From George Pess

Re: Comments on Volume IV - Pacific Lumber Company Habitat Conservation Plans, Sustained Yield Plan/Habitat Conservation Plan, Public Review Draft July 1998.
Permits: PRT-828950 and 1157

Page 7 — Section 1.1.3 — Rock and Gravel Mining, Rock Quarrying

However, there is no methodology within the Washington State manual that analyzes the effects of rock and gravel mining on fish habitat. This is known from having co-authored several of the Washington State watershed analysis modules, including the stream channel and fish habitat module, as well as participating in over four watershed analyses in Washington State. PALCO does not identify a specific methodology on how it will evaluate the potential adverse effects of rock and gravel mining on fish and wildlife, aside from stating that all new pits and quarries will be mapped when constructed. In my opinion, mapping quarries and pits, after they are constructed, does not constitute an scientific evaluation process that identifies potential adverse effects of mining to fish and wildlife.

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Page 28 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.1.2 Storm Proofing

PALCO identifies a road storm-proofing audit procedure on page 28, numbers 1 through 5. The procedure is similar to the detailed analysis developed and implemented by Pacific Watershed Associates (1998a, 1998b) for the North Fork Elk and Bear Creek watersheds. Details regarding the procedure are identified in Volume II, Part O (Assessment and Implementation Techniques for Road-related Sediment Inventories). The methodology, developed by Pacific Watershed Associates, is a detailed analysis which requires a basic understanding of geology and geomorphic processes, as well as, an intimate understanding of how to quantify sediment production. PALCO identifies that trained observers" will implement the audit, including the identification of potential erosion hazard areas, quantification of sediment deliver to stream channel, and remedial action that can help reduce sedimentation.

In my opinion, a detailed analysis such as the one described in this section, requires formal education in geology, with an emphasis in geomorphology, or forest hydrology and forest road engineering. Furthermore, years of experience on forest lands is also needed in order to help identify and quantify potential erosion hazards. The quality of the individual doing such analysis will have, in my opinion, a major effect on whether the audits are accurate, precise, repeatable, and thorough. PALCO does not give sufficient information to identify if such a person will be the trained observer.

PALCO also does not state if a detailed analysis, such as the ones completed for North Fork Elk and Bear Creek watersheds, will be implemented on each watershed. PALCO states that at least 500 miles of existing roads will be improved to meeting the storm-proofing standards identified in the PWA guidelines (Volume II, Part N)." It is not clear if the 500 miles of road includes all watersheds in which PALCO owns land.

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Page 28 —Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.1.3 Road Construction, Maintenance, Improvements, and Abandonment, Statement number 1

The PALCO HCP recognizes the importance of a road management plan, and attempts to implement road management in the following manner:

According to the road erosion inventory methodology, future (expected) erosion and sediment delivery information will be gathered (Volume II, Part O, Pages 4 and 5; Pacific Watershed Associates, 1998a&b, Pages 7 and 9), including information of potentially" unstable areas that do not show signs of imminent" (e.g., visual) failure.

However, poorly built or maintained roads that have not begun to show signs of visible failure (e.g., slumps, scarps, and cracks), but do have a high potential to fail due to unstable fill, or other problems, will not be upgraded.

PALCO does not describe why such areas where left out of the upgrade plan. A road maintenance and upgrade plan that does not include all potential high risk failure areas, regardless of whether or not they show current signs of failure, which can impact a watercourse, is likely, in my opinion, to lead to significant cumulative adverse impacts to fish habitat and production.

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Page 29 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.1.3 Road Construction, Maintenance, Improvements, and Abandonment

The PALCO HCP identifies that fish passage will be accommodated for all new roads which pass over fish-bearing streams and restorable" fish-bearing streams (Volume IV, section 1.2.1.3, page 29, first paragraph). PALCO, however, does not define what a restorable" fish-bearing stream is, nor do they give any reference to information that is needed to define a restorable stream. According to my knowledge of the scientific literature no one has ever defined when a stream is or is not restorable.

