Comments on 1-00-484 SON

Calif. Dept of Forestry and Fire Protection
Coast Cascade Region
135 Ridgeway Ave.
Santa Rosa, CA 95402

January 15, 2003

Re: COMMENTS - THP 1-00-484 SON - Haupt Creek, Wheatfield Fork, Gualala River

The waters of our north cast rivers continue to suffer under the burden of pollution in the form of excessive sediment, elevated temperatures, nutrients, and lack of dissolved oxygen as continuing effects from silvicultural activity. In part, this is because CDF is doing an inadequate job of managing pollution from silvicultural activities.

This THP proposes substantial harvesting of late seral type trees ("old-growth") which are functional habitat for listed species in very steep and unstable areas adjacent to, and within the inner gorge, of Haupt Creek - a tributary of the Wheatfield Fork of the Gualala River. The sensitivity of this THP has been noted by extensive comments of all the participating Review Team agencies (CGS, CDFG, and NCRWQCB). The slopes on this land are extreme (80%) and the soils erosive. THPs on the adjoining Olhsen properties are already sliding and adding cumulative impacts to the already impacted Haupt Creek and the Wheatfield Fork of the Gualala.

We strongly urge CDF to reject this THP. Late seral forest is rare in Sonoma County and must be protected, and adequate surveys and descriptive analysis must be accomplished. The mitigations and discussions in this THP do not adequately address these issues. In particular, Forest Practice Rule 919.16 (a), must be strictly enforced, and a thorough analysis of the stands, lacking in this THP, must be submitted for CDF and other agency review.

Why does this matter? We mention the recent Living Planet Report by the World Wildlife Federation:

"The report <http://www.panda.org/livingplanet/lpr02/> shows that humans are currently running a huge deficit with the Earth - using over 20 percent more natural resources each year than can be regenerated - and this figure is growing each year. Projections based on likely scenarios of population growth, economic development and technological change, show that by 2050, humans will consume between 180 percent and 220 percent of the Earth's biological capacity. According to the report, this means that unless governments take urgent action, by 2030, human welfare, as measured by average life expectancy, educational level, and world economic product will go into decline. "

Sincerely,

Jay Halcomb
RRRAUL

Forest Practices
California Department of Forestry
135 Ridgeway
Santa Rosa, CA 95401

My comments relate to a timber harvest plan 1-00-484 SON that proposes to cut some of the last uncut old growth redwoods and Douglas fir in the Gualala watershed. The main issue here is whether the Forest Practices Act will be upheld and the old growth portions of this plan will be taken out and protected. These stands have never been cut.

Hope for the return of listed fish hinge on maintaining habitat. It will take 500 years to even get some semblance ofthese stands back again. Uncut stands like these that create habitat for listed species such as the Marbled Murrelet are a last refuge for many species. Their loss would speak volumes as to humans having the responsibility of their stewardship.

The Section of the FPRs that must be adhered to on this plan is as follows:

Forest Practice Rule 919.16 (a)

"When late succession forest stands are proposed for harvesting and such harvest will significantly reduce the amount and distribution of late succession forest stands or their functional wildlife habitat value so that it constitutes a significant adverse impact on the environment as defined in Section 895.1, the RPF shall provide habitat structure information for such stands. A statement of objectives over time shall be included for late succession forest stands on the ownership. The THP, SYP, or NTMP shall include a discussion of how the proposed harvesting will affect the existing functional wildlife habitat for species primarily associated with late succession forest stands in the plan or the planning watershed, as appropriate, including impacts on vegetation structure, connectivity, and fragmentation.

The information needed to address this subsection shall include, but not limited to:
1. Maps showing....
2. A list of fish, wildlife and listed species known to be primarily associated with ..
3. Description of functional wildlife habitat elements...
4. A description of the structural characteristics for each late succession stand and ..
5. A description of the functional wild life habitat objectives, such as.....

Sincerely,
Chris Poehlmann

Forest Practices
California Department of Forestry
135 Ridgeway
Santa Rosa, CA 95401

COMMENTS - THP 1-00-484 SON - Haupt Creek, Wheatfield Fork, Gualala River

Overview

This proposed THP is interesting as it proposes substantial harvesting of late seral type trees noted as functional habitat in very steep and unstable areas adjacent to, and within the inner gorge, of Haupt Creek - a tributary of the Wheatfield Fork of the Gualala River. The sensitivity of this THP has been noted by extensive comment of all participating Review Team agency (CGS, CDFG, and NCRWQCB), with extensive comment and recommendations in submitted to the file.

It should be noted by CDF, and the plan preparer that: 1) the Gualala River is listed as sediment impaired on the current state's 303 (d) list, 2) that the Wheatfield fork is under tremendous sediment load, over 200% of natural background level - mostly related to historic forest practices and associated activity, 3) that Haupt Creek is sediment impacted and likely to deliver additional sediment from this proposed THP - unless mitigated to the fullest extent possible, 4) that the Gualala rive is on the proposed state 303 (d) list submission for the pollutant temperature - thus, the THP must consider temperature loading to the warm waters of the Wheatfield Fork, 5) loss of late seral functional habitat is an issue not yet addressed by the THP, 6) added to the above list of considerations the THP (file and agency comment) notes the sensitivity, areas of very steep and unstable ground with very high propensity for erosion, of the unique area proposed for harvest.

