Friday, August 8, 2003

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.

*******
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,
*******

Thursday, August 7, 2003

Lost Camp THP reconnaissance

I joined Steve Hunter of Colfax for a reconnaissance of the Lost Camp THP area yesterday. We left at 8:00 a.m. and drove up to the Blue Canyon exit on I-80, proceeding south and across the railroad tracks to the road fork leading east to the ridge (let us call it Fulda Ridge), in Section 24, between Fulda Creek and Texas Canyon (Texas Canyon is not so named on the modern USGS 7.5 minute Westville quadrangle, but is named on the 1866 General Land Office map of that area). We found this road gated closed with a sign reading "no trespassing" and "if you enter you will be shot."

Another road forked left near the gate and we tried it. It almost immediately leveled out and I realized it had been cut into the line of an old ditch, which could only be the historic Bradley & Gardner Ditch, or Placer County Canal, which drew from the East Fork of the North Fork of the North Fork, and went to the hydraulic mines of Dutch Flat and Gold Run, arriving in 1859. It was following almost exactly the 4680' contour where we met it. In a while we reached a locked gate, and, knowing the ditch must swing around Fulda Ridge, followed the road in. We passed a group of small cabins of recent construction, and then suddenly the road ended and we could follow the ditch itself. It is about five feet deep, and six or eight feet across at the top, and was said to have a capacity of 5000 miners inches, in the olden days.

A little less than a mile along the sinuous course of the ditch brought us to Fulda Ridge. Immediately below us to the south, a fine stand of coniferous timber had shaded out the brush, and made for easy going. We noted flagging where we left the ditch, marking it as a "truck road," and knew we were just entering the Lost Camp THP, on the north line of Section 24.

This forest had been logged at least twice, decades ago, we believed, but by a "selective" method, in which only the largest trees had been cut, and the forest canopy had remained largely intact, and no brush and relatively few small trees had become established, in the shade. So, it was a pretty patch of forest, and easy to walk through, and as we descended, the crest of the ridge flattened out to a dead level. Unfortunately this forest will be pretty well all harvested, according to the THP.

Steve has explored this area almost incredibly thoroughly over the past fifty years. He and his friends have pulled off some amazing adventures. For instance, Fulda Creek, below us to the east, has a steep gradient which only gets steeper as it approaches the North Fork of the North Fork, to the south. There is a series of high waterfalls along the creek, and essentially no way to hike up or down this section. Steve and his friends brought ropes and rappelled down the cliffs beside each waterfall in turn, all the way to the river, and then came back up the China Trail.

But this was only one of Steve's forays into lower Fulda Creek. On other occasions he had found an unusual old mining railroad. Since this is within the THP we wished to document it. I myself also hoped to discover some shred of the old trail from Lost Camp to Monumental Camp, constructed in 1862. However, in this I failed. The logging of decades ago had involved bulldozers, and the usual disruption of the land surface had effaced any sign of the old trail.

Reaching the southern end of the flat top of Fulda Ridge, where it drops away in ragged cliffs of the Shoo Fly Complex metasediments, into the main North Fork of the North Fork canyon, we veered east and began working down towards Fulda Creek. Almost immediately we struck a broad old trail or wagon road, which led back to the north and east. Following it, for a time I hoped it was my lost trail from Lost Camp, but soon it was obliterated by bulldozer skid trails from, what, 35 years ago. So we just angled on down the ever-steepening canyon wall, through a thinning mixed coniferouse forest increasingly dominated by Canyon Live Oaks, until another segment of broad trail or wagon road was reached, this, very nearly on a level.

Following it south, we passed sections of dry-laid stone walls, and finally reached a small mining area with abundant chunks of angular quartz scattered around. There the road-trail seemed to end. A sort of gully choked with angular talus was above the terminus, but no tunnel was visible. We made a short scramble beyond to some cliffy outcrops with fine views out into the main canyon, and we could see all the tributaries which make the Gorge of Gorges: Fulda, Sailor Ravine, the North Fork of the North Fork, the East Fork of the North Fork of the North Fork, Burnett Canyon and Wilmont Ravine, and Texas Canyon. Across the main canyon, Sawtooth Ridge rose steeply to Helester Point. There, a drastically ugly SPI clearcut made a square hole in the forest cover.

