Patrick Higgins
Consulting Fisheries Biologist
791 Eighth Street, Suite N
Arcata, CA 95521
(707) 822-9428
phiggins@humboldt1.com
May 20, 2003
Allen Robertson, Deputy Chief
California Department of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244-2460
Re: Timberland Conversion Application 02-506 (105 Acres) and Timber Harvest Plan (THP) 1—01-171 SON
Dear Mr. Robertson,
I am writing in regards to Timberland Conversion Application 02-506 (105 Acres) and Timber Harvest Plan (THP) 1-01-171 SON in Annapolis in the Gualala River basin at the request of, and on retainer to local citizens, who are concerned about the deterioration of the Gualala River watershed. I have read the documentation associated with this Plan both from agencies and consultants. I fined the issuance of a Negative Declaration with regard to environmental effects unjustified because of the potential for irreversible and irretrievable loss of cold water habitat in downstream areas. The analysis of impacts is fundamentally flawed because it does not focus on the scale of the entire Gualala watershed, or even adequately address existing impacts in the Annapolis Calwater Planning Watershed itself. I would encourage the California Department of Forestry (CDF) to reconsidered this permit, and instead call for a full Environmental Impact Statement under the California Environmental Quality Act.
My Qualifications: I am a consulting fisheries biologist with an office in Arcata, California with expertise in Pacific salmon restoration. I have written parts of restoration plans for river basins in California including: 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). I also did a literature search and assessment of the Gualala River (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). Most recently I helped complete the KRIS Gualala database project for CDF. In the course of helping build the project, I have studied all sources of fisheries, water quality and watershed data. I will be drawing on the information from that project for examples below. I also co-authored a paper on northwestern California Pacific salmon status (Higgins et al., 1992).
Status of Fisheries/Temperature: 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. CDFG (2002) noted that coho salmon were "extirpated or nearly extirpated" in the Gualala. Steelhead trout (Oncorhynchus mykiss) have also diminished substantially in distribution and abundance in the Gualala River watershed, with tributaries like the Wheatfield Fork Gualala now supporting roach instead of juvenile steelhead (Figure 1). Ken Spacek noted that this stream supported a summer “trout” fishery in the 1950’s (Higgins, 1997). Extensive reaches of the Gualala River are now underground as a consequence of severe aggradation (Figure 2) as evidenced by the habitat typing surveys conducted
Figure 1. This chart shows that young of the year (0+), yearling (1+) and two year (2+) old steelhead (Steelhd) were not found at one of three Wheatfield Fork locations and only in low numbers at any site. The dominance of Gualala roach in the samples indicates elevated water temperatures.
Figure 2. This map of the lower Wheatfield Fork Gualala shows CDFG habitat typing and, although there are frequent pools, several reaches lacked surface flow (hot pink). This is indicative of major sedimentation problems and advanced cumulative watershed effects on the mainstem Wheatfield Fork near the plan site.
by CDFG as part of the North Coast Watershed Assessment Program (CA RA, 2003). In addition to the loss of coho and diminishment of steelhead, the Gualala River fish community is also losing species such as the Sacramento sucker (Catostomus occidentalis). The absence of suckers in the Gualala River in all recent surveys is likely indicative of a major decline in their population, if not their wholesale disappearance. This fish is somewhat tolerant of sediment and very tolerant of warm water. Consequently, the Gualala River is well outside its normal range of variability with regards to its ability to support its native aquatic community. 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.
Timberland Conversion Application 02-506 (105 Acres) and Timber Harvest Plan (THP) 1—01-171 SON do not have a section on steelhead, which are downstream of the plan; a critical omission. The timber harvest and conversion are likely to have adverse impacts on the species in Patchet Creek below and in Grasshopper Creek, which drains into Buckeye Creek from the northern Plan area. The Wheatfield Fork Gualala River has major water temperature problems (Figure 3) and only cool tributaries such as the Patchet Creek provide potential islands of cool water near their mouths or refugia for juvenile steelhead in their lower reaches. No fish data on this reach was supplied with the Plan. The loss of a cold water refugia would create further risk to the loss of steelhead.
Flow Issues: The Hydrologic Review of the THP by Mr. William Snyder (CDF, 2001) of your Agency ignores the potential interplay of ground water dynamics and surface flow (see Kamman Hydrology and Engineering, 2003). Depressions in headwater areas are likely to have a direct feed to ground water storage. Filling them to create a level surface for growing grapes would, therefore, likely decrease ground water recharge. The tile drains and reservoir will intercept water that might otherwise feed the aquifer and streams below. There are no quantitative data on ground water dynamics.
