Patrick Higgins
Consulting Fisheries Biologist
791 Eighth Street, Suite N
Arcata, CA 95521
(707) 822-9428
phiggins@humboldt1.com
July 17, 2004
Allen Robertson, Deputy Chief
California Department of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244-2460
Re: Negative Declaration for Timber Harvest Plan (THP 1-04-059)/ Martin Timberland Conversion Permit (TCP 04-531)
Dear Mr. Robertson,
I am writing in regards to Timber Harvest Plan (THP) 1-04-059/ Martin Timberland Conversion Permit (TCP) 04-531 at the request of, and on retainer to local citizens, who are concerned about the deterioration of the Gualala River watershed. I have read THP 1-04-059/TCP 04-531 and the Negative Declaration from the California Department of Forestry (CDF), as well as related information (Baye, 2004; Erman, 2004; Poehlman and Lavine; Plum, 2004, Barbour, 2004). I would like to incorporate by reference my comments recently filed on other THP/TCP projects in the Gualala River basin also given Negative Declarations by CDF:
· May 20, 2003 on the Artesia Timberland Conversion Permit 02-506 and Timber Harvest Plan (THP) 1—01-171 SON, which was also near Annapolis on Patchet Creek, a tributary to the Wheatfield Fork Gualala (Higgins, 2003a),
· In December 2003 on the Seaview Timberland Conversion Permit 524 and Timber Harvest Plan (THP) 1-01-223 SON (Higgins, 2003b) in the upper South Fork Gualala River basin, and
· April 14, 2004 on THP 1-04-030SON, Hanson/Whistler Timberland Conversion Permit (TCP) #530 (Higgins, 2004).
The CDF Negative Declaration fails to recognize the advancements in knowledge of cumulative watershed effects (CWE) in northwestern California as embodied by works such those of Ligon et al. (1999), Dunne et al (2001) and Collison et al. (2003). These studies recognize that CDF’s fragmented approach to analysis is not preventing CWE and related loss of biodiversity, such as Pacific salmon species. Recent regional studies of Pacific salmon status and trends are not acknowledged or their relevance discussed (NMFS, 2001; CDFG, 2003). The THP/TCP does not credibly characterize existing impacts within the Little Creek Calwater Planning Watershed, let alone the Gualala River basin as a whole. The THP/TCP only mentions the Gualala River Total Maximum Daily Load (CSWRCB, 2001) study in passing without acknowledging its findings of major existing sediment problems. The THP/TCP claims that there will be no sediment and flow impacts from this land use activity, which is not possible. The Registered Professional Forester (Jacobszoon, 2004) and the CDF Negative Declaration fail to provide data or credible science-based discussions of potential changes in flow associated with conversion of intact forest land to vineyard. The above omissions and problems should have caused you to decline Negative Declaration on status on THP 1-04-059/TCP 04-531 in accordance with the California Environmental Quality Act (CEQA).
My Qualifications
I have been a consulting fisheries biologist for the last 15 years with an office in Arcata, California. My academic training includes both completion of a B.S. in Biology from Humboldt State University awarded in 1975 and graduate work in fisheries at the same institution from 1985-1989. In 1992, I served as lead author of Factors Threatening Stocks with Extinction in Northwestern California (Higgins et al., 1992), a peer reviewed position paper for the American Fisheries Society on regional Pacific salmon. I also have expertise in Pacific salmon restoration and have written elements of restoration plans for river basins in California including the: Klamath River (Kier Assoc., 1991), South Fork Trinity River (Pacific Watershed Associates, 1994), Garcia River (Monschke and Caldon, 1991) and San Mateo Creek and the Santa Margarita River (Higgins, 1992). In 1997, I conducted an assessment of the Gualala River based on existing literature (Higgins, 1997) for the Redwood Coast Land Conservancy. Since 1992, I have been working on comprehensive watershed databases for numerous Northern California basins. That project began in the Klamath, after which the project was named (Klamath Resource Information System or KRIS). A number of KRIS projects have been sponsored by CDF, including ones for the Noyo, Big, Ten Mile, Mattole and Gualala rivers. The KRIS Gualala project provides data that is in part the basis of these comments, including fisheries, water quality, timber harvest, vegetation types, roads and riparian conditions.
