THP 1-00-484 SON – Haupt Creek
California Department of Forestry
Santa Rosa, CA 95401
COMMENTS – 1-00-484 SON – Haupt Creek, Wheatfield Fork, Gualala River
January 29, 2003
To the California Department of Forestry:
I would like to submit the following comments on THP 1-00-484 SON regarding: thresholds for significant individual and cumulative impacts; the inadequacy of plant and wildlife surveys and assessments; site-specific soil erosion hazards; cumulative impacts on Haupt Creek sedimentation; biological importance of isolated relict populations of vascular plants, bryophytes, invertebrates, in the patch of historically unlogged redwood-Douglas fir forest; and potential impacts on federally listed northern spotted owls.
I am a professional plant ecologist and field botanist, specializing in coastal plant communities and species for over 25 years. I have 7 years experience in NEPA compliance (EIS and environmental assessments) with the U.S. Army Corps of Engineers (San Francisco District), and 6 years experience preparing endangered species recovery plans and Section 7 consultations for the U.S. Fish and Wildlife Service (Sacramento Office). I have reviewed the Timber Harvest Plan (THP) for “If I Would Have Only Known…”[sic], prepared by Charles Richardson, Registered Forestry Professional 2702, with attached reports by Pamela Town (wildlife “field review”) and John Coyle & Associates (engineering geology “reconnaissance review”).
There are substantial inconsistencies and inaccuracies among and within these reports, and some key conclusions regarding significant environmental impacts are either deficient or simply incorrect. Outstanding among invalid claims proposed in the THP is the assertions that the timber operation “will not have a significant adverse impact on the environment”, despite logging in endangered species habitat on soils with “extreme erosion hazard”, and in regionally rare literal old-growth redwood/Douglas fir forest (intact pre-historic forest stands).
Thresholds for “significant” individual and cumulative impacts. The THP asserts without reasonable support (citation of scientific literature or data) that the proposed timber operation, after mitigation, “will not have a significant adverse impact on the environment” (p. 4). It further asserts that the project, after mitigation, would have no significant cumulative impacts on watershed or biological resources. The THP does not cite any regulatory or other thresholds for significance, but the THP does identify numerous impacts which, though not identified as such, meet regulatory criteria for “mandatory findings of significance” under the California Environmental Quality Act (CEQA: Pub. Res. Code Sec 21083). These include:
- Degrade environmental quality. The THP would convert an intact pre-historic stand of redwood/Douglas fir forest (including regionally rare intact prehistoric remnant forest soil profiles, seed banks, clonal herb populations, and insect populations) into a disturbed, artificially replanted post-logging successional forest (including seeding of non-native invasive annual grasses for erosion control). This would in effect irreversibly degrade a regionally rare prehistoric remnant of native vegetation (in western Sonoma County, “unique”, according to the appended wildlife report in the THP, p. 59.3, Town report). The extreme steep slopes and loose, gravel loams with low shear strength, and numerous pre-existing landslides in “undisturbed” conditions prior to timber operations, indicate a reasonable likelihood of increased erosion, sedimentation, and geologic instability. There are no precedents cited in the THP for comparable projects with “less than significant” in terms of context or intensity, and I would conclude that there are none in this region.
- Reduce fish or wildlife habitat.
- Reduce the numbers or range of a rare or endangered species. The wildlife report (P. Town, p. 59.3) identifies within the timber operation area “old growth redwood and Douglas fir”, and the THP identifies late seral stage redwood-Douglas fir habitats as required for nesting and roosting of for northern spotted owls (p. 49), and the THP concedes that its habitat is present in the plan area (p. 22). Therefore, logging would “reduce wildlife habitat” for this sensitive (endangered) species. This is also indicated by the stated need to consult with the U.S. Fish and Wildlife Service (p. 49). The THP (pp. 49, 22) and Town report (p. 59.4) both state that the “plan area and assessment area does [sic] contain suitable habitat for the marbled murrelet”. In addition, the Town report (p. 59.5) confirmed the presence of the rare red tree vole (another declining wildlife species associated with late seral redwood/Douglas fir forest) throughout the plan area, and identified unavoidable (incompletely mitigated) impacts to this species. Even fragmentation of habitat is harmful to viability of this species’ populations (Mills 1995). The THP also underestimated the significance of mature and senescent unlogged redwoods for rare bat populations that depend on their large cavities (Zielinsky et al. 1999). The Town report merely referred generally to “other cavity nesters” in the context of raptors (THP p. 59.3), but failed to consider sensitive bat populations, and recommended inadequate survey methods for bats (p. 59.4).
