Jonathan J. Rhodes
Hydrologist, Planeto Azul Hydrology
P.O. Box 15286 •• Portland, OR 97293-5286
May 9, 2005
To Whom It May Concern:
My following comments on the DEIS For the Proposed Issuance of Multiple Species Incidental
Take Permits or 4(d) Rules Covering the Washington State Forest Practices Habitat Conservation
Plan (HCP) (DEIS) are based on my education and experience, including many years of
evaluating the impacts of forest management activities on watershed and aquatic resources.
I am hydrologist with more than 23 years of professional experience, with a B.S. in hydrology
and water resources from the University of Arizona, a M.S. in hydrology and hydrogeology from
the University of Nevada-Reno. I finished all the required academic work toward a Ph.D. in
forest hydrology at the University of Washington. I currently work as a consulting hydrologist
for a variety of clients, including county and tribal governments in Oregon and Idaho. I worked
for more than 12 years at the Columbia River Inter-Tribal Fish Commission, where I served as
Senior Scientist-Hydrologist. I have served as a technical advisor on non-point source water
pollution to the states of Idaho and Oregon and have worked as a consultant for several local
governments in Nevada, Oregon, Arizona, and California. My professional experience over the
last 23 years includes work for tribal, federal, state, county, and city governments, universities,
homeowners associations, and non-profit groups in eight western states.
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For more than 16 years, most of my work has focused on the effects of land uses on nonpoint
sources of pollution, water quality, channel morphology, and native trout and salmon habitat. I
have examined water withdrawals, logging, roadbuilding, mining, and other activities that affect
soil erosion, streamflow, or water quality. I have developed monitoring programs to measure
changes in streams and water quality caused by various land uses. I have also developed
measures to protect existing streams from additional degradation and to restore forested
watersheds and their streams. I have also worked with a wide variety of agencies in attempts to
get them to begin to comply with a wide variety of duties and regulatory requirements, including
the Clean Water Act (CWA), NEPA, NFMA, the ESA, and their own LRMPs.
During my tenure at CRITFC, our work with the U.S. Forest Service (USFS) provided some of
the groundwork for most of the substantive watershed protection measures ultimately adopted by
the USFS and U.S. Bureau of Land Management (USBLM) in two combined agency
management strategies designed to slow the decline in habitat for anadromous and resident
salmonids in the Columbia River basin: “Implementation of Interim Strategies for Managing
Anadromous Fish Producing Watersheds in Eastern Oregon and Washington, Idaho, and
Portions of California” (1995) (PACFISH) and “Inland Native Strategies for Managing Fishproducing Watersheds in Eastern Oregon and Washington, Idaho, Western Montana, and
Portions of Nevada” (INFISH).
I have served as a peer-reviewer for the scholarly scientific journal, North American Journal of
Fisheries, for papers related to the effects of erosion and sedimentation on fish habitat. I also
served as a peer-reviewer for a regional assessment of ecological conditions on forests in eastern
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Washington and Oregon (Henjum et al., 1994) and the proceedings of an international
conference on forestry-fish interactions for papers related soil erosion and stream sedimentation
from forestry activities.
I have published numerous papers on the effects of logging and related activities on watersheds
and aquatic systems. Under contract with NOAA Fisheries (NOFISH) I co-authored or authored
peer reviewed reports evaluating the condition of ESA-listed salmonids and their habitats in the
Columbia Basin, with recommendations to protect and restore these habitats (Rhodes et al.,
1994), the utility of various models for the estimation of erosion, sediment delivery, and effects
on fish habitat (Rhodes, 1996), and the overall efficacy of various land management plans in
protecting and restoring habitats for ESA-listed salmonids (Rhodes, 1995). I also co-authored
data-driven assessments of the status of imperiled trout across the western US (Kessler et al.,
2001) and how federal land management schema failed to protect fish habitats on the Clearwater
National Forest in Idaho from the adverse effects of sedimentation caused by roads and logging
(Espinosa et al., 1997). I have also co-authored peer-reviewed publications on the monitoring
the effects of sedimentation on ESA-listed salmonids (Rhodes and Purser, 1998) and the effects
of postfire logging on aquatic systems, together with recommendations for improving postfire
forest management (Beschta et al., 2004; Karr et al., 2004). I have also published many other
papers on the effects of landuse on aquatic systems.
I have made invited presentations in a wide variety of professional scientific society meetings,
including presentations on the very limited utility of adaptive management schema in the
protection and restoration of aquatic systems.
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My statements and comments on the DEIS and the HCP are based on my review of the
Washington Forests and Fish Report (April 29, 1999), Society for Ecological Restoration,
Northwest Chapter, Scientific Review of the Washington State Forests and Fish Plan (Jan. 31,
2000) (SER Report), National Marine Fisheries Service Memorandum Re: Statement of how the
Forests and Fish Report likely meets Properly Functioning Condition (June 16, 2000), National
Marine Fisheries Service Analysis of Riparian Conservation Measures (March 1999), the Review
of the Scientific Foundations of the Forests and Fish Plan (CHM2Hill), Washington’s Forest
Practices Regulatory Program (WFRP), and the DEIS For the Proposed Issuance of Multiple
Species Incidental Take Permits or 4(d) Rules Covering the Washington State Forest Practices
Habitat Conservation Plan (HCP) (DEIS). In my review I also drew on my knowledge of the
scientific literature, and my own professional knowledge and experience. The scientific
literature that I reviewed is too lengthy to list here, so I have appended it at the end of my
comments.
I submit these comments to explain the numerous significant failings of the Washington Forests
and Fish Report (FFR) and the HCP to protect salmon, steelhead, and bull trout populations and
their habitat from degradation from flow alteration, surface erosion, sediment delivery, and
consequent effects on aquatic resources.1 Because of these defects, the FFR fails to reduce the
negative impacts of forestry activities on affected fish and amphibians from flow alteration,
surface erosion, and sediment delivery to streams. The prescriptions in the FFR with respect to
activities that affect streamflows, surface erosion, and sedimentation, will not restore and
The term “aquatic resources” is used to denote the full suite of aquatic resources, including, but
not limited to, water quality, fish habitat, channel form, embedded aquatic biota, and other
beneficial uses.
1
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maintain riparian habitat for a minimal population of salmon, steelhead, and bull trout, and the
requirements will not protect water quality or meet state water quality standards. Indeed, it is
likely that activities allowed under Alt. 1-3 in the DEIS will cause continued damage to aquatic
populations and their habitats, leading to increased likelihood of extinction and extirpation.
Although there are many other factors besides sediment delivery and flow alteration that are
equally important to the protection and restoration of aquatic resources, I will not address those
in my following comments in any detail.
I also submit these comments to explain how DEIS to fails to reasonably analyze and disclose
the likely effects of the alternatives and to reasonably differentiate among those alternatives
analyzed with respect to surface erosion, sediment delivery, flow alteration, and consequent
effects on aquatic resources.
Ecological Impacts From Flow Alteration, Road Run-off, Sediment Delivery, and Increased
Turbidity
It is well-documented that roads, road construction, and logging cumulatively elevate peakflows,
erosion, sediment delivery, turbidity, and sedimentation via several mechanisms (Meehan, 1991;
USFS et al., 1994; Rhodes et al., 1994; UFSF and USBLM, 1997a; Beschta et al., 2004). These
activities also reduce subsurface flows to streams (Megahan, 1972; Tague and Band, 2001;
Hancock, 2002) and have been shown to reduce lowflows (Hicks et al., 1991).
Flow alteration and channel alteration from sedimentation and elevated peakflows contributes to
the elevation of summer water temperatures (Thuerer et al., 1985; Hicks et al., 1991; Dose and
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Roper, 1994; Bartholow, 2000), which is already a pervasive problem in streams draining logged
watersheds in Washington (DEIS). These effects of logging-related activities combine to cause
significant and long-lasting damage to populations of salmonids, amphibians,
macroinvertebrates, and their habitats (Meehan, 1991; USFS et al., 1993; Rhodes et al., 1994;
UFSF and USBLM, 1997a; Beschta et al., 2004, Karr et al., 2004).
Increased peak flows significantly increase channel erosion, downstream sediment delivery and
sedimentation, turbidity, channel width, and the frequency and magnitude of channel scour in
streams and aquatic habitats (Rhodes et al., 1994; Dose and Roper, 1994, SER Report, Dunne et
al., 2001). Even relatively small changes in peakflow magnitude and frequency can have major
effects on salmonids by triggering significant changes in channel erosion and sediment transport
(Dunne et al., 2001).
These combined effects contribute to channel simplification, producing straighter streams with
fewer and shallower pools, less off-channel habitat, and less large wood that is less effective at
providing cover and creating pools (Richards, 1982; Lisle and Hilton, 1992; USFS et al., 1994;
Rhodes et al., 1994; McIntosh et al., 2000, Buffington et al., 2002). Other factors remaining
equal, channel widening contributes to increases in summer water temperatures (Beschta et al.,
1987; Rhodes et al., 1994; Bartholow, 2002). All of these effects reduce the survival and
productivity of salmonids. Increased channel scour greatly increases salmonid mortality by
eliminating gravel needed for salmonid redds or by directly washing salmonid eggs downstream
(SER Report).