Fair-weather cumulus clouds graced the pure blue sky. It was cool, perfect for hiking.

Retreating north along the road-trail, I saw a faint old human trail leading down, and we followed it a short distance to a smaller trail, also about level, perhaps one hundred feet lower. This we followed south until it appeared to end at some cliffs. A bit of iron strapping stuck out of the trail at one point, of the sort one sometimes sees in old mine tunnels, a sort of poor man's railroad track, used for moving ore carts along the tunnel. Also, we saw an ancient cable stretching straight down the hill. Steve's recollection was that this cable led down to his mining railroad. However, our level old trail must be explored first, so we turned and followed it north.

It too had its dry-laid stone walls, and we walked it for a long distance, well, a quarter-mile perhaps, and saw Douglas Fir trees of increasing size, one, perhaps six feet in diameter. Strangely, the THP specifically states that there is no old-growth forest within the plan area. These large trees are clearly old-growth. The only logging which had ever occurred at this depth within Fulda Canyon (we were near the 4200' contour), was minor harvest of medium-sized trees, for mining purposes, around 100 years ago.

Suddenly, though, the old trail was crossed by what seemed to be a skid trail, which had been undoubtedly made by a bulldozer, and yet which looked very old. No stumps in the area signalled that it had been made for logging. Its rough steep bench cut had been much softened by the passage of decades. We tentatively ascribed an age of fifty years to it. The level old trail did not seem to continue, so we followed the steep bulldozer trail down a short distance. There we found large stockpiles of quartz ore, and a variety of mining equipment, including an ore cart, a sort of crucible, and several odd tubes of galvanized metal, something like water heater tanks, but meant to rotate on a longitudinal axis, some still having their axles. We could not imagine what they were for, but, clearly, it had to do with gold mining. They were of several different diameters.

We were now close to the creek, on a small flat, everywhere sloping, but not too far from level, and with a find stand of large Douglas Fir. Steve's sense was that we were far to the north of the mining railroad, which broke out onto the sunny cliffs we had visited earlier. So, with considerable difficulty, we contoured along to the south, while the creek fell away below us, and reached increasingly rocky areas with some rather large outcrops, almost house-sized. At one point Steve climbed up some shattered rock above me, and as I followed, I came within inches of a rattlesnake, which he had passed already. It was a calm snake, half-hidden in a hole, and did not rattle. I stepped away a few feet and climbed up after Steve.

After a time we found a great viewpoint and stopped for lunch. We reviewed the situation. It was impossible that the mining railroad had disappeared. It was virtually impossible that it could be below us. I suggested that perhaps his mining railroad was just the same as our lower level trail; but Steve recalled, vividly, railroad tracks crossing a cliff, and hanging into space. We had followed the entire length of the lower level trail, and had checked the slopes well for hundreds of feet below its line. So, what then?

As we continued, Steve saw a familiar-looking outcrop above us, and as we made for it, he saw a rail. A steep climb brought us to a gully where, perhaps a hundred years past, a trestle had supported narrow-gauge track. The trestle was gone, the track hung in the air, supported by cliffy outcrops at one side. So, we climbed over to the cliffy area, and, voila! There were the railroad tracks, winding sharply around a blasted-out bench on the cliff, and hanging into space at either end of this curved reach. Old cedar ties were still in place, with small railroad spikes, and round nails, and square nails too. It all suggested a turn-of-the-century date, around 1900. We had, again, tremendous views, very similar to those we'd enjoyed earlier.