Fisheries
The environmental review documents submitted by the Registered Professional Forester (RPF) for this project (Jacobszoon, 2004) state that its watershed area of analysis (WAA) is the Little Creek Calwater Planning Watershed (5,869 Acres), yet they give only the barest fisheries information regarding Buckeye Creek, the lower reaches of which are within it, or Little Creek itself. The National Marine Fisheries Service (NMFS, 2001), the California Department of Fish and Game (CDFG, 2002) and Brown et al. (1994) have found that coho salmon (Oncorhynchus kisutch) are at risk of extinction throughout Mendocino and Sonoma County. The THP/TCP notes that coho are absent in the WAA and refers to its Federally Threatened only through an abbreviation. It completely skips discussions of the implications of habitat changes related to the proposed activities and prospects for recovery of at risk salmonid species in the Gualala basin and regionally. Coho were once known to be abundant in the Gualala River (Taylor, 1972) yet CDFG (CA RA, 2002) surveyed over 100 miles of stream in the Gualala basin and collected fish samples using electroshocking and found no coho salmon anywhere. CDFG (2002) acknowledges that coho in the Gualala basin are “extirpated or nearly so.” The status of the steelhead trout (Oncorhynchus mykiss) is again referred to in the THP/TCP only through abbreviation. There are no discussions of substance as to reason for listing as Threatened under the Endangered Species Act (Busby et al., 1996; NMFS, 1996), their prospects for recovery in the Gualala, and the proposed actions effects on those prospects.
The THP/TCP does not mention that coho salmon were likely to have inhabited lower Little Creek and lower Buckeye Creek, have been extirpated and are not likely to be restored unless streams are allowed to recover. Groot and Margolis (1991) note that coho salmon prefer streams in the range of 1-2% gradient or less for spawning and rearing and data from the KRIS Gualala project show that Buckeye Creek and lower Little Creek fall within this range (Figure 1). Steelhead can actually leap 15 feet vertically and are known to inhabit reaches with higher gradient. The THP/TCP says they exist only in the lowest reach of Little Creek, but provides not supporting data. This activity is likely to further decrease suitability for coho salmon and steelhead by increasing sediment, decreasing base flows and increasing peak flows, and elevating water temperatures directly or indirectly (see discussions below).
Figure 1. Gradient of Buckeye Creek and Little Creek as depicted by maps generated from CDF elevation data in KRIS Gualala. These data show that both streams would be suitable for coho salmon in their lower reaches.
The KRIS Gualala project (IFR, 2002) advanced an hypothesis that the distribution and abundance of coho salmon and steelhead have decreased in the Gualala River basin, citing evidence of stream segments that were buried or so impaired as to lack depth, substrate conditions or appropriate water
temperature to support these sensitive species. This and other hypotheses advanced by IFR (2003) were peer reviewed with oversight from the University of California (Standiford, 2003) and reviewers said that the arguments offered were supported by the available literature and data. CDFG (CA RA, 2002) electrofishing samples included few older age steelhead trout juveniles, with smaller Gualala River tributaries being too shallow to support summer rearing of larger fish, and larger streams too warm (IFR, 2003). Barnhart (1986) noted that northern California steelhead most often spend two years in freshwater before going to the ocean. If fish do not attain a large size before ocean entry, their likelihood of survival in the ocean is quite low.
Despite steelhead trout being noted as present in Little Creek, the THP/TCP presents no fish sampling data to indicate the level of present use or standing crops. Given the depressed status of this species regionally and in the Gualala River basin, the THP/TCP should acknowledge if this stream has higher carrying capacity than Buckeye Creek itself and what role it serves in potential protection and recovery of steelhead at both scales. The THP/TCP notes that “the small number of deep pools” makes the local streams “marginal” for coho salmon juvenile rearing, but there are no quantitative data with which to judge present fish habitat quality in Little Creek such as pool frequency and depth, substrate conditions, large wood availability and riparian canopy conditions. Without these data one cannot judge potential impacts on coho salmon and steelhead populations of this and other land use activities. Lack of baseline data also prevents future monitoring to judge aquatic response to land use over time.