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Increased erosion and consequent increases in sediment delivery and sedimentation also
contribute to channel simplification, including losses in the depth, frequency, and quality of
pools and off-channel habitats. Increased sedimentation also contributes increased levels of fine
sediment which greatly reduces salmonid survival from egg-to-fry life stages. Studies have
consistently demonstrated that elevated sediment delivery increases fine sediment in channel
substrate, reducing the median particle size of channel substrate (Lisle et al., 1993; Rhodes et al.,
1994; Hassan and Church, 2000; Kappesser, 2002). The loss of pool depth from sedimentation
has been shown to be correlated with bed fining caused by increased sediment delivery (Kappesser,
2002). USFS et al. (1993) noted that increased sediment delivery was one of the primary causes of
the extensive pool loss within the area covered by the Northwest Forest Plan (NFP).
Elevated sediment delivery also increases turbidity. Increased turbidity impairs salmonid sightfeeding and can cause gill damage, both factors that can contribute to indirect mortality (Rhodes
et al., 1994). Elevated turbidity can also violate state water quality standards.
DEFECTS IN THE FFR
Shortcomings of the FFR Prescriptions For Peak Flows
Under the FFR, peakflows with a recurrence interval of two years are allowed to increase by up
to 20%. However, a 20% increase is likely to be very harmful to threatened salmonids, because
it can increase the frequency of the equivalent of a two-year flow to approximately once every
1.3 years (SER Report). Increasing the frequency of these peakflows to occur on average every
1.3 years will likely increase the mortality of salmonids due to flood scour by over 50% (SER
7
Report). The SER Report correctly concluded that elevating the two-year peak flow by 20%
would increase the rate and frequency of salmonid mortality from flood scour. For already
imperiled species, such a decrease in average survival rate clearly reduces the likelihood of
survival of the species. The decreased fry production also is not consistent with the protection of
the beneficial use of streams for salmonid spawning.
These frequently occurring flows with a recurrence interval of about two years are the flows
which primarily control channel form and dimensions (Dunne and Leopold, 1978; Richards,
1982; Mosley and McKurchar, 1993). Thus, even in the unlikely case that the FFR’s peakflow
goals are realized, they still assure the degradation of channel form and aquatic habitats, and
elevated downstream flooding.
The allowed increases in peakflows are also likely to significantly increase turbidity and degrade
water quality. This is because turbidity levels are generally correlated with peakflows by a
power function, so turbidity levels typically increase exponentially with increasing discharge.
Therefore, a 20% increase in peak flow is likely to result in an increase in turbidity far greater
than 20%. However, water quality standards for most of the streams require that turbidity levels
be increased by no more than 10% over background.
However, it is unlikely FFR provisions will meet this inadequate goal and ensure that two-year
peak flows are not actually increased by more than 20% because the FFR does not address the
amount of watershed area occupied by roads or logged within the past 15-30 years (SER Report).
Instead, the only FFR’s only concrete provision for controlling peakflows is to decrease the
8
amount of road runoff entering streams. This fails to adequately address cumulative sources of
peakflow elevation. Mere reduction, to a degree that is completely unspecified, is highly
unlikely to ensure that two-year peakflows are not increased by more than 20%.
Roads greatly elevate surface runoff. A significant amount of the road networks in most
watersheds are hydrologically connected to the stream networks, elevating peak flows (Wemple
et al., 1996; Rhodes and Huntington, 2000). Due to the density and position of roads and stream
channels, it is not possible to completely eliminate the delivery of road runoff to streams.
Studies have conclusively documented that logged areas also increase runoff in areas with rainon-snow (Bowling et al., 2000) or where snowmelt is the primary source of annual peak flows
(e.g. review in Rhodes et al., 1994). This is particularly clear in areas where snowmelt
dominates peakflow generation and the mechanisms are well-understood (MacDonald and
Ritland, 1989; King, 1989; Cheng, 1989; Rhodes et al., 1994). These increases in runoff can
contribute to elevated peakflows for several decades. Therefore, absent clear and effective
limitations on the amount of watershed area logged and roaded, it is highly unlikely that the FFR
provisions will effectively ensure that two-year peak flows are not increased by more than 20%.
In order to prevent significant elevation of peakflows and attendant damage to aquatic resources,
it is prudent to develop fairly conservative limits on the amount of a watershed affected by roads
and logging (Rhodes et al., 1994; Murphy, 1995; Spence et al., 1996). Conservative limits are
necessary for several reasons. First, it is extremely well documented that aquatic habitats are
already widely degraded and need to recover considerably if the decline of salmonid populations
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is to be reversed (Henjum et al., 1994; USFS et al., 1993; Rhodes et al., 1994; NRC, 1995; USFS
and USBLM, 1997a; b; USFWS, 1998; WDFW, 2000; Kessler et al., 2001; Karr et al., 2004).
Second, due to fragmentation, habitat damage, and declines, salmonid populations are not
resilient. Many trout populations are may not persist under the maintenance of current widely
degraded conditions (USFS and USBLM, 1997b). Additional habitat damage and attendant
fragmentation increases the likelihood of extinction (USFS and USBLM, 1997a).
Third, methods of estimating peak flow elevation from roads and logging are subject to both
abuse and considerable error and are not a reliable means for preventing peak flow increases
beyond a given threshold, such as 20%. Fourth, peak flow increases caused by logging and
roads are persistent. Once roads are built and trees logged, little can be done to rapidly reverse
these effects, except to wait decades for recovery.
These problems are compounded because the recovery of channel form typically lags well
behind the recovery in the cause of channel alteration (e.g., peakflows) (Kondolf, 1993; 1997).
However, the FFR not only fails to provide a conservative limit on logging and road area to
protect against elevated peak flows, it provides no limit on the amount of area disturbed by
logging and roads, allowing both to increase without limit.
Many assessments of hydrologic cumulative effects from logging and roads have suggested
limiting the amount area of watershed area disturbed by these activities. While there is a good
some debate about thresholds of disturbance past which there are significant cumulative effects
10
there is general agreement that if more than 30% of a watershed is in a cutover state (<30 years
old), significant negative cumulative effects to aquatic resources are very likely to accrue on a
persistent basis, as corroborated by data-based modeling (Ziemer et al. 1991a; b). Under the
FFR this level of watershed disturbance is allowed to be exceeded.
Based on their review, Spence et al. (1996) recommended that no more than 15%-20% of the
watershed should be in a hydrologically immature (logged and roaded) state at any given time.
However, they also acknowledged the potential errors associated with the approach and noted
that more conservative disturbance thresholds were warranted in cases where: channel conditions
had already been degraded by hydrologic change, significant amounts of the watershed areas
were in the transient snow zone, past harvest had occurred in hydrologic source areas, or
channels lacked large wood. Spence et al. (1996) also noted that since studies demonstrated that
models underestimated actual changes in total water yield, this underscored the need to exercise
caution in using such models and selecting thresholds.
Based on existing contexts, conditions, and salmonid response to habitat effects, limits on
disturbance from logging and roads need to be well below the limits cited by Spence et al. (1996)
to prevent significant cumulative increases in peak flows. In contrast, the FFR completely fails
to reasonably cap watershed disturbance levels and does not require that more conservative
limits be applied where damage has already occurred. For these reasons, it is highly unlikely that
the FFR will ensure that peakflows with an estimated recurrence interval of two years are limited
to less than 20%.
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The FFR’s provisions for limiting peak flows primarily focus on rain-on-snow concerns and
activities in the transient snow zone, and largely ignore likely increases in peak flows caused by
activities that elevate snowmelt in the absence of rain-on-snow. As discussed, studies have
consistently found that logging and roads elevate snowmelt and, consequently, peak flows, in
areas where snowmelt is the primary source of peak flows. In such areas, peakflows from
snowmelt annually deliver and transport the bulk of sediment (MacDonald and Ritland, 1989;
King, 1989). Therefore, the FFR provisions fail to adequately address peak flow alteration and
consequent increases in sediment delivery in areas with snowmelt-dominated peak flows.
There is little dispute that all available evidence clearly indicates that the most frequently
occurring peakflows (e.g. with a recurrence interval of up to 5 years) are increased in a
statistically significant fashion by forest removal and roads (Jones and Grant, 1996; Thomas and
Megahan, 1998; Beschta et al., 2000; Bowling et al., 2000).
Jones and Post (2004) also
documented persistent increases in peakflows in response to forest removal in the Pacific
Northwest. This will increase the frequency and magnitude of habitat damage and salmon
mortality during these larger, but more infrequent, peak flows.
While the allowed increases in the two-year peakflows are likely to elevate salmonid mortality,
larger peakflows with longer recurrence intervals are also likely to be elevated by activities
allowed under the FFR. Bowling et al. (2001) found statistically significant increases in
peakflows from logging and roads in peakflow events with return intervals up to 10 years in
western Washington.
