NMFS Critical of C.D.F.

(The following material is quoted from a draft letter from the National Marine Fisheries to C.D.F.)

General Concerns

Two areas of concern that the National Marine Fisheries service has with the implementation of the California Forest Practice Rules relate to the large number of rules under which adequate conservation for anadromous salmonids depends heavily on the Registered Professional Forester (RPF) having a high level of biological, ecological, and/or geological expertise. It is unrealistic to expect all RPFs have such knowledge. Often, the conservation of ecological resources, including anadromous salmonids, depends upon protective measures that are inserted into Timber Harvesting Plans (THPs) during the review process. Two state agencies, the California Department of Fish and Game (CDFG) and the Regional Water Quality Control Board (RWQCB) have been given statutory responsibility to review THPs for compliance with the California Fish and Game Code and Clean Water Act, respectively. The Division of Mines and Geology also reviews THPs. No integrated guidelines or policies are available to provide a framework for treatment of THPs through the review process (Little Hoover Commission 1994). In addition, the agencies can review only a small fraction of the THPs, and thus are forced to rely on RPFs, not agency personnel, to determine problems and design mitigation measures. Furthermore, even when these agencies participate in a review, there is no requirement that the agencies recommendations must be incorporated into THPs.

Specific Concerns

Definitions -- 'Abandonment' means leaving a logging road reasonably impassable to standard production four wheel-drive highway vehicles, and leaving a logging road and landings in a condition which provides for long-term functioning of erosion controls with little or no continued maintenance.

Definition does not necessarily provide for full decommissioning of roads. It does not require complete closure of road; off-highway vehicles, bicycles, horses, etc. can still use the road. Surface erosion from impacted roads could continue. Vehicles on abandoned roads may also break down erosion controls, such as waterbars, rendering themineffective. Continued use of abandoned roads could increase sediment inputs into nearby streams.

Definition does not require removal of all road features that may reroute hillslope drainage, restrict or confine stream flow, and/or present slope stability hazards (culverts, cross drains, inside ditches).

Stream crossing structures may be degraded over time or may become perched, blocked, or wash out. No requirement to periodically check these erosion control measures to assure they are maintaining full function.

Potential Biological Impacts

Surface erosion from road systems deliver sediments to watercourses that can diminish pool quality and quantity, increase turbidity, smother coho salmon eggs and larvae, increase gravel embeddedness, decrease invertebrate abundance, and disrupt social and feeding behavior (Cordone and Kelly 1961, Everest et al. 1987; Hicks et al. 1991; Kelsey et al. 1981; Lloyd et al. 1987; Megahan 1982)

Roads that are not properly decommissioned can alter hillside drainage; intercepting, diverting, and concentrating surface and subsurface flow, and increasing the drainage network of water sheds (Hauge et al. 1979, Wemple et al. 1996). This can lead to changes in peak and base flows in streams.

Improperly maintained roads may still fail, causing a large amount of sediment to enter into watercourses.

Culverts may block migration of anadromous salmonids, preventing adult access to spawning areas and restricting movement of juveniles between habitats...

Complete Text of CDF Response (Contains NMFS original)