Water Temperature of Buckeye Creek and Gualala River and Suitability for Salmonids
As discussed in my previous comments on other Gualala River THP/TCP projects (Higgins, 2003a; 2003b; 2004), smaller tributaries in the Gualala Basin like Little Creek are likely to suffer less temperature impairment than larger order streams like Buckeye Creek (Figure 2). If Little Creek is summer periods when water temperatures in larger Gualala River tributaries often exceed stressful or lethal levels (Sullivan et al., 2001). Optimum temperatures for steelhead are between 10-15 degrees Celsius (C) and data from KRIS Gualala (Figure 3) show that mainstem Buckeye Creek water temperatures are well over stressful for steelhead (McCullough, 1999) and well beyond the range needed for coho salmon rearing (Welsh et al., 2001).
Figure 2. Water temperature suitability for coho salmon is displayed above from the KRIS Gualala project showing that the mainstem of Gualala River and its larger tributaries, including Buckeye Creek, are too warm in all years (red). Only two small tributaries of lower Rockpile Creek and the Wheatfield Fork were found to be suitable in all years measured (green), although these streams are likely too small and steep to support the species.
Poole and Berman (2000) note anthropogenic mechanisms that change water temperature regimes and at least two apply to the current project. The proposed project will likely exacerbate water temperature problems by: 1) additional sediment contributions that fill pools and increase the width to depth ratio facilitating heat exchange with the atmosphere (see Sediment), and 2) reducing cool water base flows in summer because of how the project will alter flow regimes (see Flows).
If Little Creek is less impacted by sediment and has cooler water temperature regimes than other nearby streams, its alteration could be extremely deleterious for near term prospects of steelhead recovery and longer term prospects for coho recovery in this portion of the Gualala River basin. Coho should be recognized as the most critical “beneficial use” associated with cold water fish under the Clean Water Act in the Gualala River and long term goals should be to return the western tributaries to coho suitability (<16.8 C MWAT). Continuing timber harvests and conversions will have the opposite effect.
Figure 3. This chart from KRIS Gualala shows the maximum water temperature for all automated temperature probes placed in the Buckeye Creek from 1994 to 2001 with temperatures well outside the optimal range for salmonid rearing and rather in the range of highly stressful or lethal. Data provided by Gualala Redwoods, Inc. and the Gualala River Watershed Council.
Sediment Levels and Sources Not Acknowledged in THP/TCP
THP 1-04-059/TCP 04-531 (Jacobszoon, 2004) states that most sediment impacts in the Gualala River basin are from long-past logging carried out before the passage of the California Forest Practice Rules in 1972. The Gualala River watershed is listed as impaired for sediment under section 303(d) of the Federal Clean Water Act (NCRWQCB, 2003). The Technical Support Document for the Gualala River Watershed Water Quality Attainment Action Plan for Sediment (CWQCB, 2001) found that human caused sediment delivery rates are approximately 200% above the natural background level in the Buckeye Creek basin (Figure 4).
Roads are the most significant contributor of sediment in Buckeye Creek and basin-wide (CWQCB, 2001) and road densities in the Gualala River watershed over-all are high, including the Buckeye watershed (Figure 5). Road densities in the Little Creek Calwater Planning Watershed, which encompasses lower Buckeye Creek and all of Little Creek has some of the highest road densities in the Gualala River basin at over 8 miles per square mile (mi/mi2). Road density data are conservative because temporary roads, skid trails and landings may not be mapped. All Buckeye sub-basins exceed by a large margin the threshold of 2.0 mi/mi2, with no streamside roads, defined by NMFS (1996) as properly functioning watershed conditions for Pacific salmon. The USGS topographic map of Little Creek itself shows logging roads paralleling the entire stream, sometimes on both sides of the stream. Cedarholm et. al. (1981) found that road densities greater 4.2 mi/mi2 yielded sediment levels 260% to 430% higher than background levels. Jones and Grant (1996) noted that interception of sub-surface flows by road cuts as a major factor in increasing peak flows during storm events. THP 1-04-059/TCP 04-531 does not give specific road lengths in miles, but states that between 2.5 and 3 acres of roads will be constructed. This would be expected to increase both sediment yield and peak flows in the Little Creek basin.