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Although Thomas and Megahan (1998) and Beschta et al. (2000) argued that larger peakflows
with longer return intervals are not increased by logging and roads, these arguments are based on
artifacts of statistical power and the failure to properly account for it. Their results do not
indicate that larger peakflows with return intervals greater than 5 years are not affected by
logging, but instead show that results are simply inconclusive for larger flows due to low
statistical power.
Larger peakflows with greater return intervals intrinsically occur less frequently than smaller
peakflows with lower return intervals,2 resulting in steadily dwindling sample number for larger
flows. Larger flows also have greater variability. Statistical power decreases dramatically with
decreases in sample number and increases in variability. As a result, the minimum effect that
can be statistically detected increases dramatically with decreasing sample number and increased
variability. Therefore, the lack of statistically significant differences from logging for larger
flows may be solely due to associated statistical effects (decreased sample number and increased
variability) rather than reflection of the actual underlying change.3
Based on analysis of data from many watersheds in western Washington, Bowling et al. (2000)
clearly demonstrated that the detectability of increases in peakflows caused by logging decreased
2
This is irrefutably occurs, because the frequency of occurrence is the sole factor used to
estimate recurrence interval of peakflows of different sizes (e.g. Dunne and Leopold, 1978).
3
This is clearly the case for Beschta et al. (2000), in which the estimated magnitude of change in
peakflows with increasing return interval was strongly correlated with sample number, although
it was not analyzed or discussed in the paper. Based on statistical analysis of paired watershed
data, they concluded that peakflows with recurrence intervals of greater than 5 years were
unchanged by logging. However, this was based on a very small amount of data: a sample
number of three in one case, and one in the other. This clearly indicates that these results do not
show that larger flows are unaffected by logging, but, instead, demonstrates that weak statistical
power yields inconclusive statistical results.
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with increasing return interval. The analysis of Bowling et al. (2000) also indicated that the
inability to detect statistically significant increases in peakflows with recurrence intervals greater
than 5-10 years was more likely due to reduced detectabilty rather than a reflection of the actual
change in these peakflows caused by logging and roads. Therefore, Thomas and Megahan
(1998) and Beschta et al (2000) do not shed any light on the effect of logging and roads on
peakflows greater than the 5-year event, but, instead, merely illustrate the rather pedestrian result
that analyses with extremely low statistical power yield inconclusive results. Based on available
information, there is no good evidence that logging and roads do not increase larger peakflows at
the watershed scale.
A glaring defect of the FFR is that it contains no peakflow prescriptions for eastern Washington.
Numerous studies indicate that peakflow increases caused by roads and logging are most
pronounced in areas where snowmelt is the primary source of peak flow, as is the case in eastern
Washington. Channels in eastern Washington also tend to be more vulnerable to degradation
from peak flows and their associated effects due to their channel types and widespread grazing
impacts. Fine sediment problems from accelerated sedimentation are also typically greatest in
areas with flows dominated by snowmelt, such as eastern Washington (Everest et al., 1987).
Therefore, the FFR has failed to ensure that aquatic habitats and water quality in eastern
Washington are not damaged from the likely effects of logging and roads on peakflows and
resulting impacts. Instead, the FFR clearly allows more damage to aquatic resources to occur
from increased peakflows caused by logging, roads, and landings. This is likely to appreciably
diminish the likelihood of the persistence of imperiled salmonids.
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Forests and Fish Report Prescriptions Fail to Protect Lowflows
Logging-related activities also reduce lowflows. Although increases in lowflows from forest
removal have been hypothesized, it appears that these do not always occur. Harr (1982) found
that overall water yield was reduced by logging, apparently due to the loss of fog drip from large
trees, which can be an important component of precipitation in fog-influenced systems such as
the coastal ranges and Cascades of the Pacific Northwest (Calder, 1993). Where increases in
lowflow do occur in response forest removal in the coastal province, they require extensive
removal of forests, on the order of more than 25% of the watershed logged within 5-16 years.
These increases in lowflows are short-lived, lasting 5-16 years after extensive logging (Everest
and Harr, 1982; Hicks et al., 1991). The rapid regrowth of vegetation has been suggested to be
the primary cause of the relatively rapid elimination of increased lowflow, when it occurs.
Forest clearing reduces lowflows. In the only long term study of the affect of forest clearing on
flows in the Pacific Coast province, Hicks et al. (1991) found that for a watershed in Oregon that
had been 100% clearcut and burned there was nominal increase in August lowflow about 8 years,
but thereafter, lowflow was reduced relative to the pre-logging condition for 19 years in a
statistically significant fashion. Using a rotation time of 70-100 years, Hicks et al., (1991)
concluded that August low flows might be increased 8-11% of the rotation time, but significantly
reduced at least 19-27% of the time after extensive forest clearing.
Bowling et al. (2001) found statistically significant decreasing trends in lowflows at the
watershed scale in logged basins in western Washington. While this suggests that logging may
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reduce lowflows, it was not clear if this was due to solely to logging; climatic trends could not be
discounted as a contributing factor. Jones and Post (2004) also found that logging in the Pacific
Northwest reduced summer flows several years after removal. They also found that the logging
exposed aquatic biota to higher levels of annual hydrologic variability which may have negative
consequences for such biota (Jones and Post, 2004).
While the long-term effect of logging-related activities on the reduction of lowflows has received
little attention the mechanisms for it are obvious and straightforward. Roadcuts inexorably
interrupt and intercept subsurface flows (Kirkby, 1978) which provide an important source of
lowflows for streams. The interception by subsurface flows by roadcuts is likely to reduce
downslope soil moisture levels and subsurface flow contributions to affected streams during drier
periods, contributing to reduced lowflows (Tague and Band, 2001; Hancock, 2002).
Reductions in infiltration rates and the water storage capacity in soils from compaction by
ground-based equipment, especially on roads, shunt more precipitation into surface runoff
instead of the soil, which ultimately provides lowflows for streams (Kirkby, 1978). This also
likely contributes to cumulatively reduced lowflows over time.
Logging effects on organic matter in soils cumulatively reduces the ability of soils to absorb and
store water. Logging significantly reduces sources of soil organic matter (USFS and USBLM,
1997; Beschta et al., 2004). Soils with higher levels of soil organic matter typically have higher
infiltration rates and are able to store more soil moisture (Rawls et al., 1993). Cumulative
reductions in organic matter in intensively managed forests may also contribute to reduced
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lowflows by reducing soil moisture and organic matter (Griffith et al., in review; Perry et al., in
prep.), infilitration rates, and total water in the soils (Rawls et al., 1993). Griffith et al., (in
review) and (Perry et al., in prep.) documented that soil moisture and soil organic matter in old
growth stands in the Pacific Northwest were significantly higher than in comparable logged
stands.
Elevated soil erosion caused by logging, roads, and landings also inexorably reduces the water
holding capacity of soils. The effect is not trivial. The loss of one inch of soil of topsoil over
one square mile reduces potential soil water storage by more than 1.3 million cubic feet. Top
soil loss is utterly cumulative because it is essentially permanent (Beschta et al., 2004). Field
and laboratory studies indicate that reductions in water moving downslope within the soil profile
contributes to reductions in low flows (Kirkby, 1978).
As Hicks (1991) noted, reductions in lowflows are likely to reduce the survival of salmonids by
reducing rearing area and increasing water temperatures. Subsurface supply of water to streams
are important for thermal regulation and providing flows to streams draining forest watersheds,
especially during lowflow periods (Beschta et al., 1987; Hicks et al., 1991; Rhodes et al., 1994),
as the DEIS concedes. Reductions in subsurface flows to streams reduce low flow volumes,
which, alone, increase summer water temperatures (Theurer et al., 1985; Beschta et al., 1987;
Hicks et al., 1991; Rhodes et al., 1994). Subsurface flows are also typically far cooler than
surface flows, aiding in the thermal regulation of streams during low flows (Beschta et al., 1987).
Thermal regulation is critically important to salmonids and amphibians (McCullough, 1999;
Jackson et al., 2002). This thermal regulation is important not only in reaches occupied by
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salmonids, but also in headwater reaches that provide amphibian habitat (Jackson et al, 2002)
and are critical in a systemic fashion to downstream thermal regulation (Rhodes et al., 1994).
Although it is clear that the cumulative impacts of logging contribute to reduced lowflows, the
FFR has no measures to prevent such occurrences. As with peakflow issues, the primary means
needed to prevent continued damage to lowflows are to develop limits on logging and road
construction. The FFR provides no such limits and, instead, allows these logging and roads to
increase, together with their cumulative impacts on lowflows.
Forests and Fish Report Inadequacies With Respect To Roads and Other Sources of
Sediment Delivery
The most significant defect of the FFR is that it allows road construction and road density to
increase without limit in all watersheds. This is a fatal flaw because assessments have
consistently noted that reductions in road density and road effects are necessary, but not
sufficient, to reduce the on-going damage to aquatic resources (USFS et al., 1993; Rhodes et al.,
1994; USFS and USBLM, 1997a; Karr et al., 2004). There is an unmistakable relationship
between increasing road density and reductions in range and number of salmonids (USFS and
USBLM, 1997a).
