Letter to CDF on Austin Creek THPs

R.R.R.A.U.L.
Russian River Residents Against Unsafe Logging
P.O. Box 2030, Guerneville, CA 95446
Voice: 869-3302, Fax: 823-7114
E-mail: rrraul@sonic.net
Web: htttp://wwww.sonic.net/~eggitti/rrraul.html

Tom Osipowich
Deputy Chief of Forest Practice
Calif. Dept. of Forestry and Fire Protection
Coast Cascade Region
P.O. Box 670
Santa Rosa, CA 95402

August 7, 1998

Dear Mr. Osipowich,

RRRAUL is deeply concerned about the three Austin Creek THPs, Nos. 1-98-254 SON, 1-98-218, and 1-98-283.

These THPs, like the Munchie THP of 1996 and the more recent Hulbert Creek THP, adjoin a heavily populated residential neighborhood. They also impact a major Class I tributary of the Russian River, Austin Creek, as well as a Class I tributary of that tributary, Kohute Creek.These THPs will affect approximately 600 acres in the Austin Creek watershed, in each case, a large percentage of the individual watershed assessment areas.

According to the THPs' own accounts:

(No. 254) "The plan area was last entered in the early 1980s. Four
THPs have been filed in this watershed assessment unit within the last 10 years... There is likely to be decreased water use by vegetation on the THP area during the first five years after harvest... The Biological
Resources Assessment Area has been impacted by a long history of timber harvesting, ranching, and residential uses.... Timber harvesting which took place prior to the Z'berg Nejedly Forest Practice Act of 1973, undoubtedly had the most devastating effect on the biological resources in the area." [Italics ours. Note that this comparative statement logically implies that some 'devastating' biological effects must also have occurred due to harvesting *after* 1973. This is indeed the case].

"During this period, watercourses were routinely used for skidding
and landing logs. These activities degraded streambeds, resulting in a
tremendous influx of sediment to the Class I streams. The increased
sediment had a profound effect on the quality of the salmonid spawning habitat across the Biol. Assess. Area... "

(No. 218) "Approximately 1/2 mile east of the intersection of the
main haul/access road to the project area and Highway 116, there is an ongoing landslide that is creeping onto the highway. Sonoma County Transportation Dept. has stabilized the toe of the slide with rip-rap and drain pipes were installed in an attempt to reduce lubrication of the slide mass. Currently the County's efforts seem to be working, however, only time will tell."

218, Watercourse Conditions, also speaks of rotational slides with
the THP area, and talks of "numerous obstructions within [Kohute Gulch]" and "evidence of past abuse" from "skidding logs down the stream", and "ripped riparian vegetation from the streambanks". It states, "The project are was logged in the late 1970s and, unfortunately, road maintenance has been nonexistent in the intervening years to present." The RPF states, "past projects within the assessment area have resulted in some unnatural sedimentation, mainly from recent past logging and road systems."

There is extensive evidence that the Watershed Assessment Area and the THP areas themselves are significantly biologically damaged from past practices and that the entire area is geologically unstable in many
instances. This particular Watershed Assessment Area registers the highest rainfall in the state (averaging 80 inches a year, often much more during wetter years), yet these THPs nonetheless propose tractor yarding on slopes over 65 percent and in some cases up to 80 percent.

Note, too, that a landslide recently ran down onto Highway 116, near the 218 area, and that a vehicle on that road became damaged, injuring its occupants.

In light of such considerations, RRRAUL hopes that CDF will look
especially carefully at these THPs, both individually and collectively
with regard to potential cumulative impacts, and that CDF will bring the
Dept. of Mines and Geology, Fish and Game, and Water Quality on the PHIs and to the Reviews.

We know that these THPs, like so many others, while acknowledging the existing seriously damaged conditions, and slide potentials, assert that operations will decrease the problems, improve conditions. Such assertions should be based on objective facts, quantified as much as possible. The critical element for CDF to decide here, is whether the proposed oaperations will in fact improve conditions as much as asserted, and whether yet other mitigations would be least danaging alternatives. For example, would cable logging or even helipcopter logging be better choices?

We recognize the problems created by the arrival of four controversial
THPs (remembering also the Clar Tree THP recently submitted) so close together, and three of them much larger than the usual average for this county, PLUS a 2346 acre NTMP. This problem is exacerbated by the fact of CDF's having only a two-man inspection staff, by vacations, illnesses, and so forth. Yet the Austin Creek THPs (218, 254, 283) demand careful inspection on a large and very difficult terrain. And we are concerned because among other things, the normal Second Review procedure does not require the CDF inspector to be present, and because private RPFs are typically not present either. Thus, the public's questions which cannot be answered then and there simply remain unanswered.

In other words, there is inadequate opportunity for the public to get
answers from those most able to supply them. We think it likely that on
those three plans, that even some questions initiatlly raised in CDF's
screening process will remain inadequately answered. We make the following suggestions:

1. We request that CDF include in the PHI reports, the route
information showing where the inspector visited; this should facilitate
answering some of the public's questions. On the PHIs, if CDF or other
agency staff conclude that the description of the conditions on the ground are not as described in the THP, then the inspection should immediately be halted, and that THP returned for redoing. This process also is described in your manual; it could save many man-hours of climbing over difficult terrain, and many lengthy corrections via PHI reports.

2. The Second Review of all three should be held in a different
location from the usual small room which CDF reserves for these occasions; we believe that better space can be found elsewhere, as was done with the Munchie plan.

3. All three THPs should be reviewed together, after coordinating the
PHIs as one, with sufficient time given to cover the back country and the different terrain types and stand conditions. All three THPs adjoin, they have a number of similar problems in our opinion, and the two RPFs are working together. The cumulative impacts of all three need to be addressed concurrently on the PHIs and concurrently considered in CDF's decisions.

If even one of the RPFs could attend this joint Second Review, then
answers might be produced for some of the troubling questions which
otherwise would not be available. There also needs to be, in our opinion, a way to ask the CDF inspector for answers to the public's questions, some of which originated with the very first screening of the THPs, and which seem to us to have been answered primarily with stock phrases.

Such a procedure as this would require getting one or more extensions from the RPFs, but we believe this is a reasonable request in view of the limited staff and heavy workload: it is similar to the extensions when staff is pulled off for firefighting.

If there is not adequate time for the State to cover these large and
controversial plans and if there is not an opportunity for full
explanations, then distrust in the system in general, and in the analyses
and decisions on these three plans in particular, will increase rather
than be allayed.

Sincerely yours,

Jay Halcomb
Greg Zuckert
Patty O'Leary
Dziko Standard

R.R.R.A.U.L.

Cc: Supervisor Mike Reilly
Assemblywoman Virginia Strom-Martin
Senator Mike Thompson