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patches of merchantable timber are on Increasingly steep and 

 unstable ground. Past practices have lead to over-cutting which 

 means that a period of light timber extraction and re-investment in 

 the productivity of the land must begin. The USPS must move away 

 from token fisheries projects such as channel manipulations and 

 move toward a more sound ecological approach. The primary barrier 

 to better management on USPS lands seem to be administrative but 

 the fundamental changes needed may be difficult without major 

 changes in staff. Specific legislative protection of the best 

 Pacific salmon refugia is necessary at this time, however. 



Private Forest Lands : Current logging practices on private land in 

 California completely ignore concerns for cumulative effects. 

 Recent disturbances on private timber lands have set the stage for 

 substantial degradation to stream habitats which will be triggered 

 by the next major storm event. While Six Rivers National Forest has 

 withdrawn all its lands from timber harvest in Grouse Creek (South 

 Fork of the Trinity) , all timber harvest plans on private land 

 continue to be approved. Some watersheds with unstable geologic 

 conditions have experienced disturbance levels from 60-80 percent 

 in a decade despite warnings from scientists of extreme risk of 

 soil loss associated with such practices. 



The California Department of Forestry has allowed clear cut 

 timber harvesting in steep, inner gorge areas that pose greatest 

 risk of sedimentation to stream channels. Large coniferous trees 

 are often removed from riparian zones when steep slopes or 

 deciduous trees provide shade to streams; only stream temperature 

 was considered when current rules were formulated. Humboldt AFS has 

 appraised the California Board of Forestry, both at hearings and in 

 writing, about the potential loss of stocks of salmon in streams 

 effected by industrial timber practices. Our requests that 

 watersheds harboring stocks at risk be designated as Sensitive 

 Watersheds under Forest Practices Rules have received no response. 

 Other aquatic species in our region, such as tailed frogs 

 ( Asclepjus truei ) and Olympic salamanders ( Rhyacotriton olympicus ) 

 are also at risk of extinction but CDF has no plan to protect them. 



California Forest Practices Rules have failed several times 

 over the course of a decade to be approved as Best Management 

 Practices under the Clean Water Act. Currently, the EPA delegates 

 authority over control of non-point source pollution to the 

 California State Water Resources Control Board. Humboldt AFS 

 additions of streams impacted by non-point source pollution to the 

 list of impaired water bodies in 1988 showed that the system of 

 delegation is not working. The SWRCB failed to include many of 

 these water bodies in their data base without justification but the 

 EPA then forced them to reconsider. Most of the streams were 

 ultimately included. It seems that a stronger, direct enforcement 

 role for the U.S. Environmental Protection Agency in oversight of 

 timber harvest should be considered during the re-authorization of 

 the Clean Water Act. 



