Mattole Forests: Certification of Humboldt Redwood Company
July 19, 2014
Forest Stewardship Council Attention: Liz Forwand LForwand@scsglobalservices.com
MICHAEL EVENSON Lost Coast Ranch OldGrowthTimbers.com
RE: FSC Certification of Humboldt Redwood Company, Mattole forests
These comments are being made by myself. I began working in the woods as a timber faller in the late 1960s cutting selective harvests in Jackson State Forest. By the time I moved to Humboldt in 1969, it had become obvious that our salmon runs were rapidly declining. I thought long and hard about this problem and came to the uncomfortable conclusion that we had overcut our forests and damaged the landscape in a way that affected the salmon. By 1980, I became involved in the work of restoring our streams, using much of the skills I gained from working in the woods. It was a natural step, an essential step, if we were to get our salmon back. I co-founded the Eel River Salmon Restoration Group with Scott Downie and Bill Eastwood, and have been on the Board of Directors of the Mattole Salmon Group since 1987, currently serving as its President. I also have contracted out in forest restoration projects, planting trees and thinning young stands to increase growth and productivity, and I am author and logger of the first Institute of Sustainable Forestry Smartwood certified Sustainable Yield Plan approved by CalFire in northern California. In those days one was considered a Resource Professional unless you bothered to get an RPF’s license.
My experience in the forest was also engaged by the USFS and federal land managers, beginning in 1994, as a charter member of the California Coast Provincial (Federal) Advisory Committee and the Klamath PAC as well, in order to implement the President’s Forest Plan. Members of those committees represented all stakeholders in our region, from logging contractors to environmentalists, in addition to federal wildlife agencies, state wildlife agencies, all branches of federal land managers and elected government officials.
The comments I am submitting are based on long experience working in the woods, personal observation from over 50 years - admittedly, just a moment in a forest’s evolution - of what happens when different practices are implemented.I am pleased that HRC does not practice clearcutting. That is certainly a step in the right direction for a modern forest operation. It may take two centuries for our forests to fully recover from the brief era of clearcutting after WWII. And I am pleased that HRC engages with the public in a meaningful way. This certification process allows for a formal conversation on their practices. There are serious concerns with HRC’s plans that can be addressed under the criteria for FSC sustainable certification (below).
The certification process of HRC needs to treat the Mattole separately from the other, more redwood- dominated portions of the ownership. It is known as the Mattole Exception. The Mattole portion of HRC’s forests are unique on the ownership. Any certification criteria for practices in the redwood region do not necessarily apply here. For one, there is no redwood. That is, the forest differs greatly. But more importantly, the underlying geology is more unstable, the slopes steeper, the soils unconsolidated. The potential for mass wasting is extreme.
Past harvests in the Mattole generally removed large swaths of intact forest, mostly by clearcut. The resulting soil movement and sediment generation have degraded aquatic habitats far downstream of the ownership. These effects are still with us even in the case of harvests from the 1980s. While most northcoast watersheds show a high degree of recovery, the North Forks of the Mattole show little recovery. One has to ask why these basins have not recovered.
An inescapable answer is that they are now destabilized to such an extent that what native forest remains cannot be recruited fast enough to stem the movement of sediments. Further, a closer analysis of the native landscape reveals that this is a fire determined landscape. Periodic and intense wildfires have maintained open prairies. The mixed conifer hardwood forests developed around the fire-surviving hardwoods, which maintained stable forest habitat and structure when the more volatile conifers were torched out. The hardwoods enabled large, old conifers to grow in pockets in the hardwoods. They were protected from wildfires by large, old hardwoods which kept the topsoil in moisture longer in the summer and forced young conifers to grow into the canopy rapidly and shed lower limbs, thus reducing the ladder of fuels found in other young conifer stands.
C4.4 Management planning and operations shall incorporate the results of evaluations of social impact. Consultations shall be maintained with people and groups (both men and women) directly affected by management operations.
Indicator 4.4.a The forest owner or manager understands the likely social impacts of management activities, and incorporates this understanding into management planning and operations. Social impacts include effects on:
• Archeological sites and sites of cultural, historical and community significance (on and off the FMU;
• Public resources, including air, water and food (hunting, fishing, collecting);
• Aesthetics;
• Community goals for forest and natural resource use and protection such as employment, subsistence,
recreation and health;
• Community economic opportunities
• Other people who may be affected by management operations
Indicator 4.4.b The forest owner or manager seeks and considers input in management planning from people who would likely be affected by management activities.
