From: Russian River Residents Against Unsafe Logging
P.O. Box 2030
Guerneville CA. 95446
To: Board of Forestry and Fire Protection
P.O. Box 944246
Sacramento CA. 94244-2460
attn: Dennis Hall
Dear Board Members,
Since the inception of the California Forest Practice Rules in 1974 we have seen a steady increase in the volume of regulations which they contain. The endless debate on whether or not many of these rules are appropriate, applicable, and/or sufficient rages on and will certainly continue to do so in the foreseeable future. In keeping with this mostly civil discourse we would like to state for the record that we feel the Forest Practice Rules as currently written and implemented are not sufficient to protect the soil , air, fish and wildlife, water resources and other public trust resources. This sentiment has been echoed by many, including the authors of the 1999 Scientific Review Panel Report who wrote that the FPRs, including their implementation (the THP review process) do not ensure the protection of anadromous salmonid populations.
That being said, we wish to continue to provide constructive and relevant evaluations of various specific rules contained within the current FPRs, and , when appropriate, request that a rule be revised to properly reflect the intent of what is supposed to be a functional equivalent of an Environmental Impact Report (EIR) as it relates to the California Environmental Quality Act. Perhaps the most vacuous and insufficient rule in the FPRs is the rule pertaining to the recruitment of large woody debris (LWD), FPR916.3(g).
What is so striking about this rules inadequacy is the simplicity of its remediation. The importance of LWD in a watershed cannot be understated. Dr. Leslie M. Reid of the United States Forest Service (USFS) states "Woody debris is a critically important component of streams in forested areas. In the smallest streams, logs act as check-dams that store sediment from eroded hillsides. When landslides occur, the wood catches much of the sediment before it reaches larger channels.Where a landslide triggers a mud flow, abundant or woody debris just downstream of the initiation site may halt the debris before it reaches larger channels. On larger channels , wood also provides an important element in the habitat of aquatic organisms. In addition to creating pool habitat for salmon and trout during the summer, large pieces of wood pond water and create refuges for fish during winter floods. Wood must be of the appropriate distribution of sizes and species if it is to function properly in a stream system. Conifer logs are generally more decay resistant and so are more effective than small ones. The progressive loss of large pieces of coniferous wood from streams due to continued logging of riparian zones and continued salvage of logs from channels has led to widespread changes in channel form and to impaired aquatic habitat." (Reid, letter to assemblyman Fred Keeley, 24 May 1999). Dr. Reid also goes on to state, "The Forest Practice Rules are not sufficient to maintain the composition, size , and quantity of in-stream wood necessary to protect channels from increased disruption from debris flows or gullying or to provide adequate habitat for fish and wildlife."
Even CDF's own memo to Registered Professional Foresters (RPFs), dated 29 April 1997, underscores the critical value of LWD in a watershed. Sections 3.2.1-3.2.1.2 of Coho Salmon Considerations under the California Forest Practice Rules (29 April 1997) deal specifically with LWD. The following statements are quotes from these sections:
It is clear that LWD is vital to hydrological stability in watersheds, vital to controlling the flow of fine sediment into the in-stream environment and vital to anadromous salmonid habitat. It is also clear, as previously stated , that the current rule addressing the recruitment of LWD is NOT sufficient to do so. We therefore request that rule 916.3(g) of the California Forest Practice Rules be changed to read as follows: "For recruitment of LWD the largest10 trees per 100 meters of streamside shall be retained within 50 feet on both sides of the watercourse on Class I and II streams.The trees to be retained must be permanently marked by securing (by nail or screw) a 4 inch by 4 inch color coated aluminum plate at a level at least 6 inches above breast height."
Than you for your consideration.
Gregory C. Zuckert, Chairman:
RRRAUL
RRRAUL Home | Search RRRAUL | News | Logging | Fishery | Watershed | Photographs | Contacts | Organization | Calendar | External Links |