- Eliminate important examples of the major periods of California history or prehistory. Western Sonoma County has a history of extensive rangeland and logging. Unlike Humboldt and Del Norte counties, where substantial and numerous fragments of intact prehistoric forest remain, pre-historic intact remnants of any type of native vegetation are exceedingly rare here. There are no protected prehistoric remnants of native vegetation to represent landscape conditions inhabited by prehistoric Pomo tribes. The proposed THP would irreversibly destroy the paleoecological integrity of this intact prehistoric remnant of coastal redwood/Douglas fir forest.
The THP’s claim that the timber operation impacts would be less than significant is inconsistent with the evidence presented in the THP, its own expert wildlife report, and established CEQA thresholds for mandatory findings of significance. The THP does not explain in any way these inconsistencies, or offer any rationale or explicit reference to any alternative threshold for significance. This is an arbitrary and unjustified interpretation of the threshold of “significance”.
Impacts to significant plant species, communities, and populations: unique prehistoric remnant redwood-Douglas fir forest. The THP grossly underestimates the significance of existing plant species and community resources associated with prehistoric redwood-forest remnants in Sonoma County. It fails to provide the two most basic, essential and important sources of information about site-specific botanical data: (1) site-specific plant surveys seasonally timed to detect sensitive species, performed by a regionally experienced, qualified field botanist; and (2) review of the Flora of Sonoma County (Best et. al. 1996) and CALFLORA (www.calflora.org, on-line comprehensive database of U.C./Jepson herbarium records and literature citations). The Flora of Sonoma County relies heavily on herbarium specimens from the California Academy of Sciences/Dudley Herbarium, including historic collection data not found in other plant databases. The basic deficiencies in botanical review make the THP’s conclusions about botanical resources unreliable.
The THP performed only perfunctory database searches covering the general geographic area. These would certainly exclude the specific privately owned parcel which appears to have history of botanical surveys. The THP then literally blindly asserts that “no threatened, endangered, or sensitive species have been located on the plan area” (p. 48). This is a vicious circularity: in the absence of any history of a proper plant survey on private lands, it is not logically possible to find any records of any rare plants. The THP bases the claim that no sensitive plant species occur in the plan area on mere reconnaissance “fieldwork” by observers with no stated qualifications, training, or experience in plant taxonomy and identification of rare plants in the region (“…by the forester, his supervised designee, the landowner, and a certified wildlife biologist”, p. 48).
The THP discloses that redwood/Douglas fir stands with no history of logging occur on the THP parcel, but it fails to identify any aspect of its distinctive ecological significance. The THP area contains significant prehistoric remnants of redwood-Douglas fir forest vegetation, including intact soils, seed banks, and clonal bud banks of the vernal herb community. Unlogged remnants of North American forests generally contain highly significant refugia of forest floor (herb layer) species suffering declines or local extinctions in logged forests; they also are likely to contain plant populations with relatively high levels of genetic diversity compared with equivalent logged forests (Duffey and Meier 1992, Braton, et al. 1994, Jules and Rathcke 1999). Intact forest remnants within highly altered landscapes support highly valuable regionally specific paleoecological information of great scientific, educational, and conservation value. In addition, they are likely to support critically important refugia for disturbance-intolerant plant and wildlife populations.
The THP failed to address the cumulative impact of losing what may be among the last, if not the last, substantial relict prehistoric stand of western Sonoma County’s redwood forest flora. This would require assessment of the distribution, abundance and patch sizes of relict prehistoric forest vegetation in Sonoma and southern Mendocino County, covering this floristic subregion (Plantation-Annapolis-Gualala). The location of late-succession or old-growth redwood vegetation patches is one of the highest priority criteria in the conservation planning of redwood forests (Noss et al. 2000).
