As you are well aware CDF has already approved an illegal conversion and a new timber harvest plan on the Ridgetop Partner property which adjoins the Hansen/Whistler THP and my property.
The recent positive response shows that inadequate studies of Northern Spotted Owl have been performed on the Hansen/Whistler property, the Ridgetop property and the rest of the Wildwood Subdivision. The Ridgetop THP and Hansen/Whistler THP are next door to each other. Is CDF asserting that the Northern Spotted Owl habitat is restricted to a single tree within Wildwood?
Approval of the Hansen/Whistler THP and the Ridgetop THP along with Hansen/Whistler’s existing three acre vineyard and Ridgetop Partners 15 acre illegal vineyard will create a substantial clear-cut area within the Wildwood Subdivision, resulting in major alteration and possible destruction of proven Northern Spotted Owl habitat. Yet, no study of the cumulative effect of habitat disturbance has been performed even on these two parcels --- much less the surrounding area which includes the “Wilson” three acre illegal conversion on Brushy Ridge Loop and the “Roessler” conversion on Flournoy/Little Creek Road and the Martin THP Conversion on Stibi Road.
A complete list of the projects in the Annapolis area and Gualala River Watershed that could impact sensitive species including the Northern Spotted Owl has not been provided.
The THP/Conversion has failed to identify the extent of habitat that would be lost from the combined projects.
The THP/Conversion has failed to evaluate the effect the cumulative
loss of habitat would have on the viability of the local species population
or the species as a whole.
.
Water Drainage
All of the illegal conversions and THPs within Wildwood subdivision along with the “Roessler” Conversion on Flournoy/Little Creek Rd. drain into Little Creek to the south and Buckeye Creek to the north. Both of these creeks run into the Gualala River.
The Gualala River is listed as an "impaired" river under the federal Clean Water Act because of excessive sediment and high temperatures, both of which can be lethal to salmon and steelhead. The California Fish & Game Commission has officially listed coho salmon populations from San Francisco to the Oregon border under the California Endangered Species Act (CESA).
Because of these listings the incremental effect of THP #1-04-030 SON, THP# 1-02-019 and other THPs in the Gualala River Watershed are cumulatively considerable.
Proper assessment of the cumulative effects from the combined activity above these impaired creeks and rivers has not been provided. EIRs have not been provided for any of these projects.
The Hansen/Whistler THP needs to address the impact all of these second
growth conversions will have on storm peaks flow volumes and increased
incremental suspended sediment loads for the impaired Gualala River watershed
due to reduction of rainfall interception and transpiration. (Impacts of
Logging on Storm Peak Flows, Flow Volumes and Suspended Sediment Loads
in Caspar Creek, California Jack Lewis, Sylvia R. Mori, Elizabeth T. Keppeler,
Robert R. Ziemer )
(Attached Exhibit 6))
Wells, Pond and Fog Drip
The Wildwood subdivision is located in a water scarce area. Residential
springs and private wells have already gone dry near the new conversions.
The Hansen /Whistler THP/conversion is proposing the bizarre practice of
pumping scarce ground water into a pond so it can evaporate.
Proof has not been provided that this excessive practice will not affect neighboring wells, not to mention Little Creek and Buckeye Creek.
Throughout the year the Wildwood Subdivision receives fog even in the summer, especially at night. The trees catch this fog which drips to the ground. The ground is often damp in the mornings during summer.
Numerous studies show that trees can trap ocean fog and condense it into water, which then drips onto the forest floor and into underground aquifers.
Plant ecologist Todd E. Dawson of Cornell University and University of California Berkeley, published a study on the utilization of fog by redwoods in northern California and southern Oregon. Dawson's The Use Of Fog Precipitation By Plants In Coastal Redwood Forests(Attached Exhibit 7) did much to dispel conventional wisdom deeming trees, especially old growth conifers, as harbourers of water, capturing and storing water then made unavailable to streams for example. Dawson's work indicates that fog and its interception by these giant trees contributes large volumes of water to forest habitat through the process of fog drip.
"From a management perspective," reports Dawson, "the fact that loss of redwood trees due to natural disasters (e.g., fire, wind throw, or floods) or from logging or other land use practices which convert the forest to open habitats will dramatically alter the hydrological and ecological balance of these forests." Loss of the canopy tree “would mean not only the loss of biomass, nutrients within the biomass, and the soils, but also a fundamental conversion of a once moist, cool, forested ecosystem into a more drought prone, and warmer ecosystem”, he says. (Dawson, Todd E; 1996. 'The Use Of Fog Precipitation By Plants In Coastal Redwood Forests. (Attached Exhibit 7))
The THP has not addressed fog drip in in this water-scarce area and
its
effect on ground water within Wildwood.
Even if “clumps” of redwoods are left RPF Fischer has not shown that
clearcutting around the redwoods will not diminish the water retaining
properties of fog drip within the shelter of existing canopy in Wildwood.
The THP has not addressed the issue of inevitable soil compaction around
the remaining Redwood “clumps” and how this will affect moisture absorbsion
under these trees.
