Letter to CDF

Below, my somewhat hurried attempt at a letter to CDF re the Lost Camp timber harvest. The more letters we can get in to Schultz the better. Short letters are fine. Talk the historic townsite, the trail, the need for a longer public comment period, etc. Letters may also be faxed to 530.224.4841; but in any case, remember to use the THP number, 2-03-040-PLA.

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August 8, 2003

William Schultz
CDF
6105 Airport Road
Redding, CA 96002

re: Timber Harvest Plan 2-03-040-PLA

Dear Mr. Schultz,

I have now had an opportunity to review the actual Timber Harvest Plan, and the CDF PHI, with respect to the "Andy Siller THP," THP 2-03-040-PLA. I have a number of comments.

First, however, I ask that the public comment period be extended through at least the end of August, and preferably, the end of September, so that many interested citizens can have a better chance to become acquainted with the THP, and offer comments.

Second, I ask that CDF conduct an archeological review of the site. Although I am unable to examine the RPF's archeological survey-it is kept secret, and with good reason-from my reading of the THP and PHI I am inclined to think that his survey was inadequate.

Although historic and prehistoric sites are likely to be scattered across the entire area, the locus of historic mining and occupation was at the town of Lost Camp, in Section 23. From Lost Camp several trails led away to different places. One, the so-called China Trail, is a particular favorite of many people, and gives access to Tahoe National Forest (TNF) lands encompassing the North Fork of the North Fork of the American River (NFNFAR), to the southeast of Lost Camp.

I saw no reference to Lost Camp as a townsite-it "boomed" in 1858-and I saw no reference to the China Trail, in the THP. In fact, in the copy of the THP I obtained from Auburn-Bowman CDF, the trail seemed to have been, somehow, deleted from the more-detailed maps.

This trail is a very important component of our historic trail system in Placer County. The more southern part, across the NFNFAR from Lost Camp, climbing to the summit of Sawtooth Ridge, has already been effectively obliterated by timber harvests, on private lands, administered by CDF.

Concern for this trail goes back to at least 1953, when it was one of sixty historic trails listed in a Placer County ordinance, enacted by the Board of Supervisors, all formally declared to be public trails, and assigning misdemeanor-type penalties to whomever might block such a trail.

I do find the trail on page 30.2 of the THP, which shows the entire extent of the 600 acres involved in the plan, and distinguishes areas of tractor yarding, from areas of helicopter yarding, proposed in the plan. The trail and trailhead can be seen on this map, with difficulty, in the more southeastern portion of that part of Section 23 involved in the THP.

We have had tremendous problems, in Placer County, with our historic trails. They have been gated closed; they have been obliterated by timber harvests; and this process began before 1953. In the Placer County ordinance, each of the sixty trails is referenced to one or more old USGS maps, which depicted that trail. In this case, the China Trail shows clearly on the 1866 GLO map T16N, R11E. So does the town of Lost Camp.

In addition to the various intervening USGS maps of this region, the trail is also depicted on the 1962 TNF map of the Big Bend and Foresthill ranger districts. It is also shown on the current USGS 7.5 minute Westville quadrangle.

Because I am both interested in Placer County history, and concerned about the preservation of our historic trails, and public access to these trails, I have urged, for a number of years, that TNF seek to acquire all private lands in Section 23. By purchasing these lands, both the historic townsite, its associated mining areas, and the China Trail could be protected. They form an important part of Placer County's heritage.

By a twist of fate, as I understand it, the leader of the movement to protect our historic trails, in 1953, was Wendell Towle Robie, of the Auburn Lumber Company; and either Robie himself, or his lumber company, owned the very lands now involved in THP 2-03-040-PLA.

I have been informed by CDF archeologist Rich Jenkins that rather narrow conditions must be met for a historic trail to be treated as a historic trail, in the context of a timber harvest. Perhaps the China Trail does not meet the narrow criteria. However, I asked Rich, and he offered no response: where in the Forest Practices Act does it condone the destruction of "trails," whether they meet the narrow criteria or not?

Now, as to more specific components of the THP.

The Lost Camp mines, within Section 23, are of several types, but all involve placer deposits, likely Eocene in age, and the largest mining areas are relicts of hydraulic mining. Add to these a complex of gullies which look to have resulted from a related method, known as ground-sluicing. I believe there were some drift mines in the area. In both methods, the auriferous gravels were washed through sluice boxes charged with mercury. This mercury not only leaked directly from the sluice boxes, through cracks between the boards, but also leaked out the ends of the sluice boxes, where the tailings were discharged.

Hence many of the smaller ravines in the area are very likely contaminated with mercury, as are the larger streams below, such as Blue Canyon, Texas Canyon (not so named in the THP; Texas Canyon is identified as a Class II watercourse in the THP, and is that stream across which one of the new roads is proposed in the THP. It is to the east of Lost Camp, the town, and has many small tributaries, and many of these tributaries are likely to be contaminated with mercury), the NFNFAR itself (not within the THP boundaries), and Fulda Creek (partly within the THP boundaries, but not actually contaminated from the Lost Camp mines, but rather-and this is an outright guess-by placer mining on the creek itself, upstream.

