February 20, 2004
Jason Marshall,
Assistant Director
Department of Conservation
801 K Street, MS 24-01
Sacramento, CA 95814
Subject: California Geologic Survey, Technical Advisory Committee On Forest Report and Review of the Empirical Sediment Budget approach developed by Dr. Leslie Reid to assess sediment production in Elk, Stitz, Bear, Jordan, and Freshwater Creeks, Nov 15, 2004.
I am not a geologist. But, I have read and followed the science and controversy related to sediment production from forest practices on California's north coast rivers since 1990. I am familiar with the methods, science, and reporting related to sediment production from forest practices in this region and the recent assessment and findings by panels of experts in the drainages in question.
The following are points of discussion for consideration of the TAC findings:
TAC has spent much energy to be openly and severely critical of Dr. Reid's findings and methodology in her "Empirical Sediment Budget" approach. The TAC basic criticism is based on a claim of uncertainty due to reliance by Dr. Reid on certain assumptions - where some areas of assumption-based analysis is missing data or information that may skew findings.
Over the years, while trying to deal with the subject of accelerated erosion from timber harvesting, the members of the California Geologic Survey, have been unable (less than competent) in developing policy to address the problem of accelerated erosion from timber harvest activity in the steep, unstable watersheds of the north coast. Their reasoning for not developing a policy or methodology that tackles the issue in a comprehensive way was (and is) that there is not sufficient information.
Currently, almost all of the north coast rivers are listed on the State's Impaired Waterbodies List as impaired due to sediment, or temperature (a sediment related effect), and nutrients (also a sediment relationship).
However, CGS and TAC members have taken a negative and critical stance when learned scientists criticize historic and current assessment methods, which suggests that additional and more comprehensive policy must be put in place to deal with the issue of level of disturbance. Level of disturbance (and related risk assessment) is the real (and allusive question) that is in want of attention - how much of a watershed can be operated on over a certain time period given known slope, geology, and operational practices.
CGS (and TAC) have failed to consider mandates under the State and federal clean water law for addressing such an issue. It may also be pointed out that issues of public health and safety are at stake in the watersheds in question.
As noted above; CGS (and TAC) have failed to accept, are critical of, the methodology suggested by Dr. Reid, and others, to address clean water mandates. They have also failed to accept and acknowledge need to accept that the concept of "level of disturbance" as a concept that needs to be dealt with.
Dr. Reid's model, with assumptions, is designed to take factors into account that will offer a fairly accurate estimate of sediment production - given uncertain circumstances. It has always been understood that the exactness of such estimation is not ideal or perfect. The estimates are the best that the best scientists can provide - as all information is not available, there are unknowns which never can be entirely certain. Such modeling (which provides relative risk assessment) is acceptable as the accuracy level, or level of certainty, is accounted for in the methodology of Dr. Reid. This is a generally accepted practice and provides generally good results (80% accuracy would be acceptable in the sediment business). This level of accuracy can also be considered acceptable as the clean water mandates include a necessary margin of safety.
Where the TAC (and CGS ) make a colossal error ( as noted above they responsible for insufficient thinking and action to this point) is that their criticism of assumptions made by Dr. Reid are based on assumptions and insufficient information on their own part.
The criticism based on analysis of the Casper Creek studies is directed at assumptions and conflicting interpretation of the findings of that study. Admittedly (by CGS and TAC members) the Casper Creek findings indicated by Mr. Munn are disputable (for a myriad of reasons); 1) they are also incomplete as to data and long term findings, 2) they are not in watersheds that compare to the watersheds in question in regards to such variables as: slope, slope stability and geology, level of disturbance, hydrology, and intensity and duration of rain events.
Mr. Munn's assumptions and flawed analysis, in light of findings by several scientific review panels, is not a supportable testament of the efficacy of the PALCO HCP - which has been shown to be flawed by the best science available.
It can be said, in regards to this TAC (CGS) report, is that you are standing on unstable ground when the basis for your attack on a methodology is to criticize certain basic assumptions with your own assumptions. This attack on reasonable methodology (including historical and continuing attacks on TMDLs and other water quality actions) coupled with CGS/TAC historic inaction in the area of addressing issues of accelerated erosion in impaired watersheds, except to be critical and to generally support the Forest Practice Rules efficacy when they have been shown to be incompetent, threatens the credibility of the work and mission of CGS and the TAC.
Sincerely, For Coast Action Group
Alan Levine
Coast Action Group
P.O. Box 215
Point Arena, CA 95468
Cc: Senate Natural Resources and Water Committee
SWRCB
CGS State Mining and Geology Board
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