It was hard to see how far the original line of trestle and track might have continued, to the west, but, as we climbed up above the tracks, the question was likely answered, for we caught sight of a steep-walled, steeply-plunging gully, which I recognized as a quartz vein complex which had been "stoped out" along the surface, to a depth of nearly if not more than twenty feet, measured perpendicular to the overall steep rocky slopes. This may well have been because the material closer to the surface was more weathered, and the gold easier to extract by ordinary, gravity-based methods, i.e., crushing followed by of a sluice box. Sometimes at greater depths, the gold is far harder to separate from other minerals.

We followed the stoped-out vein complex on up the cliff. I have seen very similar workings in the Stanislaus river canyon. At the top of the cliff, the stoped area continued down the far side, and we realized that we had returned to the southern end of our first, highest, level road-trail. Thus Steve's mining railroad was really part of the lower old level trail; and we had just been mistaken, when we thought it had ended at some rocks, earlier.

Thus, the two parallel, almost-level trails are ore cart runs leading from the stoped-out vein complex, north to the ore stockpiles in the little flat with the old mining equipment and the old bulldozed steep road.

Steve says there are other mining artifacts down along the creek itself. I want to emphasize that, not only are these artifacts on private property, but in any case, all such things should be left alone. Carry nothing home, no old railroad spikes, no arrowheads, nothing. Photograph them if you like. Be careful about even mentioning such sites to anyone. It is a shocking fact that many archeological sites have already been looted. This has to stop.

We climbed back to the level summit of Fulda Ridge and retraced our steps back to the ditch and to Steve's jeep.

Later in the day we took a look at various parts of the Lost Camp area, including the proposed new road, to cross Texas Canyon, which is detailed in the THP, and which will require rather extreme cuts on steep slopes and a huge culvert, and, all in all, I would like to see this and other new roads *not* constructed, for this timber harvest, instead, if any harvest occurs, let there be much more in the way of helicopter yarding, much less tractor yarding, and no new roads.

Later we drove down the Lost Camp Divide out of the THP area and into some horrible clearcuts on what I presume is SPI lands.

Such was a very interesting day.

Lost Camp THP Comments

Tim Lasko took the time to call Rich Jenkins and Auburn CDF and wrote the following:

*******
Russell,
I placed a call yesterday to Rich Jenkins and Gary - possibly Britner? and
received return calls from both today. They both told me to write a letter
to William Schultz CDF (6105 Airport Road, Redding, CA 96002.) In the
interest of time, Rich also recommended faxing a copy to 530.224.4841. The
faxed copy would be time / date stamped and placed directly in the file. I
was assured that any letters would receive an official response.

My conversation was lengthy and friendly with Rich. He admitted that he has
never been to the site and informed me that a relatively new CDF
archeologist covers the Central Sierra. Dr. Garrett Fenenga works out of
the Sacramento office, but lives in Placerville. Rich suggested that I
request Dr. Fenenga to review the site. Rich stated that by making that
request, in a formal letter, it would almost guarantee the CDF take the time
to send an archeologist to the site. He also stated that it would be
helpful to submit a map with the areas of concern shown, to ensure that they
are included in the review.

I will write a letter and send it today. What are you thoughts on
submitting a map? I think we should send more letters to William Schultz
CDF (6105 Airport Road, Redding, CA 96002.)

Thanks
Tim Lasko
*******

Tim is right, we need more letters ot Schultz, and we need an extension of the public comment period! And, as Tim found, we should and will request a CDF archeological review. And we should and shall make a map.

Thanks Tim!

Tuesday, August 5, 2003

Lost Camp THP obtained

I drove to Auburn and picked up the Timber Harvest Plan for Lost Camp, from CDF.

It is far worse than I had imagined. 590 of the 600 acres owned by Andrew and Sharon Siller will be logged. This includes the lands around the trailhead and first part of the China Trail. Several new roads are to be constructed, including roads which violate ordinary forest practices, since they would be within riparian zones *and* on steep slopes.

The steepest slopes will be helicopter-logged. The rest, tractor-logged. It looks pretty bad.

I am going to Lost Camp tomorrow with Steve Hunter, who has hiked that area for 50 years, to investigate the situation more closely. I hope we find about a million historic archeological sites, 'cause that's what it's going to take.

