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Institute for Fisheries Resources Response to NCWAP Agency Comments on KRIS Gualala

Below are the Institute for Fisheries Resources (IFR) responses to comments regarding the KRIS Gualala database, which underwent a year of review. The first wave of comments are from agencies (February through April 2002), including the California Resources Agency (Cathy Bleier), the California Department of Fish and Game (Cynthia LeDoux Bloom), the California Geologic Survey (Stephen C. Sterling) and the North Coast Regional Water Quality Control Board (Robert Klamt). Additional comments (May-December 2002) come from agency personnel, this time including Scott Downie, NCWAP CDFG leader; David Leland, NCRWQCB TMDL leader; Henry Alden, Gualala Redwoods, Inc.; Kathleen Morgan and Dr. Matt O'Connor for the Gualala Watershed Council; Roger Dingman, Gualala River Steelhead project and several interested parties commenting as individuals. These are shown in order to track changes made to the KRIS Gualala database or explanations offered in response to comments. These include discussions of relationship of North Coast Watershed Assessment Program's Gualala Watershed Synthesis Report and data analysis methods and the approach of KRIS Gualala. Response to comments from the University of California peer reviewers are on a separate page.

References not found in the KRIS Gualala Bibliography but used in response to comments are found at the bottom of the page. Comment letters are also in full text for reference, if available.

Response to Comment Table

Number Commenter Date Subject Comment Response
1 Cathy Bleier 3/15/2002 Thresholds How will you include the EMDS suitability curves? EMDS outputs will be available in electronic form in the Synthesis Report. Model results not available to IFR.
2 Cathy Bleier 3/15/2002 Thresholds EMDS model parameters, TMDL Targets, KRIS Thresholds The break points in EMDS model curves used by NCWAP do not, in most cases, correspond to what would be the most useful and scientifically-supported reference for indicator species response to environmental variation.  KRIS charts will continue to use the most pertinent and scientifically defensible reference values for most sensitive of concerned species. These references sometimes reflect TMDL targets, when the latter are well defended and consistent with regional literature. Reference values change through discussion (see comment #108). Science is an evolving process.
3 Cathy Bleier 3/15/2002 Thresholds Add additional lines into charts to show NCWAP suitability indices In the current version of KRIS Gualala, both interpretations of the data are shown on separate charts because too many lines on one chart confuses users. Retaining the coho reference in KRIS is useful because they are a regional, cold water, keystone species for which temperature tolerances are known (Essig, 1999). To say a stream is "not fully suitable" or "somewhat suitable" for salmonids is not as clear as referencing a threshold for whether coho can live there.
4 Cathy Bleier 3/15/2002 Temperature The influence of watershed size on temperature The linkage between stream order and size and increased water temperature is well recognized and Lewis (2000) added to the Gualala Bibs. Gualala tributaries in question have mostly been documented to have had coho historically, but are currently out of their normal range of variability with regard to temperature and suitability for coho.
5 Cathy Bleier 3/15/2002 Temperature Henry Alden's temperature regression analysis Included for reference as pictures accompanying temperature charts with GRI data. Henry's regression of water temperatures appears in Appendix 9 of the Gualala NCWAP Report. It uses Bull Creek, tributary to the SF Eel, as an "Old Growth" stream implying that it is representative of late seral forest conditions, when Bull Creek is actually a classic cumulative effects case study. The Bull Creek watershed was intensively logged in the 1950's and is massively aggraded (>20 feet) by subsequent floods. The only old growth is in Humboldt Redwoods State Park near its mouth.
6 Cathy Bleier 3/15/2002 Temperature Water temperature shown in Fahrenheit? KRIS Gualala has two charts in both scales for some locations. Scientific documents usually use Celsius while NCWAP chose Fahrenheit. Dual axis is too confusing. Background Temperature page has conversion information.
7 Cathy Bleier 3/15/2002 Temperature Geographic scope for temp studies Temperature data is sampled at specific locations and it is difficult to extrapolate to reaches up or downstream for any length due to various influences such as ground water inputs or other anomalies. Maps of gauge locations are included with Topics as Pictures and in the KRIS Gualala Map ArcView Project.