The THP arbitrarily limits consideration of botanical resources to listed or legally protected plant species, without addressing:
- regionally rare plants (one or few records in Sonoma-southern Mendocino-Marin counties);
- plants with distinctive, disjunct populations (including stabilized hybrid zones);
- species at or near their geographic range limits;
- plants in with uncertain taxonomic status (potential cryptic taxa, anomalous populations with unclear relationships with published taxa);
- plants in rapid regional decline or range collapse due to rapid cumulative impacts from changes in land use; and
- unique, distinctive, or highly representative stands of vegetation with limited distribution.
These are substantial issues for plant conservation biology. Destruction of single populations of plant taxa falling in these categories could have major effects ranging from regional extinction, range contraction, to irreversible loss of within-species variation (Hunter and Hutchinson 1994, Lomolino and Channel 1998, McKinney 1999). Examples of species which fall in some of these categories, other than the four listed rare plants superficially considered in the THP (p. 53) include Vancouveria hexandra, Allotropa virgata, Chimaphila menziesii, Hemitomes congestum, Synthyris reniformis, Cypripedium californicum, Cypripedium montanum, Taxus brevifolia, Adiantum aleuticum, Polystichum dudleyi, and Botrichium multifidum. This species list of examples is partial, not exhaustive. All are slow-growing, slow-dispersing species intolerant of logging disturbance (large canopy and soil gaps). They are especially likely to occur in the refugia provided in remnants of cool, moist, canyons with bedrock outcrops, ancient soils, and prehistoric redwood forest cover with occasional canopy gaps. All are historically recorded in northwestern Sonoma County in mature forested habitats. The vast majority of forests in this region have highly disturbed soil profiles and severely impacted forest floor floras, due to 20th century tractor logging operations.
Other unique biological diversity impacts: relict and refugial populations in prehistoric remnants of redwood-Douglas fir forest (true “virgin old-growth”)
The THP also fails to consider the importance of amphibian populations, invertebrate populations, bryophytes and lichens supported in prehistoric remnant redwood-Douglas fir forest. The diversity of the vascular plant community in the herb layer is likely to indicate the level of diversity in the bryophyte and lichen flora (Pharo et al. 1999). Uncommon to rare extinction-prone populations of amphibian and invertebrate taxa (those slow, short-range dispersal, and close dependence on year-round moisture, cool temperature, and shade), are likely to be concentrated in north-aspect canyons with old, undisturbed forest canopies, seeps, springs, and seasonal streams (Welsh and Lind 1991, Olson 1992, Lattin 1993, Welsh and Ollivier 1998). These conditions are described for the THP area. The old growth in the THP area is likely to serve as a refugium from which recolonization may gradually proceed as surrounding 20th century logged forest gradually recovers canopy and soil conditions capable of supporting such species.
The THP provides no meaningful information on the diversity or abundance of inconspicuous populations of non-megafauna wildlife, particularly amphibians (salamanders, newts). The THP failed to address the potential significant impacts of microclimate change on resident amphibian populations due to canopy reduction and stand thinning. Remnant populations in undisturbed prehistoric forest stands are likely to support important pockets of genetic variation within resident populations (infrequent or rare alleles [genes] not previously subject to logging-induced bottlenecks), and important sources of genetic diversity among populations in the region. The loss of this “virgin” biological diversity would be irretrievable and effectively irreversible after logging. This impact, again, would be unmitigable, significant, and irreversible.
The CDF should require independent scientific peer review of the THP by qualified experts in the herpetofauna and invertebrate fauna of the region because of the high potential for significant impacts to these resources in disjunct patches of pre-historic redwood/Douglas fir forest.
Northern spotted owl and marbled murrelet impacts. The proposed THP would cause “take” of the federally listed northern spotted owl, and potential “take” of marbled murrelet habitat, at least because of habitat destruction (degradation of rare old growth conifer forest at the southern limit of the north coast forest belt). It would adversely affect the northern spotted owl by degrading the quality of a regionally rare, intact, pristine prehistoric forest stand with no logging history, supporting large, old trees and scarce superior quality habitat at the southern limit of the contiguous north coast redwood forest. Although the THP and Town report both concede the presence of suitable habitat for the northern spotted owl, they provide no contemporary survey data on the presence of these species, and avoid evaluation of the likelihood of presence, and quality of habitat. For wildlife and forestry professionals, this reticence borders on the disingenuous. In any case, the systematic avoidance of both habitat evaluation and survey data precludes justification of the conclusion that the proposed logging, after mitigation, would have no significant effect on the northern spotted owl. All available evidence about habitat conditions described in the Town report justify a presumption of significant impacts (cf. mandatory findings of significance in CEQA; see discussion above), especially in the absence of survey data. The impact to the species must be determined in consultation with the U.S. Fish and Wildlife Service, based on adequate survey and habitat data.
