Consulting Fisheries Biologist
791 Eighth Street, Suite N
Arcata, CA 95521
Ms. Leslie Markham, ForestPractice Division Chief
California Department ofForestry and Fire Protection
135 Ridgeway Avenue
Santa Rosa, CA 95401
Re: Response to Comments on Timber Harvest Permit THP 1-04-030 SON, Hansen/Whistler THP and Timberland Conversion Permit (TCP) #530
Dear Ms. Markham,
I have just completed reviewof the response to comments for the Hansen/Whistler TimberHarvest Permit THP 1-04-030 SON, including responses to comments I filed onApril 14, 2004. I am once again doing this review for local watershed residentswho are concerned about the health of the Gualala River. They also feel thatthe California Department of Forestry (CDF) is not preventing damage to theriver as required under the Federal Clean Water Act (CWA) and the CaliforniaEnvironmental Quality Act (CEQA). This conversion and harvest are in theLittle Creek watershed, a lower tributary to Buckeye Creek, which is showingadvanced signs of cumulative watershed effects (CWE) as established in myprevious comments, and new evidence presented by CDF indicates that LittleCreek itself has a similar level of impacts.
After acknowledging that thestream is barely showing surface flow due to aggradation, CDF has approved theTCP and is now moving to approve the THP. This is a direct violation of CEQAbecause sediment impacts will occur and other recent and foreseeable activitiesin the watershed have also contributed to this recognized problem. The repeatedstatement that all effects from the plan can be fully mitigated and that therewill be no impact to Little Creek is not credible (Dunne et al., 2001; Collisonet al., 2003).
To remind you, my expertisein the Gualala River watershed is a result of my having studied the watershedsince 1997. I have recapped (and recaptured) the literature on fisheries andwatershed processes for the Gualala River for the Redwood Coast LandConservancy (Higgins, 1997). I then worked closely with the Gualala RiverWatershed Council and the California Resources Agency to provide technicalassistance for the Gualala River Watershed Assessment (CARA, 2002) as part of the North Coast WatershedAssessment Program (NCWAP). In addition to providing analytical support to theagency staff, I helped assemble all available data, bibliographic resources,photos and electronic maps into the KRIS Gualala database (IFR, 2002), which ispart of your record. Despite the fact that the KRIS Gualala project was fundedby CDF to provide a tool for cumulative watershed effects analysis, your staffdoes not appear to be using it, even at this late date.
Once again the projectproponents and CDF have failed to deal with risk of cumulative watershedeffects quantitatively or credibly. For the purpose of these comments, theseimpacts will be termed cumulative watershed effects and be abbreviated CWE. Thedefinition of CWE from Dunne et al. (2001) was provided in former comments, butit is similar to those described in CEQA:
- “Cumulative impacts’ are defined as ‘two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.
- Individual effects may be changes resulting from a single project or a number of separate projects.
- The cumulative impacts from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.”
As I pointed out in my April14, 2004 memo to your regarding this THP/TCP, until risk is quantifiedscientifically, CDF and other agencies cannot gauge effects or prevent furtherdamage to the Gualala River and its tributaries as required by CEQA. Responseto my comments, and those of others who oppose the project, show that partiespreparing these responses are unwilling or unable to understand argumentsadvanced related to CWE and confirm that they, like CDF staff, do not havecapacity to meet CEQA requirements in this regard. The Dunne et al. (2001)report is from the foremost authorities on watershed processes from theUniversity of California system and they point out systematic problems intimber harvest review and problems with dealing with CWE that are exemplifiedin this THP/TCP. The fact that this project involves a Timberland Conversionraises hydrologic impact questions even further beyond those normallyconsidered for THPs.
The statement in responses tocomments that CWE from the pending vineyard conversion “have been mitigated to less than significant” isnot credible. Since the response, like the original THP/TCP, fails to reflectthe findings of Dunne et al. (2001), I will provide the following quotes fromthe document which are applicable to attempts at CWE analysis. It is obviousthat methods of analysis have not changed since 2001, despite the advice of theU.C. systems foremost watershed science authorities.
