Elk County Water District
Post Office Box 54
Elk, CA 95432
December 17, 1996
Louisiana Pacific Corporation
POB 489/32600 Holquist Ln
Fort Bragg, CA 95437
Dear Mr. Schultz:
Thank you for attending the ECWD meeting on September 4, and for providing us with
pages 9-13 of Louisiana Pacific's draft Sustained Yield Plan for Greenwood Creek. The
following discussion of ECWD concerns is based on a review of the full first draft of the
SYP for Greenwood Creek and a document dated May 5, 1996, which contains state
agency questions and L-P responses regarding the overall SYP.
Our main areas of concern about the Greenwood Creek SYP are organized below into
problems and solutions. The problems are as follows: 1, 2 & 3) the lack of water quality
standards and monitoring; 4) the use of herbicides and pesticides; 5) the artificial division
of Greenwood Creek into two "planning watersheds" (upper and lower) with different
"relative risk" ratings and different levels of mitigation; 6) low risk rating scores for the
fishery and for erosion potential, which also appear to lower the overall level of mitigation;
7) inconsistency and confusion of the risk rating system; 8) errors about ECWD storage
capacity and the risk of flooding; and 9) quality of the data in the risk rating system.
1. PROBLEM: no water quality standard
- The draft SYP does not establish a standard for water quality or quantity for Greenwood
Creek. Without such standards, it is impossible to evaluate the methods, goals and proposed
mitigation measures of the SYP as they may affect the public water supply for the town of Elk.
- One page 12 (paragraph 2), the draft Greenwood Creek SYP states that
- "The impacts of increased sediment yields due to forest management activities have
implications for soil productivity, channel morphology, fisheries, and other beneficial
water uses. Institution of Best Management Practices to minimize erosion and sediment
yield can be expected to limit potential impacts." [our emphasis]
- The U.S. EPA has refused to certify California forest practice rules as Best Management
Practices (BMPs), largely because of water quality concerns. To the extent that L-P goes
beyond those rules to protect Greenwood Creek water quality, L-P is to be applauded.
However, the goals of L-P's BMPs remain unacceptably vague. Without measurable
standards for water quality and water quantity, words such as "minimize" could mean just
about anything. The intent of limiting potential impacts is laudable, yet the SYP does permit
some level of impacts and does not say what the limits will be, nor what standard they will
be judged by.
- Part of the solution can be found within the SYP itself, which states
- "Where possible, quantify the water quality requirements for each facility and
determine a range of desirable conditions of water quality for each identified
- (SYP - Watershed Analysis: Beneficial Water Use Assessment Methods, p.1)
- This assessment goal is stated in the watershed assessment methods section but it has
not been carried out in the Greenwood Creek SYP. The key word, from our point of
view, is "quantify." Drinking water standards are quantifiable and should be the basis
for determining the "range of desirable conditions of water quality" for Greenwood
Creek. A time-line with specific water quality/quantity goals should be laid out.
2. PROBLEM: no water quality and water quantity monitoring plan
- The draft SYP does not have a plan for monitoring the water quality or quantity of
Greenwood Creek, nor does it provide any means by which to determine the
effectiveness of mitigations.
- Once again the SYP contains the seed of the solution. In a section called "Products of
assessment" (Sustainable Forestry Program - Watershed Analysis: Beneficial Water
Use Assessment Methods, p. 3), the following product is listed:
3. PROBLEM: use of water quality monitoring stations
- "A mitigation and monitoring plan."
- While the ECWD measures turbidity at one site near the town well (and in the well),
and is certainly willing to share this information with L-P, these turbidity measurements
are not sufficient to determine the impacts of specific upstream management projects
nor the effectiveness of specific mitigations. The SYP should include additional
monitoring of the following: (pollution) turbidity, temperature, herbicides/pesticides;
(characteristics of stream flow and stream channel) peak flows, low flows, total water
yield, stream cross-sections; (sediment) bedload, suspended load, total sediment load.
- The SYP/SFP directs the assessment team to "Determine which watersheds should be
tracked by a monitoring program" (page 4). Page 4 also states
- "Evaluate the potential for restoring impacted streams and improving
water quality." (#2)
- "Discuss restoration and enhancement measures that can be used to
correct problems." (#2b)
- L-P's plans to restore impacted streams and improve/enhance water quality should
be included in the SYP and spelled out in detail with a time-line. (The "Additional
Management Requirements" table does not include stream restoration, and the
table's implementation schedule and priorities for other mitigations are unclear vis a
vis Greenwood Creek. See PROBLEM #7: the risk rating system.)
