170 



Kondolf: Cumulative Effects in the Sequoia National Forest 5 



failure to Analyze CuMOilative Effects on Entire Watersheds 



The Forest Service has repeatedly failed to analyze 

 cumulative watershed effects on master streams receiving impacts 

 from multiple timber sales on many smaller watersheds. The 

 Forest Service has net applied even its faulty, rigged procedure 

 to these downstream channels. For example, Fish Creek drains a 

 watershed affected by three timber sales, but the so-called CWE 

 "analyses" for each of the three timber sales did not examine the 

 downstream impacts on Fish Creek. The Forest Service has argued 

 that it is adequate to evaluate the local effects, in direct 

 contradiction to underlying principle of cumulative effects. 



The Forest Service has also argued that by implementing 

 "Best Management Practices" (BMPs) there will be no impacts 

 anyway. If this were true, then why bother with its cumbersome, 

 complex, fanciful procedure for "analyzing" cumulative effects? 

 If BMPs truly eliminate impacts, then why not simply say so and 

 declare management activities impact-free? 



Failure to Test the Procedure Against ActueLL Field Conditions 



The Forest Service's CWE "analysis" procedure is an office- 

 bound addition and multiplication exercise. There is no explicit 

 attempt to determine the actual linkages between site disturbance 

 (from timber harvest and road construction) and sediment delivery 

 to streams in the Sequoia National Forest. In a number of cases, 

 I have observed streams to be in such degraded condition as to 

 indicate cumulative effects were already evident in the 

 watershed, but the Forest Service's "analysis" indicated that 

 these channels were below their threshold of concern, allowing 

 further disturbance in the watershed. 



Even when a stream is acknowledged by Forest Service staff 

 to be in degraded condition, this observation is not used to 

 calibrate or test the "analysis" itself. For example, the 

 Environmental Assessment for the Ranger Timber Sale described 

 numerous problems with channel stability and excessive levels of 

 fine sediment in Nobe Young Creek (p. 38). Aside from influencing 

 the assignment of a "channel sensitivity index of .09", the 

 conditions observed in the Nobe Young Creek were not factored 

 into the CWE "analysis". Evidently, results of the CWE 

 "analysis" indicated that the stream could tolerate still more 

 watershed disturbance, because seven harvest units were proposed 

 in the Nobe Young drainage basin, including one adjacent to the 

 channel itself. 



In the Casa-Guard Sale area, the Forest Service fishery 

 biologist reported evidence that cumulative effects were already 

 evident : 