Dunne et al. (2001) describehow mitigation such as that offered on this THP/TCP will likely be imperfectand lead to impacts, but because of the lack of effectiveness monitoring thatCWE will be untraceable, but none-the-less extant:
“However,widespread experience in most types of terrain and land uses (forestry,agriculture, urbanization, mining, etc.) has proven that mitigation by on-siteBMPs is usually imperfect, and much of the induced perturbation (say of runoffor sediment) “escapes” or “leaks” from the impoundment device or from thesurface protection, and accumulates downstream, though at a reduced level. Itis because of the limited effectiveness of on-site mitigation that CWEs havebeen identified widely by environmental scientists.”
Once again, the respondersand CDF remains use an artificially defined boundary for CWE analysis for thisproject and ignore substantial evidence of previous disturbance and aquaticstress at the scale of Little Creek, the Little Creek Calwater PlanningWatershed, Buckeye Creek and the Gualala River. Dunne et al. (2001)characterized this approach to CWE assessment:
“Theresulting ‘postage-stamp’, or ‘parcel-by-parcel’, approach, in which only theimmediate project area of a single, small timber harvest is ever reviewed. ––as all other reviewers have said — does not capture the cumulative influenceof multiple harvests over a long period of time in a large, complex watershed.”
Dunne et al. (2001) noted asignificant impediment to proper characterization of CWE in the THP reviewprocess is CDF’s “unquestioning and unverified reliance on mitigation.”
“Whilethere are clear benefits of, say, removing unstable, eroding roads, the notionthat such practices coupled with new land-use activities will avoid CWE isunsubstantiated. There has also been a reliance on untested mitigation measuresrather than an effort to documenting CWE processes. The resulting belief thatBMPs mitigate or prevent potential problems accounts for the proclivity amongmany THP applicants to assert that no cumulative effects will occur becausethey will be mitigated out of existence.”
his is exactly the approachtaken with THP 1-04-030 SON and response tocomments and it lacks scientific credibility or a basis in data collected atthe appropriate scales. This includes a complete lack of quantitative aquaticdata from Little Creek, the water body most likely impacted by this project.
The responders say that theTHP will cause the loss of some forest and have some watershed impacts, butsuch impacts are insignificant because they affect only 2.5% of the LittleCreek Calwater Planning Watershed (CPW) and “approximately 95% of the planningwatershed remains forested.” This statement does not reflect that tree size inthe basin indicates very early seral conditions, as shown by CDF and U.S.Forest Service (Warbingtron et al., 1999). Figure 1 shows the size of trees inthe Little River CPW as of
Figure 1. Tree size andvegetation types of the Little Creek Calwater Planning Watershed derived from a1994 Landsat image shows that the forest is in early seral stages. Data fromthe USFS Spatial Analysis Lab and CDF Fire and Resources Assessment Program(FRAP).
1994 according to Landsatdata. Because site potential in old growth redwood forests on the Gualala canbe in excess of ten feet (IFR, 2002), the fact that there are almost no treesgreater than 3 feet in diameter at breast height (dbh) shows that the entirearea is in early seral conditions. The fact that 30% of the watershed is intrees smaller than 12 inches shows that there has been disturbance at thatlevel in the 15 years prior to 1994. Recent timber harvests are likely tocontinue to cause erosion problems for at least 15 years after logging. Effectsfrom roads related to projects may have a much more long lasting hydrologicimpact (Quigley and Arbelbide 1997).
Reeves et al. (1993) point outthat timber harvest in greater than 25% of Oregon coastal watersheds in lessthan 30 years caused a loss of Pacific salmon species diversity. That patternof disturbance and response is extant in the Gualala River watershed asestablished in KRIS Gualala (IFR, 2002), where coho salmon have disappeared andattempts to re-establish them as recently as 1995-1998 through direct plantinghave failed as a result of CWE in the North Fork Gualala River and itstributaries.