8 Cathy Bleier 3/15/2002 Fish Explain coho "functionally extinct" We will use other words to describe coho status in the Gualala. To clarify, however, only scattered small groups of juvenile coho have been found in the Gualala over the last six years. It would take thousands of juveniles to lead to a viable adult return of (>200 adults). Despite three years of planting 10,000 yearling size fish from 1995-1997, only incidental juveniles were found in surveys in 1996 and 1998 and none in 2001. See Hypothesis #1. CDFG (2002) called Gualala coho "extirpated or nearly extirpated."
9 Cathy Bleier 3/15/2002 Bibliography Taylor's not in your references Taylor, S.N. 1978. CDFG status report on salmon is in both KRIS Bibs and at the bottom of Hyp #1 page.
10 Cathy Bleier 3/15/2002 Fish Where's the data showing it to be a "substantial producer" without stocking CDFG Biologists (Brauer, 1953) stated that there were millions of juvenile coho and steelhead in arguing for a reopening of summer "trout" fishing. That would indicate an adult population at least in the thousands and thus a "substantial producer".
11 Cathy Bleier 3/15/2002 Fish Are there data reflecting observations by NCRWQCB or Bob Klamt Bob Klamt was on at least two surveys in 1970-1971 when he was staff to CDFG. Klamt and Edwards (1970) and Parke and Klamt (1971) represent field data collected with a standard methodology of the time, which is valuable for understanding standing crops of salmonids, abundance of warm adapted species and such habitat parameters as substrate, pool frequency and pool depth. Not all surveys from earlier periods are of equal caliber.
12 Cathy Bleier 3/15/2002 Sediment DMG data, maps, overlays and analysis needed for sediment discussions Electronic map data from CGS not available as KRIS Gualala went to press in January 2003. No data analyses requiring charts in KRIS Gualala were identified by CGS, although IFR offered to build any charts for which they provided data..
13 Cathy Bleier 3/15/2002 Sediment GRI's thalweg profiles Have not seen thalweg data from GRI nor any report which would provide methods and validation of study. Thalweg and cross section data are more useful when there are several years of data. Will put in Metadata table and it can be integrated by those updating the KRIS system at a later date.
14 Cathy Bleier 3/15/2002 Thresholds EMDS temperature criteria and KRIS chart references See comments #1-3
15 Cathy Bleier 3/15/2002 Riparian DFG canopy density data should be included (explain high on the suitability curves) Additional canopy data added as acquired from CDFG. EMDS reach model outputs and CDFG (and CDF) discussions on riparian function mistake canopy for functioning riparian zone. You can have good canopy closure and still have warm airflow over the stream and poor LWD recruitment if there is no over-story of conifers. See Hypothesis #5.
16 Cathy Bleier 3/15/2002 Sediment Please clarify whether sediment assessment methods employed extensive field sampling All sampling regimes are available as discussions in Info Links and in the reports that are appended as part of the Bibliography. If the question refers to the TSD, they sampled where ever they were allowed access.
17 Cathy Bleier 3/15/2002 Sediment D50 particle size: Dry Creek increase in median particle size shows improvement? Dry Cr is 4-8% gradient and would not have small median particle size naturally. Although the increase since 1997 to a larger D50 shows a trend back towards the norm, the 1997 particle size was skewed small likely by sediment influx in preceding storm event. DWR noted that Jan/Mar 1995 and Jan 1997 were large storm events and widespread timber harvest and road building on steep slopes prior to these storms likely set the stage. Changes in Dry Creek may have been due to excavations with heavy equipment according to Roger Dingman (see below).
18 Cathy Bleier 3/15/2002 Fish Co-evolution item may not be meant as hypothesis in NCWAP (February 2002) Draft Report Changes made in alternative hypothesis to no longer ascribe to NCWAP May 2002 Draft. Link to NCWAP site will provide access to reports with their own hypotheses when available.
19 Cathy Bleier 3/15/2002 Fish Separate hypothesis about trends and recovery relative to fish Prevailing hypotheses can be switched with if enough scientifically valid evidence is offered.
20 Cathy Bleier 3/15/2002 Fish Habitat GRI thinks some of their data shows improvement trends IFR awaits scientific evidence and has been working with GRI for over two years in the process of Gualala Synthesis Report assembly.