Information in the File

CDF letter to RPF, 10/29/02 - CDF asks for explanation regarding "significant adverse impact as defined in 14 CCR 895.1, nor does it significantly reduce the amount of Late Successional Forest". At question, raised by CDF, is what is "significant" or where is the threshold of impact? The RPF answers, in the file, that impacts are not significant with the argument that the LSF to be harvested is 1% of the total protected LSF and 8% of the ownership LSF. If the owners 8% is 1% of the protected LSF, then one can surmise that there is not all that much LSF left. Then there is the distribution of LSF. How much LSF is left in Sonoma County, or Sonoma County and Mendocino County combined? Consideration of the statistical availability of LSF, or this particular unique LSF as described in agency documents, from information and argument supplied by the RPF makes good argument for the complete maintenance of this habitat type in the proposed THP area. The FPRs imply that LSF is rare and should be protected and that survey and descriptive analysis be accomplished. Mitigations and discussion in THP do not adequately address this issue.

The response statement (conclusion) by the RPF "...any conclusion that wildlife habitat value will be significantly reduced by this THP is unreasonable and unsubstantiated", is not in itself supported by evidence and differs greatly with statements in reports by CDFG, CGS, and NCRWQCB. To suggest that LSF is not an issue on this THP is a gross misstatement that needs to be corrected and addressed.

CGS Report, 7/23/01 - Report indicates that cut mark indicates loss or substantial near stream canopy. CGS's concerns are not limited to canopy but also slope stability in cut units related to inner gorge. Fifty percent canopy in Seed Tree Step unit does not address the issue(s) of near stream canopy loss or related filtration and soil stability effects - near stream. Haupt Creek is described as having "true inner gorge which are being actively undercut by creek". Landslide and unstable areas are noted as areas needing protection with limited cut and operations. Effects of proposed cut on inner gorges is not sufficiently addressed by the RPF - CWEs. The report notes there are existing slides on previously clear cut slopes that are contributing to ongoing erosion.

Recommendation for retention of 50% of overstory in Seed Tree Step unit. This recommendation has been accepted but it does not address loss of LSF or additional needs and recommendations regarding LSF and near stream protections and/or limitations in inner gorge.

Recommendation for higher canopy level in the proposed clear cut unit.

CDFG Report, 6/21/01 - Notes "risk of the degradation of rare and unique ecological qualities of a contiguous stand of Late Seral coast forest". Asks for analysis of availability of unique and limited habitat areas - under 14 CCR 919.16. States "potential decrease in the structural complexity and thus degradation of the late seral stand on the plan area" and suggests that such analysis is crucial.

Has a raptor survey been completed?

NCRWQCB Report, 7/27/01 - Notes aggraded condition of Haupt Creek and Wheatfield fork of the Gualala River - 200% above natural background levels (evidence in NCWAP and sediment study in EPA/NCRWQCB Gualala TMDL). Concerns for canopy reduction and loss of shade as well as stream bank and upslope stability issues. Notes landslide and erosion potential in all harvest areas.

Recommendation #1, due to concerns related to temperature effects a survey by solar pathfinder of Class I area WLPZ trees for determination if trees marked for cut will reduce shade. It must be stated that loss of canopy not only affects solar impact on the waters of the stream, also ambient stream temperature is controlled to a great extent by overstory canopy and ambient stream zone temperature is a large determinant of instream temperature. CGS and NCRWQCB both argue for more nearstream and hillslope retention for the sake of slope stability and erosion potential. This suggestion suggest great tree retention along watercourse and in WLPZ.

Recommendation #2, asks for sediment input analysis for potential inputs to the aggraded Haupt Creek and Wheatfield Fork sections of the Gualala River.

Recommendation #3, to limit harvest on steep and unstable areas.

Recommendation #4, 50% canopy retention in unstable areas.

Recommendation #6, assess and mitigate road configuration with re-review by agency.

Recommendation #7, reclassify (where indicated) watercourse to Class II

Recommendation #8, fix erosion site and dump.

Hydrology

No analysis has been provided regarding effects of the proposed cut on stream hydrology. Dense canopy (see basal area stocking estimates) proposed for removal provides significant water contribution to stream hydrology through fog drip. How will expected canopy loss affect stream hydrology. Additionally, there are effects on stream hydrology from sediment inputs. These impacts (see sediment discussion in agency documents) must be assessed and mitigated.

Conclusion

Given evidence in the file, supplied by all Review Team Agency, one could fairly argue that this project, as currently mitigated, poses significant degradation (impact) to the environment.

Loss of LSF needs to be addressed and mitigated. There are also unresolved issue of water quality and fishery habit impacts not yet addressed. Mitigation of leaving 10 largest tree per 300' in WLPZ doe not fully address LSF or temperature, bank stability, or filtration issue. No harvesting should be allowed in any unstable near stream area or within the steep inner gorge of Haupt Creek. One possible solution is additional reduction of near stream and unstable area cut with retention of more LSF inventory.

Several recommendations were made by Review Team Members. When such recommendation is made to mitigate extensive and ongoing impacts they should be made part of the THP. Failure to do so is a violation of the intent of the Forest Practice Act and not compliant with CEQA. Failure to provide adequate discussion and findings, based in fact, on decision to not include a recommendation is not consistent with CEQA.

Sincerely,

For COAST ACTION GROUP

Alan Levine
Coast Action Group
Box 215
Point Arena, CA 95468