The interception of flow in the aquifer could lead to loss of summer base flows, which are critical to the survival of steelhead juveniles. Ground water pumping will also likely have an effect on ground water storage and the effect of this activity on downstream areas is unknown. Stored ground water is likely to be fed slowly into the stream, possible through seeps and springs down hill and downstream and maybe even off the property. Ground water is very cool and the diminishment would compound an acute temperature problem in the Wheatfield Fork and potential loss of what may be one of the last refugia for steelhead in the lower part of that basin.
Even if Mr. Snyder’s assumptions in his calculations had been correct, his finding that diminishment of flow of two cubic feet per second (cfs) will have no effect of salmonids is baseless. There are no field data collected in Patchet Creek below the project to show that the loss of two cfs in summer base flows will not harm survival of steelhead juveniles. As pointed out above, only tributaries of the Wheatfield Fork are capable of supporting salmonids at this time, not the mainstem itself. If the base flow of Patchet Creek is four cfs, which is in the likely range, the reduction to two cfs would certainly be significant in terms of reduction of rearing habitat. The cumulative effect of the loss of yet another tributary of cool water to the larger steelhead population in the Gualala basin may also be significant.
Sediment Issues: Headwaters of Grasshopper Creek, a tributary to Buckeye Creek, flow from part of the THC/THP. Knopp (1993) found that pools in Grasshopper Creek were approximately 60% filled with sediment (Figure 4), indicating advanced cumulative effects and sediment impairment. Knopp (1993) found high correlations between watershed disturbance and pool filling. The Gualala TMDL suggests a target of 0.21 for V* or roughly 20% filled with sediment.
Figure 3. This map shows the Annapolis Calwater and surrounding areas and water temperature gauges analyzed for the North Coast Watershed Assessment Program. Red temperatures indicate stressful conditions for salmonids. Only the small tributary of the Wheatfield opposite Patchet Creek shows water temperatures cool enough for coho salmon. It is likely Patchet has the same character.
Figure 4. The chart above shows results of Knopp (1993) for streams in the vicinity of the Gualala River, with Grasshopper Creek showing values indicating a high degree of watershed impacts. Creeks like Brandon Gulch in Jackson Demonstration State Forest have less harvest and lower V*.
The sediment in Grasshopper Creek and other Gualala River tributaries is largely a result of human caused disturbance (CWRCB, 2001), including timber harvest and road building. The Gualala Basin as a whole has numerous sub-basins that have very high timber harvest rates between 1990 and 2001 (Figure 5). Reeves et al. (1993) found that timber harvest in Oregon coastal basins over 25% of a watershed’s area caused loss of aquatic habitat diversity and loss of diversity of Pacific salmon species. Similar patterns are clear in the Gualala basin, as pools have filled in (Knopp, 1993) and coho salmon have been all but lost (CDFG, 2002). The Plan acknowledges that 37% of the Annapolis Calwater Planning Watershed has been timber harvested between 1990 and 2001, but fails to acknowledge the consequences of such activities (Figure 6). An even more important oversight in Plan discussions is that lower Patchet Creek has been intensively timber harvested in this period, so the water course is likely experiencing elevated sediment yield at present.
Timber Harvest/Conversion Cumulative Effects: The pattern of very high timber harvest in the Gualala River basin is under-represented by timber harvest data from 1990-2001 because much of the basin was harvested between 1985 and 1989, and lingering problems from cumulative effects from these activities is likely still on-going. The assertion in the Plan that because recently disturbed sites are “fully stocked” and, therefore, no longer creating erosion problems is false. New tree starts do not provide full protection from continuing gully and surface erosion. An even larger legacy problem is roads (see below). If herbicides are used as part of the post harvest treatment, it may leave the window for increased erosion risk open longer.
Comparing landsat images from 1994 and 1998 is another index of the rapidity of change on the landscape in the vicinity of the Plan. These data were derived by CDF’s Fire and Resource Assessment Program (Fischer, In press) and it is called change scene detection. These data allow visual comparison of vegetation patterns between 1994 and 1998, indicating the degree of canopy removal. Fog in one or both images near the coast did not allow comparison of the Annapolis site itself in those two periods; however, data from just east of the area shows rapid change between 1994 and 1998, including vineyard conversions on adjacent headwater tributaries of the Wheatfield Fork and Fuller Creek (Figure 7). The impacts of the Artesia-Fairfax conversion need to consider with all these others of recent origin.
Roads and Cumulative Watershed Effects: The Technical Support Document (TSD) for the Gualala River Watershed Water Quality Attainment Action Plan for Sediment (CWRCB, 2001) was recently completed to help abate sediment problems in the Gualala yet it is nowhere referenced in the Plan, which means the Plan did not use the best scientific information available as required under CEQA. The TSD found that roads were a major source of sediment in the Gualala basin. Road densities throughout the basin are well over the recognized thresholds for sediment yield that are likely to cause harm to spawning gravel conditions in areas downstream (Figure 8). The National Marine Fisheries Service (1996) set 2.5 miles of road per square mile as a target for “properly functioning condition”, while Cedarholm et al. (1981) found the threshold for maintaining salmonid spawning gravel quality to be 1.6 miles per square mile in Washington State. While the Plan area itself has few roads, the Annapolis Calwater has six miles of road per square mile, more than double the level expected to cause problems of cumulative watershed effects (Figure 9). The erosion from the site needs to be cosidered with the erosion from existing roads.