21 Cathy Bleier 3/15/2002 Thresholds Reeves et al - 25% harvest over what period? From Gordy Reeves: Air photos were used to determine % harvest. Approximately 30 year period. Tractor and high lead clear cut mostly.
22 Cathy Bleier 3/15/2002 Watershed Did the watershed recover from 1840-1945 activities? Description by Brauer (1953) would indicate that the watershed was in advanced recovery from the first wave of logging, which was played out as of about 1920. Certainly habitat would not have recovered totally but enough to produce healthy runs of coho salmon and steelhead. Original community may have included king salmon. Chinook spawn in mainstems which would have been profoundly effected by log drives and sediment from upland areas logged with a steam donkeys.  Patterns of recovery from railroad and cable logging were relatively rapid (50 years) probably because they did not leave a legacy of roads. Case studies are SF Ten Mile and Freshwater Creek (see KRIS Ten Mile and Higgins, 2001).
23 Cathy Bleier 3/15/2002 Sediment Pacific Watershed Associates (1998) and Gualala sediment yield. PWA (1998) Bear Creek report found that post WW II logging produced 6X more sediment than 1997 storm. The sediment affecting Bear Creek was significant because it buried the channel 8-15 feet deep putting it underground in places. Post WW II sediment inputs to the Gualala were catastrophic and likely far larger than recent sediment incursions; none the less, recent additions are significant in terms of impairing fish habitat (i.e. pools 2 feet deep and less, mobile gravels, high fines).
24 Cathy Bleier 3/15/2002 Timber Harvest CDF now has THP maps that includes all harvests We believe that Don Morse is finishing historic digitizing of 1942-1972 timber harvests but have no indication from Susan Lang that THP data from 1980-1990 is forthcoming. This is a problem since some harvests slated for the 1980's actually were cut in the 1990's and add to cumulative effects but are not available in EMDS calculations. This was discovered by IFR staff and noted to CDF in September 2001 because Landsat change scene detection (1994-1998) indicated areas cut that were not within 1990-2001 THP boundaries.
25 Cynthia LeDoux Bloom 3/15/2002 NCWAP/KRIS KRIS is not “parallel” or “built to support NCWAP" NCRWQCB staff fully utilized KRIS and built graphics for the temperature and Gualala Synthesis Report. IFR staff worked with NCWAP staff from other agencies in numerous meetings and at their desks to discuss data acquisition and methods of data analysis. No agreement on analysis methods could be reached and NCWAP agents from these agencies mainly chose not to use the KRIS Gualala database to build charts. Consequently, IFR built the system more in parallel. See note Background page on KRIS and NCWAP off Home page.
26 Cynthia LeDoux Bloom 3/15/2002 System Consider using the NCWAP Synthesis Report cover as the KRIS front page. Text and graphics in the synthesis report should be identical to that provided in KRIS. NCWAP report not available as KRIS Gualala went to press.
27 Cynthia LeDoux Bloom 3/15/2002 NCWAP/KRIS The issues presented in the NCWAP Gualala Synthesis Report were not located in the KRIS Gualala. The Synthesis report is issue-driven in both a general watershed  and SPW level.  See Background page on KRIS and NCWAP.
28 Cynthia LeDoux Bloom 3/15/2002 Hypothesis The hypotheses, supporting and contrary findings were not up front.  Hypotheses in KRIS are based on regional scientific literature and how data or literature from the Gualala arrays. Alternative hypotheses are advanced and monitoring suggestions to test the hypothesis follow. Links to local or regional literature are available at the bottom of the page for further reading. NCWAP hypotheses are available in report, which is available over the Internet (not complete at KRIS Gualala press time).
29 Cynthia LeDoux Bloom 3/15/2002 Fish The fisheries conclusions were not supported or scientifically justifiable by the available data Need more specific, constructive criticism in order to address such comments.
30 Cynthia LeDoux Bloom 3/15/2002 Fish Several data were inappropriately compared in terms of methods, years and watersheds. More focused comment needed in order to respond and to improve KRIS Gualala.
31 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing Number of miles habitat typed in 2001 is 101.1, not 80. Not all tributaries were included in the KRIS analysis.  Corrected.
