Letter from botanist & coastal ecologist Peter Baye on the recirculated “Dogwood” logging plan in the floodplain of the Gualala River (May, 2016) — download pdf:
Conclusions and Recommendations
The addition of skid road maps without corresponding data and analysis of sensitive floodplain forest resources is meaningless for impact assessment and mitigation. CAL FIRE and the applicant have done only half the job they are supposed to do: the skid road layout should correspond to essential flood prone riparian geomorphic and biological functions, and significant biological resources, consistent with RPC guidelines or some reasonable scientific equivalent sufficient to meet FPR and CEQA standards. The multiple recirculations of the Dogwood THP fundamentally fail to do this despite ample comments on record regarding the need to do so.
The sequence of recirculated ad hoc THP materials convinces me that the Dogwood THP process is essentially a rationalization for a THP that GRT admits was planned before the flood prone area that comprises Dogwood THP was reclassified as WLPZ (riparian protection zones). The late submittals and recirculation provide only half of the information needed to conduct a meaningful analysis of direct, indirect, and cumulative impacts to floodplain forest ecosystem functions and sensitive biological and archeological resources. The THP still fails to analyze and mitigate potentially significant impacts to these resources.
Read the complete Comments by Peter Baye on the recirculated THP-01-15-042-SON Dogwood.