Indicator 4.4.c People who are subject to direct adverse effects of management operations are apprised of relevant activities in advance of the action so that they may express concern.
While HRC has certainly been active consulting with community members about their planned activities, some representatives of the community have not been able to secure for the community strict adherence to the criteria set forth in the Principles. HRC has incorporated some of the community concerns put forth by the Mattole Restoration Council, but the Council does not speak for downstream residents. The Council is a dues paying membership-driven organization with community goals as its purpose. Those who do not belong are not necessarily represented by them, nor does everyone agree with the results of “compromises” gained from the Council’s efforts in talks with HRC.
PRINCIPLE # 5: BENEFITS FROM THE FOREST - Forest management operations shall encourage the efficient use of the forest’s multiple products and services to ensure economic viability and a wide range of environmental and social benefits.
C5.5 Forest management operations shall recognize, maintain, and, where appropriate, enhance the value of forest services and resources such as watersheds and fisheries.
Indicator 5.5.a In developing activities on the FMU, the forest owner or manager identifies and defines appropriate measures for maintaining and/or enhancing forest services and resources that serve public values, including municipal watersheds, fisheries, carbon storage and sequestration, recreation and tourism.
In the Mattole, the social benefits of HRC harvests do not trickle down. We live downstream of the activities, receive all the impacts to our river which we have spent over 3 decades trying to restore to aquatic function for salmon. The jobs are exported out of the Mattole to the Eel. The primary environmental and social benefits at risk under HRC’s plan are salmon and water.
Salmon
Salmon have been vital to the Mattole community for 10,000 years. It is only recent times where salmon numbers have been diminished to the point that there is no take for the community. The community wants them back to where we can take salmon. HRC’s plans do not move in that direction. They are committed to no further degradation, but that is not the same as being committed to restoring the salmon to the community. Maintaining the current state of degradation is not providing anything positive for the community and actually puts recovery of the salmon off for more years than if they did nothing.
The Pacific Lumber Company maximized their take of the Mattole forestlands. There was a good deal of contention from 1986 to 2004 and when the dust settled, PL took all of what they could get. Now we find a new landowner purchasing these depleted lands and wanting to take more after a brief interlude of no harvest. How is a community that pushed its public agencies hard, and with considerable cost of time and effort to enforce existing law, to react? It feels that public trust resources are being put at risk. Once again, we are compelled to make room in our busy, productive lives to engage in a public process to preserve our valued public trust resources. HRC promises to limit the cutting of older trees and stands, but these promises are not made in writing or include a duration of the commitment. In contract terms, there is no assurance that HRC will respect their promises. How is the public to react to promises that are not made in writing or with a time secured duration? All the stakeholder meetings and field tours do not provide that assurance.
On a personal note, as President of the Board of the Mattole Salmon Group, I have held discussions with HRC’s Mike Miles beginning in 2011 about the potential for salmon restoration work in McGinnis Creek. I certainly look forward to restoring that important stream with its low gradient coho-potential bottom reaches. Unfortunately, no action plan has come out of those discussions. They have been just talk. Recently, I have been invited to attend meetings and field tours in the North Forks, but owing to a heavy work schedule, I had to decline. Now that the certification audit is upon us, I reluctantly have to make time to express the concerns of my community.
One major concern that does not seem to be understood by HRC is the use of poison on the landscape. HRC plans to poison the hardwoods in order to grow more conifers. There is evidence that young conifers grow productively throughout the basin. But conifers are a ready target for devastating wildfire. Plantations in the local national forests are routinely set back to zero by wildfire, and each succeeding generation has less topsoil on which to draw for nutrients.
Removing the hardwoods, especially the older hardwoods, is not a sustainable practice. Maintaining the diversity of the North Forks is the only path to sustainability. That means maintaining prairie and mixed stands, as well as pockets of pure conifer stands. That diversity protects the watershed from natural disturbances, such as fire and high rainfall storm events. We are experiencing drought conditions and will likely continue to experience lower rainfall owing to climate change. Elsewhere, this has meant more numerous and more extreme wildfires. Increasing the hardwood component may be the best strategy for protecting the conifers in the future. I fail to see how increasing the conifer component makes sense on steep south-facing slopes which are dry throughout the summer. A wildfire ravaged landscape will not provide the cover and ecological function necessary to promoting water retention and late summer water release to our streams.
