NAIL Issues With NTMP

Issues and Concerns regarding
San Jose Water Company’s NTMP 
Affecting 1002 Acres of Los Gatos Watershed

 Prepared by: Neighbors Against Irresponsible Logging – N.A.I.L.

A community organization of residents affected by the NTMP

November 1, 2005


Increased Fire Danger:

Cutting a large percentage of the largest, healthiest, most fire-resistant trees weakens the forest and increases the risk of a fire spreading into our neighborhoods. 66% of the trees to be cut are over 36” in diameter. These are the most fire-resistant trees in the forest. This forested land has a long history of large fires and is considered one of the most fire-volatile areas in the Battalion 3 region, as described by the California Dept. of Forestry and Fire Protection. (See CALIFORNIA DEPARTMENT OF FORESTRY AND FIRE PROTECTIONSANTA CLARA UNIT FIRE MANAGEMENT PLAN, 2005 - attached to this document.

The overwhelming body of scientific evidence supports the fact that commercial logging increases fire risk. Sources for this evidence include the Congressional Research Service of the Library of Congress and the US Department of Agriculture. "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."

  -  Sierra Nevada Ecosystem Project, 1996. Final Report to Congress

We support activities that reduce ladder fuels. However, such fire suppressant efforts should not be funded by activities that increase fire danger and harm the community in a variety of ways. Logging slash will cover the forest floor to a depth of either 18” or 30” (NTMP states 30” which differs from other SJWC statements).  "As a by-product of clear cutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. USDA (PNW-GTR-355)

  • The NTMP contains contradictory information about the amount of trees to be cut. While Section 2 describes a 60% cut of trees over 18” diameter (the maximum allowable by law). Section 3 details a 40% cut of trees over 24” in diameter. It is important to note that once the plan passes, SJWC (or whoever buys SJWC in the future) can change Section 3 with little/no public comment and still be within the limits of this NTMP. The NTMP Document states in Section 2:"A well distributed timber stand shall be left after operations that is at least  40% by number of those trees 18 inches or more in dbh (diameter at breast height) and at least 50% of those trees over 12 inches but less than 18 inches." 
  • The plan calls for far more cutting of the most fire resistant trees than is mentioned in SJWC's previous public statements. 

SJWC letter to residents states that "about 80% of the total Redwoods and Douglas Firs remaining after the harvest". The precise figure in the NTMP is 66%. NTMP Section 3 page 71: 
Present Volume Of All Trees In The NTMP = 337,837

Harvest Volume of All Trees = 112, 011 (33% of present volume)

Harvest Volume Of 36" Trees = 73,150 (65% of harvest volume)


Risk To Water Quality:


o       Los Gatos Creek acts as the primary water source for hundreds of local residents and as secondary source for hundreds more. Logging will take place on slopes along Los Gatos Creek and an additional 11 streams that feed into the creek.


o       Since timber harvesting and related activities such as road building are associated with increased risk of landslides and sediment generation, the planned logging activities pose a threat to our water supply.  Residents of mountain communities such as Aldercroft Heights and Chemeketa Park will be forced to bear the burden of increased sedimentation to their water source, brought about by the logging.


o       Large west coast cities such as Seattle, Portland, Marin County, San Francisco and Santa Cruz all protect their water supply by explicitly prohibiting logging in their watersheds. Why should Santa Clara County permit something other communities find it prudent to prohibit?


o       CDF in their response to the NTMP has raised this issue. In a response from CDF to SJWC they ask: “Given that the Plan Submitter/Timberland Owner is in the business of water collection, distribution and supply, have Class I watercourses (both fish-bearing and domestic supplies) been provided adequate protection? “


Decreased Quality of Life:


o       The proposed logging takes place in a heavily residential area. Over 2,000 people live within 800 yards of the logging area boundary. Thousands more live within 2 miles.


o       Five schools and a pre-school lie within 1 mile of the area. Some of these schools are within a few hundred feet of the boundary.


o       Chain saws generate noise levels of 125 decibels. Ambulances generate noise levels of 120 decibels; rock concerts generate noise levels of between 110-120 decibels. Source: League for The Hard of Hearing ( Residents will, in effect, have the equivalent of a Shoreline Amphitheatre placed 300 feet from their homes.


o       We feel that the proposed logging will be in violation of local noise ordinances. Santa Clara County Noise Ordinance Section B11-192 states that “No person shall operate or cause to be operated any source of sound at any location within the unincorporated territory of the county or allow the creation of any noise on property owned, leased, occupied or

otherwise controlled by such person, which causes the noise level when measured on any other property either incorporated or unincorporated to exceed: 55 decibels for residential land use between 7:00AM and 10:PM.