More importantly, PALCO does not address the need to evaluate if existing culverts are fish passage impediments. Work in other Pacific states, such as Washington, have identified and implemented large-scale programs which inventory and identify culverts blocking salmon passage (Conroy, 1997). For example, the Snohomish River, a 1200mi2, watershed in Western Washington that includes a significant portion of its land in managed timberlands, has had field crews from five agencies (local county governments, non-profits, tribes, state agencies, and federal agencies) implementing culvert inventories for over four years. This effort has resulted in approximately 25% of the entire basin being inventoried, with 75% remaining. In some cases, 50 to 75% of the existing culverts in a watershed that has forestry as its primary land-use are fish passage blockages (Conroy, 1997). The Stillaguamish River, a 700mi2 watershed in Western Washington, has had a culvert inventory recently completed for over 50% of the basin. Blocking culverts have reduced potential coho smolt production in small stream habitat by 38% to 40% from historic conditions (Pess and others, 1997). Approximately 60 miles of small stream habitat is blocked for at least one coho freshwater life stage (Pess and others, 1997). The DEIS/EIR for the Headwaters Forest Acquisition, and the PALCO Habitat Conservation Plan and Sustained Yield Plan also identifies that critical freshwater habitat for juvenile coho is particularly susceptible to human disturbance such as fish passage barriers that prevent upstream access or modify downstream conditions (USFWS, October 1998, page 3.8-23). Based on this, and other efforts throughout the entire region where salmon occur, it is clear that existing blocking culverts are a problem.

PALCO does not address the issue of existing blocking culverts, even though it, in all likelihood, is a problem, particularly to coho. In addition, state and local rules that govern the design of water crossing structures for roads normally include a specific provision for fish passage (e.g., Washington State Administrative Code 222-24-050). It is my opinion that existing blocking culverts do have a significant adverse effect of coho use and production, and do result in the loss of fish over time. Leaving existing blocking culverts in streams will reduce the recovery of wild salmon stocks, such as coho, because of a reduction in the amount of total available habitat.

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Page 30 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.2.1 Channel Migration Zone

In order to plan for the future recruitment of large woody debris (LWD) to stream channels, it is necessary to maintain a riparian forest on the entire flood plain, as well as the adjacent slopes. PALCO states the definition of the CMZ as the following:

The NMFS definition gives more resource protection because it utilizes a greater spatial and temporal extent, which is scientifically more accurate because we cannot

accurately predict future channel locations, especially in forested channels which have a tendency to move in significant, discrete steps (e.g., avulsions).

The NMFS draft forest practice rules for Oregon, and other HCPs, provide a more scientifically credible and conservative definition of a CMZ. PALCOs definition has a greater probability of leading to significant adverse impacts than the NMFS definition. The dynamic nature of a CMZ and the flood plain, in my opinion, warrants a definition that encompasses a greater percentage of the total area than how it is defined in the PALCO HCP.

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Page 31 through 34 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.2.2 Class I Stream Buffers

The PALCO stream buffer plan has several key aspects which reduce the potential success at protecting and enhancing freshwater coho salmon habitat. This list includes the following from pages 31 through 34 of Volume IV, Section 1.2.2.2:

• All fish bearing (or restorable) Class I streams as defined in the CFPRs will have a Riparian Management Zone....
• The RMZ will measure 170ft (slope distance)...
• The Class I streams is divided into three management bands, the Restricted Harvest Band (RHB), the Limited Entry Band (LEB), and the Outer Band (OB). The bands are measured 0ft to 30ft, 30ft to 100ft, and 100ft to 170ft...
• There will be a maximum of 1 entry every 20 years.
• A minimum 300sq-ft post harvest conifer basal area per acre will be retained with the LEB.
• Tree sizes and quantity distribution will be retained as per Table 4...
• A minimum of 240sq-ft post harvest conifer basal area per acre will be retained.
• Tree sizes and quantity distribution will be retained as per Table 4.

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Enough information is not given in Volume IV, section 1.2.2.2 to justify the riparian buffer width distance of 170ft. According to DEIS/EIR (Chapter 3.7, page 36):

PALCO does not give enough information to determine if the three bands - restricted harvest band (RHB), limited entry band (LEB), and outer band (OB), within the RMZ are scientifically justifiable. The only assumption that can be made is that each allows for progressively more management activity because the potential to recruit LWD decreases going away from the stream channel. However, it is not clear why 30ft was chosen as the RHB and 100ft for the LEB. The 170ft OB is based upon an average site potential for PALCO lands. Even though the stream buffers start at the edge of the CMZ, it is not clear if the stream buffers will protect areas with actively eroding terraces or stream banks. If not, then large portions of the stream buffer will be lost to the stream channel in a short time period. For example, recent studies on PALCO lands (PWA 1998a&b) found that bank erosion rates average 2.5ft per year and range between 1ft to 30ft per year. The majority of erosion occurs during high flow events. A 30ft RHB along a channel with a actively eroding bank that is not part of the CMZ, but is either a terrace or steep bank, can be lost within one year. On average, the 30 RHB could be lost within a 12 year time period.