- L-P maintains two water quality monitoring stations in Greenwood Creek but only uses
them for temperature monitoring. The SYP ranks fish habitat at "low/moderate" risk
and the beneficial use of water at "very high risk," yet does not use these stations to
gather data on the "very high" risk use.
- L-P should institute a monitoring plan for the highest risk use, not the lowest.
4. PROBLEM: use of herbicides and pesticides
- The SYP states that pesticides and herbicides will be used in Greenwood Creek watershed.
It discusses this matter in one brief paragraph which fails to answer any of the questions
that are of concern to the ECWD. Some of these questions are as follows:
- What types of pesticides and herbicides will be used, with what frequency and
intensity? How will pesticides be applied? What is the basis for determining the safety
of ground-based methods of herbicide application? What chemical changes occur in
these toxins, individually or in combination, as they leach into the soil from decaying
vegetation, and as they move through ground water or surface water? What is the
potential for increased toxicity from the combination of different types of herbicides (or
pesticides)? Which toxins will be mixed together?
- What plans does L-P have for notifying the ECWD of the use of toxic substances that
may impact the Elk town water supply? What sort of warnings, notifications and
protections will be provided to nearby residents and to workers?
- What is the meaning of the word "currently" in the follow sentence: "Currently,
herbicide use is excluded from the Class I and Class II Watercourse and Lake
Protection Zones (WLPZ) and from 20-foot buffers among Class III watercourses."
(Does L-P plan to use these toxins within stream protection zones at some future time?
If so, when and why?)
- The California Department of Forestry has repeatedly stated that it "doesn't do
herbicides." By its own admission, CDF has no expertise or inclination to evaluate the
cumulative effects of herbicide-intense logging practices. This SYP therefore needs to
be reviewed by agencies that "do herbicides," such as Cal-EPA.
- L-P should not use pesticides and herbicides in Greenwood Creek watershed. With a
town's water supply at risk, there is simply no room for mistakes when it comes to
5. PROBLEM: division of Greenwood Creek into two parts; impact on WRR/mitigations
- The SYP separates Greenwood Creek into two "planning watersheds"--Upper
Greenwood and Lower Greenwood--and combines these with an unrelated watershed,
Cuffey's Point, to create WWAA 84 (watershed and wildlife assessment area). Several
ECWD concerns about the SYP are connected to this artificial creation, WWAA 84.
- What is the rationale for dividing Greenwood Creek (which is one continuous watershed
of relatively small size - 15,600 acres) into two parts? How was the dividing line
chosen? What is the justification for giving lower Greenwood Creek and upper
Greenwood Creek different risk ratings? What will be the practical impact on ratings and
mitigations of combining Greenwood Creek watershed with Cuffey's Point watershed?
- Upper Greenwood Creek and lower Greenwood Creek form one continuous drainage
system which together supply water to the town of Elk. They are not separate; they are
one watershed. Lower Greenwood Creek, and the ECWD water wells, will be the
direct recipient of impacts of management activities in the upper watershed.
- Cuffey's Point watershed is unrelated to Greenwood Creek watershed and has no direct
impact upon it. It is also very different from Greenwood Creek. Cuffey's Point has
far less L-P acreage, far less timber land, and, unlike Greenwood Creek, it apparently
contains no Coho salmon. The SYP artificially combines Cuffey's Point with Upper
and Lower Greenwood and gives this WWAA a combined WRR index of "moderate."
This "moderate" rating does not reflect the critical nature of the beneficial uses of
- We had trouble understanding what the WRR (watershed relative risk) index is for
upper Greenwood Creek, lower Greenwood Creek and for Greenwood Creek
watershed as a whole. We're still not sure what the ratings are. (See below,
PROBLEM #7: the risk rating system.) But it does seem to be apparent that the
artificial division of Greenwood Creek into two "planning watersheds" has serious
implications for the ECWD.
- For instance, lower Greenwood Creek is apparently given an overall WRR (watershed
relative risk) index of "high," while upper Greenwood Creek is given a WRR index of
"moderate." These ratings are important because they determine the level of mitigations
that are set forth in the "Additional Management Requirements" table. A "high" rating
will receive significantly less attention from management than a "very high"; a
"moderate" receives even less than that.
- A "very high" rating would require "50 ft. WLPZ on Class III Streams" (which means
no-cut zones for Class IIIs, except for old growth trees). It would appear that upper
Greenwood Creek will definitely not receive this protection, and that lower Greenwood
Creek might receive it--depending on whether or not lower Greenwood's "very high"
risk rating for beneficial use of water corresponds to the "very high" level of mitigation
(in the "Additional Management Requirements" table), or is dilluted by the "moderate"
risk rating for upper Greenwood Creek and by the "low/moderate" risk rating for fish.
