April 10, 2009
In the small Sheephouse Creek watershed west of Duncans Mills, multiple timber harvest plans have been proposed to log 20 percent of its area. The creek’s headwaters are part of the Jenner Headlands a new acquisition of the Sonoma County Agricultural and Open Space District. It is also the site of an ongoing taxpayer-funded captive broodstock program for coho salmon initiated in 2001.
Designated by the California Coastal Commission as a special treatment area, partially because it still support of silver (coho) salmon and steelhead trout, this watercourse has been proposed for multiple restoration projects. The National Marine Fisheries Service has determined Sheephouse Creek to be a core restoration area for coho recovery. Its waters are important in the development of the summertime fresh lagoon proposed for the lower Russian River to create a healthier nursery for young steelhead and salmon.
In January of 2008 Forester Glen Edwards filed Nonindustrial Timber Management Plan 1-08NTMP-004 SON in the Sheephouse Creek watershed on behalf of the Rocioli Ranch. Because of the multiple threats to the recovery salmon,some local residents the Friends of Sheephouse Creek and sought Forest Unlimited’s help understanding the California Department of Forestry’s review process for NTMPs.
This NTMP, about 2-1/2 miles west of Duncans Mills and bordering Sheephouse Creek, involves 228 acres of “Selection” silviculture. Forty-three acres of the area are Coastal Commission Special Treatment Zone. The area contains areas of moderate to high erosion which will be logged with tractor and cable yarding. The forester proposes extensive road reconstruction and new roads, as well as in-lieu practice for the use of heavy equipment on an existing seasonal roads and landing within a Class 1 watercourse. The area contains Osprey habitat, Steelhead trout, as well as the California Red Legged Frog and Red Tree Vole. A domestic water supply may be threatened. The ongoing Russian River Coho Salmon Captive Broodstock Program may be jeopardized.. Based on a ten year harvest cycle taking 800 MBF per decade over the next 40 years. Headwaters are part of the Jenner Headlands Project. Proposed for multiple habitat restoration projects by DFG in 2009 and identified as a Core area by NMFS for Coho recovery.
This plan was originally submitted in February 2008 and returned by the California Department of Forestry (Cal Fire) ten days later with four pages of corrections. Resubmitted in December 2008, the NTMP was returned again by Cal Fire ten days later with eight more pages of corrections. We are currently waiting for the plan to be resubmitted a third time.
This NTMP is an open ended perpetual logging plan with a 40 year planing horizon. Logging would occur every ten years. Like most timber plans, it does not acknowledge cumulative watershed effects and makes a claim that mitigations proposed in conjunction with logging and road construction can prevent them. Major issues, such as changes in hydrology associated with the NTMP go completely unrecognized. Relevant data that show significant environmental problems are not analyzed or discussed, failing to meet CEQA standards for cumulative effects.
The fisheries section of the NTMP now acknowledges that Steelhead trout and Coho salmon are found in the watershed, and mentions that Sheephouse Creek is a restoration stream for the Coho Salmon Recovery Program, initiated in 2001. Sheephouse Creek is considered to be in the Willow Creek watershed assessment area, which contains Coho salmon, and therefore Sheephouse Creek is also considered to contain Coho. Since 2004, Sheephouse Creek has been actively planted with young Coho.
While the RPF apparently downplays the numbers of Coho found in Sheephouse Creek, he neglects to mention NMFS considers Sheephouse Creek as a Core area for immediate restoration by NMFS in its draft Recovery Plan for Coho.
The RPF admits “The Sheephouse Creek watershed has been impacted in regards to sediment primarily from past timber harvesting.” The Ricioli Ranch NTMP then tries to make a case that the plan will be able to make corrective changes and improvements to the areas proposed for harvest and will have “a positive net effect upon the beneficial uses of the watershed resources,” without providing any evidence to support this claim as required by CEQA.
Despite stated objectives, the proposed activities under this NTMP are exactly the opposite of what is needed for recovery of fish and wildlife in Western Sonoma County and the lower Russian River. The stated mitigations are inadequate to protect the fishery. The plan is inconsistent with the Russian River Biological Opinion released by NMFS in September, 2009 and the NMFS draft Recovery Plan for Coho which is now being circulated among co-managing agencies. The NTMP should assist salmon and steelhead recovery in the Russian River basin instead of further contributing to their decline. It does not state even the most general goals for salmonid recovery nor include plans for increasing the salmon or steelhead resources of the state. The NTMP states “Erosion control measures contained in the Forest Practice Rules and the NTMP should mitigate the potential for sediment input into any watercourse on site or off site of the project area.” It concludes – “it is anticipated that no impacts will occur to the habitat or watershed resources which could significantly adversely impact these species.”
