere can be said to insulate the stream. These characteristics include the height, density, and proximity to the channel of riparian vegetation and the width of the stream channel. Riparian vegetation shades the stream, blocking solar radiation from reaching the channel and reducing the heat load to the stream (Hostetler 1991, Naiman and others 1992, Davies and Nelson 1994, Li and others 1994). Vegetation also reduces wind speed across the stream channel thereby trapping air against the water surface. This action reduces conductive heat exchange with the atmosphere by decreasing convection and advection of heat energy to the water surface (Naiman and others 1992). Width influences channel surface area across which heat is exchanged; a greater surface area allows for more rapid conductive heat transfer. Under the same climatic conditions, narrower, deeper channels will not exchange heat with the atmosphere as rapidly as shallow, wide channels. Similarly, riparian vegetation of a given height will shade a larger percentage of a narrow channel than a wide channel." (Source: http://www.krisweb.com/krisgualala/krisdb/html/krisweb/stream/tempkr_gualala.htm)

Consider, too, the effects that increased sedimentation (clearly visible in our slids) has had on stream temperatures in the Gualala (e.g. wider channels, increased width-to-depth ratios, simplified bed topography and the resulting reduction of hyporheic exchange, shallower pools, etc). With respect to the adequacy of the current FPRs, the State's own independent panel of scientists (Scientific Review Panel) concluded 4 years ago that:

"...the state agreed to organize an independent panel of scientists to undertake a comprehensive review of the California Forest Practice Rules (FPRs), with regard to their adequacy for the protection of salmonid species...

The SRP concluded that the FPRs, including their implementation (the “THP process”) do not ensure protection of anadromous salmonid populations. The primary deficiency of the FPRs is the lack of a watershed analysis approach capable of assessing cumulative effects attributable to timber harvesting and other non-forestry activities on a watershed scale. As currently applied, Technical Rule Addendum No. 2 does not provide the necessary cumulative effects assessment at the appropriate temporal and spatial scales." (Source: Report of the Scientific Review Panel, http://resources.ca.gov/SRP_Rept.pdf)

When, if ever, is the BOF going to acknowledge these scientific facts and do something to cure this disgraceful situation, which it has permitted for so long? In the long run, the only help will be through beneficial changes in the Forest Practice Rules, and in their enforcement.

Consider also the joint policy statement of the BOF and the California Fish and Game Commision (August, 2001), which reads in part:

"The departments shall be guided by the understanding that it is the desire of the State of California to: 1) recover Pacific salmon and anadromous trout populations to viable self-sustaining levels; 2) maintain wild populations where they exist; 3) restore populations where feasible; 4) sustain the human uses that depend on them; and 5) ultimately allow for delisting... All feasible steps shall be taken to protect habitat and facilitate habitat recovery. The Board and Commission shall oppose any project which will result in the irreplaceable loss of fish, the net loss of fish habitat and/or impede the recovery of populations and habitat."

Brave words. Helen Libeu is today proposing a microclimate alteration in the rules regarding clearcutting: a rule whose effect would be to prohibit adjacent cuts until the trees removed in a clearcut have been replaced by new growth reaching twenty-five feet. That is a entirely sensible restriction which would both permit continued logging and go a long way towards cooling off our overheated streams. We strongly urge you to adopt this rule.

Sincerely,
Jay Halcomb
Russian River Residents Against Unsafe Logging (RRRAUL)
<http://www.rrraul.org>

Attachments (excerpts):

California Regional Water Quality Control Board (CRWQCB). 2001. Assessment of aquatic conditions in the Mendocino coast hydrologic unit. North Coast Region, CRWQCB. Santa Rosa, CA. 284 pp.

Higgins, P.T. 1997. Gualala River Watershed Literature Search and Assimilation. Funded by the Coastal Conservancy under contract to Redwood Coast Land Conservancy. Gualala, CA. 59 pp

Libeu, Helen: Microclimate Rule Proposal, Presentation to the California Board of Forestry

Rynearson, Gary, Frank Ligon, Alice Rich, Dale Thornburgh, and William Trush, Report of the Scientific Review Panel on California Forest Practice Rules and Salmonid Habitat, June 1999, Prepared for The Resources Agency of California and the National Marine Fisheries Service, Sacramento, California Scientific Review Panel.

