December 17, 1996

Tom Schultz
Area Forester
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 beneficial use."

(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:

"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 toxic substances.

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 Greenwood Creek.

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.

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? )

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

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