It is truly rare when the Department of Fish and Game (DFG) provides formal disagreement with Cal Fire over the approval of a THP, but that’s exactly what happened with THP 1-11-038SCR, “Victoria”. The “Victoria” THP covers only 38 acres of selection logging in Santa Cruz County. However the THP is located in Branciforte Creek, a tributary to the San Lorenzo River, where the state of Central California Coast Coho salmon is extremely dire. The San Lorenzo Coho run is considered to be either extinct or on the brink of extinction, and logging, along with other human-related activities, has been identified as the primary cause of habitat loss and degradation.
As part of its Pre-harvest Inspection (PHI) for the “Victoria” THP, the DFG raised substantial concerns over the reconstruction of a landing in a stream channel that drains directly to Branciforte Creek, where it is believed that Coho salmon may be hanging on. The landing construction inside the watercourse channel, and the subsequent use of this landing and the road associated with it, raises significant concern over the potential for sediment to discharge into Branciforte Creek. The Forester for the THP, the Cal Fire inspector, and the Cal Fire review team all disagreed with the DFG’s recommendation to delete the use of the landing from the THP. The construction of a landing inside a watercourse channel is contrary to standard Forest Practice Rules provisions, and a special dispensation and justification must be made in order to go forward with such a proposal.
The DFG provided a formal letter of disagreement with Cal Fire review team recommendations to approve the THP without incorporating the DFG recommendation to delete the use of the landing. Cal Fire, for its part, remains complicit, and continues to rationalize away the potential dangers of reconstructing the landing inside the watercourse channel. Cal Fire has merely required the plan submitter to provide more discussion to justify the use reconstruction of the landing, and subsequently recirculated the THP for 30 days (re-opening the public comment period).
The Cal Fire review team and the plan submitter are not required by the Forest Practice Rules to accept and incorporate all the recommendations of the DFG into approved THPs, and as often happens, Cal Fire is siding with the landowner, while disregarding the concerns of the DFG. Cal Fire and the DFG have a long and sordid history of disagreement over recommendations made by the DFG, and in most cases, the DFG is forced to either formally disagree with Cal Fire, or simply let its recommendations go by the wayside. The DFG is often reticent to provide formal disagreement with Cal Fire, as Cal Fire almost always gets their way in these disagreements. This betrays one of the most fundamental flaws in the Forest Practice Rules; Cal Fire and landowners are allowed to disregard the recommendations of other public trust agencies such as the DFG, while the DFG is forced to fight for its proposals at management level.
EPIC will continue to monitor this situation closely. The DFG’s formal disagreement raises substantial concerns over potential harm to endangered Coho salmon, and we will continue to engage with the DFG and Cal Fire in hopes that an amicable resolution can be achieved.