Waste Discharge Requirements (WDRs) are standards designed by the Water Quality Control Board to be used in the evaluation of the potential for destructive impact to water systems from timber harvest plans. Over two years ago in December 2003, the North Coast Regional Water Quality Control Board (Regional Board) took an important step towards addressing cumulative impacts from Pacific Lumber's (PL's) logging in Freshwater Creek and the Elk River, directing their staff to require PL to apply for and obtain watershed-wide water pollution control permits. After significant delays by PL in providing required information to the Regional Board, and after Regional Board and independent scientists demonstrated severe cumulative watershed impacts from high levels of timber harvesting by PL, the proposed permits are now available for public review and comment.

The proposed WDRs are designed to address cumulative watershed impacts from timber harvesting activities in the two watersheds with regard to sediment delivery and nuisance flooding. Downstream residents of Pacific Lumber have complained of severe flooding damage to property over the last several years, and these impacts have occurred in watersheds whose rivers are already listed as impaired for sediment and temperature under the Clean Water Act.

EPIC supports the concept of the proposed WDRs and believes that correlating timber harvest levels with watershed damage is a welcome and long-overdue method for reliably predicting some of the damaging impacts of timber harvest. However, the proposed permits as written contain some "gaps" which will have to be filled before the final WDRs are adopted in order to ensure watershed protection. EPIC will submit extensive expert comments for the record.

Members of the public are encouraged to write or email the Regional Board
BY AUGUST 8, 2005 BEFORE 5pm
North Coast Regional Water Quality Control Board
5550 Skylane Boulevard, Suite A
Santa Rosa, CA 95403

For details on the Watershed-Wide WDRs, see http://www.wildcalifornia.org/pages/page-244

For a sample letter or to send a prepared email message, see below.