32 Cynthia LeDoux Bloom 3/15/2002 Hydrology Stream orders are incorrect on several tributaries. The Strahler stream order system is based on USGS topos. Stream order in KRIS Gualala was calculated from accurate USGS data in ArcView. The orders in KRIS are correct. The CDFG Manual has the same definition. The only way to change the orders is to improve the USGS map, which is probably a good idea in the long run but not practical at present. See Stream Order Background page.
33 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing Stream orders of tributaries surveyed were lumped as all 3rd order and compared inaccurately against a 3 foot minimum pool depth Various stream orders ascribed to Gualala tributaries are in the table Hab_Mega_Sum_12_25.dbf. They range from 2nd order (Doty, etc) to 5th order (NF, Wheatfield). CDFG has not provided any literature to substantiate that 3 foot deep pools did not occur in 2nd order streams historically. See also #32.
34 Cynthia LeDoux Bloom 3/15/2002 Hypothesis Hypotheses do not match those in the NCWAP Gualala Synthesis Report and some have no supporting evidence. Hypotheses from Gualala Synthesis Report not available at KRIS Gualala press time. Data, charts, maps and bibliographic resources are offered in support of existing KRIS Gualala hypotheses. Particular criticism of a specific hypothesis or scientific argument would have been more useful.
35 Cynthia LeDoux Bloom 3/15/2002 NCWAP/KRIS If the KRIS Gualala is meant to be a NCWAP product it should be in agreement with the content in the Gualala Synthesis Report.   IFR's contract with CDF calls for IFR to supply technical support for report writing to State staff and to produce KRIS database and map projects. KRIS projects adhere to "best science" standards. Attempts were made to work with NCWAP agency staff to make analysis methods conform to recognized scientific analysis techniques.
36 Cynthia LeDoux Bloom 3/15/2002 NCWAP/KRIS The context and relationship of the Gualala Assessment and the KRIS product must be clear and if they are not twins, their differences must be explained. See Notes on Data Sharing and KRIS and NCWAP Background pages off KRIS Gualala Home Page.
37 Cynthia LeDoux Bloom 3/15/2002 NCWAP/KRIS KRIS Gualala was not used by the participating agencies to work up data relationships NCRWQCB figures generated in KRIS were used in the synthesis reports. Other charts that should have been useful, such as modern THPs (1990-2001) by Calwater, are in KRIS Gualala and could have been used by CDF analysts. CDFG analyst made fish charts in Sept 2001 but used none in the report. They are in KRIS Gualala.
38 Cynthia LeDoux Bloom 3/15/2002 NCWAP/KRIS The KRIS Gualala was not constructed in parallel, as the final draft was finished prior to the agency team completing synthesis KRIS Gualala was built in parallel because IFR staff was requested not to attend NCWAP team meetings or to participate in discussions related to the NCWAP report after November 2001. NCWAP report still not available as of January 2003.
39 Cynthia LeDoux Bloom 3/15/2002 Restoration Add Restoration section which includes available federal, state and private grants as mentioned in the BCP before Regulation and Policy.  Requested information from Pacific Watershed Assoc and GRWC related to Fuller Creek, but never received data. Made similar request of CDFG and GRI regarding restoration photos but never received any.
40 Cynthia LeDoux Bloom 3/15/2002 Fish KRIS does not mention the marine portion of the salmonid life cycle KRIS is focused on factors within watersheds that limit fish production or impair water quality similar to NCWAP. For discussions of ocean conditions on Gualala salmonids, see pages 9-10 in Higgins (1997) in KRIS Bibliography.
41 Cynthia LeDoux Bloom 3/15/2002 Fish Available data assessing salmonids and the oceanographic conditions should be included when possible. Data not widely available. Does this apply to NCWAP also?
42 Cynthia LeDoux Bloom 3/15/2002 Fish Direct Observation by diving- Add- Most historical dive observations have not incorporated Hankin & Reeves methodology, thus cannot be used very well to estimate population abundance.  Will note on Fish Population pages. Already noted in Metadata tables.
43 Cynthia LeDoux Bloom 3/15/2002 Fish Electrofishing:  Add different methods can select for different age classes and species.  Will respond when provided citations and more specific information.