AB 1986 states that the final HCP shall establish a no-cut buffer of 100 feet on each side of each Class I watercourse, until watershed analysis is reviewed by the USFWS or NMFS, or site-specific prescriptions are established by USFWS or NMFS. A 100ft no-cut buffer along a channel with a actively eroding bank that is not part of the CMZ, but is either a terrace or steep bank, can be lost in less than four years. On average, the 100 RHB could be lost within a 40 year time period, less than the life of the HCP. More information is needed to determine if bands or zones will give enough protection not to have significant adverse effects on freshwater coho habitat. There is also a lack of information on justifying how one entry in the stream buffer for harvest every 20 years would not reduce wood loading levels to a point of adversely affecting coho production.

PALCO identifies minimum post harvest basal area retention requirements (Table 4, page 34), but does not give enough information to analyze the projected impact of the stream buffer on wood loading, and the scientific justification for each post basal area requirement. The only information given about the science behind the retention numbers of 300 and 240 sq. ft per acre is given in Chapter 3.7, page 57 of the DEIS/EIR:

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The retention standards also do not attempt to define how many trees per acre of a given size are maintained. The only limit to how many larger trees are retained is 10 trees per acre, per side that are greater than 40" DBH, or the 10 largest trees, per side. Leaving 20 trees greater than 40" DBH, or 20 of the largest trees will not be enough to provide stable LWD in larger streams and rivers. These large trees have been shown to be necessary to catalyze log jam formation and associated habitat elements in large stream channels (Abbe and Montgomery, 1996; Montgomery and others, 1996). The minimal number of large trees left within the RMZ will not be enough to create and maintain key habitat structures such as log jams, which create large and high quality pool habitat. The PALCO DEIS/EIR also recognizes the importance of large trees in larger streams:

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Page 35 through 37 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.2.3 Class II Stream Buffers

• The RMZ will measure 100ft (slope distance)...
• The Class II streams is divided into two management bands, the Restricted Harvest Band (RHB) and the Selective Entry Band (SEB). The bands are measured 0ft to 10ft and 10ft to 100ft...
• There will be a maximum of 1 entry every 20 years.
• A minimum of 240sq ft post harvest conifer basal area per acre will be retained.
• Tree sizes and quantity distribution will be retained as per Table 4.

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PALCO does not give enough information to determine if the two bands - restricted harvest band (RHB), selective entry band (SEB), within the RMZ are scientifically justifiable. The only assumption which can be made is that each allows for progressively more management activity because the potential to recruit LWD decreases going away from the stream channel. However, it is not clear why 10ft was chosen as the RHB and 100ft for the SEB. Even though the stream buffers start at the edge of the CMZ, it is not clear if the stream buffers will protect areas with actively eroding terraces or stream banks. If not, then large portions of the stream buffer will be lost to the stream channel in a short time period. For example, recent studies on PALCO lands (PWA 1998a&b) found that bank erosion rates average 2.5ft per year and range between 1ft to 30ft per year. The majority of erosion occurs during high flow events. A 10ft RHB along a channel with a actively eroding bank that is not part of the CMZ, but is either a terrace or steep bank, can be lost within one year. On average, the 10 RHB could be lost within 4 years.

AB 1986 states that the final HCP shall establish a no-cut buffer of 30 feet on each side of each Class II watercourse, until watershed analysis is reviewed by the USFWS or NMFS, or site-specific prescriptions are established by USFWS or NMFS. A 30ft no-cut buffer along a channel with a actively eroding bank that is not part of the CMZ, but is either a terrace or steep bank, can be lost in one year. On average, the 30 RHB could be lost within a 12 year time period, less than the life of the HCP. More information is needed to determine if bands or zones will give enough protection not to have significant adverse effects on freshwater coho habitat. There is also a lack of information on justifying how one entry in the stream buffer for harvest every 20 years would not reduce wood loading levels to a point of adversely affecting coho production.

