On Tuesday, March 2, 1999, RRRAULians and others testified for 4 hours before a science panel of the Watershed Protection and Restoration Council on the subject of defiencies in the Forest Practice Rules and CDF politicies, as these defiencies respect the viability of California's salmon population.
Scientific Review Panel
Watershed Protection & Restoration Council
c/o NRM Corporation
1434 Third St.
P.O. Drawer 1247
Eureka, CA 95502-1247
April 1, 1999
Ladies and Gentlemen:
Thank you for the opportunity to comment upon the current situation regarding
salmonid protection vis-a-vis the Forest Practice Rules and their implementation
in the THP review process. RRRAUL is a watchdog environmental group concentrating
on forestry along the Russian River; we have participated extensively in THP
reviews in Sonoma County and have lobbied the Board of Forestry concerning rule
changes.
Very briefly, our general concerns regarding the THP review process are:
1) A lack of expertise (coupled with a lack of concern) amongst too many practicing
RPFs about the habitat needs of salmon.
2) (Because of understaffing), too often the appropriate agencies (especially,
for salmon habitat protection, DFG and RWQCB) are absent from the review teams
and on the PHIs. The folk who should be inspecting and commenting on THPs simply
don't have the time to do it.
3) The sometimes too-hasty review period for THPs imposed by the FPRs. Sometimes
the time for review should be extended, especially when the consulting agencies
can't get to their homework. The present informal process whereby CDF requests
a delay from the RPF puts an unwarranted burden upon CDF.
4) Too many THPs are "boiler-plated", with little or no concrete justification
given for: in-lieu practices, rejection of "infeasible" alternatives,
lack of cumulative impacts, choice of silvicultural methods, claims that MSP
will be achieved, and the like. Particularly, there is very often a lack of
site-specific justification for such items, while conclusory statements are
often made -- both by external RPFs and by CDF inspectors and reviewers. There
are many examples of such THPs to be found; I have attached one such, together
with a CDF rejection letter addressing it. This particular THP was rejected
for filing by a stalwart CDF reviewer after drawing intense public fire, but
many very similar plans are not rejected -- are, indeed, approved without significant
mitigation.
5) No quantitative methods are used in assessing cumulative impacts. "No
actual measurements are intended." Suggestion: incorporate TMDL methodology
into the Rules.
Now I turn to the Forest Practice Rules:
1) Many FPR definitions are in need of revision. Some are too vague to provide
clear guidance to their users in the context in which they are employed and
would be usefully clarified by having operational amplification within the FPR:
e.g, canopy.
(The definition of the period for winter operations , on the other hand, is
too artificial. In practice it can, as employed in the Rules, license timber
operations having significant harmful impacts to Salmon. A more realistic definition,
working in combination with the appropriate Rules, would take account of the
actual climatological conditions of a watershed, especially as these affect
salmon, and which may vary from time to time. In general, the FPR should take
better cognizance of actual watershed conditions than they presently do in their
blanket, a priori uniformity. Aristotle once wrote that women have fewer teeth
than men; a mistake he could have corrected if he had looked in Mrs. Aristotle's
mouth.).
2) Specific FPR rules should be better tailored to respect the habitat needs
of salmon. E.g., road abandonment should require longer periods of maintenance.
No-cut buffers ought to be provided for WLPZ. The procedures for establishing
EHR ought to be revised to reflect a factor for slope instability. The cumulative
impacts discussion should include a discussion of the potential for mass wasting
of the site, and the rules regarding use of tractors, road and landing construction,
should reflect this potential. The rules regarding road construction should
prohibit construction during critical times for fish.. Standardized methodologies
for determining the design of roads, landings, and culverts should be incorporated
into the FPR and their use documented within THPs; where standardized methods
do not exist, they should be created.
Respectfully,
Jay Halcomb
Chair, RRRAUL
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