THP 2-03-040-PLA

August 5, 2003

Rich Jenkins
CDF
6105 Airport Road
Redding, CA 96002

Dear Mr. Jenkins,

I am writing with regard to Timber Harvest Plan 2-03-040-PLA, near Blue Canyon in Placer County. I am hoping that the public comment period for this THP is still open; if it is open, my initial comments are as follows. I understand that CDF does not normally admit emailed comments, and that I should mail a printed version of these comments to William Schultz, CDF, 6105 Airport Road, Redding, CA 96002.

This area is of special concern to me, as it contains the site of the historic gold mining town, Lost Camp, from which various historic trails radiated to other mining camps. I have not yet seen the THP itself, and of course, the accompanying archeological survey data is not available to me. The plan involves 590 acres across sections 22, 23, and 24, of T16N, R11E.

I am an amateur historian and have published books on the history of nearby Dutch Flat, including the diary of gold miner/photographer Isaac Tibbetts Coffin, who lived near Lost Camp, at Texas Hill and Burnett Canyon, from 1858 to 1864. His diary records visits to Lost Camp and use of the historic trails in the area.

It seems to me that special care should be taken when harvesting timber in this area. Lost Camp is more than a set of old mining ditches, reservoirs, and cabin sites; it is a town site, and has not ever been adequately surveyed from an archeological standpoint. The area of the town has been subjected to several timber harvests since the 1850s. I am concerned, then, that any further timber harvests, especially those where tractor logging is involved, but also those where helicopters are used to transport sawlogs, may blur the archeological record in critical areas. Road construction may also damage the archeological resource.

I am also concerned about the effects of further timber harvests upon the historic trails in this area. One trail in particular, sometimes called the China Trail, leads from Lost Camp down to the North Fork of the North Fork of the American River (NFNFAR) to the south. This trail once continued south, across the river, climbing Sawtooth Ridge, and giving access not only to the Sawtooth Ridge Trail, but to the Burnett Canyon Trail and Texas Hill. Now, this more southern, Sawtooth Ridge part of the China Trail has been obliterated by logging.

The more northern, Lost Camp reach of the China Trail is depicted on the 1866 General Land Office map of T16N, R11E. Both the northern and southern reaches of the China Trail are depicted on the 1962 Tahoe National Forest (TNF) map of the Big Bend and Foresthill Ranger districts.

The China Trail gives access to one of the most beautiful areas in TNF. There is a remarkable gorge, with many waterfalls, upstream on the NFNFAR from the base of the trail. Over a period of several years I have tried to bring this area to the attention of both TNF and Placer County, and have urged that every effort be made to purchase the private lands in this area, especially Section 23, which contains both the site of Lost Camp, and the top of the China Trail.

The 1866 GLO map also depicts the "Trail to Monumental Camp," leading due east from Lost Camp and across the ridge separating Texas Canyon from Fulda Creek. While trying to find the line of this old trail, a few days ago, I found many trees marked with blue paint, and much flagging, and realized a timber harvest was planned. Several mining ditches and reservoirs were in the area, along with what appeared to be a cabin site, and an old orchard, and many gullies left from ground sluicing.

I immediately called CDF at Bowman, near Auburn, and spoke with a very pleasant man named Kelly (I am not sure of his full name). Kelly did not know if the THP was still open to public comment, and suggested I call Jeff Dowling. Kelly said that, although I could not myself see the archeological survey of the area, Jeff could look at his copy, and verify whether any particular site or artifact had been documented.

I talked to Jeff yesterday. To my surprise, he seemed to know me quite well. Apparently he thought that I was raising questions about archeological resources merely as a ploy to stop or impede the timber harvest. Rather than check his copy of the archeological survey performed by the Registered Professional Forester (Dave Levy of Nevada City), Jeff merely asserted that he had walked "all over" that area, and that the survey was adequate. When I suggested that Lost Camp was more than a mining ditch and reservoir or two, he declared that our conversation had reached an impasse, and treated me to quite a lecture upon property rights, and "people like me" who oppose any and all timber harvests.

Jeff did not know if the public comment period for this THP was open or not, and suggested I call you. He told me that, supposing that I identified some new archeological site not already recorded, you and he would simply have to visit Lost Camp and devise mitigation measures; the timber harvest itself would go forward.

In years past I have been assured by CDF personnel that no archeological resource whatsoever would stop a timber harvest, but only, perhaps, change its extent, slightly.

I understand this, and I know that CDF, and its employees, and all timber harvests, are governed by a variety of regulations and laws. For instance, on the CDF home page it is stated that "In addition to timber, the state's wildlands also provide valuable watershed, wildlife habitat, and recreation resources. Maintaining the sustainability of all these natural resources is the goal of the CDF Resource Management Program."

Now, I do not believe that CDF has been properly maintaining and sustaining the historic trails in this area--I mean, not just near Lost Camp, but broadly, in Placer and Nevada counties generally. For, again and again I have seen historic trails obliterated by logging. Placer County used to have a rich network of trails, interconnecting, and fairly well spanning the entire county. Now, I am not saying, in some kind of reductio ad absurdum, that each and every one of these old trails should have been preserved intact. It is only natural, over the course of time, that some of these old trails became roads, for instance.

However, when timber harvests destroy one trail after another in Placer County's "high country" (and I would count Lost Camp as part of that high country, being above the usual snow-line, in the winter), I cannot help but think that both CDF and TNF are much at fault, and are, in fact, breaking the law. For it is my understanding that historic trails are to be protected, under the various laws, not destroyed.

I know many such instances of destroyed trails: the southern part of the China Trail has already been mentioned; add to that, the Big Valley Trail, the Sugar Pine Point Trail, the Monumental Creek Trail, and others.

I spoke with Mike Wopat of the California Geological Survey, who had submitted comments with regard to this "Lost Camp" THP. Mike said that his concerns involved proposed construction of a haul road in the northeast part of Section 23, giving access to lands in the northwest part of Section 24 to the east. This new road would have to cross the stream known as Texas Canyon, and Mike was concerned about erosion and sedimentation.

I too am concerned about this proposed new road. A road already exists, which forks to the east from the road to Lost Camp, south of the railroad tracks, in Section 14 to the north of Section 23. This existing road already gives access to the lands in the northwest corner of Section 24. I would think that is much to be preferred that this existing road be used as a haul road, rather than constructing a new road. Although I am not sure of the exact course of the proposed new road, I would also fear that it might have considerable impacts upon the old mining ditches in the area.

Thank you very much for your consideration of these issues.

Sincerely,


Russell Towle