While CDF quantifiesagricultural conversions in Sonoma County as part of CWE analysis, theirdatabase queries for CWE analysis do not even include timber harvests,presumably because they think they have been fully mitigated. The timberharvest map
Figure 2. Timber harvestspermitted in the Little Creek CPW by CDF between 1991 and 2001. Data from CDFSanta Rosa.
Figure 3. Summary chart oftimber harvest levels by CPW in the Buckeye Creek sub-basin showing most haveharvests over the recognized 25% harvest level CWE threshold demonstrated byReeves et al. (1993). Chart from KRIS Gualala and data from CDF.
what was inferred above from tree diameters, that 34% of the CWP has beenlogged in a ten year period. The addition of the 4.5% of the area of the LittleCreek CPW developed in vineyards must be considered in conjunction with thislevel of pre-existing disturbance, which is well over recognized CWE thresholds(Reeves et al., 1993). As indicated in my previous comments, there isphotographic evidence of additional, unpermitted timber harvest and conversionin this CPW and CDF and responders are failing to quantify or fully recognizethis as well.
CDF did respond to questionsI raised about unpermitted land use activities in the Little Creek CPW withuseful information. In fact CDF acknowledges illegal, unpermitted timberharvests and unpermitted vineyard conversions had taken place as well as legalconversions of parcels less than 3 acres that did not require permits. Theresponse states that one illegal timber harvester paid a “substantial fine.”Payment of fines to the State does not abate environmental problems caused bythe illegal activities. It is likely that less care was taken by illegaloperators than by those working with State agencies and CDF and that sedimentcontributions from their activities has been considerable.
Although CDF and thoseproviding comments say they are responding to my CWE concerns with regard tofisheries and aquatic habitat, indeed the additional information they havesupplied prove problems already exist. The CDF or private consultant habitat“survey” as part of Response to Comments really only represents a quickreconnaissance, but confirms my assertions of advanced CWE:
- “Pools in Little Creek tend to be shallow and silted in….
- Pools in Little Creek are intermittent due to siltation….
- Pools observed on the subject property are acting as sediment traps for fines and gravel.”
The same report documents a“load of silt not yet flushed through the system.” CDF states that itacknowledges Buckeye Creek impairment but cites NCWAP (CARA, 2002) asindicating “apparent recovery in watershed conditions.” The Gualala River WA (CARA, 2002) found compromised habitat conditions inBuckeye Creek in 2001 and, without more recently collected channel data toconfirm this “apparent recovery”, such claims lack credibility.
For Little Creek to classifyas an unimpaired water body, it would have to meet the following criteria:
- Pools frequency of 40% by length with pools greater than three feet deep in abundance,
- Water temperatures at its convergence with Buckeye Creek of less than 16.8 C MWAT, and
- Coho salmon juveniles present and steelhead juveniles of several age classes abundant, including some two year old fish.
This would indicate thatLittle Creek were a healthy freshwater ecosystem within its former range ofvariability and not suffering from CWE.
Fisheries Issues: CohoSalmon, Steelhead Trout and ESA Requirements
Fish discussions in theTHP/TCP and Response to Comments are generic, in that coho life historyinformation is not specific to the Gualala River basin and no discussions ofthe status of Gualala River coho are to be found. CDF avoids fundamentalrequirements to protect coho salmon since they are listed as Threatened in theGualala River basin under both the Federal and California Endangered SpeciesActs. Similarly, steelhead are listed as Threatened in the Gualala River basinunder Federal law, but no discussions of population status in the Gualala Basinor regionally is offered. The response to comments and CDF are still not citingthe Status Review of California Coho Salmon North of San Francisco (CDFG, 2002) after my repeated requests that thedocument be recognized, and that credible discussions regarding both coho andsteelhead be included in your reviews.
The field memo from LittleCreek provided with the Response to Comments indicates that “coho salmonhabitat in the assessment area is marginal due to the small number of deeppools and inconsistent flow levels” and that coho were not found. No methods, suchas electrofishing or direct observation (Adams et al., 1999), were discussed inthe memo and or the extent of the reach surveyed. In order to ascertain thatcoho do not occur in some years, surveys would have to be conducted for threeyears because coho are even age spawners and develop strong and weak yearsclasses as a result.