The significance of this mature redwood-Douglas fir stand for the northern spotted owl is not limited to the presence/absence or breeding status of spotted owl or marbled murrelet populations on site. Greater significance inheres in the size, quality and regional distribution of suitable long-term habitat along the coast. In the southern end of the species geographic range, suitable habitat becomes distributed in a series of disjunct habitat “islands”. Viability of spotted owl “metapopulations” (interacting complexes of sub-populations) depends on demographic and genetic linkages among populations, which in turn depends on the relative position, size, and quality of habitats that support. Loss of habitat in the THP area is likely to cause a disproportionately large gap in the distribution of high-quality habitat for this species in the Sonoma-Marin coast. Increased habitat gap size is likely to cause reduced gene flow and dispersal success among populations. Impacts to the species (“take” of a federally listed species under the Endangered Species Act) must be analyzed quantitatively not only in terms of direct habitat loss, but indirect loss of reproductive success and population viability in the Marin-Sonoma coastal region.
Inherent erosion hazards: The soil series surrounding Haupt Creek are mountainous uplands. Soil and topography are predominantly excessively steep (to 75% slope), gravelly loams in the Hugo series (Hugo-Atwell complex, Hugo-Josephine complex), listed as high to very high erosion hazard (Soil Survey, Sonoma County, Natural Resources Conservation Service, U.S. Department of Agriculture). The THP identifies hazards as “extreme” (steepest slopes) and “moderate”(less steep slopes) (pp. 9, 13). The engineering geologist “reconnaissance” report appended to the THP (John Coyle & Associates; Coyle report) identified at least seven (7) specific large landslides (including “young” ones) within the 55 acre THP area even in intact conditions undisturbed by logging operations. The slopes in the proposed harvest areas range from 50% to 60% (described as “relatively gentler”) to 80 to 100% slopes. The Coyle report did not explicitly assess the shear strength of the gravel loam, colluvium, and landslide debris that prevails over the site, but the soils have little bearing capacity. These extreme slope and erosion hazards are proposed to be mitigated merely by refraining from “intense harvest activities”, road building, and poor drainage control. The Coyle report offers no examples or precedents of cable logging in similar topography or soils to compare with the proposed project, and thus fails to provide specific support for its judgment (note the legal disclaimer on p. 9 of the Coyle report, “review limitations”). The THP itself proposes as mitigation for erosion hazards only seeding bare soil over 100 square feet in area with annual grass and straw mulch (p. 10). The THP concludes that proposed actions in these extremely hazardous erosion contexts would fail to cause significant soil disturbance, gully erosion and slope failure. This conclusion is not reasonable, credible, or accurate, in view of available evidence. Felling and cable logging 500 year old redwoods would cause substantial soil disturbance and substantially increase risks of slope failure and mass wasting, particularly following extreme rainfall events. Erosion impacts of logging pristine forested slopes in this watershed would be, by any reasonable standard (including legal standards of the California Environmental Quality Act), highly significant and unavoidable.
The CDF should carefully review the arguments regarding “significance” thresholds presented by the Registered Forestry Professional (THP preparer), the pertinent statements and arguments in the appended consultant reports, and any pertinent precedents or regulatory thresholds for “significance” of environmental impacts related to CEQA. The CDF should require independent, rigorous scientific peer review of these conclusions prior to final agency action. In my professional opinion, the arguments presented are not reasonably justified by evidence, logic, or reference to scientific literature.