Figure 4. The Buckeye Creek basin sources of sediment estimated by the CSWRCB (2001). Road sources had the highest sediment yield in combination. Estimated sediment yield is shown as tons of sediment yielded per square mile per year. Chart from KRIS Gualala.
Figure 5. This chart from KRIS Gualala shows the density of roads in miles per square mile for Buckeye Creek watershed with a reference line of 2.5 mi/sq. mi which is slightly above NMFS (1996) properly functioning watershed condition level for Pacific salmon. Little Creek has one of the highest road densities in the Gualala River basin. Data from UC Davis ICE and North Coast Regional Water Quality Control Board.
With regard to the THP/TCP’s inference that all sediment sources are old, IFR (2002) advanced the following hypothesis in KRIS Gualala: “Continuing sediment contributions to the Gualala River and its tributaries from recent land use (1985-2001) are preventing recovery of coho salmon and steelhead habitat.” This hypothesis was supported by several lines of evidence: small median particle size distribution (Dietrich et al., 1989; Knopp, 1993), increasing fine sediment in size classes with potential to prevent successful salmonid spawning (McHenry et al., 1994) and decreased pool volume, frequency and depth (Knopp, 1993; Entrex, 1994; CDFG, 2001). It was also evaluated and validated by the U.C. Berkeley appointed peer review panel funded by CDF’s Fire and Resource Assessment Program (FRAP) in Sacramento (Standiford, 2003).
Sediment Impacts on Aquatic Ecosystems Evident in Buckeye Creek and Gualala River Basin
There has been a substantial amount of data collected in the Gualala River basin that can be used to judge the health of streams (CA RA, 2001; Knopp, 1993), much of which has been captured in KRIS Gualala. Results of various surveys and their significance are described below.
Mean Particle Size (D50): The median size of stream bed gravels (D50) can be used to characterize stream health (Knopp, 1993). Small median particle size may lead to bed load instability, which may cause mortality salmon or steelhead eggs when bed load transport occurs during their gestation (Nawa and Frissell, 1990). Dietrich et al. (1989) point out that small particles on stream beds are extremely mobile and, if the median particle size distribution of substrate is small, then it is likely that active erosion in the watershed recently contributed sediment. Knopp (1993) studied 60 streams in northwestern California and found that watersheds with a history of high intensity timber harvest management had a D50 of below 37 mm in diameter. Data from KRIS Gualala show that most sites measured in the western Gualala River basin were below the 37 mm threshold indicating high impairment likely related to recent, active timber harvest and road building (Figure 6). The reference lines shown on Figure 6 show undisturbed or recovered values for D50 from Knopp (1993), which range from 52 mm to 88 mm.
Fine Sediment in Spawning Gravels: Small sediment particles less than 0.85 mm are known to infiltrate salmon and steelhead nests, which are excavated in the stream bed gravels, and greatly decreasing survival due to smothering of the eggs (McNeil and Ahnell, 1964). Gualala Redwoods Inc. collected fine sediment data in the North Fork Gualala from 1992 to 1997. The North Fork Gualala River watershed was undergoing rapid timber harvest and a substantial increase in its road network (see CWE discussions below). Gravel grab samples showed a sharp increase in fine sediment less than 0.85 mm (Figure 7), from 10-12% of the stream bed to as high as 28%. McHenry et al. (1994) found that, when fine sediment (<0.85 mm) comprised 13% or greater of the substrate inside redds, it caused the mortality of steelhead and coho salmon eggs. The Gualala River TMDL (CSWRCB, 2001) set 14% as a target for fine sediment in accordance with this knowledge of potential harm to salmonid spawning. Extensive logging, road building and conversions have taken place in the lower Buckeye Creek basin (see CWE discussions below), but no fine sediment data have been collected. Photos from the NCRWQCB staff (Figure 8), however, show that some adjacent tributaries like Franchini Creek are choked with fine sediment. This not only shows that sediment is of recent origin, but also illustrates CWE in this nearby basin not acknowledged by Jacobszoon (2004).