There is no indication thatthere are older age steelhead in Little Creek, and compromised pool depth wouldlikely limit carrying capacity for yearlings and two year old fish. This meansthat Little Creek has similar CWE to most Gualala River basin tributaries,which lack older age steelhead juveniles (CARA, 2002). Electrofishing at dozensof sites in the Gualala River Basin in 2001 caught very few large steelheadjuveniles. This is important because steelhead must spend one or two years infreshwater before entering the ocean in order to survive as adults (Barnhart,1986).
As I have pointed out in pastcomments, Buckeye Creek and Little Creek are both of sufficiently low gradientsthat coho salmon would have been at least a co-dominant salmonid species inboth streams. The lack of attention to population viability under ESA alsoshows negligence in terms of CWA requirements. No land use activities should beallowed to further degrade either Little Creek or Buckeye Creek until they aresupporting a cold water fishery, including both coho salmon and steelheadjuveniles, CWA “beneficial uses.”
Roads and CumulativeWatershed Effects and THP 1-04-030 SON
Road discussions again showthe incapacity of responders to grasp yet another critical CWE issue. The roaddensities in the Little Creek CPW are 8 miles per square mile of watershed area(Figure 4), which is very high with regard to CWE risk as defined by theNational Marine Fisheries Service (1996). They recommended that densities belimited to less than 2.5 mi./sq.mi. with no streamside roads.
Cederholm et al. (1981)showed that major damage was done to watersheds when road densities exceeded4.7 mi./sq.mi. and that sediment yield to streams was on the order of 2.6 to4.2 times the natural rate of sedimentation. CDF does not provide aquantitative assessment of sediment from roads anywhere in the THP/TCP nor doesthe Response to Comments. This ignores well founded science provided as part ofthe Gualala River Technical TMDL(CA SWRCB, 2001) indicating elevated, man-caused erosion from roads. Thoseresponding to comments should recognize these pre-existing impacts and CDFshould consequently deny further development requests until results frommonitoring of stream channels indicate recovery.
Figure 4. This chart showsthe density of roads in miles per square mile for Buckeye Creek watershed witha reference line of 2.5 mi./sq. mi., which is slightly above NMFS (1996) properlyfunctioning watershed condition level for Pacific salmon. Little Creek has oneof the highest road densities in the Gualala River basin. Data from U.C. DavisICE and North Coast Regional Water Quality Control Board.
The U.S. Forest Service (USFS, 1996) considered road densities greater than4.7 mi./sq. mi. “Extremely High” in terms of potential aquaticimpacts in the Interior Columbia River Basin (Figure 5). Their reference wasderived by comparing data for bull trout and other salmonid species with roaddensities over 3,000 watersheds. They concluded that “the higher the roaddensity, the lower the proportion of sub-watersheds that support strongpopulations of key salmonids” and that bull trout were absent fromwatersheds with more than 1.7 mi./sq. mi. of watershed area. They alsofound a relationship between fine sediment in streams and roaddensity. Quigley and Arbelbide (1997), also in the Interior ColumbiaBasin, found “increasing road densities (combined with the activitiesassociated with roads) and their attendant effects are associated with declinesin the status of four non-anadromous salmonid species.” Jones and Grant(1996) noted that road cuts disrupted subsurface flows and routed them tostreams, which increases flood frequency.
Figure 5. Road density classifications, in miles of road per square mile(mi./sq. mi.), are from USFS (1996) Figure 9 and represent risk to sensitiveaquatic species. Note also that they categorize as Extremely High roaddensities of 4.7 mi./sq. mi. andgreater and that the Little Creek CPW has nearly double that.
In response to my comment that the THP and TCP had failed to dealeffectively with CWE related to roads, responders acknowledged that there weresignificant problems with the Little Creek-Flournoy Road, but they were beingfixed. This shows a patent misunderstanding that similar problems exist onvirtually all roads and there are dozens of miles of roads in just the LittleCreek CPW alone. As I pointed out before, the road densities are conservativeestimators of disturbance with potential for surface erosion because they donot reflect temporary roads, skid trails or landings.