DFG has concluded, and NMFS agrees, that Coho salmon in the Central Coast Coho ESU are in serious danger of extinction throughout all or a significant portion of their range. Coho salmon once inhabited the entire Russian River basin, but are now restricted to the lower watersheds near the coast and within the redwood forest zone. A captive broodstock program to prevent the extinction of Coho salmon and re-establish new native populations has been started in 2001 at Warm Springs Dam Hatchery based on juveniles taken from Green Valley Creek. The first planting was done in 2004 in Ward, Mill, and Sheephouse Creeks, which were chosen for their quality habitat. Initial results are encouraging. The Ricioli Ranch NTMP places this multi million dollar, taxpayer subsidized program in jeopardy. Â The forester states in his plan that “It is anticipated that no significant adverse impacts will occur to the habitat or watershed resources which could significantly adversely impact these species.” Yet he later admits “Changes in stream flow may adversely impact aquatic species if peak flows exceed the carrying capacity of the existing stream channel.” then, “An increase in late summer flows may be expected following timber harvesting. However this effect diminishes within a few years as the forest regenerates.”
Cold water fish species are recognized as a beneficial use of the Russian River, therefore some quantitative measurements of fish habitat also serve as water quality indicators for Sheephouse Creek. Data such as flow, channel type, temperatures, habitat type, embeddedness, shelter rating, substrate composition, canopy, and bank composition were last noted by DFG in an assessment of Sheephouse Creek’s habitat and biological inventory completed in 1996. This data is now included many times throughout the revised NTMP. The DFG report concluded that Sheephouse Creek and its tributaries should be managed as an anadromous, natural production stream. Access for migrating salmonids is an ongoing potential problem in the Southwest and Northeast tributaries of Sheephouse Creek, where log debris from upslope timber operations periodically moves downslope. Also, the report notes road related erosion should be identified and corrected. Lastly, cross sections to monitor sediment transport should continue to be monitored by DFG staff. Many of these legacy conditions were created by past logging entries by the very same family which proposes the current NTMP. While the RPF now repeatedly points out that the current NTMP has been designed with the protection, maintenance, or restoration of the beneficial uses of water or the populations and habitat of anadromous salmonids or listed aquatic or riparian associated species as significant objectives, nowhere does he state what will be done to correct conditions which were caused by past events which are today causing serious adverse environmental impact.
In 1999, biologists estimated there were only 100 adult Coho salmon in the Russian River and its tributaries, or 6% of what the population was in the 1940’s. A variety of factors led to this decline, including loss of habitat to farming, dams, overfishing, and logging. NOAA Fisheries has identified the failure of the Forest Practice Rules to adequately assess cumulative impacts, focusing in particular on their adverse effects on anadromous fisheries. The DFG has concluded that historical forestry practices impacted and continue to impact watersheds inhabited by northern California Coho salmon. Cumulative impacts from logging include an increased sediment yield, promotion for warming of ! stream temperatures, and an alteration of watershed hydrology.
The NTMP continues to fail to fully evaluate road impacts, especially for the proposed use of the contested easement road through Keller property to access the timber area. Much of the sediment that enters our California streams comes from road related erosion. Roads, such as that proposed for use along Sheephouse Creek, and which parallel the watercourse have the highest chronic sediment delivery. Over 1250 of new road and road reconstruction are proposed in the Ricioli Ranch NTMP along with 12 new crossings of class II and III watercourses, as well as replacement of a log stringer bridge over a class I crossing. If the Problem Sites and Landmarks section of the 1996 DFG Sheephouse Creek survey are any indication, stream side landslides are contributing sediment directly to Sheephouse Creek today. Roads that parallel watercourses for most of their length pose high risk of sediment yield and disrupt riparian function. Degradation affects many aspects of the riparian and wetland ecosystem: riparian vegetative cover decreases, bank and channel erosion increases, sediment deposition into channels increases, flooding increases, water quality decreases and recreational opportunities decrease. This is the very reason we are contesting the use of our easement road for logging purposes, decommissioning it and strongly encourage the use of an identified alternative road on Ricioli property and/or Berry property, which would have far less environmental impact upon the riparian area along Sheephouse Creek. While the Keller property is not included in the NTMP, it should be afforded the same protection of its riparian area that the FPR’s dictate with the WLPZ and EEZ. As this is private property, no in lieu practice is allowed as a deviation from standard rule.
The NTMP now admits the existence of many active and dormant landslides and areas of unstable soils which are associated with the timber harvest area. The RPF notes that the surface erosion hazard rating for the NTMP area is moderate to high, and the soils types found here to have a permeability considered moderate with runoff very rapid and a hazard of erosion at high. Slopes are steep (50%+) leading into the watercourse area. Trees are shown to be harvested on slide areas and road construction is proposed in unstable areas, as well as in slide prone areas. The Ricioli Ranch NTMP deals with slope stability and sediment contributions by implying mitigation measures are designed to reduce the potential for adverse impacts to the species of concern to a level of insignificance. Because of the unstable nature of the landscape on which this plan will be operated, the Ricioli Ranch NTMP will not be able to a chieve its goal of no net sediment discharge. Any addition of sediment into an impaired waterway is a significant adverse impact upon the environment and grounds to deny this NTMP. Because of the potential association of these landslides and unstable soils with existing and planned disturbances (logging), we have asked for further review with a CA Geologic Survey independent geologic investigation allowing for peer review of the findings. The investigation should be done independent of the Santa Rosa office.