Water!
The aquatic habitats of the tributaries of the North Forks are seriously impaired in regard to temperature and sediment (EPA 303d listed as impaired). Lack of forest cover, especially in stream course zones, is a major factor. Removing trees, especially large trees, from these zones (which generally reach all the way up to the ridges in such steep terrain) will have an incremental impact on stream temperatures.
Water quantity is also a factor in high stream temperatures. The more water that flows, the lower the water temperature will be as it takes on heat from the surrounding air. Studies elsewhere in the Mattole (http://www.fs.fed.us/psw/publications/documents/psw_gtr238/psw_gtr238_183.pdf) have shown that young forests require more water than old, established or un-entered forestland. For fifty years, young forests draw enough water from the basin to diminish streamflow on fish bearing streams. Removing or disrupting old trees and/or replacing them with young, vigorous conifers is a recipe for diminishing stream flow for several decades. Today we are in a drought. Any loss of streamflow puts the survival of aquatic species at risk of extirpation. But to extend that risk for 50 years is certainly not a practice that one would certify as sustainable. Sustainable practices, by definition, reduce the risks to the natural environment, and especially as projected over a long time period.
In short, HRC fails to uphold Principle 5, and especially C5.5
PRINCIPLE 6: ENVIRONMENTAL IMPACT
Forest management shall conserve biological diversity and its associated values, water resources, soils, and unique and fragile ecosystems and landscapes, and, by so doing, maintain the ecological functions and the integrity of the forest.
Indicator 6.1.c Using the findings of the impact assessment (Indicator 6.1.b), management approaches and field prescriptions are developed and implemented that: 1) avoid or minimize negative short-term and long-term impacts; and, 2) maintain and/or enhance the long-term ecological viability of the forest.
Forest regeneration and succession.
Genetic, species, and ecosystem diversity.
Natural cycles that affect the productivity of the forest ecosystem.
Indicator 6.3.a.3 When they are present, management maintains the area, structure, composition, and processes of all Type 1 and Type 2 old growth. Type 1 and 2 old growth are also protected and buffered as necessary with conservation zones, unless an alternative plan is developed that provides greater overall protection of old growth values.
Type 1 Old Growth is protected from harvesting and road construction. Type 1 old growth is also protected from other timber management activities, except as needed to maintain the ecological values associated with the stand, including old growth attributes (e.g., remove exotic species, conduct controlled burning, and thinning from below in dry forest types when and where restoration is appropriate).
Type 2 Old Growth is protected from harvesting to the extent necessary to maintain the area, structures, and functions of the stand. Timber harvest in Type 2 old growth must maintain old growth structures, functions, and components including individual trees that function as refugia (see Indicator 6.3.g).
Indicator 6.3.c Management maintains, enhances and/or restores the plant and wildlife habitat of Riparian Management Zones (RMZs) to provide:
habitat for aquatic species that breed in surrounding uplands;
habitat for predominantly terrestrial species that breed in adjacent aquatic habitats; habitat for species that use riparian areas for feeding, cover, and travel;
habitat for plant species associated with riparian areas; and,
stream shading and inputs of wood and leaf litter into the adjacent aquatic ecosystem.
Indicator 6.3.f Management maintains, enhances, or restores habitat components and associated stand structures, in abundance and distribution that could be expected from naturally occurring processes. These components include:
a) large live trees, live trees with decay or declining health, snags, and well-distributed coarse down and dead woody material. Legacy trees where present are not harvested; and
b) vertical and horizontal complexity.
Trees selected for retention are generally representative of the dominant species naturally found on the site.
C6.4 Representative samples of existing ecosystems within the landscape shall be protected in their natural state and recorded on maps, appropriate to the scale and intensity of operations and the uniqueness of the affected resources
C6.3 Ecological functions and values shall be maintained intact, enhanced, or restored, including:
Because the FSC Criteria break up natural resource values into categories that overlap, I would repeat much of what has been written above in relation to meeting Principle 6 categories. The downstream community is extremely conscious of its public trust resources and determined to protect them from industrial destruction. In that way, a violation of Principle 5 standards in the Mattole is also a violation of Principle 6 standards.