Based on the road densities in the DEIS for timberlands that would be covered by the HCP, road
densities are already at levels that exceed levels that damage aquatic systems and result in
reductions in the abundance and range in salmonid populations (USFS and USBLM, 1997a).
Existing road densities in the areas that would be covered by the HCP are well beyond the
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criteria of USFWS (1998) and NOFish (1996) for road density at which watersheds are “Not
Properly Functioning.”
The FFR directs that timber harvest practices decrease the amount of road runoff entering
streams. However, it accomplishes that by diverting road surface runoff onto hillslopes rather
than directly into stream channels. This re-direction is often inadequate to prevent surface flow
from entering streams during storms, especially when the roads are in close proximity to streams.
Further, the re-direction often causes other problems, such as hillslope gullying, which
significantly increases sedimentation, while continuing to contribute to peak flow increases
(Wemple et al., 1996; Rhodes and Huntington, 2000). Diversion of surface runoff can also
increase the mass failure rate, increasing sediment delivery, sedimentation, and salmon habitat
damage.
While some road management practices can, in some limited cases, provide slight reductions in
the amount of road runoff directly entering streams, these practices cannot eliminate road runoff
into streams, as the DEIS concedes. There are absolutely no assurances that the reductions will
be either significant or adequate to reduce the peakflows in watersheds with high levels of road
density and recent logging to less than 20% over natural levels. It is extremely unlikely that
efforts to reduce runoff from existing roads into streams can more than offset increases in runoff
and peakflow caused by additional logging and road construction in watersheds, especially since
both are allowed to increase without limit under the FFR.
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The FFR’s provisions fail to assure that sediment delivery from logging, roads, and road
construction is limited or reduced to levels that prevent additional habitat damage and allow
some recovery in already damaged habitats. The provisions are also inadequate to assure that
turbidity standards are not exceeded. The FFR sets as a goal that existing road networks produce
sediment at levels no more than 50% over background or show an improving trend in sediment
delivery. This approach is grossly deficient on several counts.
First, the objective of limiting sediment production from existing roads to no more than 50%
over background is only set as a goal. This condition is not required, and therefore, not likely to
be met in most watersheds with salmonid habitats.
Second, the FFR sediment production objective applies only to existing roads and fails to include
sediment production from future road construction. This defect is even more egregious because
FFR does not limit the amount of future road construction or ultimate road density.
For this
reason, alone, it is likely that under the FFR both total sediment production and sediment
production from roads will increase significantly in many watersheds, including those with
damaged habitat and degraded water quality conditions. These increases in sediment production
and delivery will cause further damage to salmonid habitats, water quality, and streams. It will
also prevent recovery in already damaged systems, because such systems require significant
reductions in sediment production and delivery for recovery. This will increase the likelihood of
continued fragmentation of salmonid populations, local extirpations, and extinction.
20
Third, the FFR sediment production goal is for the inventoried road network. It does not take
into account or limit sediment production from orphaned or abandoned roads that are not
included in existing inventories or transportation maps. Such uninventoried and orphaned and
abandoned roads often comprise 10-50% of the actual road mileage in logged watersheds. These
uninventoried roads are a significant source of elevated sediment production.
Fourth, the FFR ignores significant sources of sediment production from logging operations
because it applies only to sediment production from roads. Although roads are typically the
largest source of sediment in logged watersheds, logged areas also produce significant amounts
of elevated sediment delivery, especially in heavily logged watersheds. By setting goals only for
sediment production from roads, rather than all logging-related sources, the FFR also ignores
sediment production from allowed levels of bank damage on non-fish-bearing streams. As
previously discussed, elevated peak flows will also increase sediment delivery to salmonid
habitats.
Fifth, the approach relies on BMPs, road upgrading, and road obliteration and abandonment
instead of limiting road construction and road density. This is a fatal flaw because numerous
studies have documented that sediment production from roads is greatest during the construction
period and a few years thereafter (Furniss, 1991; Beschta et al., 2004). Management practices
cannot eliminate increased sediment production from road construction (USFS and USBLM,
1997b). As Beschta et al., 2004 noted, “Furthermore, the assumption that road obliteration or
BMPs will offset the negative impacts of new road and landing construction and use is unsound
since road construction has immediate negative impacts and benefits of obliteration accrue
21
slowly.” This clearly indicates that the FFR approach will not effectively limit surface erosion
and sediment delivery to streams, and, instead, allows it, and attendant damage to aquatic
resources to increase.
The FFR also ignores that there is an increasing body of work indicating that BMPs are
inadequate to protect aquatic systems from the cumulative damage caused by continued logging
and road density. Espinosa et al. (1997) demonstrated that aquatic habitats were severely
damaged by roads and logging in several watersheds despite BMP application. Espinosa et al.
(1997) specifically noted that blind reliance on BMPs in lieu of limiting or avoiding activities
that cause aquatic damage serves to increase aquatic damage. This conclusion is highly germane
to the FFR because it exemplifies just such a blind reliance on BMPs.
There are no reliable data that BMPs can relegate the adverse effects of significant soil and
vegetation disturbance on aquatic resources to ecologically negligible levels, especially within
the context of currently pervasive watershed and aquatic degradation (Ziemer and Lisle, 1993;
ISG, 1999; Espinosa et al., 1997; Beschta et al., 2004). Even activities implemented with
somewhat effective BMPs still often contribute to negative cumulative effects (Ziemer et al.,
1991b; Rhodes et al., 1994; Espinosa et al. 1997; Beschta et al., 2004). Based on review of
available data, MacDonald and Ritland (1989) concluded that roads typically double suspended
sediment yield even with state-of-the-art construction and erosion control and that suspended
sediment contributions from surface erosion, alone, from roads in the absence of mass failure,
are typically in the range of 5 to 20 percent above background and remain at elevated levels for
as long as roads are in use. Notably, this would, in many cases, violate water quality standards
22
for turbidity. Based on a review of available information, Kattleman (1996) concluded that
BMPs could do little to reduce sediment delivery from roads at stream crossings.
In the case of the FFR the term “best” is not an apt term for its management practices, because
the FFR does not prescribe management practices for controlling sediment delivery from surface
erosion from roads that can truly be considered the “best.” For instance, the FFR includes no
prohibition on wet weather haul on native surfaced roads even though it is well-documented that
this greatly increases surface erosion and sediment delivery on roads. Wet weather haul causes
rutting, which has been documented to increase sediment delivery from surface erosion on roads
by about 2-5 times that occurring on roads without ruts (Burroughs, 1990; Foltz and Burroughs,
1990). This increase in sediment delivery is over and above the grossly elevated levels caused
by the very existence of roads as exacerbated by haul traffic. Because these negative impacts of
haul traffic on wet roads are so well recognized, one of the more commonly employed BMPs on
many national forests is prohibition of timber haul during periods when roads are wet. As USFS
research has noted (Burroughs, 1990), road closure during wet weather is one of the most
important measures to take in order to avoid road damage and to reduce sediment production
from roads. However, the FFR fails to require any similar BMP application, even in watersheds
where sedimentation is already a problem for water quality and imperiled aquatic species.
Similarly, the FFR woefully fails to protect an adequate width of vegetation along all streams to
somewhat limit sediment delivery from upslope logging, landings, and roads. This despite that it
has long been recognized that full protection of the area of vegetation within 200 to >300 ft of
the edge of all stream types is one of the most important and effective ways to limit sediment
23
delivery from upslope disturbances, as numerous independent assessments have repeatedly
concluded, including, to but not limited to, Anderson et al. (1993), USFS et al. (1993), Henjum
et al. (1994), Rhodes et al. (1994), NRC (1995), Erman et al. (1996), Moyle et al., 1996; USFS
and USBLM (1997a), Beschta et al. (2004), Karr et al. (2004).
The FFR also fails to put a ceiling on total road density and the amount of immature forest (<30
years) from logging in watersheds, despite strong evidence that this limiting these cumulative
watershed disturbances is critical important means of limiting long-term damage to aquatic
systems (Ziemer, 1991a; b; USFS et al., 1993; Rhodes et al., 1994; Murphy, 1995; Spence et al.,
1996; NOFish, 1996; CWWR, 1996; USFS and USBLM, 1997a; USFWS, 1998). Clearly the
FFR’s management practices for limiting sediment delivery from roads and logging can not be
accurately termed “best management practices,” because they fail to incorporate management
practices for doing so, that have been widely recognized as among the most effective measures.
As will be discussed in greater detail, there is no merit to the notion that the adaptive
management approach in the FFR can be used to improve BMPs in a timely manner to a degree
necessary to adequately protect aquatic resources is extremely unlikely. There are several
formidable reasons adaptive management is not amenable to limiting or reducing damage to
watershed and aquatic resources (Ziemer et al., 1991a; Ziemer, 1994; Rhodes et al., 1994;
Rhodes, 1998). As Ziemer (1994) noted, the notion of effective use of adaptive management to
fine tune activities, while protecting watersheds and aquatics “...is an attractive, but ecologically
naive idea.”