Therefore, construction of roads and skid trails in the small tributaries of Blue Canyon and Texas Canyon in particular, may remobilize mercury, causing it to move downstream, or have local biological effects.

I have found it difficult to understand the THP, and have had little time to read it and make adequate notes. So, I sometimes recall reading some statement within the THP, but do not remember where in the THP that statement was made. Hence I will not reference many of my comments to page numbers in the THP.

One rationale given for the timber harvest is that, by removing overstory, the smaller trees will be released. This is true. However, this site has been harvested in the not-too-distant past, overstory removed, smaller trees released, and the result, in many areas, is a drastically overstocked stand of small conifers, such that high mortality is now occurring, and a tremendous fuel loading of dead and dry woody material exists. I see this especially within Section 23. The THP also asserts that harvest will reduce fuel loading and thus protect against wildfire. I see no provision for removing the existing dead and down small trees, and suppose that with further overstory removal, i.e., the harvest of the remaining larger trees, even more fuel loading will ensue. If anything, the larger trees should be left alone, and smaller trees removed.

In contrast to Section 23, lands in Section 24 to the east, on the ridge between Texas Canyon and Fulda Canyon (let us call it the Fulda Ridge), contain a nice stand of timber which has been more lightly logged, by selective means, in past decades. The forest canopy was left intact, and there is much much less understory, little brush at all, and every chance that a "cool" fire would leave the larger trees alive. However, being within the THP, this ridge-top stand will likely be decimated, sunlight will flood in on soils disturbed by tractor logging, and a very dense and overstocked stand of small conifers will ensue.

I have explored part of the east side of Fulda Ridge, and have found, on the steeper slopes, and along the area of inflection between gentler and steeper slopes which roughly coincides with the boundary between tractor yarding and helicopter yarding, as depicted in the THP, various old trails and ore-cart haul trails associated with hard-rock gold mining. I saw many large Douglas Fir, one ancient tree near six feet in diameter, and one Ponderosa Pin with an old blaze, and the large bark plates typical of an old-growth tree. I would call these trees "old-growth." There was never any commercial logging down there, only a minor taking of trees, principally Incense Cedar, I believe, for mining purposes, around a century ago.

Taking an educated guess, the lands within the THP, across Fulda Creek to the east, have likewise never been logged to any appreciable extent, and there might be regarded as old-growth stands. However, the THP specifically states that no old-growth stands are involved in the harvest.

The THP also declares that no scenic values are at stake, and that no one would even see the harvest area, except from a plane or helicopter. This is not true. I have been hiking in this area for thirty years, and the scenic qualities are very important to me. Much of this area, for instance, can be seen from Sawtooth Ridge. Fulda Canyon itself is quite remarkably beautiful, with many waterfalls. I much enjoy the views from the China Trail, for instance.

Please create a buffer zone around the China Trail, in which no harvest takes place. I suggest a radius of .25 mile from the trail.

I have been told, by someone long familiar with this area, that the trout fishery on the NFNFAR has been ruined by sedimentation on the main stem and tributaries. I do not doubt but that this is true. It is not mentioned in the THP.

The THP mentions probable negative impacts upon raptors, and states that no Northern Goshawk nests were found in the area. Two days ago, on Fulda Ridge, I was startled by a sharp peeping much like that of a Northern Goshawk, in a stand of pines. I could see no nest, and the bird moved away, down the slope, and I never saw it. It much reminded me of the peeping I heard last summer from Goshawks at a nest site in the North Fork American River canyon.

The THP does not mention the existence of Foothill Yellow-legged Frogs in the project area. I have seen these frogs in the NFNFAR, and in many other streams, large and small, and based upon my experience, would expect these frogs to live in Blue Canyon, Texas Canyon, and Fulda Canyon, and their tributaries, wherever accumulations of cobbly sediment are found, and also, in some areas of bare rock (adult frogs will inhabit bare rock areas). A better survey of both raptors and amphibians seems called for.

Finally, with respect to the proposed new roads, I am quite concerned. This seems an extremely heavy-handed component of what is in any case, in my terms, a rather drastic timber harvest. I have examined the course of the proposed road across Texas Canyon, with its associated steep slopes, where a very large culvert will be needed. This haul road is needed only because, it seems, the existing road over to Fulda Ridge, to the east, has been gated closed. I suggest that all harvest east of the main Lost Camp Road be yarded by helicopter; in fact, the entire project should be yarded by helicopter.

If I had more time I could do a better job of relating my comments to specific pages and sections of the THP. Please do extend the public comment period.

Thank you very much for your consideration of these issues.

Sincerely,
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