Allen Robertson, Deputy Chief
California Department of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244-2460
Re: Negative Declaration for THP 1-04-030SON, Hanson/Whistler Timberland Conversion Permit (TCP) #530
Dear Mr. Robertson,
I am writing in regards to Timberland Conversion Permit #530 (Hanson/Whistler) and Timber harvest Plan (THP) 1-04-030SON at the request of, and on retainer to local citizens, who are concerned about the deterioration of the Gualala River watershed. This conversion and harvest are in the Little Creek watershed, a lower tributary to Buckeye Creek. These comments bear substantial similarity to those which I filed on May 20, 2003 with your office on Timberland Conversion Application 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) and in December 2003 on Timberland Conversion Application 524 and Timber Harvest Plan (THP) 1-01-223 SON (Higgins, 2003b) in the upper South Fork Gualala River basin. Please review the first of those correspondences for my qualifications to comment in this regard.
The California Department of Forestry continues to blatantly disregard any prudent, risk based management of cumulative watershed effects as recommended by Ligon et al. (1999) and Dunne et al, 2001). It also ignores a preponderance of evidence that the Gualala River is an extremely degraded water body (CSWRCB, 2001) and fails to recognize the recent National Marine Fisheries Service (2001) and California Department of Fish and Game (2002) coho status reviews. The latter points out that coho are “extirpated or nearly so” in the Gualala River basin. There are numerous false statements in THP 1-04-030SON/ TCP #530 regarding watershed condition and cumulative effects. A major problem with analysis of potential cumulative effects of this project, and ones adjacent, is that the vegetation of the area has been dramatically altered, yet there are no recorded timber harvest permit applications (see below). Once again, the analysis of impacts is fundamentally flawed because it does not focus on the scale of Buckeye Creek and the Gualala watershed as a whole. Consequently, a Negative Declaration is wholly inappropriate for THP 1-04-030SON/TCP #530 and complex unanswered questions, such as its potential impact to flows, water temperatures and fisheries, should necessitate a full Environmental Impact Statement under the California Environmental Quality Act.
Fisheries
The environmental review documents submitted by the consultants for this project ignore the regional and in-basin status of coho salmon (Oncorhynchus kisutch) and steelhead trout (Oncorhynchus mykiss). 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 are at risk of extinction throughout Mendocino and Sonoma County. 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. As indicated in my previous correspondence steelhead in the Gualala River are also greatly diminished.
The acute aggradation of the Gualala River mainstem reaches has shifted the ecology of the river substantially. THP 1-04-030SON/TCP #530 mis-characterizes Buckeye Creek as having healthy conditions for salmonids and as being in recovery from past forest harvest effects. In fact conditions for fisheries are extremely poor in Buckeye Creek and advanced cumulative effects are recognized in tributary channels adjacent to or near Little Creek, such as Franchini Creek and Grasshopper Creek. If corrective actions are not taken with regard to sediment abatement and flow preservation, more of the Gualala River channel can be expected to go dry causing further impacts to the already imperiled fish community. This project will exacerbate both problems.
Temperature
Buckeye Creek is characterized in the report as suitable habitat for salmonids with few lingering cumulative watershed effects (CWE). In fact Buckeye Creeks water temperatures remain substantially over those recognized as suitable for coho salmon (Welsh et al., 2001) and in fact are in the range known to be highly stressful for steelhead (Sullivan et al., 2000). Figure 1 shows the maximum water temperature of Buckeye Creek for several years between 1994 and 2001 and values are all in the range of stressful for steelhead trout and completely unsuitable for coho salmon. 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. Continuing timber harvests and conversions will have the opposite effect. Figure 2 shows that water temperatures are above suitable for coho salmon not just in Buckeye Creek but in all larger tributaries.
Figure 1. This chart shows the maximum water temperature for all automated temperature probes placed in the Buckeye Creek from 1994 to 2001. Data provided by Gualala Redwoods, Inc. and the Gualala River Watershed Council.