Last updated: 10/24/99
Awareness of a rapidly spreading disease/beetle infestation of tan oaks and coastal live oaks has been spreading less slowly than the infestation itself has. Greater public awareness and further official Dept. of Forestry action might be spurred by articles which recently appeared in the Press Democrat and the S.F. Chronicle.
The problem is a rapidly escalating destruction of tan oaks and coast live oaks, in counties from Santa Cruz through Sonoma; although the exact etiology of the dissease is presently debated, it is associated with, if not caused by, infestation by two species of beetle: Western oak bark beetle (P. pubipennis) and the oak ambrosia beetle (M. scutellare). Symptoms of infested trees include brown, dying leaves, "bleeding" -- a black, tear-like drop extruded from the bark, causing a dark-stained appearance, and boring dust on the lower trunk. Healthy trees can be attacked and killed in as little as three weeks. Property owners with oaks, as well as other environmentally concerned persons, should watch for signs of such infection and should report them to Bruce Hagen, forester at the Santa Rosa office of the California Dept. of Forestry: 576-2275. Besides the obvious aesthetic and environmental concerns, dead trees in quantities bring greatly increased fire hazard.
In July, CDF revised its THP documentation process in several respects; one change was in response to court-ordered alterations in Dept. of Fish and Game's 1603 Streambed Alteration Agreement reviews. From a July 2 memo to Registered Professional Foresters issued by Andrea Tuttle, CDF Director:
"Section 1603 of the Fish and Game Code requires any person who proposes a project or activity that will substantially divert, or obstruct the natural flow, or substantially change the bed, channel, or bank of any river, stream, or lake, or use materials from a streambed, to notify DFG before beginning the project or activity. The DFG issues 1603 Agreements to landowners with approved THPs when necessary. The 1603 Agreements have been issued in the past regardless of whether the mitigation measures were disclosed in THPs. This changed as of May 1, 1999, due to a recent court ruling which requires the 1600 Agreement process to fully comply with CEQA... The process envisioned by DFG will dovetail the 1603 Agreement process with the THP process. This proposal achieves the CEQA needs because the latter is a Functional Equivalent Review under CEQA. Section 1606 of the Fish and Game Code spells out the information requirements for THP submitters in order to meet the notification requirements of 1603. To fulfill the CEQA requirement of full disclosure of impacts and potential mitigation measures, additional analysis and descriptive information will have to be included in the THP if a project proposes activities that trigger section 1603. " (Italics added)
These potentially very useful changes have not yet been fully implemented and it remains to be seen how soon and how adequately they will take force. Environmentalist Helen Libeu has retained environmental lawyer Paul Carroll (responsible for the original legal action requiring CEQA compliance in the 1603 process), to further clarify the issues and practices involved, which recently became prominent with a Peaks Pike Road (Occidental) THP, among others.
The same Tuttle memo issued other new guidelines for THP preparation (regarding scoping, surveying, and mitigation of timber harvests):
"The Department has long recognized the need to evaluate the potential for THPs, Nonindustrial Timber Management Plans (NTMPs), or PTHPs (plans) to have a significant impact on any species and, where the impact may be significant, implement appropriate survey and mitigation measures. Further, CDF has, in the past, requested information or surveys prior to plan approval for listed species or unlisted species where potential significant impacts have been identified in the plan review process... CDF believes that these procedures need to be more clearly included in the plan review process in order to comply with all the applicable laws, including California Environmental Quality Act (CEQA). Failure to provide complete and accurate information about all species on which a significant impact may occur only slows down the plan review process since such information must be included and considered before a plan can be approved."
Persons interested in informed public participation in THP reviews should acquire copies of this important memorandum from RRRAUL or elsewhere, and insist that these guidelines be adequately followed. (More of this memo is available on the RRRAUL webpage: CDF Survey Guidelines )
Another change in the THP process: Northern Spotted Owl survey consultations are no longer being done by DFG, but are being reviewed by U.S. Fish and Wildlife.
It looks as though the Board of Forestry may finally adopt some significant new forestry regulations. The relevant meeting occurs in Sacramento on October 5th.