At other places in the THP/TCP and in Response to Comments it is noted thatthe road that parallels Little Creek has been abandoned because of stream sidelandslides. CDF and those responding to comments seem to think that justwalking away from such a road prism means that sediment will no longer becontributed to streams. It is likely, however, that this old road bed will continue to erode unless it isrecontoured and planted with trees. It also represents a major pre-existingsediment source only recognized by CDF late in the review process. There isdiscussion of getting grant money for fixing the Little Creek-Flournoy Road andthis is taken as mitigating road problems off site. It is inappropriate to beusing public money to fix a private land road and then count it as mitigationthat allows further development.
Those responding to comments,like CDF before them, continue to miss the connection between sediment andwater temperature. As Dunne et al. (2001) point out, there is almost always“leakage” from mitigation measures, so sediment from the THP/TCP area is likelyto reach Little Creek. CDF has established that Little Creek is suffering fromadvanced CWE, with silt-filled, shallow pools and loss of surface flows due tomassive aggradation. Filling of streams with sediment changes the width todepth ratio and increases heat exchange, which results in stream warming (Pooleand Berman, 2000). The continued reiteration by CDF and the responders thatstreams do not cross the property, that there is no riparian removal associatedwith this project and, therefore, the THP/TCP cannot warm the stream isincorrect.
The responders and CDF arealso missing a second well recognized mechanism for stream warming. Brosofskeet al. (1997) found that soils warmed in response to vegetation removal andthat ground water temperatures also warmed. Changes in ground water temperaturesin turn warmed spring flows and adjacent stream reaches. These mechanisms arealso likely to cause additional warming to Little Creek for which no actualtemperature data are available.
While substantial quantitiesof information have been filed by the proponents of THP1-04-030 SON and TCP-530, there are still fundamental flaws in argumentsregarding likely effects on surface flows from this project. I am not ahydrologist so I will restrict my remarks to the mechanism that I know willoperate to reduce surface flow.
I havedescribed in previous comments how the Gualala River and its tributaries havelost surface flow because aggradation of the stream bed is so severe that flowsnow percolate through the gravel bars in late summer and fall. The Response toComments notes that Little Creek loses surface flow, which is consistent withsubstantial, pre-existing sediment pollution. Additional sediment from thisTHP/TCP will continue the pattern of sediment yield over background, and thus furtherdegrade Little Creek and cause it to lose surface flow earlier in the seasonand ultimately to lose all function as fish habitat. This is a text book casefor CWE and, as an issue on its own, should cause CDF to turn down this projectand ones similar until Little Creek has recovered.
In my previous comments, Ihave supplied a scientific basis for CWE assessment, including watertemperatures required by coho salmon (Welsh et al., 2001), for fine sediment inspawning gravels (McHenry et al., 1994) and for pool frequencies (CDFG, 1998).In my response here I have acquainted CDF staff with new literature from theColumbia Basin on CWE thresholds and roads (USFS, 1996; Quigley and Arbelbide,1997) and how sediment affects temperature (Poole and Berman, 2000).
I have provided data to showthe compromised quality of Buckeye Creek and CDF or project proponents have nowdemonstrated advanced CWE in Little Creek. Unfortunately, as Dunne et al.(2001) pointed out, CDF, other agencies overseeing and those responding tocomments on this THP/TCP lack the professional capacity to deal with the issuesI have raised.
CDF and the plan proponentshave failed to supply data that show functional aquatic habitat conditions inBuckeye Creek or Little Cree or support of beneficial uses, to prove that CWEare not extant. Dunne et al. (2001) point out that regionally recognized CWEstandards should be acknowledged and applied:
“If there are specific scientific limits(such as a lethal stream temperature for fish or a threshold fine-sedimentconcentration for spawning beds), RPFs are expected to know this and to applyit in the context of the rules and in protecting beneficial uses of water. Ifthe RPF doesn’t know or apply existing knowledge, reviewing agencies have theduty to require additional mitigation.”
