Pat Rutten, Supervisor
PRD Division
NMFS
777 Sonoma Ave, Rm 325
Santa Rosa CA 95404

April 23, 2003

Re: Timber Harvest Plan 1-00-484 SON

Dear Supervisor Rutten,

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 15.5o C and rearing temperatures exceed 17.8o” (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).

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.”

We cite next the WQ Pre-Harvest Inspection report on 1-00-484. Please especially note the potential impacts of these logging operations on salmonids:

"This land has never been harvested and is a Late Seral redwood and Douglas fir forest... The Late Seral stand characteristics of this property should receive complete evaluation as any loss will have a serious effect on 'listed' salmonids as well as Marbled Murrelet, Spotted Owl and other rare animals, plants (CCR 14 912.9 (f), (g))... " (P. 1-2)

"The two THPs (1-99-098 SON Amendment 2 and 1-00-484 SON) intend to cut portions of this last intact Late Seral forest in this area. These plans infer that harvesting 13 and 55 acres will have an insignificant effect on the remaining 800 plus acres. This is not justified by the facts on the ground nor has a proper analysis been completed... It can only be stated that reduction of this Late Seral forest in the Gualala River watershed by timber harvesting has had a serious and continuing effect on fish, wildlife and plant communities, which is not an insignificant effect as stated in the plan." (P. 4)

"Any loss of habitat at this time cannot be justified. Coho salmon and Marbled Murrelet are just two species that were abundant in the past and specifically thrive on just this type of habitat are now hanging on by a thread and the future of others (Steelhead, red tree vole, and spotted owl) depend at least on retaining this entire late seral stand." (P. 5)

With respect, then, to the protection and restoration of salmon, RRRAUL requests that your department review this THP and its potential effects upon Coho and Steelhead.

Sincerely,

Jay Halcomb
RRRAUL

Cc: Forest Practices
Coast Cascade Region
California Department of Forestry
135 Ridgeway Ave.
Santa Rosa, CA 94002