PALCO identifies minimum post harvest basal area retention requirements (Table 4, page 34), but does not give enough information to analyze the projected impact of the stream buffer on wood loading, and the scientific justification for each post basal area requirement. In my opinion, experimental prescriptions, such as this one, should be treated as an experiment, and include a hypothesis, study design, and an overall smaller scale approach before it is implemented on an HCP scale. My opinion comes from reviewing numerous experimental riparian prescriptions written without scientific justification in Washington State (Collins and Pess, 1997).

The retention standards also do not attempt to define how many trees per acre of a given size are maintained. A basal area requirement that does not include a trees per acre requirement, as well as a size class distribution requirement, allows for the removal of larger trees. These trees are essential to the development of sediment storage locations within Class II stream channels.

Wood stores sediment in steep channels by forming steps in the stream bed, resulting in sediment accumulation. This limits the amount of sediment which moves downstream, thereby reducing impacts to fish habitat and water quality. LWD also helps stabilize hillsides and dissipate stream energy by reducing the effective channel slope (Megahan, 1982; Keller and others, 1996; Haas, 1996). This reduces the amount of energy available for bank and bed erosion, thereby reducing stream channel incision.

In the Northern Redwood Creek basin, Keller and others (1996) found that up to 70% of increase in stream channel slope with first and second order stream reaches was controlled by the loss of LWD. Removing large trees along Class II streams, that are already depleted of LWD, is likely to have significant long-term adverse effects on downstream coho habitat by reducing the amount of upstream sediment storage locations, and subsequently increasing the amount of downstream sediment impacts.

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Page 38 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.2.4 Class III Stream Buffers

Wood is important in Class III streams because it stores sediment by forming steps in the stream bed, resulting in sediment accumulation. This limits the amount of sediment which moves downstream, thereby reducing impacts to fish habitat and water quality. LWD also helps stabilize hillsides and dissipate stream energy by reducing the effective channel slope (Megahan, 1982; Keller and others, 1995; Haas, 1996). This reduces the amount of energy available for bank and bed erosion, thereby reducing stream channel incision.

In the Northern Redwood Creek basin, Keller and others (1995) found that up to 70% of the increase in stream channel slope with first and second order stream reaches was controlled by the loss of LWD. An increase in channel slope increases stream power and reduces the number and size of sediment storage sites. A decrease in LWD obstructions decrease the amount of sediment retained, and results in an increase in sediment production from a first and second order streams. Approximately 5 to 30 times the amount of sediment that is moved out of a watershed is stored within the stream channel behind LWD obstructions (Megahan, 1982). Removing all trees along Class III streams is likely to have significant long-term adverse effects on downstream coho habitat by reducing the amount of upstream sediment storage locations, and subsequently increasing the amount of downstream sediment impacts.

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Page 46 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.9 Watershed Analysis

Our review of prescriptions from the first 20 watershed analyses completed in Washington State found that the majority of prescriptions were similar in form and content to the state standard rules (Collins and Pess, 1997a). Prescriptions that did vary from standard rules incorporated additions that increased state authority, identified specific hazard" areas such as slopes more prone to landslides or more sensitive to increases in erosion rates, and were more systematic and detailed. The majority of prescriptions, however, closely follow the standard rules because the scientific assessment methodology in the Washington State watershed analysis manual closely follows" the standard rules (Collins and Pess, 1997a).

For example, the most common mass wasting prescription (65 out of 117 or 56%) requires a site evaluation by a specialist in a particular map unit that includes an unstable landform such as an inner gorge. The Washington State standard rule requires that an environmental checklist be completed under the Washington State Environmental Policy Act for proposed timber harvest in slide prone areas" (Collins and Pess, 1997a). This, in most cases, includes a site evaluation by several specialists. Furthermore, the majority of these mass wasting prescriptions do not require a systematic method to identify the risk of landslide hazard. This means different specialists can use their best professional judgment" without any more data, utilize various methods that may not be repeatable by others, or focus on determining existing stability rather than potential future stability (Collins and Pess, 1997a).