24
However, the greatest evidence that the adaptive management process under the FFR will not
appreciably improve management practices is the FFR itself. Adaptive management is often
described as “learning by doing,” which obviously requires learning from what is done.
However, the FFR indicates that most effective practices and prescriptions have been ignored
despite overwhelming evidence for their necessity, indicating that nothing has been learned from
what has already been done. Since the FFR indicates a severe inability to learn from what has
already been done, it is even more unlikely that it is possible for the process to “learn by doing.”
The FFR allows up to 10% of streambanks on non-fish bearing streams to be disturbed by
logging. This is likely to be a significant source of elevated sediment. Non-fish- bearing streams
account for 50-70% of the channel network (SER Report). Therefore, a significant amount of
the banks in a stream network can be mechanically disrupted, creating a large source of sediment
that is efficiently delivered to downstream salmonid habitats (SER Report). This plainly
indicates that the FFR’s provisions for sediment production focusing solely on existing roads
ignore significant sources of sediment caused by logging operations.
These defects are significant because it is total sediment delivery to streams, not just that from
existing roads, that degrades channel habitats and water quality. Due to these omissions of
sediment sources, it is likely that total sediment production from logging and related activities
will be well above 50% over background, even if the goal for existing roads is met. These
omissions also make it highly likely that sediment delivery from surface erosion will actually
increase significantly in many watersheds under the FFR, resulting increased damage to aquatic
resources, and decreased likelihood of the persistence of salmonid populations.
25
Fifth, even if it is met, the sediment production goal for existing roads, together with the lack of
goals for other sources, allows increases in sediment production, and consequent increases in
turbidity and habitat and water quality damage. This is allowed even in watersheds where
turbidity is already elevated and existing levels of sediment delivery are already causing habitat
and water quality degradation. In areas where the total sediment load from logging and related
activities is already damaging habitat, the FFR allows significant increases in sediment
production from logging, elevated peak flows, and mechanical bank damage on streams
comprising the majority of the stream network. Together, these sediment sources can greatly
increase sediment delivery, even in systems that already have elevated turbidity and highly
impaired habitat and water quality conditions caused by existing levels of sediment delivery.
This will increase the intensity and extent of aquatic damage from sediment delivery and thwart
recovery of damaged habitats, further imperiling the persistence of salmonids.
Sixth, models used to estimate both background and existing sediment production from roads are
often in error and fraught with potential for abuse (Rhodes, 1995; Hickey, 1997). Therefore, in
many watersheds, actual sediment production from existing roads will remain greater than 50%
over background, despite estimates to the contrary.
Seventh, even if met in all cases in all watersheds, the goal of limiting sediment production from
roads to no greater than 50% over background does not ensure that turbidity, water quality, and
habitat conditions are not degraded further by sediment production from roads and other sources.
Sediment delivery levels well below 50% over background levels degrades pools, fine sediment,
26
channel morphology, and turbidity (Rhodes et al., 1994). Similarly, sediment delivery that is
<50% contributes to the maintenance of degraded conditions of pools, fine sediment, channel
morphology, and turbidity, preventing or severely retarding recovery of habitat attributes
essential to the survival of salmonids (Rhodes et al., 1994). Notably, the FFR, National Marine
Fisheries Service Memorandum Re: Statement of how the Forests and Fish Report likely meets
Properly Functioning Condition (June 16, 2000), the National Marine Fisheries Service Analysis
of Riparian Conservation Measures (March 1999), CH2M (2000) all fail to provide any
compelling data, scientific literature, studies, or rationale indicating that limiting sediment
production from existing roads to 50% or less of background levels ensures that habitat and
water quality conditions are not further degraded. Similarly, there is no sound scientific basis
that this goal, even if met, would allow improvement in damaged habitat conditions, instead, data
countermands this proposition (Rhodes et al., 1994). This is especially true since the FFR
provides no limit on increased sediment production from other sources, such as bank damage,
peak flows, and logging. Because the FFR provisions ignore sediment contributions from other
sources, total sediment production from logging and related activities is likely to be far higher
than 50% over background.
Eighth, the sediment production goal for roads allows significant, and essentially permanent,
elevation of turbidity well beyond existing standards. Most sediment produced from roads
contributes to suspended sediment levels. In most watersheds, turbidity is proportional to
sediment levels. Therefore, even if the sediment production goal for existing roads is met,
sediment production from existing roads, alone, is likely to elevate turbidity to 50% over
background (natural) levels. In fact, this exceedance of turbidity standards is likely to be even
27
greater because turbidity will also be elevated by allowed bank damage, logging, elevated peak
flows, and newly constructed roads. Therefore, the FFR clearly allows significant and longlasting exceedance of turbidity standards.
Ninth, the FFR inadequate riparian protection measures assure that sediment delivery from
logging, landings, and roads will be relatively efficient. On all streams, the FFR provides
riparian protection areas that are far narrower than recommended to reduce sediment delivery,
based on data assessments (e.g., USFS et al., 1993; Henjum et al., 1994; Rhodes et al., 1994;
NRC, 1995; Erman et al., 1996; Moyle et al., 1996; USFS and USBLM, 1997a; Beschta et al.,
2004; Karr et al., 2004). For instance, based on an analysis of sediment movement data in granitic
terrain in climatic conditions similar to eastern Washington, USFS and USBLM (1997a) estimated
that a distance of about 550 feet from each side of an ephemeral stream was needed to reduce the
risk of accelerated sediment delivery to intermittent streams from upslope sources where a 50%
slope abutted an ephemeral channel. Notably, USFS and USBLM (1997a) concluded that such a
reserve width did not ensure protection against increased sedimentation, but only reduced its
probability. The FFR riparian provisions fall well short of protecting 550 feet from either side of
streams.
These are extremely significant defects. Roads are primary source of habitat degradation
throughout the Pacific Northwest (USFS et al., 1993; Rhodes et al., 1994; Beschta et al., 2004).
The fine sediment delivered to streams from surface erosion on roads is particularly deleterious
to salmonids and many other aquatic fauna, including those that comprise the aquatic food web
28
(Waters, 1995; Fore and Karr, 1996). Damage from sediment delivery is already a pandemic
problem for salmonids in streams draining areas covered by the FFR.
The Forest and Fish Report Fails To Adequately Protect Riparian Areas – Especially Those
on Non-Fish-Bearing Streams.
The other significant defects of the FFR with respect to flow alteration and sediment delivery are
exacerbated by highly inadequate protection of riparian areas, especially those on smaller nonfish-bearing channels. The FFR provisions allow considerable degradation of riparian areas by
allowing road construction and logging with these areas. Protection is especially lacking along
non-perennial non-fish-bearing streams that comprise the majority of the channel network in
most watersheds. On these streams, the FFR does not require the retention of any trees.
The FFR fails completely to heed the recommendations of NRC (1995) and Rhodes et al. (1994)
that riparian protection areas should be sized conservatively with factors of safety in mind due to
the irreversible nature of damage to these areas from logging, landings, and roads. It also fails to
protect all riparian areas along all streams and is egregiously defective with respect to the
treatment of small headwater streams, especially non-perennial ones.
It is well established that these streams are necessary to protect if downstream habitats and water
quality are to be protected from the riverine insults of elevated sediment delivery from loggingrelated activities (Rhodes et al., 1994; Moyle et al., 1996; Erman et al., 1996). Due to their
characteristics, many small headwater streams with high gradients and unconsolidated channel
substrate are extremely vulnerable to channel erosion caused by peakflow elevation (Rhodes, 1994;
29
Rosgen, 1996). These headwater streams are typically flanked by slopes that are steeper than those
flanking larger downstream stream segments with fish. These streams also have smaller
floodplains to buffer degradation from upslope impacts (Rosgen, 1996). Due to their position in
the channel network, this increases downstream sedimentation in fish habitats (Montgomery and
Buffington, 1998). Increases in peakflows can also increase bedload movement reducing the
survival of salmonids (King, 1989; USFS et al., 1993). These streams are not only extremely
sensitive to disturbance, but also typically comprise the bulk of the stream network, and
cumulatively exert an extremely strong control on downstream aquatic conditions (Rhodes et al.,
1994; Moyle et al., 1996). Damage to headwater streams and riparian areas not only degrades
habitats in headwater streams, but downstream habitats as well, because headwater streams
provide most of the water and sediment for downstream reaches (Rhodes et al., 1994; Moyle et
al., 1996; Erman et al., 1996).
Due to their extent and density on the landscape headwater streams typically have more length
that is proximate to land management activities than larger fish-bearing streams, because the
former comprise the majority of the channel network. Proximity exerts a strong control on the
magnitude and types of impacts to streams caused by land management (Meehan, 1991; Rhodes
et al., 1994; Murphy, 1995). Therefore, non-perennial streams tend to be more intensively and
extensively affected by land management activities.
