Letter to CDF re: Haupt Creek THP

Anthony Lukacic
California Department of Forestry
135 Ridgway Ave.
Santa Rosa 95401

5 May 2003

Notes for 2nd Review of 1-00-484
Revised draft

I have been retained as a watershed specialist and professional forester to review THP 1-00-484 by the Friends of the Gualala River. I have not been on the ground of this THP and make the following brief comments based on review of the submitted THP and addenda, RWQCB comments and DFG comments. Some of these points may have been addressed in first review. These points are followed by recommendations.

1. Acreage (p. 5). The total acreage is misstated. WLPZ harvest area has been specifically excluded from the total of 37 acres, and accounts for 12 acres of selection logging.
2. Acreage (p. 5) The total acreage does not include the area between the road on Ohlsen (to the north) and the harvest plan. The landings, cable settings and cable corridors are part of the plan; they cannot be out of the plan. See also THP boundary map (p. 28). Note that Mr. Ohlsen is designated as an additional landowner for this THP, but his requirements will extend beyond road maintenance.
3. Tractor restrictions for layouts and assist (p.11). Here and on the map (p. 32), it is proposed that tractors will not be on excessively steep slopes and landslide areas. This is contrary to the contour intervals shown and the slope stability map (Huffman, 1980; attached), a publication referenced in Coyle’s geologic report.
4. Road pitch – length (p. 17). Item 24.c. is contradicted by the attached map (p. 30) which shows 500 feet of road greater than 15% (approaching 40% by contour evaluation). Please note that the proposed steep pitch is indicated to be in a swale, likely a class III channel.
5. Listed Species ID (p. 22). Item 32 indicates that LTO and workers will halt work and notify DFG when a listed species is found. DFG notes that red tree voles are present on the site. No training for LTO and staff is mentioned, so there is no demonstration that workers will actually see signs of listed species.
6. Silviculture and yarding (p. 28) Map does not indicate slide areas noted by Huffman or Coyle. Huffman’s slope stability map indicates significant slides within area, known and expected. Water Quality statements suggest sliding occurs readily on unstable ground, and slopes lead directly to the stream. Excessive sedimentation could result from an unmodified plan.
7. Road placement (p. 30) Roads will cross landslide areas designated by Huffman. Road to the north will enter and exit Bf delineation, determined to be unstable at its margins. Concerns are consistent with Water Quality’s photographs of slides at plateau edges.
8. Alternatives (p. 61). Public purchase statement says this area is not unique or special. Old growth in Sonoma is extremely unusual, and the RPF needs to acknowledge this. This site may be well worth public preservation.
9. The Watershed Assessment Area is not well suited to this plan area. Upstream areas are not included, while downstream and areas and out-of-watershed areas are in.

Recommendations:

1. No harvesting on mapped landslides.
2. No road construction or reconstruction on mapped landslides.
3. Mitigate road crossings of Bf slope stability boundary on Ohlsen (northern) part of plan and road system.
4. Limit heavy equipment as in § 914.2 (f)(1)(iii) with regard to ‘slopes > 50% which lead without flattening…’ The southern portion of the plan appears to contradict this rule on the THP map.
5. Remeasure distance of road slope already noted as >15% to ensure no pitches longer than 500 feet.
6. Redraw Watershed Assessment Area to meaningfully include upstream watershed.
7. Identify methodology for protecting Sonoma Tree Voles, either by training tree markers, tree fallers or using an independent biologist.
8. Expand THP boundary to include landings and setups for cable area on Ohlsen, to the north. Notify Ohlsen of responsibility respective to Forest Practice Rules.

These comments are respectfully submitted for comment. If you have questions or wish further information, please contact me.

Sincerely,

Fred Euphrat, Ph.D. RPF 2365
for Friends of the Gualala River