The Epiphany

STATE OF CALIFORNIA-THE RESOURCES AGENCY

DEPARTMENT OF FORESTRY AND FIRE PROTECTION
COAST-CASCADE REGION
135 RIDGWAY AVENUE
P.O. BOX 670
SANTA ROSA, CA 95402-0670
(707) 576-2959
PETh WILSON, Governor

Date: August, 1998
ThP #: N-NN-NNN SON

Dear Sir:

The above referenced Timber Harvesting Plan (THP) was reviewed by the CDF. The rules of the State Board of Forestry require that Timber Harvesting Plans contain certain specific information before further action can be taken. It is clearly stated in the Forest Practice Rules under 14 CCR 1035.1, that the RPF who prepares and signs the plan is responsible for the accuracy and completeness of its contents. During the review of your proposed Timber Harvesting Plan (referenced above), the Department has found it to be lacking any many areas. Because your plan was found to be incomplete in the areas listed below, your plan has not been found in conformance with the Rules of the Board of Forestry, and therefore cannot be accepted for filing as per Section 1037, Title 14 of the California Code of Regulations (CCR). In responding to the questions below, consider my comments above, and provide adequate information in your responses to fully evaluate the potential for cumulative impacts to resources in the assessment areas. Also, ensure that the proposed plan is complete, and accurate upon resubmittal.

At a minimum. the following information or corrections are needed before the plan can be accented for filing:

1. The THP lacks adequate explanation and justification for the use of roads on unstable areas, nor is it explained in the plan why each unstable area cannot be avoided (ref. 14 CCR 914.2(d) & 14 CCR 923.1(c)).

In addressing this issue, please address the following concerns:

a) Information provided at the First Review Team meeting indicates that roads within the plan area have been recently reconstructed. These roads are reported to traverse areas of instability identified in your plan. Additional unstable areas were also re ported to exist along these roads that have not been identified in the plan. Furthermore, a landing was reported to have been constructed in association with the road reconstruction. Please provide information which adequately addresses these issues. If roads have been reconstructed within the plan area, $e~ provide your rationale for not including this information within the plan prior to submittal, and indicate who conducted the reconstruction operations and what standards were used in the reconstruction. If additional unstable areas exist along these roads, describe them in the plan, and provide your rationale for not including them in the plan prior to submittal.

b) Information provided during the First Review Team meeting indicates that the road failures identified in the plan (as well as those reported to exist, but not identified) could be related to an earthquake fault zone. Provide information which indicates the level of geologic review that was utilized in identifying the cause of the road failures (i.e. geologic maps, air photos, input from consulting Geologist), and how you determined that outsloping, rolling dips, and French drains were adequate to ". . . help to improve the stability of the area. . ." Please provide the specifications (with drawings) that describe the mitigation work to be applied at each unstable road point, showing the extent of the unstable area in relation to the road work propose d and the watercourses affected (where applicable).

This information is critical for review of the plan, and also for providing adequate instructions to the LTO for operations in these sensitive areas.

2. Your THP lacks upgrades to your watercourse protection measures needed to comply with the new watercourse protection rules as required by 14 CCR 916.5(e)(B), (E), and (G). Also, revise the Class III protection measures pertaining to ELZ widths where slopes are equal to 30% (ref. 14 CCR 916.4(c)(1).

3. The THP states that "Tractor roads to be used within the ELZ shall be flagged prior to the start of timber operations . . ." Since ELZ crossings will not be flagged, how will our inspector be able to evaluate that tractor crossings will minimize disturbance to LWD and stored sediment? The Forest Practice Rules (ref. 14 CCR 916.4(c)(1)) state that "The location of the areas of heavy equipment use in any ELZ shall be clearly described in the plan, or flagged or marked on the ground before the preharvest inspection." Although some temporary skid crossings are depicted on the Roads Map, it is not clear that these are associated with Class ifi ELZs. How do you propose to tractor yard the southwestern portion of the plan without crossing the Class III water course which originates below the water tank? Clearly describe the location of the areas of heavy equipment use in the ELZs (referenced in the plan, and above), or revise the plan to conform with 14 CCR 916.4(c)(1).

4. Your THP lacks an explanation of why the silvicultural method which is most nearly appropriate or feasible, is not appropriate or feasible in conformance with 14 CCR 913.6(b)(3).