(9/22/99)
On Monday, July 26, Sonoma County Judge Laurence Sawyer turned down a request to stop a timber harvest plan proposing to log 121 acres in the Willow Creek watershed. The action was sought by the Western Watershed Alliance, alleging that CDF had not sufficiently considered the cumulative impacts of the proposed logging and its sedimentation effects. Mendocino Redwoods, on the other hand, maintained that restoration efforts towards which it was contributing, coupled with mitigation measures within the plan, would in the long run actually reduce overall sedimentation damage to Willow Creek. In agreement with the latter view, Helen Libeu and Jay Halcomb opined (see: On A Willow Creek THP), based upon their review of the THP and inspection of the proposed logging area, that the THP was indeed relatively environmentally benign and likely to improve conditions at Willow Creek under the strong additional mitigation measures recommended by Water Quality and the Department of Fish and Game -- mitigations which included repair to a significant and ongoing erosional feature. Mike Swaney of Trout Unlimited, which is conducting restoration work on Willow Creek, had previously stated that he’d like to see MRC retain control of the land and proceed with restoration efforts affecting Willow Creek. (See also: A Willow Creek Controversy.)
RRRAULians appeared before the Board of Forestry on Monday, August 2, to discuss 1) the Forest Practice Rules which concern the “rehabilitation” method of silviculture, and 2) the clearcuts and burns being conducted by Gualala Redwoods, Inc., upon the Gualala River and its tributaries. The Gualala River Improvement Network also spoke upon the latter issue at this meeting. More information concerning the Gualala THPs can be found on the RRRAUL webpage: see Gualala references. Comments by Alan Levine on the Gualala presentation by Alan Levine, Coast Action Group, follow:
GUALALA PRESENTATION TO THE BOF, 8/02/99
Folks made a presentation on the Gualala, with slides and a report from NCRWQCB, about the frequency of clearcutting and the burning for site preparation. Slides were presented of the incidence of burns getting very hot and entering the watercourses, and showing where all vegetative matter was incinerated and large areas of exposed soil, known to be erodible, were left. Also, from the slides the frequency of this practice was obvious up and down all watercourses on this holding by Gualala Redwoods. A report on file by NCRWQCB was presented, which indicatied their concern and the fact that the elevated fines had to impact the watercourse.
CDF made their own presentation on this subject. CDF staff said that there was a hot burn that got out of control. Upon their investigation they could find no evidence of soil reaching the watercourse.
At this point I would like to point out (others were not allowed to speak due to time constraints) that the Gualala River may be the most impacted river on the north coast. Due to mismanagement (or no management) by CDF and other agencies it is functioning under a massive load of sediment, enough to rival that of recent Freshwater Creek proportions, and it has for many years. If one would care to go through the file of Gualala THPs 1985 to present, one would find documents attesting to the continuing and ongoing impacts of these THPs. These problems are severe and documented. There is just no one living in the flood plain to complain. Also the tributaries are not only being severely aggraded, but are very hot with temperatures approaching 80 degrees F for long periods of the summer months. This temperature problem is related to the aggradation and also the extreme lack of near stream canopy for many of the reaches.
So here we have a major problem and CDF sees no problem. And the BOF sees no problem. Where the hell are the Cumulative Watershed Effects!?!? Which is the question with THPs -- ARE THERE EVER ANY CONTINUING IMPACTS marked "yes"? How can a trained person say, as they repeatedly do, "the forest practice rules are working"? Not only do we need education; we need our eyeballs peeled and new tissue regrown -- that can go for some new grey matter, too.
Why does this constant practice of clearcutting, burning, pesticiding, and road building go on and on -- without anyone's noticing and/or acknowledging current stream conditions as severely impacted by past and recent operations? Not to notice problems is a very good example of what can go wrong with management policy -- and why the Forest Practice Rules need MAJOR fixing.
Alan Levine
Coast Action Group
P.O. Box 215
Point Arena, CA 95468
A proposal to convert to vineyards 10,000 acres of property stretching from Annapolis through half of Mendocino County is being heavily debated in both counties. Fresh doubts have emerged about the propriety of the plan. Coastal Forestlands had optioned this property from Strategic Timber Trust, to whom it had earlier sold its holdings. Discussions now underway indicate that the option agreement may not permit the contemplated uses.
The proposed conversion is unprecedented in scope. It has roused much attention, including concern in local and State agencies. Critics in both counties question the drastic lowering of previous conifer stocking levels under Coastal Forestlands management and with CDF compliance, and oppose the potential loss of much more forest.