Tonight I spoke to the CanyonKeepers group in Auburn. They were very nice and I rambled on and on about geology and glaciers.

Letter to CDF re Lost Camp

Hi Rich, thanks for your reply, in which you wrote,

Thanks for the informative e-mail. Please follow up with a printed version sent to Mr. Bill Schultz for a formal response.

I am mailing a printed version today.

Prior to the formal response I want to say a few words about the protection of historic sites which include trails. Current rules, regulations, and laws do not provide protection for all such resources. Only "significant" historic sites, as defined by the Forest Practice Rules, require protection. Text from the 2003 is as follows:

Significant archaeological or historical site means a specific location which may contain artifacts. or objects and where evidence clearly demonstrates a high probability that the site meets one or more of the following criteria:

(a) Contains information needed to answer important scientific research questions.
(b) Has a special and particular quality such as the oldest of its type or best available example of its type.
(c) Is directly associated with a scientifically recognized important prehistoric event or person.
(d) Involves important research questions that historical research has shown can be answered only with archaeological methods (excavation).
(e) Has significant cultural or religious importance to Native Americans as defined in 14CCR895.1.

Criteria c is most frequently used when evaluating the significance of trails. The Emigrant Trails (Donner, Lassen, Nobles, etc) fit this criteria due to their importance in providing routes to the California Gold Rush and the settling of the west. Other local trails have a more difficult time qualifying under this or other criteria. If you feel that your trails qualify under one or more of these criteria by all means let us know in writing......


So, this is an excerpt from CDF's Forest Practice Rules. But, what of Federal laws, such as the National Historic Preservation Act; or CEQA? I suppose it is likely enough that the Forest Practice Rules have been carefully worded so as to comply with existing state and federal statutes.

And, in what way is the utter destruction of hiking trails consistent with CDF's avowed mission to sustain recreational resources?

Now, I call these trails "historic trails." Suppose instead we simply call them "trails," and do not appeal at all to their historic nature. Where in the Forest Practice Rules does it condone the destruction of trails?

Thank you very much for your consideration of these matters, Rich.

Sincerely,


Russell Towle

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

Monday, August 4, 2003

Lost Camp THP

I spoke at length this morning with CDF archeologist Jeff Dowling, about the Timber Harvest Plan for sections 22, 23, and 24, including the site of Lost Camp, an old gold mining town. This is THP code number 2-03-040-PLA, and involves 590 acres.

Jeff seemed to know all about me, from my opposition to a timber harvest here in the Dutch Flat Diggings, a few years ago. He was rather full of scorn and dismissal towards me and all my tree-hugging kind. I was a little surprised by the vehemence of his feelings. I tried to keep things on an even keel, but again and again Jeff took me to task for wanting to stop all logging.

Nevertheless, I obtained some useful information about the Lost Camp timber harvest. In brief:

1. The property is owned by Sillers Bros. lumber company. One of the principals, Andrew Siller, recently died.

2. The THP may or may not still be open to public comment. I should call the main office in Redding to find out.

3. So far as Jeff is concerned, the site has been adequately surveyed (by the Register Professional Forester and his assistant, Dave Levy and Steve Furlong), and all historic sites well protected. He says that the steeper slopes will be helicopter logged, and that impacts using this method are so light that there is no restriction upon where trees may be taken. Jeff has, in the past, walked "all over" that area.

4. Jeff says the harvest itself will likely not take place for one to one-and-one-half years.

5. Jeff said, if I want TNF to own Section 23, then, don't wait for TNF to find the money, find it myself, contact Siller Bros., and hope for the best.

6. If I have any concerns about protection of historic and archeological sites in this THP, I should write to Rich Jenkins, CDF, 6105 Airport Road, Redding CA 96002. If I do write, Jeff will receive a copy of my letter, and, (sigh) he and Rich will then have to go out and re-survey the area themselves.

Such is what I learned about the Lost Camp THP. I have not yet seen the THP myself. It may be, as Jeff characterized it, a rather benign timber harvest, as such things go.