The Hansen/Whistler commercial use of Little Creek Road will lead to increased sedimentation, degradation of salmon and steelhead habitat, pollution of water, degrade private resources, and increase negative cumulative effects on the environment.

There is not any access route to the Hansen property that will provide a less than significant impact on Steelhead and Coho Salmon habitat for the uses proposed if the conversion were approved.

There also is not any access route to the Hansen property that will provide a less than significant impact on the impaired Gualala River Watershed for the uses proposed if the conversion were approved. .

This is also true for the 3 acre Wilson Vineyard, the 15 acre Ridgetop Partners Vineyard, the 18 acre Ridgetop Partners THP, the 3 acre Hansen Vineyard, the 16 acre Hansen THP, the 3 acre Roessler/Zapar, Inc Vineyard, the proposed 8 acre Roessler/ Zapar, Inc THP, and the 80 acre Webster THP 1-00-328 SON on Little Creek Road.

“We emphasize that Cumulative Watershed Effects cannot be predicted through the existing parcel-by-parcel analysis for Timber Harvest Plan applications, even if it were based on the best current understanding.”
(A Scientific Basis for the Prediction of Cumulative Watershed Effects (Attachment Exhibit 2))

What are the cumulative impacts of these projects combined with one another, combined with past projects, combined with present ones, and combined with future ones?

The answer to these questions is the essence of a cumulative impact analysis, but it does not appear anywhere.

Roads are a major source of sediment to streams. Surface erosion from roads can produce chronic sources of fine sediment which can diminish salmon and steelhead spawning success. Failure of roads during major storm events can lead to large landslides which can overwhelm streams  (KRIS GUALALA) (Attached CD 31)

Roads by them selves supply 650 tons/square mile out of the approximately 1400 tons/square mile of sediment delivered to the Buckeye Creek Sub basin each year.

 
Caption:  The chart above shows the sources of sediment estimated for Buckeye Creek by the "Technical Support Document for the Gualala River Watershed Water Quality Attainment Action Plan for Sediment" (CWRCB, 2001). The Buckeye basin shows a similar pattern to the Gualala basin as a whole with roads being the largest estimated sediment source. High road surface erosion is also consistent with the high road densities in the Buckeye Creek watershed (see related sediment Topic). Kelly Road runs through much of Buckeye Creek and adds to road surface erosion (ROAD_SURF) and road related gully erosion (ROAD_GULLY). Estimated sediment yield is shown as tons of sediment yielded per square mile per year. ((KRIS GUALALA) (Attached CD 31))

The tentative Sediment Load Allocation for the Gualala River Watershed is 475 tons per square mile. (RPF Fischer (THP 1-04-030 Page 172)

While some northwestern California river basins, such as the Garcia and the Mattole are showing signs of recovery, the Gualala falls into the class of a river still in decline. ((KRIS GUALALA) (Attached CD 31))

Buckeye Creek, Rockpile Creek, and the lower Wheatfield Fork appear to be aggraded, as indicated by the wide, flat channel geometry, lack of an armor layer, scarcity of pools, and exposed tree roots in the stream banks.( Technical Support Document (TSD) for the Gualala River Watershed Water Quality Attainment Action Plan for Sediment (CWRCB, 2001)(Attached Exhibit 8))

RPF Fischer said. “These factors combine to make recovery from past aggradation a very slow process especially in Little Creek.” (THP 1-04-030 Page 178)

On page 172 THP#1-04-030, RPF Fischer makes the puzzling statement, “Factors contributing to current stability within the watershed include the existence of mature second growth forest throughout much of the watershed, emphasis of cable and helicopter yarding, use of thinning and selection silvicultural methods in sensitive areas, and well maintained and managed road systems.

On page 173 THP#1-04-030, RPF Fischer contradicts this previous statement by describing Little Creek Flournoy Road as follows:

The most visible off-site impact within the planning watershed is that of road generated sediment from Little Creek/Flournoy road entering the tributaries of Little Creek and ultimately Buckeye Creek. This appears to be primarily due to poor grading and maintenance practices along with an insufficient amount of cross-relief drains. The following has been observed and should be brought to the attention of the local road association for their consideration:

1. The grading of loose road material into the inboard ditch in the form of a loose berm which is then subject to transport by heavy winter rains. This has resulted in the overburdening culverts and sediment discharge into minor watercourses.

2. The side-casting of graded material into the inlet and outlets of cross-relief drain and watercourse crossing culverts thus blocking them and contributing sediment to the watercourses.

3. The improper placement of berms which results in concentrated flow of water and sediment which is often relieved on to fill slopes or directly into watercourses resulting in sediment discharge.

4. Grading when there is not sufficient moisture in the road base resulting in loose roadbed material and/or excessive berm buildup resulting in increased sedimentation.

5. Lack of watering or use of a dust sealing binder during the dry season. This results in excessive dust buildup followed by sediment transport early in the rainy season.
(page 173 THP#1-04-030)

Is RPF Fischer’s first statement intentionally misleading or a flawed assumption?

“Our reviews of THPs and discussions with CDF officers responsible for reviewing applications indicate that the training of Registered Professional Foresters is not adequate for the legally mandated multidisciplinary assessments of CWEs. The Committee reviewed two summaries of recent THP applications in the redwood region, which suggest that potential environmental effects of proposed harvests are not being recognized by RPFs.” (A Scientific Basis for the Prediction of Cumulative Watershed Effects (Attached Exhibit 2))

For the last 15 years I have lived on Brushy Ridge Loop and have used Little Creek Road to access my property. Little Creek Road has been prone to winter slides that enter the Creek. A few years ago one slide took out half of the road. This slide area was repaired by adding more sediment fill.

The conditions of the Little Creek Road system and the surrounding waterways are in such degraded condition that no commercial activities of any kind, whether on these roads or on the ridge tops, can be justified as less than significant to the salmonid spawning grounds in Little Creek and Buckeye Creek.

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