Cumulative sedimentation impacts in Haupt Creek and Wheatfield Fork, Gualala River: Past logging has induced excessive instability in the Haupt Creek watershed, resulting in severe channel aggradation with coarse stream alluvium, and heavy transport of fine sediment during peak discharges. Channel sections on lower Haupt Creek (above the confluence with the Wheatfield fork, Gualala River) are typically choked with gravel and cobble, and an anomalously large, dynamically persistent instream gravel delta occupies the bed of Gualala River immediately below the confluence. Additional artificial loading of this stream with coarse alluvium eroded from landslides of the “high to very high erosion hazard” slopes of the proposed 55 acre THP would cause effectively irreversible, severe, significant cumulative impacts to stream sedimentation. The generic, programmatic (best management practices) mitigation measures to offset cumulative impacts to stream sedimentation (THP, p. 44) are not proportional with the extreme erosion hazard and instability of steep canyon slopes with gravel loams and weak, weathered graywacke bedrock. This is indicated by the presence of at least 7 pre-existing landslides (young and old) within the 55 acre plan area (Coyle report, p. 5). The generic, nominal mitigation measures provide trivial protection against the risk of severe pulses of landslide-induced sedimentation. Meaningful, substantive, site-specific mitigation for this impact after-the-fact is lacking. Corrective measures (after-the-fact mitigation for landslides, slumps, and debris flows) would be infeasible.
The CDF should rigorously review all pertinent statements regard topography, slopes, erosion hazard, and background conditions in the THP plan area, and Haupt Creek watershed. The CDF should also rigorously review the full details of proposed mitigation measures discussed in the THP and appended consultant reports. The THP’s conclusion that mitigation would be adequate to prevent significant cumulative impacts to stream sedimentation appears to be fundamentally flawed. The only reliable mitigation measure to prevent significant cumulative sedimentation impacts to sensitive Coho and salmon streams in the watershed would be to avoid soil disturbance and tree root system disturbance on unstable, steep canyon slopes.
Special-status salmonid impacts of sedimentation. The Gualala River, Wheatfield Fork immediately downstream from Haupt Creek is also highly aggraded, but persistent scour pools have stabilized against old redwood trunks and bedrock outcrops beneath riparian tree canopies, often in association with cool springs and minor tributaries from forested north slopes. These cool, shaded pools, often connected by above-bed channel flows in years of high baseflow, are highly important refugia for special-status salmonids (steelhead, coho salmon) during summer. They provide foraging, shelter, and potential spawning habitat most years. Logging in the Haupt Creek watershed would result in significant sediment pulses, adding substantial local loads of both coarse and fine sediment from the mouth of Haupt Creek to a long segment of the Gualala River downstream from their confluence. Pools in the downstream discharge zone would be at significantly increased risk of pool infilling (loss of depth, area) and fining-upward sediment profiles (accretion of silt and fine sand at the surface, highly adverse for spawning and foraging of juvenile salmonids).
Substantial state, federal, and private resources are committed each year to study and enhance salmonid habitat in the Gualala River watershed. It would be capricious for the state, through CDF, to support and fund such efforts, and also authorize actions causing significant, effectively irreversible cumulative impacts to sedimentation and fish habitat in this river system. This would be both economically and ecologically unjustifiable, and would cause significant unresolved conflicts of resource management and land use.
The THP’s presumptuous conclusions that the proposed logging operations would have less than significant impacts are scientifically unjustified and arbitrary. Its key conclusions are prima facie inconsistent with the limited evidence presented, and established regulatory criteria for mandatory findings of significance in CEQA. The THP lacks adequate biological survey data (or no survey data at all, in some critical cases) to support any conclusions regarding the impacts of sensitive, rare, or endangered species or communities. The THP commits basic errors of omission by failing to identify the paleoecological and contemporary ecological significance of logging impacts in intact, prehistoric forest remnants. The THP, therefore, should either be (a) denied; (b) withdrawn and resubmitted with full, complete, and scientifically adequate information, consistent with regulatory requirements; or (c) subjected to scientific peer review by qualified, independent experts prior to final agency action.
I suggest that any THPs involving logging operations in previously unlogged coastal redwood-Douglas fir stands in southern Mendocino and Sonoma counties be elevated for policy-level review as special cases. This is justified because of the exceptional biological, scientific, educational, and historic/heritage value of rare pristine mixed coastal conifer forests in this subregion. Evaluation of any THPs in excessively steep, high erosion-hazard soil series adjacent to tributaries of the Gualala River should also trigger rigorous policy review. It is unlikely that this or similar THPs could be consistent with CEQA or the Forest Practices Act in the absence of such review.
Peter R. Baye, Ph.D.
Coastal Plant Ecologist
cc: California Native Plant Society, Point Arena
Friends of the Gualala River
Carl Wilcox, California Department of Fish and Game, Yountville
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