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To all,

Discussion – below – is a summary of the Regional Board action to Suspend NTMPs from the Categorical Waiver for Timber Operations.  This is a short summery for folks who are not understanding the situation regarding NTMPs .

There is another e-mail to follow with a summery and history of TMDLs and Implementing Programs.   If you do not understand this information – recovery of your watershed will not occur.

NTMPs are Non-Industrial timber plans, approved once, and lasting for eternity.  NTMPs continue future operations under the rules in place at the time of approval.  These are private timberlands –  the average NTMP is 500 acres in size. There are now 233,000 acres of approved NTMPs in the north coast region.

At the March 24 meeting the
Regional Board "Suspended" NTMPs from Waste Discharge
Requirement and/or Categorical Waiver compliance. 

NTMPs are no longer subject to stream protection requirements and erosion
control requirements - under the Categorical Waiver for WDRs on private
timber lands. 

There are lots of words about this issue - below - read on if you care to
understand. This issue is related to, and of paramount importance to,
maintianing and recovering water quality values and fish on impaired
north coast waterbodies.

Timber harvest is the primary land use, and thus responsible, in a large
part, for the loss of salmon habitat on our north coast rivers. 
In fact there are a number of rivers where timber harvest, and associated
activity - road building, yarding, etc..  Gualala, Garcia, Albion,
Big, Ten Mile, Noyo,and the Mattole Rivers and Redwoood, Usal and Kings
Range Creeks - are primarily impacted by timber harvest.   On
the Klamath, Scott, Shasta, Trinity, Mad, and Russian Rivers timber
harvest is a particpant with other uses. 

Interested Parties concerned with impaired status of north coast rivers
and streams please note:

The Regional Board is proposing suspension of regulations now in place to
control pollutant contributions from timber harvest activity on impaired
waterbodies in the north coast region. 

Timber harvest and related activities are responsible for a great
percentage of impairment on impaired listed waterbodies. 

The Gualala, Garcia, Albion, Big, Ten Mile, Mattole, and  Van Duzen
Rivers - and -  Freshwater Creek, Elk Creek, Redwood Creek are
primarily impaired by timber harvest and timber harvest related activity
( road and skid trail construction and re-construction, landings,
yarding, etc.). 

Russian River, Navarro River Shasta River, Scott River, Klamath River,
Eel River, Mad River are all also impacted by timber harvest - with
additional agricultureal and urban issues adding to impairment issues. 

There is no argument that Timber Harvest activity under the Forest
Practice Act as administered by Cal Fire does not adequately protect the
Beneficial Uses of Water - the cold water fishery. 

To control pollutant effects from timber harvest land use the Regional
Board correctly included NTMPs under the standards set for industrial
timber harvest as Waste Discharge Requirements and Categorical Waivers.
Waste Discharge Requirement and Categorical Waiver conditions are imposed
as TMDL backstops (otherwise known as Implementing Programs) to control
pollutant (sediment, temperature, and nutrient) inputs related to timber
harvest activity.

In short, these regulations provide greater shade requirements and
Erosion control requirements for all classes of watercourses than the
Forest Practice Rules. 

Non-industrial private timberlands comprise 40% of the forested land base
of the State. NTMPs represent a minor share of that landbase. That
percentage is increasing every year as NTMPs represent a regulatory
loophole in environmental review and approval process these forever
permits to harvest. 

There is no credible evidence or argument that NTMPs represent a lessor
threat to water quality than industrial timber plans and should not be
subject to the same rules. 

And, in fact if the Regional Board, is willing to backslide on regulation
on this sector of the timber land base it is fairly clear that: 1)
recovery actions become a larger burden to those remaining subject to
this regulation, 2)recovery becomes more elusive and that much harder to
attain, 3) that the use of Waste Discharge Requirements and Categorical
Waivers as TMDL backstops to deal with impairment issues is greatly
compromised. 

Finally - this action now proposed by the Regional Board is being
considered on the basis of a large scaled outcry by NTMP owners and the
Forest Landowner's Association.  NTMP owners think that they have
given up the right to clear cut and should receive in turn the right to
not be subject to rules necessary to be in compliance with Basin Plan
requirements - i.e. erosion control for roads and erosion sources and
necessary stream protection. 

ACTION:  

CAG is prepared with documents and arguments address this issue. Due, to
previous commitments I can not be at the March 24 meeting. 

CAG is not prepared to move forward with actions to address this issue
unless there is significant commitment from other interested parties. 

Please respond -
       1)If you are willing to write a letter - you will be provided information - and -
written copy in support.
Thanks, Alan