171 



Kondolf: Cumulative Effects in the Sequoia National Forest 6 



Management activities including past timber sales..., timber 

 associated reading, OHV use, livestock grazing and others 

 have combined to increase the sediment load... The main 

 impact of the increased sediment load appears to be the 

 filling of pools and the corresponding reduction of fish 

 habitat availability. {US Forest Service, Casa-Guard Working 

 Paper - Fisheries, April 29, 1992:7-8) 



Despite these statements ,^ the Forest Service CWE "analysis" 

 concluded that the watershed could accommodate further 

 disturbance before cumulative effects would be evident. 



# 



The Forest Service's procedure is based on assumptions about 

 increases in peak runoff from watersheds resulting from 

 Bianagement activities. However, the Forest Service has failed to 

 flzeasure peak runoff from watersheds, despite the existence of 

 standard hydrological techniques for making these measurements at 

 numerous sites at relatively low cost. Students in my hydrology 

 class probably make more peak flow measurements each year than 

 the entire staff of the Sequoia National Forest. The Forest 

 Service's statements about peak ninoff increase would be more 

 credible if a portion of the person-hours that have been devoted 

 over the past six years to fanciful calculations for their CWE 

 "analysis" had been devoted instead to collection of real 

 hydrological data using- tested hydrologic techniques . The 

 predictions of the Forest Service's CWE "analysis" procedure are 

 completely unverified, and in my opinion, contradicted by actual 

 field conditions. 



Conclusion 



While most attention in this hearing is directed at the 

 Giant Sequoia trees themselves, we should not ignore the 

 persistent, underlying erosion and sedimentation resulting from 

 timber harvest, logging roads, and livestock grazing. The 

 available evidence (including statements by Forest Service 

 fisheries biologists) clearly indicates that cumulative watershed 

 effects have already occurred. However, the Forest Service 

 denies this fact, pointing to the results of a confusing, 

 scientifically unsound, and easily manipulated computer model. 

 This so-called "analysis" has been rigged so it always indicates 

 that more trees can be cut and more roads built in a given 

 watershed. During the time spent creating this worthless paper 

 trail. Forest Service staff have not collected scientifically 

 defensible data from which the true cumulative effects of 

 management could be evaluated. 