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In addition, the majority of prescriptions developed for specific issues in watershed analysis, such as mass wasting, are somewhat generic because watershed analysis does not produce the site-specific data necessary for managers to prescribe site-specific remedies (Collins and Pess, 1997a). In some cases, site-specific data generated during the assessment process or the scientific literature is not used by land managers to develop prescriptions (Collins and Pess, 1997a). For example, approximately 25% (29 out of 117 reviewed) of mass wasting prescriptions allow partial harvest operations of dominant trees in areas identified as having a high likelihood of landslide failure, if understory" or unmerchantable" (e.g., small shrubs and trees) trees are maintained (Collins and Pess, 1997a). The belief is that understory will maintain root strength. However, there is little support in the scientific literature that understory" and unmerchantable" trees alone provide adequate rooting strength on unstable terrain (Collins and Pess, 1997a).

In my opinion, it is likely that PALCO watershed analysis will not result in many site specific management prescriptions. This is based on my experience in developing, implementing, and analyzing Washington Stateís watershed analysis process, which is the basis of PALCOís future efforts.

PALCO also states the following:

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Our review of the first 20 Washington State watershed analysis prescriptions indicates that many prescriptions are not based on the assessment or most recent science (Collins and Pess, 1997a). This results in prescriptions that do not maintain and/or enhance the aquatic environment" to the point of preventing cumulative adverse effects (Collins and Pess, 1997b).

We found that almost two out of every three prescriptions (260 out of 430, 60%) were based on hypotheses that lacked enough scientific justification to guarantee success in meeting the watershed analysis goal of protecting and restoring aquatic habitat without testing. In addition, 16% of prescriptions did not even attempt to scientifically justify prescriptions (Collins and Pess, 1997a). In my opinion, if PALCOís site-specific prescriptions follow the same trend as in Washington State, then it is likely that future land management will not result in the maintenance and enhancement of aquatic habitat.

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Page 48 — Section 1.2 - Aquatic Habitat Conservation Measures to be Implemented Under the Plan, 1.2.9 Watershed Analysis

The DEIS/EIR state the following with regards to increased peak flows due to forest roads:

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Page 96,98 and 99 — Section 2.0 - Implementation of the Plan, 2.1 - Habitat Condition Goals

LWD volume

The LWD volume targets in the matrix do not include a goal for functioning LWD. The scientific literature identifies that LWD size (e.g., length and diameter of a tree) is important because it determines whether wood properly functions" in a stream (Bilby and Ward, 1989; Montgomery and others, 1995; WFPB, 1995; Beechie and Sibley, 1997; Kennard and others, 1998). For example, Bilby and Ward (1989), found that in order for LWD to be stable in smaller stream channels (less than 25 meters bankfull width) and function to create pools, store sediment and reduce bank erosion, average LWD size needs to increase with channel width. Others have also found this relationship to be true, especially when LWD functions to create and maintain pools (Montgomery and others, 1995; WFPB, 1995; Beechie and Sibley, 1997; Kennard and others, 1998). Abbe and others (1997) have defined a way to determine the functioning size of wood in larger streams (e.g., greater than 30 meters bankfull width), which is based on bankfull depth in relation to the size of wood. In both cases, there is a minimum functioning LWD size, and a given size that achieves specific functions such as pool formation.

The HCP wood volume goals by channel width can be met without having LWD that functions to create desired habitat characteristics, such as pools, because table 7 does not identify a minimum functioning size for each channel width. This goal also contradicts what was developed by NMFS in September of 1996. According to NMFS (1996) properly functioning LWD needs to have a minimum diameter of 24 inches. A wood volume target, without a companion minimum functioning LWD size target, is likely to result in significant cumulative adverse effects.

Pool frequency

The goal of 6 channel widths per pool is typical of low gradient (<3%) channels, and can be met with or without wood. Published data on pool frequency v. wood loading show that some forest channels that are severely depleted in LWD will still meet the proposed goal (Montgomery and others, 1995). Beechie and Sibley (1997) examined 28 second-growth streams in Western Washington and found that all but one stream had less than 6 channel widths per pool. The one stream that did not meet this level had a dam-break flood take out all functioning wood for the lower several miles. Pool frequency in streams with old growth riparian areas average 1 channel width per pool, but more importantly only range between 0.5 and 2 channel widths per pool (Montgomery and others, 1995). Washington Stateís watershed analysis manual identifies that channels less than 3% gradient and 15m in width are in good" condition if pool spacing is less than 4 channel widths per pool. The goal of 6 channel widths per pool will also be met in steeper channels, regardless of wood loading (Montgomery and others, 1995).