The road density data under-represent actual problems with compaction of soils. They do not include landings, temporary roads and skid trails. The likely effect of wide spread compaction is a change in watershed response, elevating winter runoff and decreasing summer base flows (Leopold and McBain, 1995). The overall extent of compaction in the watershed and changes in flow basin wide should be considered along with changes in hydrology at the Artesia-Fairfax conversion site.
Figure 5. The timber harvest in all Gualala River Calwater Planning Watersheds is shown above as percentage of watershed area. Half of the basins are more than 25% cut in just over ten years. Data from CDF, Santa Rosa.
Figure 6. Timber harvests in the Annapolis Calwater Planning Watershed have covered 37% of the landscape between 1990 and 2001. This exceeds thresholds recognized in Oregon to be related to maintaining diverse assemblages of salmonids (Reeves et al., 1993). Harvests also included lower Patchet Creek, which comes off the meadow (white area on USGS Topo near the town of Annapolis). Data from CDF Santa Rosa.
Figure 7. This map shows a USGS orthophoto to the east of Annapolis with Landsat change scene detection for the years 1994-1998. The photo shows rapid landscape change in just four years, with clear-cut equivalent timber harvests (red) and vineyard conversions (purple). Grey is fog (no data). Data from CDF FRAP, Sacramento, CA.
Figure 8. This chart shows road miles per square mile of Calwater Planning Watershed with a reference line indicating regionally recognized cumulative effects levels (NMFS, 1996). Data from U.C. Davis, I.C.E.
Figure 9. This map shows the Artesia-Fairfax THC/THP area at the center near Annapolis and high road densities around it.
Conclusion: 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 Plan and discussions do not even include data from Patchet Creek’s lower reaches, which may be a key cold water refuge for steelhead in the lower Wheatfield Fork Gualala River.
Each of the sub-basins of Gualala River is currently impaired, to varying degrees, due to sediment levels that exceed natural background, as indicated by CWRCB (2001). Even the relatively small Annapolis Calwater Planning Watershed has extremely high cumulative effects risk with 1) 37% timber harvest in less than eleven years, 2) other vineyard conversion projects, and 3) more than six miles of road per square mile. This timber harvest and conversion, regardless of mitigation, will add to cumulative effects and alter the hydrology and sediment supply in Patchet Creek. The headwater slated for disturbance is a rare intact patch of watershed, which should be a priority for protection if restoration of steelhead is a goal (Bradbury et al. 1995).
Kauffmann et al. (1998) point out that: "The first and most critical step in ecological restoration is passive restoration, the cessation of those anthropogenic activities that are causing degradation or preventing recovery." Additional timber harvests in the Gualala River basin, and especially vineyard conversions, should not go forward until water quality has returned to unimpaired levels and salmonid productivity has been restored. Road densities in the Annapolis Calwater Waterhed should be meet “properly functioning condition” for salmonids of less than 2.5 miles of road per square mile (including landings) and have few or no streamside roads (NMFS, 1996) before additional, large scale disturbance is allowed.
The entire Artesia-Fairfax Plan is a classic example of how CDF falls short of dealing with cumulative watershed effects as noted by Ligon et al. (1999), Dunne et al. (2001) and Twiss et al. (2002). The discussions of the potential changes of flow and their effects on fish bearing streams down slope are particularly lacking and well outside the expertise of Registered Professional Foresters (RFP). I would recommend that the Department consider changing the administrative process for conversion of timberlands to vineyards, if not for timber harvest review overall, as suggested by Dunne et al. (2001).
This timber harvest and conversion, in combination with others already permitted, are highly likely to negatively impact 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, as more of the river will lose surface flow.
Sincerely,
Patrick Higgins
References
Bradbury, W., W. Nehlsen, T.E. Nickelson, K. Moore, R.M. Hughes, D. Heller, J. Nicholas, D. L. Bottom, W.E. Weaver and R. L. Beschta. 1995 Handbook for Prioritizing Watershed Protection and Restoration to Aid Recovery of Pacific Salmon. Published by Pacific Rivers Council, Eugene, OR. 56 p.
Brown, L.R., P.B. Moyle, and R.M. Yoshiyama. 1994. Historical Decline and Current Status of Coho Salmon in California. North American Journal of Fisheries Management. 14(2):237-261.