Due to their importance and sensitivity, smaller headwater streams need to receive as much or
more protection than larger streams if aquatic resources are to be protected (Rhodes et al., 1994;
Moyle et al., 1996; USFS and USBLM, 1997a). This information indicates it is extremely
30
unlikely that aquatic resources can be protected and restoring without adequately protecting streams
that comprise the bulk of the channel network and more vulnerable to degradation than larger
streams.
The failure to require the retention of all trees within at least one site potential tree height along
all streams will contribute to increased sediment delivery from logging and roads in three ways.
First, sediment delivery to streams from any activity generally increases with increasing
proximity to the stream, other factors remaining equal. By allowing sediment producing
activities, such as roads and logging within a tree height of streams, the inadequate riparian
protection measures allow elevated sediment delivery to streams.
Second, vegetation removal reduces the sediment filtering capacity of riparian areas by reducing
terrestrial downed wood. This increases the efficiency of sediment delivery from logging and
roads. Third, tree removal reduces the size and frequency of in-channel downed wood, which
stores delivered sediment in-channel. This increases the efficiency of in-channel sediment
transport to downstream fish habitats.
The failure to fully protect riparian vegetation on non-fish-bearing streams ensures that
downstream fish habitats will not be adequately protected for several reasons. Because seasonal
streams comprise the majority of the channel network length, they cumulatively exert a profound
influence on downstream aquatic conditions via the transport of water, sediment, and nutrients.
Due to the amount of the stream network comprised by seasonal streams and their linkage to
31
downstream conditions, it is impossible to protect perennial streams without fully protecting
seasonal streams.
The FFR’s riparian protections along perennial fish-bearing and non-fish-bearing streams are
also highly deficient and will not maintain the sediment buffering capacity provided by trees and
other vegetation in riparian areas. These are also significant defects, especially since most
riparian areas on private forest lands have already been significantly degraded by previous
logging and existing roads.
The Forests and Fish Report Fails To Address Baseline Conditions and Cumulative
Effects.
For waterbodies already harmed by sediment pollution and in systems where sedimentation is
already affecting salmonids and amphibians, allowing continued degradation will not put those
streams on a path to compliance or allow recovery of aquatic habitats. Instead, even incremental
increases in sediment levels will perpetuate the degradation. For waterbodies that are currently
in compliance with water quality standards, continued degradation endangers water quality and
is likely to eventually cause water quality standard violations. Likewise in systems where habitat
quality is not endangering aquatic biota, cumulative watershed disturbance and consequent
aquatic degradation is likely to eventually reverse the situation (Ziemer, 1991a; b)
In order to actually comply with water quality standards and protect and restore aquatic systems,
first, the harm to the system must be stopped (Rhodes et al., 1994; Kauffman et al., 1997;
32
Beschta et al., 2004; Karr et al., 2004), and then the sediment-producing situation improved in
order to ultimately gain improvement in water quality and habitat conditions.
The FFR prescriptions are not a path towards recovery in damaged conditions. First, the FFR
allows actions (such as tree removal in riparian buffer zones and significant increases in total
sediment delivery) that significantly depart from measures needed to attain water quality
standard compliance. Imperiled fish populations simply cannot hold out for years or decades for
the instream water quality problems to abate.
Finally, the FFR fails to adequately consider cumulative effects of logging and related activities
on fish populations and habitats. This defect is exacerbated by the failure to constrain activities
causing cumulative effects, road density, the total area of immature vegetation, bank damage,
increased peak flows, increased sediment delivery, and loss of riparian vegetation. Due to the
FFR’s deficient protection provisions, this will contribute to increased peak flows, elevated
sediment delivery and consequent damage to salmonid habitats and turbidity, and damage
riparian areas. This is damage that cannot be rapidly reversed, even if the need to do so is
ultimately recognized. In the case of weak and/or fragmented populations of aquatic biota, the
effects irreversibly lead to increased likelihood of extirpation and reduced likelihood of recovery.
DEFECTS IN THE DEIS
The DEIS Distorts the Disclosure of Impacts With a Make-Believe Baseline
33
The DEIS’s clearly premises its analysis of the differences among alternatives and their impacts
via a set of far-reaching prognostications about political, social, economic forces and resulting
possible changes in land use, citizen participation, and environmental impacts under the various
alternatives (e.g., DEIS, pp. S-3 to S-4, 2-3 to 2-4, 4-5, 4-19 to 4-21). This significantly usurps
the overall validity of the DEIS, because these prognostication are plainly of very questionable
veracity. Such predictions are always questionable, regardless of expertise. But there is no
indication whatsoever that NOFish and USFWS have any particular expertise in such soothsaying. There is no indication that any of the primary authors of the DEIS have any expertise or
education in analyzing such socio-economic systems, much less predicting them. Therefore,
these prognostications are intrinsically suspect.
The record of USFWS and NOFish indicates that as agencies that are poor at predicting the
outcome of much simpler situations, since they have pressed their defense in cases where the
courts found they had acted in violation of laws they are to administer. Examples include the
site-specific NoFish Biological Opinions under the USFS Northwest Forest Plan and the 2000
NOFish Biological Opinion for the Columbia River Hydrosystem, the USFWS Biological
Opinion for timber sales on the Willamette National Forest in Oregon, USFWS Biological
Opinion for the Rock Creek Mine in Montana.
These wide-ranging predictions of complex systems in the DEIS pervade the analysis. The
DEIS’s clearly premises its differentiation among alternatives and their impacts on a set of
guesses about the future of complex systems. Because they are wholly questionable and most
likely wrong, it render the entire analysis similarly so. Since the actual outcomes of social forces
34
cannot be reasonably predicted, especially given the DEIS’s authors’ lack of expertise and
established track record in so doing, these prognostications should be fully excised from the
analysis. As it stands, the DEIS does not examine the environmental impacts of the FFR on fish,
but rather the predicted impacts from a set of questionable predictions about sociopolitical
systems, a defect that the permeates the DEIS “analysis” of impacts and differentiation among
alternatives. To rectify these fatal and far-reaching defects in the DEIS, it should be revised to
do the obvious: examine the likely bio-physical impacts of the alternatives as written in terms of
the type and magnitude of activities that they allow.
The DEIS’s Assumptions About the Effectiveness of Adaptive Management to Limit
Aquatic Damage to a Degree That Does Not Further Imperil Aquatic Biota is Baseless
and Without Merit
One of the primary bases for the DEIS’s evaluation of impacts and differentiation among
alternatives is its assumptions about the overall effectiveness of adaptive management provisions
and how they differ among alternatives (e.g., DEIS, pp. 4-5 to 4-19). The DEIS views these
through a grossly distorted lens that obfuscates rather than discloses environmental impacts on
aquatic systems. In particular, the DEIS’s unstinting faith in the divine implementation of
adaptive management as a panacea for its gross defects are without merit and highly misleading
for several reasons.
Adaptive management involves attempts to “learn by doing,” through iterative monitoring of
outcomes with use of the monitoring information to guide future activities. There are several
35
formidable reasons adaptive management is not amenable to limiting or reducing damage to
watershed and aquatic resources due to on-going watershed damage and inadequate protection
measures (Ziemer et al., 1991a; Ziemer, 1994; Rhodes et al., 1994; Rhodes, 1998), as is the case
under the FFR. It is worth re-iterating that the notion of effective use of adaptive management to
fine tune activities, while protecting watersheds and aquatics “...is an attractive, but ecologically
naive idea,” as noted by Ziemer (1994).
The first reason is that aquatic degradation is often lagged in time well after the on-site the
causes have been fully implemented, with no possibility for fine-tuning or rapidly reversing onand off-site impacts within the affected watershed (Ziemer et al., 1991a; Ziemer, 1994; Rhodes
et al., 1994; Rhodes and Huntington, 2000). For instance, if logging and road construction
significantly elevate suspended sediment levels in a protracted fashion, little can be done to
rapidly reverse the cumulative effects. In the case where activities cause imminent extirpation of
fragmented aquatic populations, as has happened already over large areas (USFS and USBLM,
1997a; USFWS, 1998), there is no potential for reversing the damage, including the increased
risk of further extirpation due to the increased fragmentation of remaining populations.
Second, adaptive management requires both adequate monitoring and detection of change.
Because of the high variability in aquatic systems, it is typically only dramatic changes that can
be detected, often after considerable time, even with the best possible and expensive monitoring
(Rhodes et al., 1994; Ziemer, 1994). Notably, adverse impacts that are not detectable with
conventional monitoring still have considerable ecological and societal impacts. For instance,
consider the case of a municipal watershed, where suspended sediment levels are so variable that
36
only a change of that is somewhat consistently greater than 20% over three years is detectable. If
the actual change is only 17% over this time period, it would not be detectable by monitoring,
but it would have significantly degraded drinking water, possibly to the point of requiring
additional treatment facilities.