Bibliography:

Armour, C.L. 1991. Guidance for evaluating and recommending temperature regimes to protect fish. U.S. Fish and Wildlife Service. Fort Collins. Biological Report 90(22). 13 p.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/usfws/armour.pdf>

Bartholow, J.M. 1989 . Stream temperature investigations: field and analytic methods. Instream flow information paper no. 13. Biological Report 89(17). U.S. Fish and Wildlife Service, Fort Collins, Co.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/usfws/bartholo.pdf>

Bartholow, John M., U.S. Geological Survey: Estimating Cumulative Effects of Clearcutting on Stream Temperatures <http://smig.usgs.gov/SMIG/features_0902/clearcut.html>

Beschta, R.L., and R.L. Taylor. 1988. Stream temperature increases and land use in a forested Oregon watershed. Water Resources Bulletin. 24:19-25.

Bolton, Susan and Carrie Monohan: A Review of the Literature and Assessment of Research Needs in Agricultural Streams in the Pacific Northwest as it Pertains to Freshwater Habitat for Salmonids, Center for Streamside Studies University of Washington, July 21, 2001.
< http://depts.washington.edu/cssuw/Research/finalcted.pdf>

Bourque, Charles P.-A. and Joseph H. Pomeroy, 2001: Effects of forest harvesting on summer stream temperatures in New Brunswick, Canada: an inter-catchment, multiple-year comparison, Hydrology and Earth System Sciences, 5(4), 599–613.
< http://www.copernicus.org/EGS/hess/hs5/5/599.pdf>

Brett, J.R. 1952. Temperature tolerance in young Pacific salmon, genus Oncorhynchus. J. Fish. Res. Board of Canada. 9(6):265-323.
<http://www.humboldt.edu/~fsp/tim/1952article.html>

CA Department of Fish and Game. 2002. Status Review of California Coho Salmon North of San Francisco . Report to the California Fish and Game Commission. California Department of Fish and Game, Sacramento , CA. 336pp.
<http://www.dfg.ca.gov/nafwb/pubs/2002/2002_04_coho_status.pdf>.

California Regional Water Quality Control Board (CRWQCB). 2001. Assessment of aquatic conditions in the Mendocino coast hydrologic unit. North Coast Region, CRWQCB. Santa Rosa, CA. 284 pp.
<http://www.krisweb.com/krisgualala/krisdb/html/krisweb/biblio/regional/swrcb/assessmentmhu2001.pdf>

CA Resources Agency. 2002. DRAFT Gualala Watershed Synthesis Report. April 2002. Sacramento, CA. 145 pp (report body, 6.1 Mb pdf file) and 123 pp (appendices, 9.2 Mb pdf file) .
<http://www.krisweb.com/krisgualala/krisdb/html/krisweb/biblio/gualala/gualala_synthesis_draft_appendix.pdf>
<http://www.krisweb.com/krisgualala/krisdb/html/krisweb/biblio/gualala/gualala_synthesis_draft_appendix.pdf>

Chen, J., Franklin, J.F. and Spies, T.A., 1993. Contrasting microclimates among clearcut, edge, and interior old-growth Douglas-fir forest. Agriculture and Forest Meteorology, 63: 219-237.

Cooperrider, A., R.F. Noss, H.H. Welsh, Jr., C. Carroll, W. Zielinski, D. Olson, S.K. Nelson, and B.G. Marcot. 2000. Terrestrial fauna of redwood forests. (136k) Pages 119-163 in R.F. Noss, ed., The Redwood Forest: History, Ecology, and Conservation of the Coast Redwoods. Island Press, Covelo, California.
<http://www.fs.fed.us/psw/rsl/projects/wild/cooperrider1.pdf>

Dong, J., J. Chen, K. D. Brosofske and R. J. Naiman: Modelling air temperature gradients across managed small streams in western Washington
<http://research.eeescience.utoledo.edu/lees/pubs/Dongetall1998.pdf>

Essig, D. 1998. The Dilemma of Applying Uniform Temperature Criteria in a Diverse Environment: An Issue Analysis. Idaho Division of Environmental Quality Water Quality Assessment and Standards Bureau, Boise, ID. 34p.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/misc/essigidahotemp.pdf>