- A recent timber harvest plan in lower Greenwood Creek included involvement of a
registered geologist (a "very high" risk mitigation), but did not include the Class III no
cut zones. The application of mitigations based on the WRR index seems inconsistent.
- A "very high" would require a "watershed plan for road improvement/closure and
density reduction" by 1997 and improvement actions in road maintenance by 2001.
A "high" gives later deadlines to these requirements--1999 and 2006, respectively.
A "very high" requires a "complete inventory of road conditions" by 1996. "High"
is given until 1998. A "moderate" rating has delayed schedules for everything, no
plan for proactive road maintenance, and it schedules improvement actions only in
connection with THPs.
- The SYP does not make clear how these mitigations will apply to Greenwood Creek,
nor what the impact will be of managing upper and lower Greenwood Creek as if they
were separate watersheds.
- The SYP states that "All three planning watersheds drain into the Pacific Ocean near
Elk, California." This statement creates a false picture of Greenwood Creek. Upper
Greenwood Creek flows from the Greenwood Creek headwaters near Signal Ridge,
down a steep gradient, and becomes lower Greenwood Creek, near Elk, where
Greenwood Creek drains into the Pacific. The upper part of the Creek does not drain
separately into the Pacific.
- Debris flow torrents, sediment generation, landslides, surface erosion, elevated water
temperature, hydrological changes, and summer and winter flows in upper Greenwood
Creek, and any management activities that affect these conditions, have a direct impact
on lower Greenwood Creek.
- Upper and lower Greenwood Creek should be treated as one "planning watershed"
with a WRR of "very high" considering that they together provide the sole source of
water for the town of Elk.
6. PROBLEM: "low/moderate" risk for Coho fishery and for hillslope disturbance
- In addition to the beneficial use of domestic water, there are several other components
that go into the WRR index, namely the "Hillslope Disturbance" scores and the "Fish
Habitat/Channel Sensitivity" scores. These other scores are all determined to be "low"
or moderate," and the combined result seems to be to lower the WRR index and to
decrease the level of concern in the "Additional Management Requirements" table.
- According to the SYP, Greenwood Creek contains Coho salmon and more than 16
miles of Coho salmon habitat. The SYP gives a "low" overall risk rating for fish
habitat for WWAA 84, on page 3, although Table 2 says "moderate."
- Whether the rating is "low" or "moderate," this rating is too low, given the recent EPA
listing of the Coho salmon as a "threatened" species in our area. The SYP combines
these surprising "low/moderate" ratings of the risk to the Greenwood Creek fishery
with the "very high" risk rating for domestic water use, for a Combined WRR index of
"moderate." The low fish ratings therefore have a direct impact on the ECWD as they
will influence the level of mitigations that are triggered by these ratings.
- Lower Greenwood is given a fish habitat risk rating of "low." Upper Greenwood,
"moderate." Cuffey's Point, "low." We don't understand the different fish habitat
ratings for upper and lower Greenwood. They both have Coho. They both have Coho
salmon habitat problems.
- The risks for water quality and for the fishery are intimately related, as are the
mitigations for these two resources. If the risk to the beneficial use of water is "very
high," then the risk to the fishery is also "very high." Certainly, a "low/moderate" risk
rating for the fishery should not be used to downgrade the level of concern for domestic
water use. The two resources needed to considered together.
- The scores for "Hillslope Disturbance," which include "hillslope stability," "road
stability" and "potential hillslope disturbance," are also all said to be "low" or
"moderate," and serve to lower the overall risk index.
- These "low/moderate" scores are also surprising, given the general steepness and
erodable soils of Greenwood Creek watershed. On page 9, paragraph 6, the
Greenwood Creek SYP states that, "Generally, the EHR (erosion hazard rating) map
displays predominantly high erosion conditions." Then, in paragraph 8, the SYP states
that, "These tables (Tables 12 and 13) indicate that all planning watersheds
predominantly exhibit a stable to moderately stable environment."
- We don't understand how Tables 12 and 13 convert "high erosion" conditions into a
"moderately stable" environment.
- The quality of information that went into the WRR index is questionable. It did not
include a comprehensive survey of roads or landslides, nor study of historical aerial
photos, nor empirical data on erosion rates and sedimentation. (See below, PROBLEM
#9: quality of the data).
- Given the EPA listing of the Coho salmon, the risk to the Greenwood Creek fishery
should be upgraded to "very high." With two critical resources at serious risk, the
overall risk index should also be "very high." The "Hillslope Disturbance" scores
should be discounted until better information is available.