Notably, none of the alternatives analyzed in the DEIS actually require adequate monitoring of
important issues associated with the outcome of the alternatives. Further, none of the
alternatives have the funding needed to do even minimal monitoring needed for adaptive
management (McClure and Stiffler, 2005).
Regarding the implementation of adaptive management processes, it has been my consistent
experience over the past decade that the neither the monitoring nor the processes are ever
implemented in fashion, even when they have been legally mandated or otherwise binding.
Prime examples of such failures to implement effectiveness monitoring in a timely fashion are
the aquatic monitoring for the USFS Northwest Forest Plan and the tributary monitoring under
the 2000 NOFish Biological Opinion for the Columbia River Hydrosystem. Although both
NOFISH and USFWS must be aware of such failures, they fail to reasonably incorporate this
information into the DEIS or use it to temper their baseless faith in the divine implementation of
adaptive management. Notably, the DEIS is devoid of single case history of any use by any
institution under an HCP that indicates that adaptive management was used in a timely fashion to
reverse the trend towards extinction of populations. In so doing, the DEIS grossly skews the
analysis of the likely outcomes of the alternatives under consideration.
37
Third, aquatic impacts are usually caused by cumulative effects and linking the effects to specific
activities or attributes of activities is difficult (Ziemer, 1994; Rhodes, 1998). Nonetheless, it is
fairly common for management entities to insist on fairly clear cause and effect relationships
before even considering altering on-going practices (Rhodes et al., 1994; Hirt, 1996; Rhodes,
1998). This often results in on-going irreversible damage.
Fourth, activities may have irreversible impacts, such as extirpation of imperiled species or loss
of irreplaceable topsoil. This aspect of the impacts is in direct conflict with one of the prime
guidelines for responsible use of adaptive management: the impacts of the activities should be
reversible (Ludwig et al., 1993). The DEIS utterly fails to note the lack of effective aquatic
protection provisions in the alternatives conflict with the responsible use of adaptive
management, because they will cause irreversible impacts.
However, there are also institutional barriers to adaptive management. The first is that
bureaucracies are resistant to change, often more committed to maintaining status quo direction
than responding forthrightly to information that requires significant management changes
(Worster, 1985; Hirt, 1996; Wilkinson, 1998). The DEIS and the FFR exemplify this resistance.
Case histories provide ample empirical evidence that individuals that collect information which
indicates that a course change is necessary often have their careers truncated in retribution
(Wilkinson, 1998), providing another major obstacle to adaptive management. Since adaptive
management requires rapid response to information, these are formidable obstacles to its use. In
the case in point, the DEIS wholly fails to factor into its analysis and differentiation among the
38
alternatives that under a 50-year safe harbor, there is little motive to aggressively pursue adaptive
management.
Learn by doing requires learning by what has been done. Land management has a consistent
track record of refusing to learn from what has been done. As mentioned, the FFR and the DEIS
provide very strong evidence of an inability to learn from what has been done. Despite
compelling evidence of their necessity as part of measures to protect aquatic systems, none of the
alternatives include limits on logging, road density, and sediment delivery, nor do they require
adequate riparian protection. This remains the case despite legions of studies demonstrating the
importance of these measures to a multitude of critical aquatic processes and conditions. This is
clear and strong empirical evidence of the refusal to learn from what has already been done,
which indicates that “learning from doing” is likely to establish the same monotonously dismal
track record of failure.
A prime example of the inability to learn from what’s been done are the scenarios described in
the DEIS (pp. 4-14 to 4-19) regarding large woody debris, temperature, and fine sediment. In
each case which the DEIS (pp. 4-14 to 4-19) asserts that adaptive management is important,
there is already more than ample information to provide these answers and adjustment in
management practices without any additional wasteful monitoring of issues that have already
been amply researched. That the FFR has failed to adopt needed management practices on the
basis of available information amply contradicts the DEIS’s assumptions regarding the efficacy
of adaptive management.
39
Finally, there is no sound basis for assessment of the assumed levels of effectiveness in the DEIS
of adaptive management among the alternatives because they are based on unsubstantiated
surmise of unknown veracity on the outcome of complex social and political issues. For this
reason, the DEIS wholly fails to reasonably differentiate among the alternatives regarding this
aspect.
This skewing of the analysis permeates the DEIS and renders the analysis of likely impacts and
differentiation among the alternatives wholly arbitrary and misleading. These gross and fatal
defects in the DEIS need to be rectified. The DEIS needs to be revised to a) factor in that
adaptive management will be sluggish and will often fail to make necessary adjustments; b)
acknowledge that adaptive management cannot compensate for inadequate aquatic protection
measures and has almost no utility for conserving aquatic resources, especially imperiled and
fragmented aquatic populations; c) analyze the direct and cumulative impacts of the activities
allowed under the FFR instead of baselessly assuming that adaptive management is a panacea.
The DEIS Fails to Take a Reasonably Hard Look at the Effects of the Alternatives on
Aquatic Systems and Adequately Differentiate Among Alternatives With Respect to the
Impacts of Roads and Logging on Flows and Sediment Delivery
The defects of the DEIS with respect to analyzing and disclosing the likely effects of the
alternatives on aquatic resources, including aquatic biota, are numerous and fatal. They are so
numerous that time and space considerations do not allow an exhaustive itemization. The
following discussion includes only some of the most major defects. Overall, the DEIS analysis
40
and disclosure are riddled with the following severe defects: a) failure to include, discuss,
analyze, and use the best available scientific information; b) misleading and grossly distorted
interpretation of scientific information that is included; c) conclusions and interpretations that are
in direct conflict with the best available information.
For instance, the DEIS (e.g., p. 4-13) very incorrectly asserts that alternatives that have greater
restrictions on logging and roading contribute to increased risk of fire and forest pest outbreaks,
and their negative effects on aquatic systems. Notably, the DEIS is devoid of an iota of scientific
information to bolster this false claim. It is demonstrably incorrect.
Logging does nothing to reduce the extent, frequency, or severity of fires. In fact, it is welldocumented that logging actually contributes to increased fire severity and its negative effects on
aquatic systems, due to its effects on stand structure, the substitution of young plantations for
diverse forests, and activity fuels (Huff et al., 1995; CWWR, 1996; Karr et al., 2004; Odion et
al., 2004). In many of the forests covered by the DEIS, the natural fire regime is one of
infrequent, high severity fire; in such systems, the reduction of fuels do nothing to alter fire
severity and instead cause collateral damage to forests (Schoennagel et al., 2004). Roads and
logging contribute to increased frequency of fire by increasing anthropogenic ignition sources.
The DEIS also fails to disclose that fire has critically important ecological benefits to aquatic
systems (Lindenmayer et al., 2004; Karr et al., 2004), while logging and roads have none and
only degrade systems (Rhodes et al., 1994; Karr et al., 2004). In fact, the DEIS wholly fails to
disclose that impacts of roads and logging on soils and consequent effects on watersheds are
41
more severe and persistent than fire (Kattleman, 1996; Rieman and Clayton, 1997; USFS and
USBLM, 1997a; Beschta et al., 2004). The DEIS fails to disclose that the effects of fire, alone,
pose little threat to aquatic populations (Gresswell, 1999). Therefore, it is clear that the DEIS’s
statements on the effects of alternatives on fire and its effects on aquatics are clearly incorrect
and misleading in direct conflict with the purpose of an EIS. This also fatally flaws the DEIS’s
differentiation among the alternatives. These fatal defects need to be rectified.
The DEIS is also incorrect in its assessment of logging and roads on forest diseases and pests.
There is absolutely no evidence to support that such cycles can be eliminated by logging and
roads. Instead, logging and roads contribute to increased problems of this ilk by their effects on
forest structure, creating even-aged plantations, and damaging soil productivity, exacerbating
drought stress. In its 1991 Blue Mountain Forest Health Report, the Region 6 of the USFS
concluded that:
“Soil compaction, disturbance, and displacement from ground-based harvesting
equipment during salvage operations have probably resulted in significantly more
damage to watersheds than any direct influence of the pests themselves.”
Therefore, it is clear that the DEIS misleads significantly on these fronts and needs to revised to
properly disclose impacts and the differences among alternatives.
The DEIS fails to analyze effects of the alternatives on lowflows, including the results on Hicks
et al. (1991), Bowling et al. (2000), and Jones and Post (2004). Notably, the DEIS does not even
cite the only long-term study of flow alteration by logging in the Pacific Northwest, which
documented that logging persistently reduced lowflows (Hicks et al., 1991). Similarly, it fails to
discuss and disclose the mechanisms for lowflow reduction. It also fails to adequately analyze
42
and disclose the likely impacts of allowed activities on subsurface flows to streams. It also
wholly fails to disclose the likely impacts of these effects on water temperature and aquatic biota.
These fatal defects need to be corrected.
The DEIS also fails to adequately analyze peakflow alteration likely under the alternatives. The
discussion of these impacts is cursory and riddled with mischaracterization of cited data, together
with significant omissions of available information. The discussion of peakflow alteration in
snowmelt-dominated regions is particularly defective. The DEIS needs significant revision to
include disclosure of the likely cumulative effects of activities allowed under the activities based
on the best available information, instead of the misinterpretation of some cherry-picked
literature as is what the DEIS currently contains on this front.