Wildlife
The diverse prairie and forestland mix of the North Forks, Mattole, is valuable habitat for several listed species, including golden eagles, northern Goshawk, several species of frogs and salamanders. The fact that there is so little undisturbed, un-entered forestland in this region has meant that these stable habitats are essential. Presently, those habitats are fragmented from previous logging and stand as islands of health.
What HRC proposes is to destabilize these habitats. Were they to confine their activities to already entered stands, there is an argument to be made that they could sustain some level of harvest over the long term, providing the forest had recovered from past harvests. However, to disturb rare un-entered forestland can only result in habitat destruction for which no mitigation habitat exists that is unoccupied. The days of limitless old growth habitat to which species can relocate is gone. What remains in the North Forks of the Mattole is the “Last Stand” for many of these species.
Old Growth
I applaud HRC’s policy of not cutting old growth trees and for setting aside areas for conservation. Unfortunately, they have not executed long term contracts to preserve those areas. That is a major concern for those of us who plan on living and working in the watershed and whose children and grandchildren are already committed to a similar way of life.
By defining old growth as extremely old trees, their policy does not protect late-seral forests or the rich soil, terrestrial and aquatic habitats in which the trees are merely one component. In this day and age, it is evidently clear that there is no sustainability in removing old growth trees. They are irreplaceable. The soils and associated life, both on the ground and in the canopy, take nearly a hundred years to develop and reach an equilibrium despite natural disturbances. Proposed harvests in these stands lay open the soil to drying out, heavy winter rains, skidding and mechanical equipment compaction. For the late-seral stand, “old growth” is over and done with by entry.
Recovery
Key to any definition of sustainability is working within the natural bounds of disturbance and recovery. Natural habitat is always experiencing disturbances from which it recovers. The forest is only as sustainable as its ability to recover from disturbance. The level of harvest that HRC proposes only appears sustainable based on calculations of board feet growing exceeding that amount removed. The forest is never allowed to reach maximum production, as in old growth forests or, in the case of the Mattole, 80-150 year old stands. Instead, it is kept at a level far below its potential. Sustaining the harvest at such a low standing volume means the forest will never reach its true maximum sustainable production of timber, or other environmental products and services.
HRC inherited degraded forest lands from a rapacious “He who has the gold rules” billionaire from Texas. Maxxam’s Pacific Lumber took all that they felt they could from the Mattole forests. Now, less than a decade later, the new owners want to go back into the forests and take more. This is a common story in forestland ownership. It’s what happened in Mendocino County when Masonite finally decided it had taken all it could from the ownership. Louisiana Pacific bought the holding and logged it down even more, then sold out to subsequent owners who continue to deplete the forest. That is the history of forest degradation in the United States. It has nothing to do with sustainability, and everything to do with making profits from the investment. Perhaps it is sustainable in financial terms. It certainly fails to be sustainable in terms of the forest (which is much more than the total standing board feet).
The Lower North Fork Mattole was a prime coho and Chinook stream. Being just 5 miles from the ocean, it was an essential stream for the coho. Recent Fall rains have been adequate to allow adult salmonids to enter the river, but not sufficient or sustained long enough to allow them to access the headwaters spawning grounds. Had the Lower North Fork and McGinnis Creek (another tributary in HRC ownership) been functional habitat, they would have provided extensive spawning habitat during the last few years. But, alas, these streams have yet to recover from the past 60 years of logging. Their gravels are impacted, the floodplains are dewatered, and they still move great quantities of sediment with every high flow. What HRC proposes upslope will not result in hastening the recovery of these streams. The opposite will likely occur – continual disturbance upslope and all the other impacts discussed above. Sustainable salmonid use will be pushed further and further into the future.
One has to ask the questions: Have the salmonids recovered from post WWII logging? Has the forest recovered to the level of productivity that it sustained prior to WWII? The answer to both questions is a sad, “No.”
What does sustainability mean?
If timber production is to be termed “sustainable,” it should reference the level of productivity that the forest maintained prior to entry for logging. Those older forests maintained sustainably. The proof is that they were present before any logging occurred. To sustain that level of growth, one needs to understand more events and components of that old forest than growth of standing timber: snag creation (and associated wildlife habitat) upon death, recruitment of large older trees for streamside stability and sediment metering in mass wasting zones. That is, the amount of timber available for removal (harvest) cannot inhibit the ability of the standing forest to produce other products with the timber biomass. One cannot accept an arbitrary level to sustain that does not allow for the recovery of the salmonids and other rare or endangered species. HRC talks of restoring the watershed, and we applaud that goal, but ultimately they want restoration along with raising the BF inventory of the forest. HRC plans do not consider allowing the natural processes of healing in the basins to occur without disturbance.