o       Noise pollution from chain saws and helicopters, increased traffic from large, heavy logging trucks on winding two-lane roads, with the resultant damage to these roads, will greatly diminish the quality of life for Los Gatos mountain residents. 


o       Thee logging activities will harm the local ecosystem, destroying wildlife habitats (an endangered species – the red-toed frog-  has been found in the NTMP area – per the NTMP document)  and increase the risk that mountain lions and coyotes will leave the logging area and enter local neighborhoods. It appears via language in the NTMP that Native American archaeological sites have also been recognized.  Additionally, private property would face even greater exposure to landslides as the soil stability provided by large trees would be reduced significantly.


o       SJWC in their public statements had said that logging will only take place for 6 weeks at a time. Yet in the NTMP, they have asked for permission to log year-round. Even the CDF questions the need for this. This quote is from the CDF response to the NTMP: “Are full winter period operations, especially ground-based yarding, appropriate?” 

Decreased Property Value:


o       The NTMP proposal allows for logging in perpetuity. The combination of ongoing noise, traffic, increased fire risk, the slash and logged open areas in the scenic terrain are likely to create longterm property value reductions for Los Gatos residents in the affected areas.  We feel that increased profits for the San Jose Water Company should not come at the expense of thousands of residents.




(Reproduced from pages 27 and 28)



Battalion Three: (Los Gatos)

Battalion Three is located in Santa Clara County  and lies solely in  the State Responsibility Area (SRA) bordering the north of Highway 152; west of the Almaden Valley; then east of the Santa Cruz County line; South from the San Mateo County Line. The Battalion includes watershed for local communities, as this watershed flows in to many lakes and streams managed by both the Santa Clara Valley Water District and the San Jose Water Company. The Battalion also is home to a large amount of Coastal Redwoods protected from development by open space districts along with County parks. The Battalion also has a number of small rural communities that have little or no governmental services.


Historically, the major wild land fire occurrence has been in the  remote and sparsely populated South western portion of the Battalion Three, the 1987 Lexington Fire and the 1994 Croy Fire were large structure loss incidents in the Santa Clara Unit. The 2004 Fire Cause Statistics are consistent with previous years equipment use being the leading cause for preventable wild land fires. The 2004 Fire Season (May through October) statistics for Battalion Three are: 1 Battalion Chief; 7 permanent and 2 seasonal Fire Captains; 2 Fire Pilots and 2 seasonal Fire Apparatus Engineers; and 25 seasonal firefighters answered the calls with one utility (circa 1986) two fire engines (circa 1985, 1991) one helicopter (circa 1968) and one helicopter service unit (circa 1996) responded to 488 separate incidents, The California Department of Forestry and Fire Protection has identified (SRA) Fire Hazard Severity Zones as Moderate, High, & Very High - based on homogeneous lands and their fuel 27.


Santa Clara Unit

Fire Management Plan, 2005 loading, slope, and fire weather. In Battalion Three they are located by vertically dividing into three sections: the South section is a Very High (Loma Preita area), the center section is Moderate (West Santa Clara Valley Foothills), and the North section is High (Hwy 85 and Interstate 280)  Battalion Three, because of its unique combination of vegetation, topography, climate and population, has one of the most severe wild land problems in the San Francisco Bay Area. Wild land and urban interface, rugged terrain and highly flammable vegetation coupled with high winds make the South West Santa Clara County foothills especially unsafe for development unless adequate fire safe measures are taken. Without regard for wild land fire protection and water sources, continued development in the SRA will heavily impact fire protection and emergency medic services. Solutions center on designing an acceptable level of risks for firefighters and residents that measure all elements of that risk. Pre-fire planning, mutual aid agreements, standard response plans, Mutual threat zones and high fire behavior warnings are necessary elements to measure the risks to reduce losses from wildfires.


Mission Statements:


To protect and enhance Western Santa Clara County’s open areas and all who abide in it, their property, and the public lands in it. To respond with due diligence to all types of emergencies. We will assist local city and county fire jurisdictions requesting our assistance. Also, to continue to use proven methods of public fire prevention techniques such as school programs, Informational roadside check points. Foster contacts and continued involvement in the Santa Clara Fire Safe Council. Continue to Issue burning permits and aggressively pursue vegetation fuel hazard reduction inspections. Keep the good working relationship with those involved with the County building permit process to insure proper review of permits and compliance with the public resources code.



To protect all California’s open lands between local responsibility and federal lands to reduce costs and losses due to wild land fires. Additionally, to be prepared for and major emergencies and natural disasters throughout California to the best of our abilities and train for implementing the Incident Command System to assist local agencies during earthquakes, floods, landslides, hazardous materials spills and possible terrorist acts.

Terry Clark
November 4, 2005