A local decrease in chinook and coho spawning abundance accompanied a loss of pool frequency and wood debris in several streams in Western Washington (Montgomery and others, in press). Spawning nest (or redds) density in areas where pool spacing was less than 4 channel widths per pool ranged between 10 to 240 redds/km, averaging 106 redds/km (Montgomery and others, in press). In streams where pool spacing was greater than 4 channel widths per pool redd density ranged between 0 to 20 redds/km, and averaged 3 redds/km (Montgomery and others, in press). The HCP goal of 6 channel widths per pool establishes a standard that maintains stream channels in a degraded condition, and is likely to significantly reduce coho spawning utilization.

Percent pool area

The HCPís goal of greater than 20% and 25% pool surface area can also be met, regardless of wood loading. Beechie and Sibley (1997) found that only three of twenty -eight streams in second growth forest in Western Washington had a percent pool area less than 20%. Streams with gradients less than 4% in old growth forests of the Pacific Northwest can have an average percent pool area of 54% (Ralph and others, 1994). The Washington State watershed analysis manual identifies that channels which have a gradient less than 4% are considered to be in fair or poor conditions with pool areas of 40% or less (WFPB, 1995). The percent pool area goal identified in table 7 also contradicts what was stated as high" in Volume II, page 12, which is pool percentages greater than 40%. Volume II identifies that a pool percentage area of greater than 25% is considered to be the threshold between moderate and low. Once again, the goal establishes a standard that maintains stream channels in a degraded condition, and is likely to in significant adverse effects.

Failure to identify essential habitat

The lack of identification of essential habitat with respect to the various life stages and life history strategies for all salmonids, especially coho, is perhaps one of the largest flaws in the entire PALCO HCP. According to the properly functioning habitat" conditions matrix in Volume IV, Part D, Section 6, off-channel habitat is part of the essential habitat elements that need to be part of any recovery effort. Off-channel habitat includes slower water habitat that is not part of a main stem of a river, but is still hydrologically connected either through surface or subsurface flow. Such areas are normally found in the flood plain and include old river meander bends (oxbows) or side-channels which convey water during high flows. These areas are essential rearing habitat for juvenile salmonids, such as steelhead and coho. Table 7 makes no mention of off-channel habitat. It has been documented in the Pacific Northwest that winter and summer rearing habitat is the current freshwater habitat factor limiting coho production (Beechie and others, 1994).

Studies estimate that more than 50% of this habitat type has been lost to diking, dredging, levees, channelization, ditching, and riparian conversion over the last 100 years (Beechie and others, 1994). Protection and restoration which does not take into account what limits fish production will not be successful, because the capacity of the system does not change. In short, if the limiting factor, or bottleneck," is not addressed, then actions will not result in a change in the potential number of fish. Table 7 does not include any targets on essential habitat types that need to be maintained and restored for future coho production, even though Volume IV, Part D, Section 6 and the scientific literature documents the importance of such habitats. This, in my opinion, is likely to result in significant adverse effects to coho habitat and potential coho smolt production.

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Pages 99 to 101 — Section 2.2 - Monitoring, 2.2.1 - Monitoring Program Objectives and 2.2.2 - Focus of the Aquatic Monitoring Program

Under the proposed HCP, effectiveness monitoring will ask the basic question:

• Is there a trend towards the goals identified in the properly functioning habitat goals identified in Table 7?"

• What is the appropriateness of the assumptions made which define the habitat goals, and in turn, define the success of the PALCO HCP?"

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Pages 105 through 108 — Section 2.2 - Monitoring, 2.2.3 - Monitoring Variables and Data Collection Methods, Effectiveness monitoring

The goals set in the PALCO HCP, with respect to effectiveness monitoring can be easily met. The HCP is designed to prevent the following:

PALCO identifies many uncertainties associated with the effectiveness of sediment control measures. These statements, however, do not reference any of the scientific literature, and often times, contradict other portions of the plan. For example, PALCO states the following:

Methods do exist to differentiate between landslides due to management activities v. natural disturbance. This is important, because effectiveness monitoring goals for sediment can then be linked to natural background levels, as opposed to present conditions. PALCO does state the following with regards to this topic:

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Pages 108 to 111 — Section 2.2 - Monitoring, 2.2.4 - Cumulative effects analysis

The PALCO HCP proposes to use trends monitoring to assess whether cumulative effects are present". PALCO intends to implement trend monitoring in the following manner:

Trends monitoring of individual variables, such as fine sediment and water temperature, is not a cumulative effects methodology because it does not account for the accumulation of small effects of many forest practices. A cumulative effects analysis includes the necessary assessment tools to integrate different geomorphic inputs in space and time to fish habitat and populations levels (Collins and Pess, 1997b). Assuming that dominant, direct effects monitoring will substitute for such a methodology can result in significant adverse effects from land use practices on fish habitat going unnoticed.