44 Cynthia LeDoux Bloom 3/15/2002 Fish Very limited fisheries data exist on the Gualala. Please state so- Data are more limited on other north coast streams. Sufficient data are available to discern changes in community structure for instance (see Higgins, 1997).
45 Cynthia LeDoux Bloom 3/15/2002 Fish Numerous samples were taken to establish the presence of coho using the 10 pool protocol. Ten pools were sampled on each of the following:  North Fork, Franchini Ck., Wheatfield Fork, House Ck., Tombs Ck., Pepperwood Ck. (HL SPW), and Danfield Ck.  Weights and lengths were taken. Removed data from KRIS Gualala that was from coho survey since metadata was never made available.
46 Cynthia LeDoux Bloom 3/15/2002 Fish Taylor estimate of 4000 coho. By what method?  This is a CDFG salmon abundance report (Taylor, 1972) available in the KRIS Bibliography. In part relies on professional judgment but its is the only data CDFG has available. Department might want to check its archives for notes on basis.
47 Cynthia LeDoux Bloom 3/15/2002 Fish Data citation to support abundant large woody debris and ideal historic spawning? Data from Prairie Creek (Kramer, 1997) would be consistent with expected values for old growth redwood in Gualala. Historic photos of redwoods in Gualala in KRIS are up to 17 feet in diameter. These trees recruiting to the stream would provide outstanding habitat complexity and the microclimate created by such a forest would maintain optimal salmonid temperatures. (See Welsh, H. H., Roelofs, T. D., Frissell, C. A., 2000. Aquatic Ecosystems of the Redwood Region. in The Redwood Forest. Eds. R. Noss. Island Press. Chapter 6. )
48 Cynthia LeDoux Bloom 3/15/2002 Fish Specifically state the tributaries of the planting.  Table of planting with locations from TSD is available in Info Links off Hatchery Topics.
49 Cynthia LeDoux Bloom 3/15/2002 Fish No citation or documentation of restoring coho due to habitat collapse attributed to the 1964 flood. Damage to watersheds was evident to CDFG in 1960. Quote from CDFG Director Shannon: "Right now our major concern is in rehabilitating 1700 miles of Silver Salmon streams and in restoring Silver Salmon runs that have been decimated by degradation of their habitat. Our first biggest job in this program is to correct the conditions that made many north coast streams unsuitable for Silver Salmon and Steelhead, particularly during summer months. Basically, these conditions are slower flows, higher temperatures and siltation, all the results of man's activity. Artificial propagation can be a useful tool in salmon and steelhead management, but it is no cure-all. There is little to be gained from stocking fish in streams that are no longer suitable for them." See Restoration:  Stream Clearance page for more on citation for this quote.
50 Cynthia LeDoux Bloom 3/15/2002 Fish The lower Wheatfield Fork has been far from ideal spawning substrate per DMG landslide pot maps Not sure where the statement occurs in KRIS Gualala. Wheatfield spawning surveys (De Haven, 2001) show high use in late season (April).
51 Cynthia LeDoux Bloom 3/15/2002 Fish Use of gradient alone does not explain substantial coho production.  Other factors mentioned in previous paragraph. Coho would have been dominant in the western Gualala Basin because of its coniferous forests. Air temperatures over streams with towering trees would have remained cool and moist, maintaining ideal temperatures for salmonid growth. Huge trees falling in the water would have made complex habitat which supported likely at least three Pacific salmon species. See Margolis and Groot (1996).
52 Cynthia LeDoux Bloom 3/15/2002 Fish Cite which Pepperwood Creek in which super planning watershed- Will specify lower SF basin.
53 Cynthia LeDoux Bloom 3/15/2002 Fish Was the Gualala a “substantial” (?) coho producer?  When?  How many? See comment #10 above.
54 Cynthia LeDoux Bloom 3/15/2002 Fish The mainstem Gualala dominated by steelhead. See electrofishing results from Kimsey (1953). Also eye witness accounts from Ken Spacek, a life long resident, are that trout fishing was very productive on the Wheatfield Fork at the Scout Camp, where today the river barely flows and is dominated by Gualala roach. Spacek noted that suckers replaced steelhead as the dominant fish at the Scout Camp after 1964. See Higgins (1997).