The DEIS also needs to disclose that peakflow impacts will likely be exacerbated under all of the
alternatives, but especially alternatives 1-3. Just as important, the DEIS needs to disclose that
this will contribute to additional degradation of water quality and aquatic habitats, decreasing the
likelihood of the persistence of imperiled aquatic biota.
The DEIS also fails to take a hard look and adequately disclose the effects of the alternatives on
sediment delivery and resulting aquatic impacts, including those to imperiled populations of
aquatic biota. In particular, the DEIS fails to adequately disclose the impacts of the activities
allowed under the alternatives and how they will degrade aquatic systems and reduce the
likelihood of the persistence of imperiled salmonids. To cite but one example, the DEIS fails to
adequately analyze and disclose the impacts of elevated peakflows and sediment delivery on
43
channel width, water temperature, and resulting impacts on aquatic biota and water quality
standards. Bartholow (2000) estimated that the increases in channel width documented by Dose
and Roper (1994) in response to logging and roads significantly increased summer water
temperatures, even in the absence of any reduction in stream shading. Although the DEIS (p. 4-61)
acknowledges that factors other than stream shade affect water temperature, it only evaluated water
temperature impacts from effects on streamside shade (DEIS, p. 4-61), ignoring the impacts of
increased channel width, reduced lowflows, and reduced subsurface flows. These are significant
defects that must be remedied. The DEIS needs to revised to disclose the alternatives’ likely
impacts on sediment delivery, turbidity, fine sediment in channels, pools, channel morphology,
and fish and amphibian populations.
Another major defect is that the DEIS fails to adequately disclose the alternatives’ long-term
impacts on soils, their productivity, and resulting impacts on watershed processes and aquatic
resources. This defect is significant because soils are a fundamental resource of forest
ecosystems. Damage to soil productivity negatively affects forest productivity, rates of
vegetative recovery after anthropogenic or natural disturbances, the type, composition, structure
and sustainability of vegetation species, and the timing, quantity and quality of water from
watersheds.
This is an inexcusable defect in the DEIS because it has been known for decades that logging,
roads, and landings reduce soil productivity in an enduring persistent fashion via several wellknown mechanisms. Previous activities have already caused significant damage to soils
44
extensively, making it a concern over large areas that have been subjected to logging and roads
(USFS and USBLM, 1997a; Beschta et al., 2004).
Logging-related activities degrade soils and significantly reduce soil productivity by removing
sources of soil organic matter, compacting soils, and elevating surface erosion (Geppert et al.,
1984; USBLM and USBLM, 1997a; Beschta et al., 2004, Karr et al., 2004). These impacts are
highly cumulatively in space and time due to their persistence. Compaction typically persists for
50-80 years, while the loss of soil productivity from topsoil loss is essentially permanent
(Beschta et al., 2004). Because these effects on soil and soil productivity have major
implications for watershed and aquatic resources, the failure to properly analyze and disclose
these impacts and their aquatic effects is a major flaw that must be rectified.
The DEIS’s blind faith in the effectiveness of BMPs also prevents it from reasonably disclosing
the impacts of alternatives allowed under the alternatives. Notably, the DEIS is devoid of a
sizable body of work that noting the dearth of information to indicate that BMPs are
cumulatively effective in protecting watershed and aquatic resources. These defects must to be
remedied.
The DEIS exacerbates these defects in its treatment of the little scientific literature it does cite on
BMP effectiveness. For instance, the DEIS (e.g., p. 3-33) repeatedly cites that Rashin et al
(1999) as supporting that BMPs effectively reduce sediment delivery. However, the DEIS fails
to note that Rashin et al., (1999) sheds no light on the cumulative effectiveness of BMPs and
other measures in the FFR because, as stated in Rashin et al. (p. 8, 1999), “Surveys evaluating
45
sediment delivery and IN-stream disturbance relied upon residual evidence of erosion and
sediment delivery...and were not designed to detect minor amounts of suspended sediment
delivery as may occur during runoff events.” Such “minor” amounts of sediment delivery during
runoff events over entire managed landscapes can easily result in significant long-term aquatic
degradation.
The DEIS also fails to note that Rashin et al., (p. 12, 1999) states “Although based on water
quality standards interpretations, these effectiveness criteria should not be construed as being
equivalent to regulatory criteria for determining water quality standards compliance. While a
BMP rating of “effective” indicates that there is a high degree of confidence that applicable
water quality standards have been met, the rating does not guarantee that specific water quality
criteria were not exceeded, such as turbidity during short-term runoff events.” Thus, it is plain
that the Rashin et al. (1999) fails to confirm that BMPs are adequate to meet water quality
standards or prevent habitat degradation over time. This is further strengthened by the fact that
the monitoring of Rashin et al. (1999) took place during a period of lower than normal rainfall
without major storm events, as the DEIS (p. 3-33) concedes.
Just as importantly, the DEIS fails to note that the results of Rashin et al. (1999) indicates that
the riparian provisions of the FFR and alternatives 1-3 are too defective to protect aquatic
resources. This is because, as the DEIS (p. 3-33) notes, Rashin et al. (1999) “...found that in
areas where there were no buffers, best management practices (BMPs) for timber harvest were
not effective in preventing soil disturbance or preventing sediment from reaching streams.”
Under alternatives 1-3 many smaller headwater streams, especially non-perennial ones, will not
46
have any effective riparian buffers, so Rashin et al. (1999) indicates that significant sediment
delivery will occur to these streams under these alternatives. Due to the extent and position of
these streams in the channel network, the sediment will be routed downstream where it will
degrade aquatic habitats and water quality.
Similarly, the DEIS (p. 3-120) does not properly characterize the results of the study of Jackson
et al. (2003) and its ramifications. The DEIS (p. 3-120) states only that Jackson et al. (2003)
found small increases in sedimentation from clearcutting along streams with riparian buffers
streams. The DEIS fails to adequately disclose that Jackson et al. (2001) found very significant
increases in fine sediment levels in streams without riparian buffers. This is clearly germane,
because alternatives 1-3 many smaller headwater streams, especially non-perennial ones, will not
have any effective riparian buffers. Therefore, the results of Jackson et al. (2001) omitted from
the DEIS indicate that the FFR will not protect amphibian habitat in many non-seasonal streams,
and will not protect water quality and aquatic resources overall.
The DEIS’s analysis of the effectiveness riparian protection measures is also inadequate and
misleading. The DEIS fails to analyze and disclose the best available scientific information
regarding riparian protections needed to prevent continued degradation of aquatic resources. In
particular, the DEIS fails to adequately disclose the need to provide wider riparian protection on
steeper slopes and on all streams. The DEIS also fails to adequately disclose the long-term
impacts of the alternatives’ inadequate riparian treatments on water quality, aquatic habitat, and
aquatic populations.
47
The DEIS fails to take a hard look at the impacts of increases in road density allowed under the
alternatives. As previously discussed, there is a wealth of information on the negative effects of
roads, road construction, and road density on water quality, sediment delivery, aquatic habitats,
and aquatic populations that the DEIS fails to reasonably analyze and disclose. These significant
flaws need to be remedied.
Similarly, the DEIS does not adequately analyze and disclose the effects of total watershed
disturbance allowed under the alternatives on aquatic systems. This is a significant defect
because such disturbance cumulatively affects watershed processes and aquatic systems,
including embedded biota. For instance, Willson and Dorcas (2002) found that cumulative
watershed disturbance, and not just stream buffers, affected the condition of amphibian habitat.
These in the DEIS flaws should be corrected.
The DEIS does not adequately disclose the irreversible impacts and irretrievable resource
commitments that will occur from activities allowed under the alternatives. For instance, the
DEIS fails to properly disclose that the loss of soil productivity on landings and roads is a longterm irretrievable commitment of resources, because it cannot be rapidly restored after such
impacts (USFS, 2001; USFS, 2003). The DEIS also fails to disclose that loss of topsoil via
accelerated erosion and export out of the watershed is an irreversible and irretrievable loss of a
critically important watershed resource. The DEIS also fails to adequately disclose that
continued aquatic degradation is likely to contribute to irreversible extirpation of fragmented
aquatic populations. These flaws need to be remedied.
Summary
48
For the above reasons, based on the best available science, I conclude that the Washington
Forests and Fish Report will not restore and maintain riparian habitat for a minimal population of
salmon, steelhead, and bull trout, and the requirements will not protect water quality or meet
state water quality standards. Instead, it allows considerable additional and persistent
degradation of salmonid habitats, riparian areas, water quality, and turbidity. It is also clear that
the DEIS fails in several fundamental ways to adequately disclose the likely impacts of the
alternatives and their differences on sediment delivery, water quality, aquatic populations,
channel form, and streamflows.
Sincerely,
Jonathan J. Rhodes,
Hydrologist
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