The following items were not judged to be reasons for not accepting the plan for filing. but it is requested the RPF address these questions upon resubmittal:

1. You have indicated in the plan that there will be no landing construction or reconstruction (ref. p.9). Are all landings existing? As there is no road access west of the Class I and Class II watercourses, and only a single watercourse crossing proposed; it is not clear where this material will be yarded. Yarding distances could exceed 2,000' upstream, adjacent to a Class II watercourse, and on steep slopes. Discuss the feasibility of this alternative. Furthermore, you have proposed cable yarding in all areas. Are the existing landings sufficient for this type of yarding system? If landing construction or reconstruction would be necessary to allow for cable yarding in all areas, these landings must be evaluated during the review of this plan.

2. You have indicated in the plan that there will be no new road construction (ref. p.9). As indicated above, there is no road access west of the Class I and Class II watercourses. Describe the rationale utilized in developing your proposal that all area s could be cable yarded considering the lack of access to many of the areas proposed for harvest. Address your statements in the plan that "The lack of sufficient deflection and lack of sufficient road access to some areas of the plan precludes conversion from tractor logging to cable yarding." Consider your responsibilities as a Registered Professional Forester under 14 CCR 897. Clearly define those areas within the plan boundary that are suitable for cable yarding and delineate those areas on the THP map. Consider accessibility, the limits of various yarding systems, and the location of landings in your response.

3. You have proposed cable yarding as a feasible alternative for all areas of the plan. Describe the potential for significant adverse impacts to the watercourses from your proposal should the LTO decide to choose the cable option with only ". . . one end of the log suspended during cable yarding" through Class I and Class II watercourses within the plan area. Provide the rationale utilized when you developed this option.

4. You have proposed operations outside the THP boundary. The area proposed for operations appears to be relatively steep. Are operations in this area proposed for slopes over 65%, or over 50% which lead without flattening to the Class I watercourse? Have all unstable areas associated with this area of operations been identified in the plan? Did you calculate the EHR for this area so that the LTO will know what waterbar spacing to employ following operations?

5. Except for slope and rainfall intensity, all other variables utilized in calculating the EHR are moderate. What references did you utilize in developing your calculations of the EHR?

6. Information provided during the First Review Team Meeting indicated that a landing may have been constructed in the plan area prior to submittal of the plan. It was reported that the landing was in excess of an acre in size. Please address this issue.

7. Will the alternative prescription stand be marked on the ground so the areas where you are commercially thinning will be separated from the seed tree removal areas? If not, how will our inspector be able to evaluate your proposed silviculture in both the preharvest and post harvest condition?

8. Are habitats of any of the rare, threatened, endangered, or species of special concern species' whose ranges overlap the THP area found within the THP area? Although you have mentioned that fish have been observed in Kohute Gulch, you neglected to address the species. Reports indicate that steelhead inhabit Kohute Gulch. You must address this species in your plan, specifically in the cumulative impacts assessment. Additionally, it has been reported that there are serpentine soils within the plan area. Often these soils are associated with listed plant species. You have indicated that very few listed species (plants or otherwise) have been observed in the Biological Assessment Area. What level of survey was done for the species associated with the Biological Assessment Area, and what are the qualifications of those persons who actually surveyed the area to determine species and habitat present for your evaluation of potential impacts to listed species?

9. In addressing pitch canker, you need to incorporate a statement to indicate that no material exhibiting the symptoms of the pitch canker disease will be transported outside the zone of infestation.

10. You have indicated in the plan that approximately 52% of the basal area within the Alternative Prescription is composed of hardwoods. You also indicate that this is due to a failure to reduce the relative site occupancy of hardwoods in the previous ha rvests. In this harvest, you propose to increase the site occupancy of hardwoods from 52% to approximately 60%. The only treatment proposed is falling conifers into the hardwoods. Describe in detail, your rationale for determining that conifer site occup ancy would be at least maintained throughout the Alternative Prescription area despite very little treatment of the existing hardwood component, and the overall increase in basal area of hardwoods relative to the basal area of conifers following harvest. In your response, consider that the tanoak damaged or removed will vigorously sprout following harvest and will likely reoccupy the site without additional treatment, and that approximately 1/3 of the conifer basal area to be removed is composed of Douglas-fir which does not vigorously resprout and may not successfully compete with the existing hardwood dominated canopy.