I have asked the RPF through CDF if the removal of dominant overstory trees and the reduction in hardwoods will require the use of herbicides, but I have not received an answer nor does the NTMP seem to address this issue. Any use of herbicides and pesticides with the NTMP area will pose risk to the salmonids in Sheephouse Creek. This is well documented in the scientific literature.
The NTMP does not fully explore cumulative watershed effects within the Sheephouse Creek watershed or the relevant Calwater Planning Watershed (Willow Creek), much less characterize environmental stressors that exist in theÂ RussianÂ River basin for this area. When assessing the cumulative impacts of a timber harvest plan that is proposed on any portion of a 303(d) listed water body that is located within or downstream of the proposed water body, the RPF must undertake additional analysis. He must assess the degree to which the proposed operations would result in impacts that may combine with stressors for which the water body was listed to further impact the! listed water body. Also, he must determine the extent to which these combined impacts would impair the beneficial uses of the water body.
The EPA has listed theÂ RussianÂ RiverÂ as an impaired water body with regards to sediment and temperature. The NTMP makes the claim that mitigations to offset damage will actually improve current conditions and have a “net positive effect” upon the environment then if no harvesting of timber took place. The problem is that timber harvests are typically reviewed as individual impacts and not in conjunction with all the activities in the watershed. This would include the cumulative impacts of past, present, and proposed plans. Each timber harvest plan must be considered in its full environmental context and not in a vacuum. All significant environmental impacts of a proposed! timber harvest plan must be considered, whether those impacts may be expected to fall on or off the logging site. This would include the human and environmental impacts this plan would have upon the Keller property should the proposed easement road through their property be used for commercial logging.
After admitting that the Sheephouse Creek watershed has been impacted in regards to sediment primarily from past timber harvesting, the RPF briefly summarizes the recent timber activities in the Watershed and BAA approved within the last ten years, but fails to discuss their significance. If you were to look only at plans approved in the watershed over the last ten years, about 14% of the watershed has been impacted; but over the last fifteen years, 37% of the watershed has been impacted; and if you were to add in the two proposed plans for this watershed, over 56% of the watershed acres will have been impacted by logging. The RPF is ignoring the impacts this NTMP will have on the watershed by diluting its impact by only going back ten years and using the greater WAA and BAA to generate his ratios. What is lacking is a prudent limit or threshold for! timber harvest to avoid cumulative watershed effects. We have asked that the last five previous THP’s in this watershed be looked at in conjunction with the two currently proposed in order to truly understand cumulative effects. Questions which should be addressed are how much unstable ground was disturbed; how many miles of roads were constructed or rebuilt; and what monitoring data show that impacts from the plans are not already exceeding cumulative effects thresholds? What are the thresholds?
The Ricioli Ranch NTMP does admit the potential for increases in peak flow and potential for downstream impacts but feels this effect diminishes within a few years as the forest regenerates. The RPF requests that an in-lieu practice be approved that allows the use of heavy equipment in areas which are considered Class 1 WLPZ and EEZ. Extensive use of tractors and an increase in road usage will indeed increase peak discharges in Sheephouse Creek. This increased peak flow can scour stream channels and wash out large wood and spawning gravels. These effects on the habitat can greatly reduce salmonid carrying capacity. Can the RPF and Cal Fire guarantee that the carrying capacity of Sheephouse Creek’s anadromous fish runs is not compromised?
The Ricioli Ranch NTMP is interested in its short term economic yield as it fails to recognize the long term human and environmental effects it will have upon the Keller property, Sheephouse Creek, its watershed, and the Coho and Steelhead habitat. It is obvious that something is amiss in the California redwood ecosystem that is causing the decline of our salmon population. Avian indicator species such as the northern spotted owl and the osprey, which are found in the Sheephouse Creek watershed, cannot move to adjacent habitats if it is logged. A historical survey of the endangered, threatened, and sensitive species found over the last fifteen years in this watershed do not exist today in the same numbers, nor are they increasing. Congressman Mike Thompson, who has expressed concern for this NTMP, mentions Wild salmon are to the rivers and the watershed and the ocean what the canary is to the coal mine. Their decline in numbers indicates the loss of biodiversity in this watershed due to historical logging.
The Ricioli Ranch NTMP does not contain sufficient imformation on which to judge its impacts and, for this reason, the proposed plan should be denied. Data required should include a yearly population estimate of Coho salmon and Steelhead trout. Turbidity measurements for Sheephouse Creek should be required, as well as other factors of water quality. Threshold levels should be determined to know how much additional sediment the watercourse can tolerate without significantly effecting fishery productivity and domestic water uses downstream. The Ricioli Ranch NTMP will add to the impairment of water quality, cause further loss of fish habitat, and be counter productive for the recovery of Coho and the continued existence of Steelhead trout in Sheephouse Creek.