The appropriate mitigation inthe case of the THP 1-04-030 SON, especially inlight of the widespread adjacent illegal activity in the plan area, is that thepermit should be denied until the Little Creek and Buckeye Creek watershedshave been allowed to recover their watershed health and they are meeting CWArequirements, such as supporting coho salmon and steelhead juveniles ofmultiple age classes.
Dunne et al. (2001) argue forassessment of CWE risk to be removed from the hands of CDF staff. The lack ofcapacity of CDF staff, despite having data tools such as the preceding NCWAPreport (CARA, 2002) and the KRIS Gualala database, demonstrates that CDF andother agencies may need to acquire additional staff with advanced degrees inwatershed science and conversant in the us of cutting edge analysis tools asrecommended by Dunne et al. (2001).
Unfortunately, CDF staff andthose responding to comments do not appear to be reading literature cited in mycomments and those of others and, thus, refusing to recognize advancements inunderstanding of CWE regionally. Contrary to the following statement by Dunneet al. (2001), CDF is not faced with decisions where scientific literature isnot available to support decisions:
“CWEanalysis, like all other human endeavors, will have to be conducted rationallyin the face of these uncertainties. Some people will be skillful at this, andwill remain well informed as the technology evolves; others will remain confusedand be unable to proceed because the scientific literature does not contain theanswer to their specific question.”
CDF staff could study recentscientific literature on cold water fisheries and forestry interactions andmake more informed decisions on this THP/TCP. Their failure to do so and,therefore, to properly assess risk of CWE is insufficient to meet the standardsof CEQA..
CDF is now largely defendingpositions espoused by consultants for project proponents, even though expertswith credentials far exceeding those of these consultants, such as Dr. DonErman and Dr. Michael Johnson, are pointing out major flaws in logic andscience. CDF and CDFG have not collected or presented data on the fisheries orwater quality of Little Creek to show that it is in a non-degraded condition,not suffering from cumulative watershed effects problems, and, therefore, ableto sustain additional impacts.
In fact, additionalinformation provided late in the process of review of THP 1-04-030 SON and TCP-530establish that Little Creek is similar to other Gualala River tributaries andshowing advanced signs of CWE, such as loss of surface flow. This is exactlythe response that would be expected given the high degree of legal and illegaldevelopment and land alteration that has taken place in the watershed.
Four yearsafter the publication of the Dunne et al. (2001) report, where the bestUniversity of California watershed scientists pointed out deficiencies in CDF’sapproach to cumulative watershed effects analysis, the agency and process arestill showing the same flaws. I believe that CDF and the other agenciesinvolved in review are wasting a huge amount of money in defending projectsthat benefit private parties, but threaten to drive fish stocks in the GualalaRiver to extinction, and that patently violate CEQA and the Clean Water Act. Itmay be time to contract with the University of California for field studies inthis basin to define CWE thresholds, existing levels of impacts, and recommendationsfor limits to disturbance, instead of just continuing to fund agencies thatlack the capacity to deal with the issues at hand.
CC: Allen Robertson, DeputyChief
California Department ofForestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244-2460
Adams, P.B. , M.J. Bowers, H.E. Fish, T.E. Laidig, andK.R. Silberberg. Historical and Current Presence-Absence of Coho Salmon(Oncorhynchus kisutch) in the Central California Coast Evolutionarily SignificantUnit. Southwest Fisheries Science Center
National Marine Fisheries Service, Santa Cruz, CA. 28p.
Barnhart, R. A. 1986. Species profiles: life histories and environmentalrequirements of coastal fishes and invertebrates (Pacific Southwest)–steelhead.U.S. Fish Wildl. Serv. Biol. Rep. 82(11.60). U.S. Army Corps of Engineers, TREL-82-4. 26 pp.
Brosofske, K. B., J. Chen, R. J. Naiman, and J. F. Franklin. 1997.Harvesting effects on microclimatic gradients from small streams to uplands inwestern Washington. Ecological Applications 7(4):1188-1200.