Hicks, M. 2000. Preliminary Review Draft Discussion Paper Evaluating Standards for Protecting Aquatic Life In Washington's Surface Water Quality Standards Temperature Criteria. Washington State Department of Ecology, Water Quality Program, Watershed Management Section. Olympia, Washington.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/misc/hicks2000.pdf>

Higgins, P.T. 1997. Gualala River Watershed Literature Search and Assimilation. Funded by the Coastal Conservancy under contract to Redwood Coast Land Conservancy. Gualala, CA. 59 pp.
<http://www.krisweb.com/krisgualala/krisdb/html/krisweb/biblio/regional/misc/higginsgual.pdf>

Hope, D. 2001. Little North Fork Gualala Pre-Harvest Inspection Report. North Coast Regional Water Quality Control Board. Santa Rosa, CA. 14 p p.
<http://www.krisweb.com/krisgualala/krisdb/html/krisweb/biblio/gualala/swrcb/hopethprpt.pdf>

Ice, George: HOW DIRECT SOLAR RADIATION AND SHADE INFLUENCES TEMPERATURE IN FOREST STREAMS AND RELAXATION OF CHANGES IN STREAM TEMPERATURE, National Council for Air and Stream Improvement.
<http://www.ncasi.org/forestry/research/watershed/radiation.pdf>

Keeton, William S., Jerry F. Franklin, and Philip W. Mote: Climate Variability, Climate Change, and Forest Ecosystems in the Pacific Northwest, in Rhythms of Change: Climate Impacts on the Pacific Northwest, by Edward L. Miles, Amy K. Snover, and the Climate Impacts Group.
<http://tao.atmos.washington.edu/PNWimpacts/585/ROC_Ch6.pdf>

Ledwith, Tyler: "The Effects of Buffer Strip Width on Air Temperature and Relative Humidity in a Stream Riparian Zone"
<http://watershed.org/news/sum_96/buffer.html>

Lewis, T., D.W. Lamphere, D.R. McCanne, A.S. Webb, J.P. Krieter and W.D. Conroy. 2000. Executive Summary: Regional Assessment of Stream Temperatures Across Northern California and Their Relationship to Various Landsa\cape-Level and Site-Specific Attributes. Forest Science Project. Humboldt State University Foundation, Arcata, CA. 14 p.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/misc/lewis2000.pdf>

Little Hoover Commission. 1994. Timber Harvest Plans: A Flawed Effort to Balance Economic & Environmental Needs. Milton Marks Commission on California State Government Organization and Economy. Sacramento, CA. 84 pp.
<http://www.lhc.ca.gov/lhcdir/126rp.html>

McCullough, D. 1999 . A Review and Synthesis of Effects of Alterations to the Water Temperature Regime on Freshwater Life Stages of Salmonids, with Special Reference to Chinook Salmon. Columbia Intertribal Fisheries Commission, Portland, OR. Prepared for the U.S. Environmental ProtectionAgency Region 10. Published as EPA 910-R-99-010.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/misc/mccullough99.pdf>

National Marine Fisheries Service. 1996. Coastal Salmon Conservation: Working Guidance for Comprehensive Salmon Restoration Initiatives on the Pacific Coast. NMFS, Northwest Region, Seattle, WA. 6 p.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/nmfs/salmon.pdf>

Noss, Reed F. (2001) Beyond Kyoto: Forest Management in a Time of Rapid Climate Change. Conservation Biology 15 (3), 578-590.
< http://mailer.fsu.edu/~jstallin/dir/course/home/Geo5934/Noss.pdf>

Poole, G.C., and C.H. Berman. 2000. Pathways of Human Influence on Water Temperature Dynamics in Stream Channels. U.S. Environmental Protection Agency, Region 10. Seattle, WA. 20 p.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/usepa/pathways.pdf>

Poole, Geoffrey, John Risley, and Mark Hicks: Issue Paper 3: Spatial and Temporal Patterns of Stream Temperature, U.S. EPA, Oct. 2001.
<http://yosemite.epa.gov/R10/WATER.NSF/6cb1a1df2c49e4968825688200712cb7/5eb9e547ee9e111f88256a03005bd665/$FILE/Paper%203-Spatial-temporal-10-29.PDF>

