Water Quality Initiatives - The use of such initiatives is not necessarily the best or most direct way to address issues related to forestry impacts to sustained harvest and basic fish and wildlife issues. However, Water Quality Initiatives (impaired listed watersheds, TMDLs, State Water Law) are one of the only tools that are currently affecting management technique related to these issues. Read below. Support of Water Quality Initiatives deserves more active support by the environmental community.
Alan Levine Coast Action Group P.O. Box 215 Point Arena, CA 95468
From: Michael Evenson
Water Quality Declares Palco HCP Inadequate
It has finally happened: a state agency has cried out that the emperor has no clothes!
In a thorough and honest evaluation of the cumulative effects of Pacific Lumber's harvesting, the North Coast Regional Water Quality Control Board Staff issued a report last week finding that the five watersheds it had chosen to inspect (Freshwater Creek, North Fork Elk River, and Bear, Jordan and Stitz Creeks of the Eel) were so heavily impacted from logging that immediate action must be taken to allow them to heal. The Staff Report also evaluated the Palco HCP/SYP and found it and the Forest Practice Rules inadequate to protect water quality.
This has implications for the approval of PL's timber harvest plans in the Mattole and may slow down the approvals of the old growth THPs now in the mill.
We urge everyone to read the report. It can be found at: http://www.swrcb.ca.gov/rwqcb1/palco.html .We also ask that you write to Water Quality and let them know you approve of their using the best available science in protecting the water which we all treasure. They will be taking all kinds of abuse for telling the truth and they need to hear from the public, loud and clear. It is crucial that they get support NOW. The principal author of the report is Dr. Ranjit Gill.
Ranjit S. Gill, Ph.D.
Chief Headwaters Unit
California Regional Water Quality Control Board
North Coast Region
5550 Skylane Blvd., Suite A
Santa Rosa, CA 95403
Here are some quotes from the Report: "In the Regional Water Board staff's judgment, the Discharger's timber harvest and related activities under the HCP and the Forest Practice Rules will not assure adequate protection of water quality standards (water quality objectives and beneficial uses). Therefore, Regional Water Board staff propose that in order to assure restoration and protection of the impaired beneficial uses in these watersheds, the Regional Water Board should regulate the Discharger's activities using its authority under the Porter-Cologne Water Quality Control Act and the Clean Water Act, and require that the Discharger comply with the Basin Plan." … ". In fact, section 3.4.1.3 of the FEIR/FEIS for the HCP/SYP states that "because the proposed HCP/SYP is not designed to specifically address impaired waters to meet the water quality criteria, additional restrictions and BMPs may be required later by the TMDL process...." "
Water Quality Staff pointed to several specific failings of the HCP/SYP, too. 1) Mass Wasting Avoidance Strategy (MWAS) will not be adequate to prevent landslides because it only focuses on part of the slope, not all the areas do experience landslides; it does not take into account the changes in the landscape from removing the canopy, loss of root strength, increased moisture levels during storms - all leading to increased landsliding; it relies on unproven and untested postulates
2) Streamside Buffers are effective in providing recruitment of large woody debris, shade and cooler temperatures, root-induced bank stability, and filtration of coarse sediment from stormwater runoff. However, streamside buffers are only marginally effective in filtering fine sediment from runoff and they are ineffective in preventing harvest-related landslides.
3) Road Upgrading and Stormproofing will not be sufficient to mitigate other harvest related impacts. Also, as long as roads and road use remain on the landscape, sediment discharges will occur even from upgraded or stormproofed roads, though at a reduced rate.
4) Zero Net Discharge (ZND) Strategy can not adequately mitigate the impacts from current and future timber harvest and related activities in these already impacted watersheds for several reasons: it can only assure the status quo (which is a degraded condition); even a Negative Net Discharge (NND) strategy will not prove adequate in these watersheds to attain and maintain water quality standards as long as high impact harvesting and related activities continue; there is a discontinuity in time and space between when the sediment is generated and delivered from timber harvesting and when the sediment "savings" occur from implementation of the ZND strategy; sediment saved and sediment generated are not correlated by sediment classes, that is fine vs. coarse; sediment savings are based, in part, on field measurements, but also rely heavily on field staffs' judgment to estimate probability of failure, volume of sediment likely to be generated, and percentage of the sediment which is likely to be delivered to a watercourse - they have never been proven correct in their estimations; and since sediment generation calculations do not anticipate harvest-related landsliding, sediment savings do not account for sediment generation from harvest-related landslides, which are likely to occur unless prevented.
5) The Disturbance Index (DI) which was developed in the HCP to evaluate watershed health status gives a "reading" of relative levels of watershed disturbance from past logging. The DI sets a level, 20%, below which PL can harvest in any manner possible. Should the DI exceed 20%, then harvesting is curtailed somewhat. However, it is nearly impossible, given the method they designed for making the DI calculation, for a watershed to exceed 20%.
Now, these 5 aspects of the HCP/SYP are what PL and CDF rely on for compliance with existing laws and regulations. With Water Quality coming out and saying that even if an individual THP is compliant with these 5, it is still not compliant with state water laws, they are making a direct challenge to CDF's ability to act as the lead agency in approving permits to harvest timber.
Water Quality Staff also found that PL was using the above 5 HCP provisions to propose oversize clearcut units and seek waivers of certain old growth requirements or promote rather perverse interpretations of the states Forest Practice Rules. They stated that "relying on the current THP review and approval process, utilizing the provisions of the FPRs and the HCP will not assure restoration or protection of all impaired beneficial uses in these watersheds."
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