CA Department of Fish and Game. 2002. Status Review of California Coho Salmon North of San Francisco . Report to the California Fish and Game Commission. California Department of Fish and Game, Sacramento , CA. 336pp.
California State Water Resources Control Board. 2001. Technical Support Document for the Gualala River Watershed Water Quality Attainment Action Plan for Sediment. CRWQCB, Region 1. Santa Rosa, CA. 147 pp.
Cederholm, C.J., L.M. Reid,and E.O. Salo. 1981. Cumulative effects of logging road sediment on salmonid populations in the Clearwater River, Jefferson County, Washington. p.3874. In: Proceedings from the conference Salmon-Spawning Gravel: A Renewable Resource in the Pacific Northwest? Rep. 39. State of Washington Water Research Center, Pullman, WA.
Dunne, T., J. Agee, S. Beissinger, W. Dietrich, D. Gray, M. Power, V. Resh, and K. Rodrigues. 2001. A scientific basis for the prediction of cumulative watershed effects. The University of California Committee on Cumulative Watershed Effects. University of California Wildland Resource Center Report No. 46. June 2001. 107 pp.
Higgins, P.T., S. Dobush, and D. Fuller. 1992. Factors in Northern California Threatening Stocks with Extinction. Humboldt Chapter of American Fisheries Society. Arcata, CA. 25pp.
HFAC, 1999
Higgins, P.T. 1993. A Preliminary Restoration Plan for San Mateo Creek and the Santa Margarita River. Sponsored by Trout Unlimited of Southern California, Huntington Beach. CA. 32 p.
Higgins, P.T. 1997. Gualala River Watershed Literature Search and Assimilation. Funded by the Coastal Conservancy under contract to Redwood Coast Land Conservancy. Gualala, CA. 59 pp.
Kauffman, J.B., R.L. Beschta, N. Otting, and D. Lytjen. 1997. An Ecological Perspective of Riparian and Stream Restoration in the Western United States. Fisheries 22(5):12-24.
Kier (William M.) Associates. 1991. Long Range Plan for the Klamath River Basin
Conservation Area Fishery Restoration Program. Klamath River Basin Fisheries Task
Force. Yreka, CA.
Knopp, C. 1993. Testing Indices of Cold Water Fish Habitat. Final Report for Development of Techniques for Measuring Beneficial Use Protection and Inclusion into the North Coast Region's Basin Plan by Amendment of the.....Activities, September 18, 1990. North Coast Regional Water Quality Control Board in cooperation with California Department of Forestry. 57 pp.
Ligon, F., A. Rich, G. Rynearson, D. Thornburgh, and W. Trush. 1999. Report of the Scientific Review Panel on California Forest Practice Rules and Salmonid Habitat. Prepared for the Resources Agency of California and the National Marine Fisheries Service; Sacramento, CA.
Leopold, L. and S. McBain. 1995. Sediment processes in the Garcia River estuary related to enhancement feasibility. Final report. Performed under contract with Moffett and Nichol Engineers. Funded by the Mendocino Resources Conservation District. 29 pp.
Monschke, J. and D. Caldon. 1992. Garcia River watershed enhancement plan. Prepared for the California State Coastal Conservancy. Mendocino County Resources Conservation District. Ukiah, CA. CA. 130 pp.
National Marine Fisheries Service. 1996. Coastal Salmon Conservation: Working Guidance for Comprehensive Salmon Restoration Initiatives on the Pacific Coast. US Dept. Commerce, NOAA. 4 pp.
National Marine Fisheries Service. 2001. Status Review Update for Coho Salmon (Oncorhynchus kisutch) from the Central California Coast and the California portion of the Southern Oregon/Northern California Coasts Evolutionarily Significant Units. Southwest Fisheries Science Center, Santa Cruz, CA. 43 p.
Pacific Watershed Associates. 1994. Action plan for the restoration of the South Fork Trinity River watershed and its fisheries. Prepared for U.S. Bureau of Reclamation and the Trinity River Task Force, Contract No. 2-CS-20-01100. February 1994.
Reeves, G.H., F.H. Everest, and J.R. Sedell. 1993. Diversity of Juvenile Anadromous Salmonid Assemblages in Coastal Oregon Basins with Different Levels of Timber Harvest. Transactions of the American Fisheries Society. 122(3): 309-317.
Rieman, B. 1993. Consideration of Extinction Risks for Salmonids. As FHR Currents # 14. US Forest Service, Region 5. Eureka, CA. 12 pp.
Twiss, R., D. Tarboton, R. Marston, F. Everest, A. Collison, W. Emmingham, and W. Haneberg. 2002. Final Report on Sediment Impairment and Effects on Beneficial Uses of the Elk River and Stitz, Bear,
Jordan and Freshwater Creeks. Under the Auspices of the North Coast Regional Water Quality Control Board, Santa Rosa, CA.