Ca. Department of Fish and Game. 1998. California Salmonid Stream HabitatRestoration Manual. Third Edition. Inland Fisheries Division. CaliforniaDepartment of Fish and Game. Sacramento, CA. 495 pp.
California Department of Fish and Game. 2002. Status Review of CaliforniaCoho Salmon North of San Francisco. Report to the California Fish and Game Commission. California Department ofFish and Game, Sacramento , CA. 336pp.
California Resources Agency. 2002. Gualala River Watershed Synthesis. CADept. of Fish and Game, State Water Res. Control Bd., CA Dept. of WaterResources, CA Div. on Mines and Geology and CA Dept. of Forestry. Sacramento,CA.
California State WaterResources Control Board. 2001. Technical Support Document for the Gualala RiverWatershed Water Quality Attainment Action Plan for Sediment. CRWQCB, Region 1.Santa Rosa, CA. 147 pp.
Cederholm, C.J., L.M. Reidand E.O. Salo. 1981. Cumulative effects of logging road sediment on salmonidpopulations of the Clearwater River , Jefferson County, Washington. Pages 38-74in Proceedings of Conference on Salmon Spawning Gravel: A Renewable Resource inthe Pacific Northwest? Report 19. Wash. State University, Water ResearchCenter, Pullman,WA.
Institute for FisheriesResources. 2003. KRIS Gualala Database and Map Project Two CD Set. Funded bythe California Department of Forestry FRAP, Sacramento, CA. (Also on theInternet at www.krisweb.com).
Jones, J.A. and G.E. Grant.1996. Peak flow response to clear-cutting and roads in small and large basins,Western Cascades, Oregon. Water Resources Research, April 1996. Vol. 32, No. 4,Pages 959-974.
McHenry, M.L., D.C. Morrilland E. Currence. 1994 . Spawning Gravel Quality, Watershed Characteristics andEarly Life History Survival of Coho Salmon and Steelhead in Five North OlympicPeninsula Watersheds. Lower Elwha S’Klallam Tribe, Port Angeles, WA. and MakahTribe, Neah Bay, WA. Funded by Washington State Dept. of Ecology (205J grant).
Poole, G.C., and C.H. Berman.2000. Pathways of Human Influence on Water Temperature Dynamics in StreamChannels. U.S. Environmental Protection Agency, Region 10. Seattle, WA. 20 p.
Quigley, T.M. and S.J.Arbelbide (Eds). 1997. An Assessment of Ecosystem Components in the InteriorColumbia Basin And Portions of the Klamath and Great Basins: Volume I. U.S.Forest Service and U.S. Bureau of Land Management with assistance from thePacific Northwest Forest Experiment Station. PNW-GTR-405. Pages 1-351.
Reeves, G.H., F.H. Everestand J.R. Sedell. 1993 . Diversity of Juvenile Anadromous Salmonid Assemblagesin Coastal Oregon Basins with Different Levels of Timber Harvest. Transactionsof the American Fisheries Society. Vol 122, No. 3. May 1993.
Warbington, R., B. Schwind,C. Curlis and S. Daniel. 1998. Creating a Consistent and StandardizedVegetation Database for Northwest Forest Plan Monitoring in California. USDAForest Service. Pacific Southwest Region Remote Sensing Lab. Sacramento, CA.
Welsh, H.H., G.R. Hodgson,M.F. Roche, B.C. Harvey. (2001). Distribution of Juvenile Coho Salmon(Oncorhynchus kisutch) in Relation to Water Temperature in Tributaries of aNorthern California Watershed Determining Management Thresholds for an ImpairedCold-water Adapted Fauna. In review for publication in the North AmericanJournal of Fisheries Management. 21:464-470, 2001.
U.S. Forest Service. 1996.Status of the interior Columbia basin: summary of scientific findings. Gen.Tech. Rep. PNW-GTR-385. Portland, OR: U.S. Department of Agriculture, Forest Service, PacificNorthwest Research Station; U.S. Department of the Interior, Bureau of LandManagement. 144 p.