PalCo: Business as Usual at Water Quality?

PalCo: Business as Usual at Water Quality?

North Coast Regional Water Quality Control Board
5550 Skylane Blvd., Suite A
Santa Rosa, CA 95403
March 16, 2005

Re: Whether to direct the Executive Officer to enroll additional Timber Harvesting Plans in Elk River and Freshwater Creek watersheds under Order No. R1-2004-0030, General Waste Discharge Requirements for Discharges Related to Timber Harvest Activities on non-Federal Lands

Dear Board Members,

The issue before you is whether to enroll even more PalCo THPs then the ones you've already allowed under the General Waste Discharge Requirements (which are lax and inadequate to protect the beneficial uses of water) or to direct your executive officer and staff to complete preparation of the more focused Watershed-wide Discharge Requirements, which have been hanging fire for some time.

It is time -- past time -- to introduce significantly more meaningful, peer-reviewed watershed-level science into your analyses, instead of further delaying the process. There is abundant evidence of the need to move on. E.g., from the recent report of an Independent Science Review Panel:

"In sum, the Panel concludes that the HCP/THP/SYP processes have significant limitations in terms of their architecture, execution, standards and feedback mechanisms, which prevent them from ensuring attainment of water quality standards. While minor improvements could be made (that are explained within the report), the Panel finds no science basis to expect that implementing minor improvements within the existing system will ultimately lead to significant improvements in water quality."

[Phase II Report: Independent Scientific Review Panel on Sediment Impairment and Effects on Beneficial Uses of the Elk River and Stitz, Bear, Jordan and Freshwater Creeks; Authored by the Humboldt Watersheds Independent Scientific Review Panel Convened and Facilitated by CONCUR, Inc. Under the Auspices of the North Coast Regional Water Quality Control Board, Report Prepared August 12, 2003]

Today we are not even talking about implementing even minor improvements, but only of continuing business as usual, and the effects of doing that has impaired these 303d-listed watersheds in the first place.

Sincerely,

Jay Halcomb
Russian River Residents Against Unsafe Logging (RRRAUL)
P.O. Box 2030, Gueneville, CA 95446
http://rrraul.org