County Expresses Serious Concerns About Logging Plan
The following are report excerpts written by a hydrologist and
fisheries biologist representing
To see the full report go to:
In the San Jose Water NTMP
site, high rainfall, major deep and shallow landslides underlying residential
areas bordering the proposed cutting zones, and the fact that redwood trees are
notorious for 'profligate' water use raises immediate concerns about the
potential effects of forest management on slide stability and public
safety. My conclusions are that the proposed cutting schedule and volumes
will most certainly contribute to slide instability including increased rate of
motion of existing deep-seated slides that affect residential areas, streams,
and highways within the NTMP areas of the southwest side of Los Gatos Creek and
along Briggs Creek.
The primary basic premise of the
authors of the NTMP is false. They say that timber removal from
deep-seated slides is contemplated but that it will not destabilize slide
masses....Timber removal will accelerate sliding near the slide head and near
its base. The middle will follow.
Tim Best has recommended mitigations
for the sites identified in NTMP Section 5…, but concludes that “It is very
unlikely that the proposed harvest will have any measurable impact on
deep-seated stability”. I believe that I follow his reasoning but
disagree fundamentally.
….field traverses and calculation of
changed water balance show that this basic premise is both false and very
dangerous.
Today’s closed canopy forest is
proposed to be opened in each cutting cycle, thus increasing growth of shrub
and hardwood species that are now not common over the primary timber production
areas. Such increased shrub growth increases fire danger …
The majority of the NTMP timber
production zone is mapped as landslide…
The consequences of unmapped
compound slides are that proposed timber harvest roads and cutting units
probably cross onto active slide areas and displace surface water into obscured
scarps, thus accelerating unrecognized slide masses that carry increasing
sediment loads into the watercourses at the base of the slides. Sites that
should at least be classed as special treatment areas with no tractor entry
will not be recognized until it is too late to avoid the damage.
….the revised Figure 2A “Landslide
Map” from Best indicates that he recognizes nested features that he classes as
“large failures” below
The NTMP has not adequately
evaluated natural rainfall intensity in the project area and thus
underestimates winter condition site preparations such as culvert diameters,
crossing design, and road standards for winter access.
The proposed NTMP is not soundly
based in its assumptions about harvesting on deep-seated landslides that
dominate the proposed harvest areas.
I estimate that 63 percent of that
merchantable basal area would be equivalent to about 48 trees to be harvested
per acre.
The NTMP has not adequately evaluated
natural rainfall intensity in the project area and thus underestimates winter
condition site preparations such as culvert diameters, crossing design, and
road standards for winter access.
It is possible that the stream is
just now beginning to recover from cutting in the late 1800’s that destabilized
slide masses that were then exacerbated by the 1906 earthquake.
Thus, changes that may be imposed by
the proposed NTMP must be added to past stress responses and may reasonably to
expected to lengthen the period of natural recovery of the stream course in
that watershed.
It would seem prudent to simply
avoid any harvest or road activities in the slide zone, which also includes the
riparian zone.
….it is certain that the proposed
harvest schedule will seriously exacerbate slide stability.
Because the Santa Clara County
residential areas between the Summit Area and Chemeketa Park, including both
sides of Highway 17, are located on these deep seated slides that support the
trees to be cut in the proposed NTMP, the potential liability for San Jose
Water Company if they carry out the propose NTMP harvest plan becomes
extraordinary.
Robert Curry, PhD, Hydrologist
The NTMP erroneously states that
there are no non-listed species which will be significantly impacted by the
operation. Coldwater species including landlocked steelhead/rainbow trout
and riffle sculpin are potentially present in the project area. These
non-listed species may be significantly impacted by the operation. Potential
impacts are related to habitat degradation through increased sedimentation,
increased water temperature, and barriers to migration at stream crossings of
Class I and Class II watercourses. These potential impacts are not considered
or evaluated.
Data presented in Section V of the
NTMP indicates that existing temperatures approach the upper threshold of
suitability for coldwater species and contradict statements elsewhere in the
NTMP that temperature is not a limiting factor.
The NTMP provides no assurances as
to the degree to which the avoidance and mitigation measures for soil
stabilization and erosion control will actually be implemeneted.
Jeffrey Hagar, Fisheries Biologist