Ex-Supervisor Ernie Carpenter has been hired by Coastal Forestlands as an environmental consultant -- a move which has raised eyebrows.
The lengthy dispute over the “Clar Tree” THP (No. 1-98-253 SON, aka “Silver Estates”), which involved the Russian River Sanitation Distric’s sewer treatment facility, has reached resolution with CDF’s recommendation for approval of a much modified plan. Logging is now restricted to 15 acres with operations kept away from the treatment facilities and the effluent disposal areas, and from the Clar Tree itself -- Sonoma County’s tallest redwood. The negotiations involved the public, the County, CDF, and the plan submitter for over a year.
A new THP has been submitted for the headwaters of Hulbert Creek. This plan, No. 1-99-211 SON, proposes 32 acres of logging -- 25 acres of the selection method in an area which include the Creek itself, and 7 acres of shelterwood removal (a method often close to clearcutting) uphill from the Creek. The plan has the potential for significant impacts upon Hulbert Creek. In the past months, the Sotoyome Resource Conservation District has begun organizing a Creek Stewardship Program for both Fife and Hulbert Creeks. (They may be reached for information about their monitoring program and other activities at 569-1448, e-mail: sotorcd@sonic.net).
The Scientific Review Panel of the Watershed Protection and Restoration Council has released an extensive report criticizing the current Forest Practice Rules: “The SRP concluded that the FPRs, including their implementation (the "THP process") do not ensure protection of anadromous salmonid populations. The primary deficiency of the FPRs is the lack of a watershed analysis approach capable of assessing cumulative effects attributable to timber harvesting and other non-forestry activities on a watershed scale”. Besides recommending a watershed analysis approach to timber-harvesting, the panel made 11 pages of specific rule revisions, including greater watercourse protections, geological inspections, prolonged road maintenance, closer agency inspection, and better THP preparation. Three new rule packages are now up for consideration at the Board of Forestry.
Austin Creek THP 1-99-097 SON, a revision of the earlier 1-98-218, went to 2nd Review at CDF on Monday, June 14. The meeting was well attended by members of RRRAUL and the Austin Creek Alliance, who raised questions regarding: 1) the validity of a Northern Spotted Owl survey, 2) a large translational-rotational landslide complex upon a portion of the area proposed for logging, and 3) the silivicultural systems employed in the plan. ACA and RRRAUL had earlier hired an geologist to examine the THP area from the air and in existing maps and aerial photographs. The independent geologist reported features of the landslide complex which were uncommented upon in an Dept. of Mines and Geology report and which raised fresh concerns about the extent of logging planned in the THP. The plan is awaiting CDF decision.
Of two THPs adjacent to 1-99-097 and submitted at the same time, one has been withdrawn, and the other approved. Logging upon the latter has not commenced, however; the owner is said to be reconsidering his plans for the property, including seeking a conservation easement. Together, these three Austin Creek THPs comprised some 600+ acres near the confluence of Austin Creek and the Russian River.
On Saturday, May 22, the Interim Russian River Watershed Council voted to constitute itself as the permanent council, and accepted the recommendations of its workgroup on forming a Steering Committee. The Council is constituted by four igroups: a group of public agencies and elected officials, an Environmental Caucus (which includes RRRAUL), a Public Caucus, and an Economic Caucus. Each group has 18 members, and participation is divided between Mendocino and Sonoma counties. The Mission Statement of the Council (accepted at a previous meeting) reads in part: “Our primary goals [include] recovery of the Russian River and its watershed to a condition such that the native wild anadromous fishery recovers to healthy and sustainable levels.”
In January, RRRAUL working with Trout Unlimited planted 600+ redwoods at Willow Creek. RRRAUL continues to discuss modifications and additions to the Forest Practice Rules with the Board of Forestry. The project has been delayed due to Governor Davis’ laxity in making appointments to the Board of Forestry. RRRAUL continued its aerial flyovers of Sonoma County, to videotape and photograph local forest conditions. In April RRRAUL “tabled” at Sonoma State University’s Earth Action Week.
RRRAUL has established a forestry list-serv: rrraul-list@lists.sonic.net (To subscribe, send an e-mail to this address with the body, "Subscribe rrraul-list")
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