55 Cynthia LeDoux Bloom 3/15/2002 Fish Need more to predict current population. Did not try to estimate current population of adult steelhead, only estimate order of magnitude of returns using regional (Noyo) data and information from the Gualala.
56 Cynthia LeDoux Bloom 3/15/2002 Fish Why compare the Gualala and Garcia estuary data in 1986 with very limited up stream electrofishing data in 2001?  Gualala and Garcia estuary data were collected by trained scientists with known methods and make a valid comparison. The logical argument offered is that a healthier Garcia River watershed produces larger steelhead smolts and that that is reflected in estuary samples. The lack of larger steelhead juveniles in electrofishing and dive samples in the Gualala in 2001 shows nursery areas are limited, which would force steelhead juveniles into the estuary at a smaller size..
57 Cynthia LeDoux Bloom 3/15/2002 Fish The “few old age steelhead” were found with very limited electrofishing effort and no comparable data exist- Hence, this is preliminary data at best, and should not be analyzed for these purposes. CDFG fish data were collected in representative stream reaches in a large area of the Gualala basin in 2001. While data are not suitable for a population estimate, samples do reflect the fish community of the Gualala according to CDFG (1998.  Fish community structure is a commonly used fisheries science approach (see Moyle, et al., 1996). See Background page: Response to CDFG NCWAP Staff re: Electrofishing Data Interpretation.
58 Cynthia LeDoux Bloom 3/15/2002 Fish Catch rates of adult steelhead for sport anglers were much higher in 1953-54 than in subsequent years. DFG:  State the areas in miles open to fishing in each of the years compared. The hypothesis that catch rate reflected decreased populations of adult steelhead was actually advanced by CDFG (Boydsdun, 1976) and only echoed in KRIS Gualala. Please share this information if you have it and it has bearing. (Never shared 1/03).
59 Cynthia LeDoux Bloom 3/15/2002 Temperature WQ found that 23 out of the 27 thermograph sample sites in the North Fork super planning watershed were suitable for salmonids.  See synthesis report for additional clarification Suitable for steelhead, but not optimal. Suitable for coho only in tributaries. Coho is the key stone species and part of desired future conditions in the Gualala and other North Coast watersheds.
60 Cynthia LeDoux Bloom 3/15/2002 Fish Estuary discussions of Gualala and Garcia should also mention the time of year each of the samples were taken and display the histograms or describe the scale analysis used to determine the age / length relationships. Details of Garcia study are in Higgins (1996). Need to add Brown (1986) to Bibliography. CDFG never provided. Scales were analyzed by Higgins (1996) but not Brown (1986), however, approximate age classes from Shapavolov and Taft (1935) are generally accepted by regional scientists and are useful for understanding. Will qualify in text.
61 Cynthia LeDoux Bloom 3/15/2002 Fish Cite ecological change.  Add historic reference establishing when Roach were not dominant. CDFG stream surveys from different time periods documented habitat loss in tributary sub-basins and the subsequent disappearance of coho salmon. Kimsey (1953) found steelhead dominant and roach a lesser part of the fish community in the mainstem below the North Fork in 1952.
62 Cynthia LeDoux Bloom 3/15/2002 Fish Cite the methods used to record the presence of suckers throughout the basin and their dominance after the 1964 flood.  DFG does not have this record to cross check data. Only data verified by DFG is in Buckeye Creek, 1970. Ken Spacek's account of numerous suckers at the Scout Camp on the Wheatfield is similar to known sucker competitive release as rivers were warmed by the 1964 flood in the region. I saw this myself in the SF Eel and Mattole. Credible eye witness accounts can often aid watershed assessment.
63 Cynthia LeDoux Bloom 3/15/2002 Fish If information exists on Gualala ammocetes, please confirm with the recent electrofishing data being cited Ammocetes are extremely susceptible to electroschocking and would be in samples if present. Their absence in many 2001 samples framed the statement in KRIS Gualala
64 Cynthia LeDoux Bloom 3/15/2002 Fish It seems a reach to establish a conclusion of bedload mobility based upon no detection of ammocetes, which prefer sand size particles that are mobile in most flows. Please document the demise of a the species and bedload mobility and movement.. Ammocetes need stable pockets of silt and fine sediment because they stay in freshwater for up to four years. Also adults are redd builders, the same as salmonids and eggs require clean gravel for incubating. See Hypothesis #2 for bedload mobility discussions.