7. PROBLEM: the risk rating system
- The risk rating system (WRR index) is difficult to understand and its implications are
unclear. What it appears to mean for water users in the town of Elk is that the quality
of their drinking water will be of less concern to L-P management than it should be,
due the SYP's combining and averaging out of various risk factors, including the risk
factors in an unrelated watershed (Cuffey's Point).
- We cannot determine from the rating system if lower Greenwood Creek would be a
"high" or a "very high" on the "Additional Management Requirements" table. In any
case, even with lower Greenwood Creek receiving a "very high" risk rating (and
mitigations) for water quality, if upper Greenwood Creek is a "low," "moderate," or
"high," then the combined effect on management activities will be to lessen the
protections for lower Greenwood Creek (since the upper watershed directly influences
the lower watershed).
- On page 3, the SYP states that the "overall combined WRR" for WWAA 84 is
"moderate." The overall WRR for fish is said to be "low" on page 3 although it is
listed as "moderate" in Table 2. The "Beneficial Use" WRR for lower Greenwood
Creek is said to be "very high," with upper Greenwood Creek rated as "moderate" and
Cuffey's Point as "low," although the beneficial use score (under "Resource
Sensitivity") is listed, in Table 2, as "very high" for all three watersheds.
- The page 3 narrative then gives a "composite rating" of "high" (as per formula or
policy) for all three watersheds, for all uses. The "high" composite WRR is also
qualified as follows: "These results suggest that resource protection efforts should
focus on the Lower Greenwood Creek planning watershed."
Greenwood Creek forms one continuous drainage system. Resource protections need
to be determined for the watershed as a whole. The upper portion of the watershed
needs to be given equal resource protections, since it directly impacts the lower portion.
- Additional suggestions: Clarify the relationships among the various WRR scores and
indexes. Clear up discrepances. Carefully edit both the narrative text and the tables.
Spell out the relationships among scores, indexes and mitigations. Clear up the
confusing use of word synonyms, such as "combined/composite/overall" and
"score/rating/ranking/ index." Define the meaningful, on-the-ground, management
implications of these words. Consider simplifying this rating system.
8. PROBLEM: error regarding ECWD storage capacity, and the risk of flooding
- On page 5, the draft Greenwood SYP states that,"The water system is forced during
high turbidity periods to rely on storage capabilities. The system storage capacity is
approximately one week." These statements are incorrect.
- The ECWD storage capacity is approximately four days (not one week) during winter
and is less in summer. ECWD well no. 2 is sometimes used during peak flows.
Suggested rewrite: "The water system is sometimes forced during high turbidity
periods to rely on storage capabilities. The system storage capacity is approximately
four days during winter, and less in summer."
- On pages 11-12, the draft Greenwood Creek SYP states that
- "Since vegetation removal results in a temporary decrease in evapotranspiration losses
from a watershed, increases in annual water yield could be expected due to timber
harvesting activity. However, a review of 94 catchment studies indicated that
increases in annual water yield cannot be detected if there is less an 20 percent
reduction in watershed forest cover (Bosch and Hewlett 1982). As noted by Ziemer
(1987), if more than 20 percent of a watershed forest cover is removed, increases in
annual water yield may occur but generally will be too small to detect. In addition,
most of the increase in annual water yield will occur during the winter high runoff
season and during wetter years (Ziemer 1987, Keppler and Ziemer 1990)."
- The risks to the ECWD of increased water yield are twofold: 1) the dangers of
flooding are more acute in this watershed due to its steepness; 2) ECWD well no. 1 is
already seriously threatened by stream bank erosion.
- These risks may be slight to L-P but they are not slight to Elk town water users who
rely on what is, at best, a four day storage capacity in winter, and possibly only a day
or two in summer. In other words, the town of Elk, with all of its bed and breakfast
inns, restaurants and residents, is one to four days from disaster. For this and other
reasons, the issue of water yield is a critical one for the ECWD.
- The Ziemer study is one among many studies on this issue. It involved an experimental
forest which may or may not be comparable to Greenwood Creek. Estimates of
increased water yield should be specific to this Creek, and should include impacts of
roads and skid trails on water yield as well as the recovery rate for this forest. Drought
conditions should also be evaluated.
- Most of the SYP's statements on Greenwood Creek are based on studies of other areas.
These studies may or may not be pertinent to a watershed that provides the sole source
of drinking water to a public water district, nor to the particular conditions in this
watershed. Even the water gage station in the nearby Navarro River, for instance, may
not adequately reflect conditions in Greenwood Creek, which is much steeper and more
V-shaped than the Navarro. The SYP does not contain a discussion of the relevance of
its cited studies and data to our particular situation and to this watershed.
