RRRAUL Letter to WQRCB re Timber Harvest Operatons Waste Discharge Requirements - Waiver

Regional Water Quality Control Board
5550 Skylane Blvd.
Santa Rosa, CA 95403

September 8, 2002

Re: Waste Discharge Requirement and Reporting for Timber Operations
Consideration of Waiver of Waste Discharge Requirement - Comment

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.

The Regional Board should maintain the option of Waste Discharge Requirements and Reporting for silvicultural activity. The option should be maintained by:

    1. Making a THP the equivalent of a Waste Discharge Report,
    2. If Regional Board Staff recommendation are not accepted as part of a Timber Harvest Plan by CDF, NCRWQCB staff may non-concur and request Waste Discharge Requirements and Reporting,
    3. Some watersheds (hydrologic units) or sub-waterheds may be so damaged that Waste Discharge Requirements and Reporting may be required for all silvicultural activity - provision should be made for the same.

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.

Please retain the option of using Waste Discharge Reqirements as a tool for controlling pollution from silvicultural activities.

Sincerely,

Jay Halcomb
RRRAUL - Russian River Residents Against Unsafe Logging
http://www.rrraul.org
P.O. Box 2030
Guerneville, CA 95446

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