65 Cynthia LeDoux Bloom 3/15/2002 Fish Which changes where and when?  Data does show sticklebacks present, but have numbers been recorded to show that their population has been favored related to a population increase?  Did their population not decline? Will put qualifier in last sentence re: population. Wendy Jones work showed Pudding Creek stickleback increased dramatically soon after logging. See KRIS Noyo.
66 Cynthia LeDoux Bloom 3/15/2002 Fish Eulachon: Any other marine influence documenting decline in incidental catch records?  No documentation exists between the demise of a species and bedload movement.  Please fwd data to DFG.  Otherwise delete or caveat. Relationship of loss of eulachon and shifting bedload regionally is well recognized, such as the Eel (Puckett, 1977). Yurok Tribal fish biologists (Larson & Belchik, 1998) have documented on Klamath. Mainstem Gualala experienced profound change after the 1955 and 1964 floods. No profound change recognized in ocean.
67 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing 101.1 miles were habitat inventoried in 2001; remove the word tremendous, please. Changed total. Adequate will be the substitute for tremendous.
68 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing Stream order classification noted in figure does not match those presented in synthesis report. See DFG Manual, section II.2.  Change your presentation to conform w/ NCWAP manual and Synthesis report. See #33. No changes will be made to KRIS because orders are correct. See Stream Order Background page (link from Habitat Typing).
69 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing DFG: Habitat frequency as recorded during DFG habitat typing has never been used to gauge cumulative effects by DFG, and we are not sure how that could be done. Please explain how this can be done, and what kinds of changes would demonstrate the problems / conditions to which you refer.  The loss of pool habitat due to watershed damage and subsequent floods is well recognized (see Lisle, 1981; Lisle, 1989; Reeves et al., 1993). CDFG habitat typing data captures pool frequency by length and also pool depth. These parameters vary with watershed health. Other ranges that indicate land use/cumulative effects are embeddedness, canopy, pool shelter rating. Patterns are evident regionally with corollary findings by Knopp (1993) on loss of pool volumes with different intensities of land use. See Hypothesis #3.
70 Cynthia LeDoux Bloom 3/15/2002 Sediment Please consider temporal and spatial distancing between response reaches (where most of our typing is done) and disturbance source areas of the stream Response reaches in lower Buckeye, Rockpile and NF Gualala that were surveyed all have high watershed disturbance levels and debris slide sediment sources just upstream which contributed sediment in 1995 and 1997. The lack of pools and small median particle size distribution all indicate recent sediment contributions (see Dietrich, 1989). The LNF Gualala fine sediment (0.85 mm) flux from 12% to 28% between 1995 and 1997 is consistent with significant sediment contributions and represents levels that are potentially lethal for salmonids (McHenry et al., 1994). Pool filling on the lower North Fork (Entrix, 1994; CDFG, 2001) is corollary evidence.
71 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing Habitat typing is intended to yield information that can be used for fisheries management related to prescriptive actions concerning stream and riparian improvement projects and protection measures.  Habitat typing is a very useful stream inventory tool devised by Bisson et al. (1981) and revised by McCain et al. (1990) before being adopted by CDFG. Mc Cain et al. (1990) said it was "to classify and quantify fish habitat in terms of channel features" to enable "understanding of the relationships between physical habitat factors and fish production factors." Habitat typing has been used in herpetological studies in Prairie Creek to quantify sediment impacts on sensitive amphibian species (Ollivier and Welsh, 1992). See #70 also.
72 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing For first and second order streams = 2 ft. Your figure incorrectly lumps 1st, 2nd, and 3rd order streams and compares them all against the 3rd order, 3 ft depth.  See comment #33 - Streams are arrayed by stream order in the max pool depth chart.
73 Cynthia LeDoux Bloom 3/15/2002 Hydrology Stream orders assigned are incorrect.  See comments #32 and #68
74 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing Please add that each of the Gualala tributary surveys were inventoried by the same team from start to finish. Added to Gualala Habitat Background page.