Figure 6. Median particle size distribution of stream gravels from KRIS Gualala show that almost all sites measured within the Buckeye Creek watershed were at levels indicating sediment impairment (Knopp, 1993). Data from Gualala Redwoods, Inc.
Figure 7. Fine sediment less than 0.85 mm exceeded levels recognized to be harmful to salmonid egg survival and the TMDL recognized threshold of 14% in Doty and Dry creeks, McGann Gulch and the Little North Fork Gualala River, with mostly increasing trends during the period of record. Data from Gualala Redwoods Inc.
Figure 8. Franchini Creek, tributary to lower Buckeye Creek and NCRWQCB staff during 2001 survey indicating major sediment problems and recent, active contributions. This is not viable salmonid spawning or rearing habitat. Photo by Brian McFadin.
Volume of Sediment in Pools (V-Star): Knopp (1993) found that northern California streams draining watersheds with high timber harvest management had higher levels of sediment in pools. He used a method of measuring pool volume relative to sediment known as the V-star method (Hilton and Lisle, 1992). Values measured are roughly equivalent to the percent of the pool volume filled by sediment. Figure 9 shows V-star values for six pools measured in Grasshopper Creek, the tributary to the east of Little Creek that had a V-star score of 0.59. This indicates a high degree of impairment from sediment and is far above the TMDL target set for the Gualala River basin of less than 0.21 (CSWRB, 2001). Again Jacobszoon (2004) failed to note sediment impairment and to meet the standard for use of best available science under CEQA.
Pool Frequency and Depth: The California Department of Fish and Game (1998) describes a method of stream habitat inventory known as habitat typing. Pool frequency by length and depth from these surveys can be used as an index of habitat suitability for salmonids. Optimal quality salmonid streams have 50% or more of their length in pool habitat (CDFG, 1998). Survey results from the Gualala River basin collected by CDFG in 2001 (CA RA, 2002) indicate many tributaries of the Gualala River have less than 20% pool frequency by length (Figure 10), which indicates major problems with sediment filling pools (Reeves et al., 1993). The high amount of dry channel is indicative of severe aggradation where surface flows are lost because the stream bed is buried so deeply. THP 1-04-059/TCP 04-531 acknowledges that “coho salmon habitat within the assessment area is marginal due to the small number of deep pools,” but fails to link this to any proposed action or long term plan for the recovery of habitat for this species and steelhead.
Figure 9. V-star values in Grasshopper Creek as collected by Knopp (1993) indicating major sediment problems likely related to logging in this Buckeye Creek tributary adjacent to Little Creek. Reference of 0.21 V* is from CSWRCB (2001). Chart from KRIS Gualala.
Figure 10. This chart from KRIS Gualala shows habitat frequency by length from 2001 CDFG habitat typing surveys of over 100 miles of Gualala River reaches or tributaries.
Although the pool frequency of for Buckeye appears as if the stream might be in moderate health, pool depth is lacking. Brown et al. (1994) recognize pools greater than three feet in depth as optimal rearing habitat for coho salmon. Larger, older age steelhead also prefer deeper pools (Reeves, 1988), which provide better cover from predators. Gualala River tributaries measured by CDFG (CA RA, 2002) show that more than 80% of pools in Buckeye Creek are less than 3 feet deep (Figure 12). This finding is very surprising because the stream is a fourth order stream (Strahler, 1957) and has a large watershed and discharge. It is likely that Buckeye Creek would scour deep pools if there were not an over-supply of sediment from tributaries, such as Grasshopper and Franchini creeks. The survey on Buckeye Creek by CDFG in 2001 is the reach beginning at Little Creek and extending down to the lower South Fork Gualala River (Figure 11). This is within the Little Creek Calwater Planning Watershed yet Jacobszoon (2004) fails to make reference to either these data or their significance. Buckeye Creek cannot take more sediment at this time and remain viable steelhead habitat and sediment should be reduced to ultimately allow recovery of coho salmon.