Once again, recovery must precede managed disturbance if sustainability is our goal. At present, natural disturbance in such a geologically unstable region with unconsolidated soils has precluded recovery. An example of an HRC’s unsustainable activity is the building of mid-slope roads to access timber and then removing timber. This will impede recovery and likely increase the level of disturbance in the sub-basins of the North Forks.
I freely admit I am not as familiar with the HRC holding in the Mattole as I would need to be in order to offer professional judgment on particular practices and locations. The above comments are based upon an understanding of the natural processes at work on the holdings and a select reading of THP 1-14-034HUM. My interest is the restoration of our forests, our watershed, and communities that depend upon the beneficial uses of all the natural resources and processes that are possible in the Mattole. We seek a sustainable existence here and have been working toward that goal for the past 40 years. Thus far, we are sustaining the effort while timber companies come and go, cutting all that they can and selling their land to another entity that cuts all that it can. This has not been sustainable. The forest has not recovered. The salmon have not recovered. And public trust resources have been sacrificed in the process.
Surely, sustainable forest practices must first begin with the premise of recovering legally protected public trust resources before managing the landscape to provide private benefits. I am confident there are areas for sustainable timber harvests in the Mattole. Yet I know that those harvests might not meet the profit
desires of the landowner. The big question becomes whether sustaining a level of profitability counts for more than sustaining a level of recovery for public trust resources.
HRC has pledged to protect some old forests on the ownership, but, as Dr. Jerry Franklin has said, all cutting of old trees should be “off the table.” The time when it was acceptable to disrupt the native, unentered landscape by harvesting has passed. It became untenable once the amount of unentered forestland dropped to 15% of what was historically present in the watershed. A similar finding was made by the California Department of Fish and Game’s Armand Gonzales in his review of THP 1- 93-537HUM dated November 4, 1994. https://www.dropbox.com/s/ns09p3qwfpursq2/Armand%20Gonzales%20THP%20537.pdf
In his review, Gonzales notes that “with over 95% of the late-seral forest habitat having been harvested, and with the majority of harvesting having occurred over the last 100 years, and with recovery time requirements of 150-200 years needed to begin developing functional late-seral forest habitats, that it is logical to conclude, species dependent or closely associated with late-seral forests have been significantly and detrimentally impacted. This conclusion is further supported by the number of late-seral forest dependent or associated species that have either been listed as threatened or endangered ...”
Since the time of Gonzales’ finding (20 years), more late-seral forests have been removed from the North Forks of the Mattole, leaving even less than threshold levels of complex late-seral forest habitats. According to Franklin, in reference to old forests, “Some of these forests need to be left alone, at least until climate change makes itself felt.” ... “So much of production forestry is about abstracting and grossly simplifying these systems. And that might be satisfactory if all you are interested in is growing wood. But it is completely unsatisfying if you are approaching forests as systems that provide multiple goods and services. The complexity is what makes it possible for that system to provide that broad array. And when you simplify ... [create a managed forest] you lose most of the rest of the system.” ( 30:00 ff https://www.youtube.com/watch?v=deypZtfgvuE&feature=youtu.be; “Old Growth in a New Economy”)
Thus, according to Franklin, the very idea of industrial management inevitably leads to reducing the complexity of these stands, and the reduction of the services those forests provide for human and wildlife communities. When we enter forests that have not been managed, soils are disturbed and compacted, the processes of soil micro-flora and –fauna are disrupted, curtailed or eliminated. Soil fertility declines and does not recover for a century or more– the very definition of non-sustainable. The life in the first foot of topsoil is what sustains life on this planet. Cutting the old, established landscape features, will not lead to sustainability, but continue the closing of the window of the potential for sustainability or, at its best, maintaining a severely degraded level of complexity and forest services.
HRC’s approach is to promise to preserve these old stands, but, as noted before, no promise exists in writing and there is no sense that the preservation will be until old forest stands are more numerous than today. This does not adhere to the “precautionary approach” as required in Principle #9.