11. You have indicated that much of the current condition of the watercourses can be attributed to pre-Forest Practice Rules harvesting methods including road construction. You also indicate that you propose to leave a Humboldt crossing in place following operations. What is the current condition of this crossing? Is it likely to fail in the future and result in a significant introduction of sediment into the watercourse system? Please address.

12. Why did you utilize the Eureka Hill and the Point Arena quads in your assessment of potential tmpacts to Recreational, Visual, and Traffic resources? You must reassess the potential for impacts to these resources based upon information pertinent to t he applicable assessment areas identified in the plan.

13. You have not adequately identified which roads are appurtenant and which roads are not appurtenant in conformance with 14 CCR 1034(x)(4). Please revise the maps to include this information.

14. On page 10, you state that "All existing and new pipe installations will have . . . the addition of a downspout, rock armorment, or trash racks . . . at the time if installation is needed.', Describe who specifically will determine which of the three is appropriate for each individual crossing, and when will that determination be made? How will the CDF inspector or the other reviewing agencies determine the appropriateness of the work proposed at each crossing, and how will CDF enforce these standards?

15. Is a DFG 1603 permit necessary for the single proposed Class II crossing? If so, when do you propose to provide it?

16. Information provided during the First Review Team meeting indicates that there are existing unstable areas throughout the plan area that have not been identified. Have you adequately surveyed the area to determine areas of instability considering the use of heavy equipment throughout the area, and considering the unstable nature of the region?

17. Although not clearly presented in the plan, it appears that you propose to access Austin Creek at a location reported to be at or adjacent to a school bus stop. Have you considered this in your traffic impacts assessment? Are additional mitigation mea sures necessary to ensure the safety of children who may be utilizing this area during hours of operation? Please address.

18. You have provided the following statement on page 6:

"Any roadway segments within the THP area where road ruining surface wetness exists that cannot be drained (by culvert, small PVC drain, "French drain", or sub-drain) shall be stabilized with competent rock or geotextile fabric to mitigate potential transport of sediment into adjacent watercourses.

a) What constitutes road ruining surface wetness?

b) Who will determine whether it can be drained or not by one of the methods listed?

c) Who will determine what method to use?

d) When will the determination be made?

e) Does this apply only to roads, or to watercourses?

19. The EPA has listed the Russian River as impaired due to sediment. Kohute Gulch drains into Austin Creek which drains into the Russian River less than 1 mile downstream. Describe what specific methods you have proposed in the plan to address this issue, and those which you believe are likely to reduce the amount of sediment currendy being introduced into the system. In addressing this issue; consider that your plan, in conjunction with other plans recendy submitted in this area, comprise approximately 2/3 of the entire Kohute Gulch watershed; consider that your plan proposes tractor logging throughout the area; and consider that there is ongoing gravel mihing in the area (likely a permitted project which should be addressed in the cumulative impacts a ssessment if it lies within the assessment area).

20. Under Archaeological Records Check Information (THP pg. 49), Other Prefield Research and Survey Methods and Procedures (THP pg. 50), correct the sentence concerning the extent of the survey coverage by Little (1984). (CDF/ARCH)

21. Provide an NSO "No Take" certification by second review.

If you resubmit this THP, please be sure to include the original page 1 so we will know the original number of the resubmittal. Any confidential material, (Archaeological addendum) which was submitted with the THP will be held at this office in a Confidential file unless there are changes requested pertaining to this material. If this THP requires a Notice of Intent, please change the "earliest estimated date of Director's approval" to reflect the correct date and re-post.

Timber Harvesting operations are not to commence until your plan is found to be in conformance by the Director of Forestry and Fire Protection. Please realize that the extent of the review is not to be considered complete. Numerous discrepancies were disc overed during the review, and may not have been addressed in the above numbered concerns. Upon resubmittal, the Depattment will again review the information you have provided and determine if the plan can then be accepted for filing. Please review your pl an thoroughly prior to resubmittal to ensure that it is accurate and complete, and conforms to the Rules of the Board of Forestry so that we may review it in a timely manner. If you need any assistance or information, please call or write to the Resource Management Office at the above listed address or telephone number.

Sincerely,

Craig Anthony
Deputy Director for Resource Management

BY: Dennis O. Hall
Division Chief, Forest Practice
RPF#2597
Enclosure
Cc: Unit, WQ, DFG