The lack of proper characterization of existing sediment problems in Buckeye Creek and its tributaries make THP 1-04-059/TCP 04-531 insufficient in terms of proper CWE analysis. Figure 11 also shows the acute problems with sediment and CWE as reflected by lack of deep pools in adjacent Rockpile Creek and in the South Fork and Wheatfield Fork of the Gualala River. The lack of pools is clear evidence major problems with sedimentation of streams and no further land use contributing sediment should be allowed in the Gualala River basin until pool frequency and depth have recovered to those suitable for salmonids.
Timber Harvest and Cumulative Watershed Effects
Timber harvest rates in Gualala River Calwater Planning Watersheds between 1991 and 2001 show that some sub-basins have been harvested at rates as high as 78% (Figure 12). Reeves et al. (1993) pointed out that logging in over 25 % of a watershed’s area in less than 30 years compromised aquatic habitat diversity and cause loss of diversity of Pacific salmon species. CDFG (CA RA, 2001) habitat typing data showed that pool frequency by length was low in recently harvested basins, a result similar to that described by Reeves et al. (1993). All Buckeye Creek Calwater Planning Watersheds are over this prudent level of disturbance of 25% timber harvest in just ten years of records provided by CDF and harvest was active in the 1980’s. Therefore, cumulative watershed effects from this land use were underestimated by CA RA (2001). The location of permitted timber harvests are displayed in Figure 13, which also shows the number of road-stream crossings. Armantrout et al. (2001) note that road stream crossings should be limited to one per mile to reduce risk of sediment yield. There appear to be five crossings in approximately three miles of stream on Little Creek, which indicates it is over this CWE threshold as well.
Figure 10. The habitat typing results from over 100 miles of CDFG surveys in 2001 show that pools deeper than three feet are rare on smaller tributaries and even on some mainstem Gualala River reaches like the South Fork. Chart from KRIS Gualala.
Figure 11. This map image shows pool depth in lower Buckeye Creek, lower Rockpile Creek and part of the lower Wheatfield and SF Gualala River according to CDFG (2001) data. Note that the majority of pools in Buckeye Creek are 2 feet deep or less.
Figure 12. The timber harvest in all Gualala River Calwater Planning Watersheds from 1991-2001 is shown above as percentage of watershed area. Half of the basins are more than 25% cut in just over ten years, including all Buckeye Creek Calwaters (Little, Grasshopper, Harpo and Flat Ridge) except NF Osser Creek. Data from CDF, Santa Rosa.
Figure 13. This map image comes from the KRIS Gualala ArcView project and shows THP’s approved by CDF from 1991-2001, including harvest type. Road-stream crossings are shown as pink dots with five shown on Little Creek in a reach less than three miles long.
Another troubling aspect of the THP 1-04-059/TCP 04-531 application is its failure to acknowledge major removal of timber in the Little Creek watershed proper that does not appear as part of CDF THP records (Figure 14). Gualala River residents concerned about land use activities in the Little Creek watershed and the Annapolis vicinity provided aerial photo documentation of un-permitted harvests in the area affected by the THP 1-04-030SON, Hanson/Whistler Timberland Conversion Permit (TCP) #530. These impacts are not noted by Jacobszoon (2004) nor by the CDF Negative Declaration, yet they appear large enough to contribute significantly to problems similar to those that would be generated by THP 1-04-059/TCP 04-531. Kauffman et al. (1999) point out that riparian areas and watersheds can only recover when anthropogenic stressors are ameliorated. This conversion and timber harvest is particularly ill-timed because of the already widespread nature of watershed disturbance from timber harvest and roads at this time.
THP 1-04-059/TCP 04-531 states that “Adherence to plan elements should result in similar erosion potential for both pre and post-construction conditions.” Collison et al. (2003) note that all timber harvest and road building have significant sediment impacts even under current California FPR’s. Dunne et al. (2001) point out that in fact widespread disturbance, as documented here for the Buckeye Creek, Little Creek and Gualala River watersheds, have major impacts that this THP/TCP and CDF’s Negative Declaration do not acknowledge:
“Generally speaking, the larger the proportion of the land surface that is disturbed at any time, and the larger the proportion of the land that is sensitive to severe disturbance, the larger is the downstream impact. These land-surface and channel changes can: increase runoff, degrade water quality, and alter channel and riparian conditions to make them less favorable for a large number of species that are valued by society. The impacts are typically most severe along channels immediately downstream of land surface disturbances and at the junctions of tributaries, where the effects of disturbances on many upstream sites can interact.”
