Ms. Jacquelyn Schafer
Director. California Department of Fish and Game
1416 9th Street
Sacramento, CA 95814
The undersigned groups write to bring to your attention the near-total absence of DFG participation in timber harvest plan review in the North Coast.
We see media reports of the recently-announced agreements between the State, including your department, and the National Marine Fisheries Service, under which the NMFS has deferred listing steelhead on the theory that the state programs will adequately deal with steelhead and coho protection and recovery.
We do agree that the best approach would include long-range plans for cooperation between agencies, the NMFS and private landowners, using an information-driven watershed analysis system. We hope to be able to support a scientifically-developed long-range plan when it is operational. We also realize, however, that this approach would require funds for personnel training and staffing, and changes in laws and enforcement programs, as well as many other changes likely to require a long time-span to implement. In the meantime, anadromous fisheries are still in decline.
Coho, for example, are already listed as threatened. And WHERE are they located? In large numbers, they are in the short-run rivers of the North Coast, many of which are listed by the EPA and the state as pollution-impaired.
And WHAT is the principal man-caused activity in such watersheds contributing to habitat degradation? Forestry, though agricultural activities, non-forestry road building, dams and water diversions and other factors are of course also big causes. So while the long-range plans are being worked out, how is the Department of Fish and Game coping with its responsibilities to fisheries and wildlife in the forestry area, particularly in the timber harvest review process?
Timber harvest plans (THPs) are given a first review for the entire coast from Santa Cruz to Oregon, in Santa Rosa. The CDFG representative then can outline a list of issues and questions for CDF to address and report on, for the vast majority of THPs for which only CDF will make a physical inspection. The CDFG representative who provided the first reviews and questions for the ENTIRE north coast, retired January 1,1998. We consider it vital for the foresters who do most of the actual on-the-ground inspections to have such a list from a wildlife biologist. However, the Department of Forestry informs us that the incoming THPs are sent to the CDFG representative living in Mendocino County, but that they have received NO comments to date.
It would of course be far more preferable if a CDFG representative could go on the pre-harvest inspections, where on-the-ground conditions can be observed and important mitigations discussed with the other agencies and the owner's representative. Experience shows, for example, that when CDFG or the Regional Water Board staff attend, watercourses are typically given a 'higher' classification, which equates to greater protection, or afforded other needed additional watercourse protection measures. There are currently NO CDFG representatives attending field inspections in Sonoma County, nor in Mendocino County, where there is a great deal of forestry activity, and where many of those impaired, listed rivers are found.
As to the second, usually final, review where decisions are made on recommendation for approval or modification, so far as we know, there is now only occasional attendance at Humboldt County Second Review; we believe that your staff there is swamped by detailed reviews for Sustained Yield Plans, and Habitat Conservation Plans. And in Sonoma County and Mendocino County, there is now NO attendance at all by CDFG at Second Review.
We are grateful for the CDFG non-concurrence in Mendocino County, but we are dismayed by the continued near-total or total absence of CDFG in field review, and at Review Teams. Without participation by CDFG in the THP review team process, it is unlikely that current THPs will receive adequate protection for wildlife, particularly anadromous fisheries.
All the policy statements and MOUs will not help a single fish until they are given some actual effect, and at present there is evidently not enough money or staff to make the long-range plans move closer to reality, or even to carry on the existing review process. With anadromous populations barely hanging on in many watersheds, what can your department do to insure some kind of participation in the forestry process?
Sincerely,
CITIZENS for WATERSHED PROTECTION, Helen Libeu, Chair
SIERRA CLUB CALIFORNIA WILD SALMON FOREVER PROJECT STEERING COMMITTEE, /s/ Calvin French, Chair
SIERRA CLUB CALIFORNIA REDWOOD CHAPTER, /s/Marianne DeSobrino, Chair
COAST ACTION GROUP, Alan Levine, Chair
FRIENDS OF THE GARCIA, Peter Dobbins, Secretary
RUSSIAN RIVER RESIDENTS AGAINST UNSAFE LOGGING, Steering Committee, Jay Halcomb
Encl: statistics on reviews and inspections.
cc: Dr. William Hogarth, NMFS
Senator Mike Thompson
Senator Byron Sher
Senator Tom Hayden
Assemlywoman Viriginia Strom-Martin
Of approximately 800 THPs on 303 ( d) rivers from 1987 to 1996, CDFG was on site for field review on approximately 13. Of these 800 THPs, about 60% included operations that represented a high degree of potential pollutant impacts to watercourses; CDFG attended field review of about 17% of these sensitive THBPs. Since then, CDFG field participation has decreased.
The review of these 800 THPs was done by Alan Levine, in preparation for the Total Maximum Daily Load ( TMDL) litigation, which was eventually settled with EPA and the state, with the court requiring TMDLs on all 18 of the 303 (d) listed watercourses.
CDFG AT FIRST REVIEW TEAM MEETINGS (Santa Rosa, for all north coast counties) None since January 1, 1998.Personal communication : CDF Review Team chair, Santa Rosa.
CDFG ATTENDANCE AT SECOND REVIEW TEAM MEETINGS (north coast counties) a) Sonoma County, except for visit to learn process: none since January 1, 1998. Personal communication, CDF Team Chair. b) Mendocino County: none since October 8, 1997.
In Mendocino CDF Resource office, 216 THPs were acted upon during all of 1997 and 1998 through March 28. CDFG attended attended seven times, during which the team reviewed 31 plans; however, CDFG personnel there do not normally participate unless they have attended a field inspection, hence number of THPs reviewed by CDFG would be much lower. Mendocino information from review of all THP files for 1997, 1998 through March 24.
Of added concern: the Regional Water Board staff often covers issues affecting both CDFG and their own agency; but they, too have been absent in Mendocino County reviews since December, 1997.
In Humboldt County: the CDFG representative reviews about 15 THPs per year ( personal communication to Mr. Levine)
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