68 



fish habitat availabiHty." That's a quote from the Forest Service 

 paper. 



Now, these effects certainly fit the definition of cumulative wa- 

 tershed effects. Yet, the Forest Service "analysis" had concluded at 

 the same time that there were no effects. 



And the way this analysis works is, it adds up all the past things 

 that have gone on in the basin, and it makes an assumption about 

 how much disturbance the basin can accommodate. It compares 

 these two, and if their computation of past impacts is less than 

 what they believe or assume cl'a be accommodated, it is declared 

 to be OK to cut more timber. 



This general approach was developed in another national forest 

 in California and has adapted to the Sequoia National Forest. It 

 has not been field verified in the Sequoia National Forest. 



The method assumes that revegetation is successful, which is 

 often not the case. It also underestimates the area covered by 

 roads, and it also applies fudge factors to reduce the computed im- 

 pact of roads. There are some other problems which I talk about 

 in my written testimony, including manipulation of some of the 

 data that are used in the analysis. 



Now, this so-called analysis of cumulative affects by the Forest 

 Service would not be passing work if it were submitted to me in 

 a university course. It is not consistent with the principles of 

 geomorphology and hydrology, and it is inconsistent with the evi- 

 dence on the ground. 



As far as what should be done, I advocate collection of basic hy- 

 drologic data as a basis for making sound management decisions. 

 The Forest Service sends people into the field, and they spend a lot 

 of time filling out forms for what is basically a fanciful method. It 

 does not actually model what's going on at the ground. 



The Forest Service staff does not make measurements of peak 

 run-off from various drainage basins nor of erosion. Yet, their 

 method purports to predict changes in peak run-off. The students 

 in my hydrology class, who have no previous background in hydrol- 

 ogy* go out in the field and they do more measurements of peak 

 run-off than the entire Sequoia National Forest does. 



I will simply conclude by pointing out that most of our attention 

 has been directed at the trees themselves, but we can't ignore the 

 insidious effects of increased erosion and sedimentation in the eco- 

 system. The problems are serious, and the evidence is quite clear. 

 The Forest Service has not adequately or honestly evaluated these 

 problems. 



[The prepared statement of Mr. Kondolf appears at the conclu- 

 sion of the hearing.] 



Mr. CONDIT. Thank you, Dr. Kondolf I would Uke to mention, 

 you are an assistant professor of environmental planning. Univer- 

 sity of California-Berkeley, in Berkeley, and we are delighted to 

 have you here. 



You have an associate with you, Mr. Christenson. Do you have 

 a comment? We're not going to take your comment, now. I just 

 wanted to know if you will have one. 



Mr. Christenson. I would just state that I'm here to support Dr. 

 Kondolf, £ind some of the same concerns he has, I have. I do work 

 for the California Fish and Game, but I'm not here representing 



