Dear Sir or Madam:
We are writing in regard to the TMDL and NPDES Rule revisions currently proposed by the EPA. Russian River Residents Against Unsafe Logging (RRRAUL) is a not-for-profit organization dedicated to the pursuit of responsible and sustainable logging practices in Sonoma and Mendocino counties. We believe that timber is an important resource, and that the practice of sustainable and responsible forestry to protect, maintain, and restore the forest ecosystem is an essential and desirable component of our economy and environment. We have commented to the California Department of Forestry upon dozens of timber harvests, and our members have personally inspected many logging environs and made aerial photographs and videos of logging activities, both well- and poorly conducted. Some of our findings are reported upon the RRRAUL webpage, http://www.rrraul.org/rrraul.html.
In March of 1998 a Scientific Review Panel (SRP) was created under the auspices of the Watershed Protection and Restoration Council, as required by the March 1998 Memorandum of Agreement (MOA) between the National Marine Fisheries Service (NMFS) and The Resources Agency of California. The state agreed to organize an independent panel of scientists to undertake a comprehensive review of the California Forest Practice Rules (FPRs), with regard to their adequacy for the protection of salmonid species. In March of 1999 RRRAUL provided testimony to the SRP, as part of that body’s information-gathering process. The finding of the SRP (Report of the Scientific Review Panel on California Forest Practice Rules and Salmonid Habitat, June 1999: Executive Summary) was:
"The SRP concluded that the FPRs including their implementation (the "THP process") do not ensure protection of anadromous salmonid populations. The primary deficiency of the FPRs is the lack of a watershed analysis approach capable of assessing cumulative effects attributable to timber harvesting and other non-forestry activities on a watershed scale. "
For decades, California anadromous fisheries populations have declined, due in large measure to both point- and non-point-source pollution and other water quality harms resulting from poor agricultural practices, including poor silviculture: specifically, from storm water discharges into waterbodies resulting from improperly abandoned or maintained roads, inadequate water-barring, excessive harvesting, landslide sedimentation due to poor or excessive harvesting, harvesting too near streams, and other faults.
For such reasons, we strongly support TMDL and NPDES Rules which consider silviculture activities which either (1) (which is not now proposed) determine them categorially as point-sources of water pollution, or (2) (which is proposed) allow discretion for them to be so considered in when needful, i.e., when there is no way to circumvent the deleterious effects of the practices delineated above.
We believe that development of a TMDL regulatory scheme is critical for preventing further fisheries decline and for fostering their regeneration. RRRAUL supports the speedy establishment of TMDL methodologies, and coeval regulation and enforcement for our California waterways, but wishes to also urge, besides the speedy implementation of TMDLS, that while these processes are being developed, the EPA expeditiously act to prevent further water damages; in particular, act to prevent any increase in silvicultural harms.
Thank you.
Respectfully,
Jay Halcomb
Chair, RRRAUL
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