In the Fisheries section above, it was pointed out that 1-04-059/TCP 04-531 does not deal sufficiently with endangered and threatened Pacific salmon and Dunne et al. (2001) point out that at risk populations can be lost, if cumulative effects are ignored and anthropogenic stressors continued:
“Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time. They may occur at a site through repetition of a change caused by successive operations, or through two or more results of an operation, or they may occur at a site remote from the original land transformation and with some time lag. The concern about cumulative effects arises because it is increasingly acknowledged that, when reviewed on one parcel of terrain at a time, land use may appear to have little impact on plant and animal resources. But a multitude of independently reviewed land transformations may have a combined effect, which stresses and eventually destroys a biological population in the long run.”
Dunne et al. (2001) also point out that CWE must be managed by minimizing risk: “Inevitably, the institutional aspects involve decisions about how much environmental and other risks are acceptable in a project. Before the institutional evaluation can be made, however, the risks of CWEs need to be identified in some transparent manner.” The lack of provision of sufficient information on which to judge impacts of 1-04-059/TCP 04-531 fails the test of transparency. CDF should be rejecting this project because the high existing impacts and additional threats posed by previously permitted or completed projects, or at least calling for a full Environmental Impact Statement (EIS).
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Figure 14a. Area of THP 1-04-030SON/TCP #530 in 1990 showing almost complete cover, but high road and skid trail densities. |
Figure 14b. This photo shows the same area as Figure 14a in 1996 with major changes in vegetation, but no THPs filed. |
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Figure 14c (At left): The 2002 aerial photo shows major new openings and substantial thinning of forests, again with no record from CDF for timber harvests on file. This type of large scale vegetation removal is a clear cut equivalent in places and likely already contributing to changes in runoff patterns (Jones and Grant, 1996), even without further conversion to vineyards. |
Flow Issues
The hydrologic review of THP 1-04-059/TCP 04-531 is not complete or credible. It makes a number of unfounded assertions and provides no flow measurement data from Little Creek for assessing impacts of the project or judging their importance in supporting fish life. The THP/TCP notes that coho salmon are absent in the project WAA, that habitat for them is judged as marginal due to “inconsistent flow levels”, yet makes no attempt to relate that information back to the plans. Jacobszoon (2004) makes many misstatements related to flows:
· “Surface flow will occur during winter months and is unavailable during low flow summer conditions with or without project implementation.”
· “There is no scientifically valid way to directly correlate well water levels or yield in any area with local rainfall patterns or with surface runoff patterns.”
· “The hydraulic impacts of any well are limited to a cylindrical zone of tens to a few hundred feet in proximity to the bore hole…”
A report by Kamman Hydrology and Engineering (2003), which was written in response to a similar Gualala River THP/TCP, reflects a more scientific approach to the question of the affect on flow of vineyard development in headwater swales. Jacobszoon’s (2004) characterization of ground water infiltration as being unimportant in groundwater recharge has no scientific support (CDWR, 2003). Associations between rainfall, runoff and infiltration can be calculated, but such studies have not been carried out in the Gualala River basin. Again the assertion by Jacobszoon (2004) that the potential zone of influence for the wells proposed being limited to tens or hundreds of feet has no support (CDWR, 2003). Jacobszoon (2004) states erroneously that watershed size dictates base flow and implies that water withdrawal from a well could not decrease the surface flows because of lack of a groundwater connection, yet provides no data to support this contention.