PRINCIPLE # 9: MAINTENANCE OF HIGH CONSERVATION VALUE FORESTS - Management activities in high conservation value forests shall maintain or enhance the attributes which define such forests. Decisions regarding high conservation value forests shall always be considered in the context of a precautionary approach.
PRINCIPLE # 10: PLANTATIONS - Plantations shall be planned and managed in accordance with Principles and Criteria 1-9, and Principle 10 and its Criteria. While plantations can provide an array of social and economic benefits, and can contribute to satisfying the world’s needs for forest products, they should complement the management of, reduce pressures on, and promote the restoration and conservation of natural forests.
HRC plans to enter high value conservation natural forests rather than promoting their restoration. There exist plantation stands in the Mattole where HRC’s conscientious form of forest management will yield timber products. However, the base of HRC’s plan for the Mattole holdings are to enter some of those natural forests, or remove elements in those natural forests, or to manipulate those older, natural forests. This does not promote the “restoration and conservation of natural forests.” In their plans, HRC is violating Principle 10. HRC makes the claim that their activities will ultimately result in an increase in natural forestland and lead to an increase in late-seral conditions over the holding. There are studies to back up their claim. However, the precautionary principle would dictate that you don’t impact the natural forest until you have created, through management, replacement natural forests of equal value. HRC is not willing to wait until that time, however.
Increasing the forest component on the landscape may be their goal. It does not constitute a natural forest until it has survived natural disturbances, which appears to take 75-120 undisturbed years.
This is why recovery must be achieved before management disturbance of the natural forestland. It is called for by Principle #10. HRC fails to live up to this standard.
*
In sum, I believe that HRC fails to meet sustainability criteria established by FSC in their Mattole holdings (encompassing the Upper and Lower North Forks as well as McGinnis Creek basins). My hope is that the company will look elsewhere to find timber to sustain their obligations. Their philosophy of management is refreshing and likely to lead to better treatment of the land. However, the Mattole holdings are the most sensitive in the ownership and are not ready for industrial extraction.
Sincerely Yours,
COMMENTS SUBMITTED ON A RECENT THP ON LONG RIDGE, THP 1-14-034HUM
1.
The area of this THP is in remnant forestland, left behind by the disastrous butchery that the previous owner bequeathed to the present landowner. Rogers, Allwardt, East Branch North Fork, Lower North Fork and the main stem Mattole harbor past impacts from the drainages that lie within this plan. Therefore, one simply asks:
How will this plan contribute to the recovery of the hillsides?
How will this plan contribute to the recovery of the aquatic habitat downstream of the operations?
By asking these questions, one must first answer: why there is such a slow recovery from past harvests?
This THP does not attempt to answer these questions, but they are essential questions one must ask in order to assess impacts from past harvest, explain why the landscape has not recovered, and then attempt to determine a cumulative impacts assessment as required by the Forest Practice Act. For it is certain that if a plan does not contribute to the recovery of the watershed and it disturbs the present state of the watershed, then it must be creating additional negative cumulative impacts.
How is that? There is no middle ground. For example, assume one considers a full glass of water as a matter of health. If you start with a glass that is half full and you draw water out and then put water in, you end up with a glass that is half full, but there is still a discernible impact. Prolonging the glass as half full does not meet the needs of maintaining a full glass. Or, in the terms of timber harvest and wildlife, a THP which simply maintains the present state of ecological health is not sufficient under CEQA because the present state of ecological health is poor. Prolonging a poor state of ecological health is detrimental to the recovery of ecological health that would occur if the project were never implemented. In other words, until ecological recovery is achieved, no projects may be considered as neutral in their impact. This is the essence of Dr. Leslie Reid’s work concerning rate of harvest. Attempts were made to address rate of harvest using an unsound Disturbance Index or some such construction.
But before one even considers the disturbance of this proposed harvest, one still has to understand and analyze WHY this terrain has not achieved full ecological functioning. The only answer one can come up with is that these sub watersheds require more time to recover than the landowner is willing to allow before re-entry. Onsite inspections do not reveal the health of the hillsides because we have not experienced extreme rainfall events in quite some time. On that basis alone, the analysis must be found inadequate.