CDF would be ignoring the possible consequences of water draw down
in granting this Negative Dec.
RPF Fischer’s assertion that “the proposed project will not substantially deplete groundwater supplies or interfere substantially with groundwater recharge” is unsubstantiated and his analysis is incomplete.
“Members of this committee have been told explicitly by some RPFs that, in preparing a THP, they would never conclude that a CWE (Cumulative Watershed Effects) is likely because of the unnecessary regulatory burden that such an admission would bring. Denials of the likelihood of CWEs are repeated regularly by applicants and reviewers, despite the widespread recognition among environmental scientists that, in the aggregate, timber harvest in coastal California has resulted and continues to result in radical alterations of water quality, habitat conditions, and perhaps flood risk.” (The University of California Committee on Cumulative Watershed Effects (June 2001): A Scientific Basis for the Prediction of Cumulative Watershed Effects – page 6(Attached Exhibit 2))
We conclude that it is not surprising that the current methods of assessing and predicting CWEs are ineffective. Attempts to define a threshold of “significant”, adverse effects —though attractive for any agency or individual regulator, who understandably doesn’t want to make difficult decisions alone —are unworkable and too narrow. Secondly, the resources available for a THP are not adequate for the task of conducting a realistic, watershed-scale analysis of long-term, biologically relevant effects. RPFs do not have the training necessary for analyzing CWEs across a spectrum of physical, biological, and biogeochemical disciplines. An individual applicant, and a regulator processing a single application, do not have the time and other resources necessary for a truly cumulative, watershed-scale analysis. This limitation is particularly severe for ‘small ’landowners (those who own less than 2500 acres of forest land), who own approximately 50%of private forestlands in California (25%of total forest land). (The University of California Committee on Cumulative Watershed Effects (June 2001): A Scientific Basis for the Prediction of Cumulative Watershed Effects – page 25(Attached Exhibit 2))
Is the RPF Fischer a qualified hydrologist?
If not please supply a hydrologist report to support RPF Fischer’s assertions.
Only a full EIR could possible address the broad issues Hansen/Whistler’ RPF FISCHER is attempting to gloss over.
During the hot summer months the temperature is substantially lower under the trees and the humidity is higher. If you had to sit in one spot in Wildwood on a 100 degree day, would you sit in a cleared vineyard or in the shade of the trees?
The THP has not addressed the issue of increased evaporation of the hotter exposed soil in the conversion area. The THP has not addressed the issue of increased temperature after forest removal and the effect this will have on surrounding properties.
The Wildwood CC&Rs signed by both Hansen/Whistler and Ridgetop Partners say all lots must permit the natural flow and drainage of water.
Because the Hansen/Whistler THP/Negative Declaration
fails to adequately consider cumulative impacts, it cannot be approved
under the California Environmental Quality Act.
| According to NOAA Fisheries (formerly National Marine Fisheries Service):
In listing the coho salmon as threatened under the federal Endangered Species Act: "Specifically, the CFPRs do not adequately address large woody debris recruitment, streamside tree retention to maintain bank stability, and canopy retention standards that assure stream temperatures are properly functioning for all life stages of coho salmon. The current process for approving Timber Harvest plans (THPs) under the CFPRs does not include monitoring of timber harvest operations to determine whether a particular operation damaged habitat and, if so, how it might be mitigated in future THPs."62 FR 24596.In listing the steelhead trout as threatened under the federal Endangered Species Act: "[A]lthough the FPRs mandate protection of sensitive resources such as anadromous salmonids, the FPRs and their implementation and enforcement do not accomplish this objective. Specific problems with the FPRs include: (1) protective provisions that are not supported by scientific literature; (2) provisions that are scientifically inadequate to protect salmonids including steelhead; (3) inadequate and ineffective cumulative effects analyses; (4) dependence upon registered professional foresters that may not possess the necessary level of multi-disciplinary technical expertise to develop timber harvest plans (THPs) protective of salmonids; (5) dependence by CDF on other State agencies to review and comment on THPs; (6) failure of CDF to incorporate recommendations from other agencies; and (7) inadequate enforcement due to staffing limitations. NMFS further concluded that until a comprehensive scientific peer review process was implemented and appropriate changes to the FPRs and the THP approval process were made, properly functioning habitat conditions would not be ensured on non-Federal lands in the Northern California steelhead ESU. 65 FR 6966. |
| According to the California Department of Fish and Game
Bill Condon, Biologist with DFG, in sworn testimony to the Senate Natural Resources Committee: "The Timber Harvest Plan process does not prevent streams from
being silted up, does not protect Salmon and their habitat,
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| According to the U.S. Environmental Protection Agency
"On the North Coast, the majority of the streams have been listed due to impacts of sediment on the beneficial uses, most notably salmonids...The petitioners are most concerned with the cumulative impacts of sediment and state the current Forest Practice Rules and/or the implementation of these rules does not adequately address cumulative impacts from timber harvesting activities. In 1994, the Little Hoover Commission found that the Timber Harvest
Plan (THP) `process looks at potential damage on a
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