Spence, B.C, G.A. Lomnicky, R.M. Hughes and R.P. Novitski. 1996. An ecosystem approach to salmonid conservation. TR-4501-96-6057. ManTech Corp, Corvalis, OR. Funded by National Marine Fisheries Service, U.S. Fish and Wildlife Service and the U.S. Environmental Protection Agency. Available from NMFS, Portland, OR.
<http://www.nwr.noaa.gov/1habcon/habweb/ManTech/front.htm>

Standiford, R.B. and R. Arcill. 2001. A Scientific Basis for the Prediction of Cumulative Watershed Effects. The University of California Committee on Cumulative Watershed Effects. University of California. Berkeley, CA. 103 pp.
<http://www.cnr.berkeley.edu/forestry/curr_proj/cwe/cwe_i.html>

Sullivan, K., D.J. Martin, R.D. Cardwell, J.E. Toll, and S. Duke. 2000. An analysis of the effects of temperature on salmonids of the Pacific Northwest with implications for selecting temperature criteria. Sustainable Ecosystems Institute. Portland, OR. 192 pp. [1.5Mb]
<http://www.sei.org/downloads/reports/salmon2000.pdf>

Thornburgh, D.A., R.F. Noss, D.P. Angelides, C.M. Olson, F. Euphrat, andH.H. Welsh, Jr. 2000. Managing redwoods. (216k) Pages 229-261 in R.F. Noss, ed., The Redwood Forest: History, Ecology, and Conservation of the Coast Redwoods. Island Press, Covelo, California.
<http://www.fs.fed.us/psw/rsl/projects/wild/thornburgh1.pdf>

See especially the section: Appendix 8.I. California Forest Management and Aquatic/Riparian Ecosystems in the Redwoods, which discusses CDF and the FPRs.

Teti, Patrick A. 1998. The Effects of Forest Practices on Stream Temperature, A Review of the Literature. Unpub. Rpt. For the Ministry of Forests.
< http://www.for.gov.bc.ca/kamloops/district/merritt/tss/temp_review.pdf>

Torgersen, Christian E., Nathan J. Poage, Oregon State University/USDA Forest Service, Dept. of Fisheries and Wildlife, Forestry Sciences Lab, Corvallis, OR: Airborne Thermal Remote Sensing Of Salmonid Habitat For Restoration Planning In Pacific Northwestern Watersheds,
<http://www.for.gov.bc.ca/kamloops/district/merritt/tss/temp_review.pdf>

Washington State Department of Ecology. 1996 . Water Quality Standards for Aquatic Life. Wash. Dept. of Ecology, Olympia, WA.
<http://www.krisweb.com/kristenmile/krisdb/html/krisweb/biblio/general/misc/watribal.pdf>

Watson, Robert T. Ian R. Noble, Bert Bolin, N. H. Ravindranath, David J. Verardo and David J. Dokken (Eds.):Land Use, Land-Use Change, and Forestry (Summary for Policy Makers). 2000 Special Report of the Intergovernmental Panel on Climate Change, Cambridge University Press, UK. pp 375
<http://www.ipcc.ch/pub/reports.htm>

Welsh, Jr., Hartwell H., Garth R. Hodgson, and Bret C. Harvey: Distribution of Juvenile Coho Salmon in Relation to Water Temperatures in Tributaries of the Mattole River, California, U.S. Forest Service, Pacific Southwest Research Station, Redwood Sciences Laboratory, 1700 Bayview Drive, Arcata, California 95521.
<http://www.fs.fed.us/psw/rsl/projects/wild/welsh/welsh5.pdf>

Welsh, H.H., Jr., T.D. Roelofs, and C.A. Frissell. 2000. Aquatic ecosystems of the redwood region. (316k) Pages 165-199 in R.F. Noss, ed., The Redwood Forest: History, Ecology, and Conservation of the Coast Redwoods. Island Press, Covelo, California.
<http://www.fs.fed.us/psw/rsl/projects/wild/welsh/welsh12.pdf>

See especially the sections: Changes in Stream Ecosystem Processes Resulting from Timber Harvesting and Related Activities, and Stream Classification and Its Problems, which discusses CDF and the FPRs.

For more information on air and stream temperature, see also:

The Klamath Resource Information System (KRIS)
<http:www.krisweb.com>