Kamman Hydrology and Engineering (2003) note the importance of infiltration in wild land hydrology and ground water recharge. Head water springs may be an important source of water during low flows of summer. Jacobszoon (2004) notes that “a backhoe/excavator shall be used to construct a diversion from a spring to an adjacent Class III watercourse.” Activities around headwater springs with heavy equipment are likely to disrupt groundwater recharge and natural connections between spring areas and streams below. Cold water base flows in summer are critical to the maintenance of steelhead trout and their further disruption will make the eventual recovery of coho salmon less likely. CDF does not have the experience or expertise in this area to properly evaluate changes in flow related to vineyard development. Changes in hydrology and flow diversions or reductions, such as those likely to occur under THP 1-04-059/TCP 04-531, should require a full scale EIS under CEQA.
Leopold and McBain (1995) also pointed out that wide spread compaction related to timber harvest in the Garcia River basin elevated winter runoff. This finding is similar to Jones and Grant (1996) who estimated that, when 25% of the area of a basin were impacted by timber harvest and roads, flow increases of 50% resulted. They note that increased peak flows can scour riparian areas, potentially elevating water temperatures. The increase in peak flows likely associated with road construction are noted above. IFR (2002) advanced a hypothesis that coho salmon and steelhead recovery are limited by summer low flows in the Gualala River basin. Both Jacobszoon (2004) and CDF in their Negatively Declaration fail to note that extensive reaches of the Gualala River currently lack surface flow because of severe aggradation, yet many of these reaches once supported standing crops of older age steelhead. No further diversions in the Gualala River basin should be allowed until sediment has been flushed from the system and surface flows restored in formerly productive reaches and tributaries.
Conclusion
Despite CDF having spent hundreds of thousands of dollars in public money to build tools for watershed analysis in the Gualala River basin (IFR, 2003), these data seem to be ignored by CDF regional staff when reviewing land use plans, such as Timber Harvest Plan 1-04-059 SON and the Martin Timberland Conversion Permit 04-531. I am enclosing a copy of the KRIS Gualala database and companion ArcView electronic map project, although much of this information is also available over the Internet at www.krisweb.com. CEQA calls for use of the best available scientific information in planning processes and the CDF Negative Declaration for these plans certainly does not meet that criteria because it ignores a great deal that exists.
The extremely poor health of the Gualala River watershed and Buckeye Creek sub-basin are ignored by Jacobszoon (2004) and CDF. The Gualala River is losing its ability to support coho salmon and steelhead trout. Sediment over-supply is evident in the mainstem of Buckeye Creek and its tributaries in the vicinity of the plan. No data are supplied for Little Creek itself with regard to its current condition.
Rieman et al. (1993) characterize a salmonid population as at moderate risk of extinction when:
"Fine sediments, stream temperatures, or the availability of suitable habitats have been altered and will not recover to pre-disturbance conditions within one generation (5 years). Survival or growth rates have been reduced from those in undisturbed habitats. The population is reduced in size but no long-term trend in abundance exists."
The conditions described above fairly characterize the Gualala River and its steelhead population, while the coho population would merit a high risk classification (CDFG, 2002). This level of risk is nowhere acknowledged in the THP/TCP and discussions do not even include data from the effected tributary Little Creek, which may be a key cold water refuge for steelhead juveniles.
This project is likely to decrease ground water recharge and thus reduce base flows in summer needed by salmonids. The reduced cold water flow will also increase problems with elevated water temperature. Increased sediment from the site will also contribute to stream warming as it reduces the width to depth ratio of Little Creek and Buckeye Creek below and increases opportunities for heat exchange with the atmosphere. Impacts from these projects, coupled with existing high levels of disturbance and existing problems with aquatic health, are likely to have dire consequences for the prospect of salmonid recovery in the Gualala River basin.
Additional timber harvests in the Gualala River basin, and especially vineyard conversions, should not go forward until water temperature and sediment transport have returned to unimpaired levels and salmonid productivity has been restored. This timber harvest and conversion, in combination with others already permitted, are highly likely to negatively impact recovery prospects for coho salmon and steelhead in the basin and will help continue the trend toward increased sediment, increased water temperatures and decreased surface flows. Ultimately the entire aquatic community of the Gualala is at risk from such activities, including non-listed species like the Sacramento sucker (Higgins, 2003b), as more of the river will lose surface flow. The Negative Declaration should be withdrawn and a full EIS required.
Sincerely,
Patrick Higgins
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