- L-P has likely already removed more than 20 percent of the watershed forest cover,
with water yield impacts unknown because of lack of monitoring. What will be the
impacts of future forest cover removal? How much forest cover does L-P intend to
remove, on what time-table?
- If water yield impacts are "undetectable," then a very low and cautious harvest ought to
be the standard, since we cannot know at what point disaster may strike in the form of
catastrophic flooding or other major impacts.
9. PROBLEM: quality of the data
- Although the SYP uses the term "relative risk," the risk to Elk water users is not
"relative." It is fundamental. The SYP should acknowledge this perspective and start
from there. For instance, the SYP should include discussion of worst-case scenarios,
based on site-specific information, such as soil types, landslide frequency, quantity of
water, harvest levels and other factors. During one recent peak flow, the water of
Greenwood Creek reached the base of ECWD well no. 1. A slight increase in water
quantity/velocity and the well could have been blown out. The SYP needs to address
such potential catastrophes, and needs to provide sufficient information to judge
preventive measures for these and for other potential cumulative effects.
- The quality of the information that is used to determine the ratings of Watershed
Relative Risk Index seems to be very low, and is largely comprised of estimates and
projections rather than empirical data from Greenwood Creek. Erosion rates and
sediment yields are presented as projected formulae based on studies of other areas (that
may or may not be appropriate). The formulae include an undefined term ("entry")
which is not given a value. (For instance, the total sediment yield from L-P roads and
harvest areas is given as "2.7 yd3/ac/entry" (with yd3 equaling approximately one ton).
The frequency of entries, the types of entries, and the sediment yields in the intervals
between entries are not given. The SYP appears to have used only one set of aerial
photographs, from 1990, to determine the frequency of mass wasting.
- On page 8, the SYP states that, "Generally, the study area exhibits a moderate
frequency of landslide features." On page 12, the SYP states that, "Due to the lack of
historical aerial photographs for the analysis area, no conclusions about the relative
frequency of mass wasting events could be established." [our emphasis] These two
statements appear to directly contradict each other.
- There are in fact numerous historical aerial photograph sequences available for
Greenwood Creek from many different sources, going back many decades (likely all
the way back to 1945 and the Whittier College collection).
- The May 5, 1996, state agency review questions stated that, in the matter of landslide
predictions, the SYP failed to review past and present timber harvest plans (THPs) and
failed to use existing and available landslide maps created by public agencies such as
the Department of Mines and Geology. They also stated that the SYP should include
data about deep-seated landslides and that it did not utilize available historical aerial
photographs. This omitted information casts serious doubt on the reliability of the
SYP's assessment of individual watersheds.
- The potential impacts of timber harvesting on water yield (run-off) and peak flood
events, and on other environmental factors (such as fog-drip) that may impact ECWD
water supplies and water quality are insufficiently discussed and quantified, and no
site-specific data are used.
- The potential long term cumulative impacts of L-P's "even-aged" management goals
and re-entry schedule upon the water quality/quantity of Greenwood Creek have not
been adequately addressed.
- Exemptions for salvage logging can involve removal of up to 10% of the timber volume
per acre, on any amount of acreage, and can be implemented at any time without public
notice and without environmental review. It is difficult to see how the impacts of
exemption logging on water quality/quantity will determined. (Is this potential harvest
anywhere addressed in the Sustained Yield Plan? )
Louisiana Pacific's Sustained Yield Plan is a lengthy and complex document of critical
importance to the ECWD and to others who depend on forest resources. We have tried to
provide a useful commentary upon it from the ECWD's point of view, in the form of
"problems" and "solutions." We hope that our concerns can be addressed in SYP draft #2
before the Mendocino Coast SYP is re-submitted to the state agencies. Please let us know if
that will be possible. We look forward to hearing from you.
- For Greenwood Creek, which provides a public water supply and which contains Coho
salmon and more than 16 miles of Coho salmon habitat, empirical data is an essential
component for a sustainable forestry program and for credible watershed assessment.
L-P's Greenwood Creek SYP needs to include such data, as well as a long term data
collection program to determine the effects of timber management activities. The
ECWD is willing to work with L-P, to share information and assist in gathering more
information, in so far as this is possible with the extemely limited resources available to
the ECWD. The burden of sustainability, however, must remain with L-P.
- Yours sincerely,
- Gerald W. Huckaby
- President, ECWD
West Div Res Mgr - L-P
Calpella, CA 95418
Forest Res Systs Mgr - L-P
Red Bluff, CA 96080
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