Western Watershed Analysis of The Mendocino Redwood Willow Creek THP

The following is an analysis of some of the cumulative impact ramifications of THP 1-99-100Son:

1. We know from historical data that the Willow Creek river channel was an abundant anadromous fish spawning area. From existing studies and ongoing research we now can identify this channel as severely sediment impaired and of high-risk status for (at least) the Coho Salmon. Coho Salmon have been listed by National Marine Fisheries Services as threatened under the Endangered Species Act.

2. We also know from current and past studies on the Willow Creek channel that a large percentage of the downstream sediment problems come from timber harvesting in the upper watershed. There have been 13 THPs in the last ten years in this watershed. Forest Practice Rules (898.2) state: "The director shall disapprove a plan not conforming to the rules . . . if implementation of the plan as proposed would result in either a "taking" or finding of jeopardy of wildlife species listed as rare, threatened or endangered . . ." Department of Fish and Game was not a part of the review team, nor was any input from that department on the fisheries issue included in the THP. Given the state of this watershed, this seems a major oversight.

3. THP 1-99-100SON and 1-99-136SON propose harvesting in 442 acres of the Willow Creek watershed. In light of the above federally mandated restrictions prohibiting significant adverse impacts, it is the responsibility of the plan submitter to show that there will be no significant cumulative impacts. It is the responsibility of the California Department of Forestry to enforce this prohibition.

4. The primary underlying premise of THP 1-99-100SON (and its companion 1-99-136SON) is that proposed remedial actions included in the plan will somehow offset the short-term increase in sedimentation that they predict. By this assertion they conclude that the proposed operations have no reasonable potential to cause or add to significant cumulative impacts. They do not identify how many months or years "short term" identifies. The mitigations include reparations to road crossings and unstable areas. No quantitative assessment was used to estimate the potential for these mitigations to reduce the accumulation of sediment in Willow Creek. No quantitative assessment is offered to measure the potential for the harvesting operations to increase sediment. Even if this assertion were correct, a determination has not been made as to whether conformance with the Forest Practice Rules will sufficiently protect Coho.

5. Since no data has been offered to support the speculative assertion that there will be no significant impact from this THP, we must assume that there most certainly will be a high probability for such impacts due to the natural process of harvesting timber. Such impacts would disqualify this plan as not being in conformance with CEQA guidelines.

Submitted by Pieter S. Myers
Western Watershed Allianace

To the Western Watershed Alliance's recent letter

To the TRO legal filing by Kimberly Burr of The Northern California Environmental Defense Center

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