Allen Robertson, Deputy Chief
Environmental Protection
California Department of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 944244-2460
Dear Allen Robertson,
Community Clean Water Institute requests that the California Department of Forestry and Fire Protection consider these comments upon review of the draft Environmental Impact Report for the Fairfax Conversion Project.
We urge CDF to regard the cumulative water quality and quantity impacts the Fairfax Conversion Project will have on the Gualala River watershed. The DEIR cannot be assessed from a piecemeal approach and impacts must be expected to accumulate and be considered in a regional context where many forest-to-vineyard conversions are occurring. Approval of the proposed Fairfax Conversion Project will cause further depredation of the already drought impacted and federally listed Gualala River watershed, which contains federally listed salmonid species.
The Gualala River is currently on the federal Clean Water Act Section 303(d) list due to impairment and/or threat of impairment to water quality by sediment. This proposed conversion will increase sediment runoff, as well as other pollutant runoff and raise surface water temperatures, and is therefore in direct conflict with the protections enforced by the Clean Water Act.
How can we allow for more forested land to be converted to agriculture, especially vineyards? Especially when the proposed conversion is within the watershed of a federally listed river! Do we need to be reminded of how much damage a clearcut causes? Trees and other vegetation help receive, absorb, and store rain water as it percolates through the soil. Severe erosion can occur on steep forested land and soil compaction on any land during the conversion process. The soil begins to lose its absorption and filtration abilities and any sediment and herbicides, and eventually fertilizers or pesticides used to establish and maintain aquiculture, runs off directly into the stream.
Perennial streams can be completely dependent on groundwater for baseflow during dry years making the act of clearcutting especially harmful. As vegetative cover is removed, the soil loses it absorption capabilities and results in a lowered ground water table. The lack of ground and surface water is obviously extremely deleterious for aquatic life but is also a stressor for trees and vegetation outside the clear cut zone.
We question the level of significance given to Project Impacts 3.4 (12-14) of the draft EIR and strongly feel that these are prime examples of this DEIR’s tendency toward short term piecemeal analysis and solutions. Impacts 3.4-12 & 14 cannot be viewed as separate impacts for minimum instream flows must be maintained to prevent further increases in surface water temperatures, and the level of significance of these impacts on the Gualala River Watershed will only heighten with time.
Project Impact 3.4-13 states that Impacts to special-status salmonids from project-related increases in peak flows will be less than significant and therefore mitigation measures are not required. This conclusion is hard to agree with as compacted soil that is less pervious will cause extreme peak flows during winter storms.
Community Clean Water Institute asks that you take these observations into account and deny the Fairfax Conversion Project DEIR as it is written.
Sincerely,
Terrance Fleming
Community Clean Water Institute