In all the sub watersheds of both the upper and lower North Fork Mattole, many of the scars of past management have not healed. You see it in unstable watercourses still dealing with high sediment loads, whiplash bank failures, and perched soils. Trees may be growing on the slopes, but the watercourses are not functioning as they were prior to harvesting timber. Contemplating activities of extraction of resources will unfailingly contribute to an increase of cumulative impacts.
Why are CalFire and the other State Agencies justified in not requiring an answer to why impacts from past harvests have not resulted in ecological recovery after more than a decade of no activity?
Why have CalFire and the other State Agency reviewers adopted such a short time frame for analyzing the impacts since the 1980s?
How can CalFire justify removing trees that are more than 75 years old after those recognizable impacts from removing timber which are still occurring today?
2.
Removal of timber may result in a brief increase in water delivery from the slopes, but, ultimately it results in a dramatic decrease in summertime flows. Stubblefield et al (see at: http://www.fs.fed.us/psw/publications/documents/psw_gtr238/psw_gtr238_183.pdf - ATTACHED) found:
"A tight relationship was found between sapwood area (cm2 ) and water use (liters/season, y = 7.68x – 638.6, r2 = .86). Strong positive relationships were also found between DBH (cm) and water use (y = 92.40x –1068.4, r2 = .90), and for basal area (cm2 ) and water use (y = 1.261x + 241.57, r2 = .94). The relationship between basal area and water use was much steeper for the youngest trees (y = 3.42x – 233.15. r2 = .76), indicating a steep increase in water use with increasing tree size at the lower end of the size range."
In other words, forests recovering from logging are characterized by young trees which have increased water demand on the water table and result in lower flows in the stream zones for their early years, possibly as long as 40 years.
THP 034 provides for removal of both older conifer and hardwood. The units will be revegetated with young Douglas-fir. In 30 years time, these young trees will have an enormous appetite for the scarce water resources available. As in the upper Mattole which was logged in the 60s, these young stands will dry up streams that are running now. Worse, these are streams that are still showing the impacts of past management and not flowing as they were before the 1980s initial entry.
How is this THP going to affect summertime flows in 30 years? 40 years? 50 years? 60 years? 70 years?
Why is that analysis not part of the cumulative impacts assessment?
As always, the cumulative impact of breaking into the various stands in THP 034 and removing dominant trees will be to diminish the water retention of the slope during summer, owing to increased evapo-transpiration from the remaining trees now exposed to the summer heat. That, in turn, will impact water temperatures in Rogers, Allwart, the East Branch and the North Fork, as well as the main stem Mattole. Higher water temperatures will decrease the beneficial uses of the water by aquatic species, including listed anadromous fish, as well as the bald eagles, other birds and even marine mammals.
The increase of temperature is a serious impact. The Mattole is 303d listed as impaired as to temperature. Much of the North Fork forest does not have a closed canopy at
present. Exacerbating that deficiency would violate water quality standards for a 303d listed water body.
Even if (and it is an “if”) there were to be no sediment discharge from these harvests, the impact to water quality would not be acceptable.
Why is it acceptable for CalFire to accept a Cumulative Impacts Assessment which does not consider the impacts to water quantity and quality decades hence?
What is the project proponent and CalFire’s response to the long range decrease of stream flow resulting from the harvest of this plan?
3.
Nowhere in the plan is discussed what actions the project proponent will take if there is a slope failure in the following decade in the THP area. There is no assuming of long range responsibility to mass wasting, sediment generation, loss of water and aquatic habitat functioning or any other “unforeseen” impacts from the proposed harvest. Since many of these possible impacts will affect the watershed in the plan area as well as downslope and downstream, one would expect the landowner to assume this responsibility.
Why does CalFire not require the landowner to post a suitable bond to restore any natural landscape functions impacted from this plan over the next two decades? This is not a theoretical question since all previous harvests in the plan area have resulted in long term damage to the watershed and very little has been done to restore function.
Please respond in writing to the questions posed in this letter. I am very concerned with the impact of this plan, as I am a downstream landowner who enjoys the beneficial uses of water and expects these beneficial uses to be protected by State Agencies mandated to protect them.
Very Sincerely Yours, Michael Evenson
PO Box 157 Petrolia, CA 95558
Attached:
Summer Water Use by Mixed Age and Young Forest Stands, Mattole River, Northern California, USA
Stubblefield et al,. http://www.fs.fed.us/psw/publications/documents/psw_gtr238/psw_gtr238_183.pdf <psw_gtr238_183.pdf>
