Comment on Limits on Logging Proposal

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COMMENT to the Regional Water Board on Proposed New Limitations on Pacific Lumber Logging

The DEADLINE HAS BEEN EXTENDED to Monday, August 8, 2005.

Write to:
North Coast Regional Water Quality Control Board
5550 Skylane Boulevard, Suite A
Santa Rosa, CA 95403


or email to dkuszmar@waterboards.ca.gov
or fax to 805-788-3579


The proposed Waste Discharge Requirements (WDRs) are watershed-specific requirements designed to address the cumulative impacts from timber harvesting activities in the two watersheds--Freshwater and Elk River--whose rivers are already listed as impaired for sediment and temperature under the Clean Water Act. "Waste discharge" in this case is silt and sediments discharged into streams from Pacific Lumber's logging operations.


After agency response to public comment in late August, the Regional Water Board will hold hearings on the WDRs on Sept. 14, planning to adopt the new regs by Sept. 27.

This move for specific regulations follows several years of study and analysis of these two watersheds by the Water Quality agency and independent scientists, which have demonstrated severe cumulative watershed impacts from high levels of timber harvesting by PL. Freshwater alone has had over 80% of its land logged in the past 15 years. After considerable delay, brought about in no small part by PL's failure to convey information to the Regional Water Board in a timely fashion, the Regional Board has now made a formal proposal for adoption of new WDRs specifically designed for these two imperiled watersheds.


Correlating timber harvest levels with watershed damage is welcome and long-overdue. However, the proposed permits as written contain some "gaps", so public comment is encouraged, besides the detailed scientific and legal opinions that will be submitted.

You can make the following points to the Regional Water Board:

- The monitoring and enforcement provisions of the proposed WDRs are wholly inadequate to ensure that the terms of the permits are followed. The monitoring and enforcement provisions must be strengthened so as to answer, at a minimum, the following questions:

- How will the Regional Water Board know whether water quality is, in fact, improving in these watersheds?
- How will the Regional Water Board know whether channel capacity is increasing?
- How will the Regional Board enforce Cleanup and Abatement Orders pertaining to areas in these watersheds?
- How will the monitoring and enforcement process provide for public involvement and accountability?

- The proposed WDRs will apparently allow PL to log in so-called "high hazard" landslide-risk areas, which include areas protected from logging under the PL Habitat Conservation Plan's provisions for hillslope and riparian management (MWACs and RMZs). In other words, PL will be able to log in these sensitive steep slopes, albeit at a much lower level than would be harvested without the WDRs. The proposed WDRs should be amended to strictly prohibit all discharges of sediment from high-risk areas.


- The proposed WDRs fail to address the important cumulative impacts of sediment discharges and increased flow from PL's existing and future roads in these watersheds. Existing rules and clean-up orders issued by the Regional Board do not adequately assess or prevent cumulative impacts from logging roads because sediment discharges from roads are assessed on a piecemeal basis, one Timber Harvest Plan at a time. The proposed WDRs should be amended to incorporate discharge prohibitions that are designed to address the cumulative impacts of logging roads throughout the watersheds.

Pacific Lumber's Proposals for WDRs:
- PL's proposal to use mitigations alone to recover all beneficial uses in these watersheds is entirely unacceptable. Mitigations alone cannot abate ongoing damage from timber harvesting; only a drastically reduced level of harvest can do that.


- PL's history of legal and regulatory violations coupled with its history of misrepresentations and financial shenannigans indicate that PL cannot be trusted. PL's assertions about its financial condition and its need to log timber are not reason for inadequate discharge requirements.

- The Regional Water Board should stand behind the use by its staff of what the staff has determined to constitute the "best available science" in the proposed WDRs.

Supplementary information about the proposed WDRs, including background materials and technical reports, can be downloaded from the Regional Water Board's website at http://www.waterboards.ca.gov/northcoast/agenda/pending.html.
- and action alerts.

Big thanks to EPIC for providing information for this alert. You can go to EPIC's website for ongoing updates. Thank you for commenting.
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