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Pages 111 to 113 — Section 2.3 - Adaptive management

An adaptive management plan has four primary goals:

In addition, if the goals are not being met, then the technical evaluation team needs to differentiate why this is happening before a change to the management action occurs. Since there is no direct cause and effect link between resource condition (e.g., a threshold such a number of key LWD pieces) and management practice (e.g., riparian buffer and management options within the RMZ) this cannot happen. PALCO defines the fourth criteria, institutional learning, as consultation" with local, state, and federal agencies. In my opinion, adaptive management will not occur, due to the maximum limits associated with the HCP. This can result in significant adverse effects to coho habitat, if science identifies areas or restrictions larger than the maximum limits are needed.

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REFERENCES

Abbe. T.B., D.R. Montgomery, and C. Petroff. 1997. Design of stable in-channel wood debris structures for bank protection and habitat restoration: Example from the Cowlitz River, WA. In: Proceedings of the Conference on Management of Landscapes Disturbed by Channel Incision. S.S.Y. Wang, E.J. Langendoen, and F.D. Jr. Shields, (eds.) University, MS. University of Mississippi pp. 809-816

Beechie, T., E. Beamer, L. Wasserman. 1994. Estimating coho salmon rearing habitat and smolt production losses in a large river basin, and implications for restoration. North American Journal of Fisheries Management 14: 797-811.

Beechie, T.J., and T.H. Sibley. 1997. Relationships between channel characteristics, woody debris, and fish habitat in northwestern Washington streams, Transactions of the American Fisheries Society, 126:217-229. AFS

Beschta, R.L., R.E. Bilby, G.W. Brown, L.B. Holtby, and T.D. Hofstra. 1987. Stream temperature and aquatic habitat: fisheries and forestry interactions. Pp. 191-232 in: (Ed) E.O Salo and T.W Cundy, Streamside Management: Forestry and Fisheries Interactions. University of Washington Institute of Forest Resources Contribution 57. Seattle, WA

Bilby, R.E., B.R. Fransen, and P.A. Bisson. 1996. Incorporation of nitrogen and carbon from spawning coho salmon into trophic system of small streams: evidence of stable isotopes. Canadian Journal of Fisheries and Aquatic Sciences 53:164-173.

Bilby, R.E. and J.W. Ward. 1989. Changes in characteristics and function of woody debris with increasing size of streams in western Washington. Transactions of the American Fisheries Society. 118:368-378.

Bisson, P.A., R.E. Bilby, M.D. Bryant, C.A. Dollof, G.B. Grette, R.A. House, M.L. Murphy, K.V. Koski, and J.R. Sedell. 1987. Large woody debris in forested streams in the Pacific Northwest: past, present, and future pp. 143-190 in: (Ed) E.O Salo and T.W Cundy, Streamside Management: Forestry and Fisheries Interactions. University of Washington Institute of Forest Resources Contribution 57. Seattle, WA.

Cederholm, C.J., and N.P. Peterson. 1985. The retention of coho salmon (Oncorhynchus kisutch) carcasses in spawning streams. Canadian Journal of Fisheries and Aquatic Sciences 42(8):1347-1355.

Cheng, J.D. 1989. Streamflow changes after clear-cut logging of a pine beetle infested watershed in southern British Columbia, Canada. Water Resources Research 25 (3): 449-456.

Collins, B.D. And G.R. Pess, 1997a, Evaluation of forest practices prescriptions from Washingtonís watershed analysis program. Journal of the American Water Resources Association. 33 (5): 969-996.

Collins, B.D. And G.R. Pess, 1997b, Critique of Washingtonís watershed analysis program. Journal of the American Water Resources Association. 33 (5): 997-1010.

Conroy, S.C. 1997. Habitat lost and found, part two. Washington Trout Report 7 (1):1. pp. 16-22.

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