75 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing Veg layer to indicate occurring oak woodlands and grassland which have less than 80% canopy. Variation in canopy condition in vegetation on Central Belt melange terrain is described in the Gualala Temperature Background page and also Gualala Riparian page. Before inner gorge failure in 1955 and 1964 events, canopy would have been high even in eastern basin, although partially comprised of hardwoods. Douglas fir growing in the shady canyons of the Central Belt terrain were subject to harvest Post WW II, but would have completely covered many tribs before disturbance.
76 Cynthia LeDoux Bloom 3/15/2002 Fish Pepperwood Trap: Low levels compared to what?  Can the capture of 16 coho salmon juveniles in six weeks of trapping be described any other way. For comparison I would offer downstream migrant trapping data on Freshwater Creek (1989), Prairie Creek (1999-2000) and Lagunitas Creek in Marin (1995-2000).  
77 Cynthia LeDoux Bloom 3/15/2002 Fish It seems a reach to base a population shift in sculpins and roach based on one DMT in 1974 Downstream migrant trap sampling spans weeks and is much more reliable than spot samples, such as electrofishing, in assessing fish community structure. The six week sample showed a very low component of salmonids. High capture of sculpin relative to salmonids in highly aggraded streams damaged by logging is documented in tributaries to the Lower Klamath (USFWS, 1990) and in the Ten Mile River by Maahs (1997). CDFG historic reports in the Gualala concur that roach were less abundant and sub-dominant in lesser disturbed streams from 1950 to 1970 (See Higgins (1997).
78 Cynthia LeDoux Bloom 3/15/2002 NCWAP/KRIS Phrasing correctly indicates that hypotheses are an IFR product, not a NCWAP product at this time.  IFR attempted to work together with the Gualala NCWAP team but offers were rebuffed. NCWAP reports not done and will be linked to on when  they become available.
79 Cynthia LeDoux Bloom 3/15/2002 Fish Data are too limited to support Hypothesis #1 Need specific criticism of arguments advanced or countervailing evidence.
80 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing List the tributaries where embeddedness values were unsuitable to support your statement.  Embeddedness is less robust than quantitative methods such as D50 and McNeil samples. Embeddedness data from CDFG 2001 surveys seems low when referenced to channel conditions provided by other metrics. Still embeddedness is moderately powerful in comparison across Gualala SPWs because crews were the same.
81 Cynthia LeDoux Bloom 3/15/2002 Thresholds EMDS terminology of “suitable” and “unsuitable” rather that ‘limit” KRIS projects use specific reference to known biological limits when they are available. The approach was validated through peer review of KRIS Noyo project.
82 Cynthia LeDoux Bloom 3/15/2002 Fish Refer to habitat conditions rather than populations If the habitat requirements of a species are not met, the species will not be present. Habitat conditions can be used as a surrogate for understanding population status. For example, if large components of formerly viable habitat for 2+ steelhead are now underground, that would decrease their standing crop, which in turn would affect adult recruitment.
83 Cynthia LeDoux Bloom 3/15/2002 Temperature List the tributaries where temperatures were unsuitable. Data are too limited to make this statement on a basin or SPW level.  Maps of water temperatures available as Pictures in temperature Topics and in Gualala Temperature Background page. Key low gradient reaches that were formerly prime salmonid habitat are now at stressful or lethal levels.
84 Cynthia LeDoux Bloom 3/15/2002 Sediment Hypothesis #4 (now #3): Sediment Contributions significant compared to what? Sediment contributions have lead to inviable conditions for successful salmonid spawning in NF and filled pools making them too shallow to support coho juveniles and older age steelhead, therefore, significant under ESA. Not maintaining beneficial use, therefore, significant under Clean Water Act.
85 Cynthia LeDoux Bloom 3/15/2002 Sediment How is sediment from recent and past landuse and geology being separated Many lines of evidence support recent contribution: V*, D50, McNeil's and PHI reports from NCRWQCB. Dead alders 15 years old killed by rising water table related to aggradation. Dietrich et al. (1989) point out that small median particle size is indicative of recent sediment contributions. CGS (nor CDFG or GRI) ever provided counter-veiling data to show other cause for low pool volumes, small particle size and high fines.
86 Cynthia LeDoux Bloom 3/15/2002 Sediment The tie with recent land use vis-à-vis naturally occurring sediment yield is not substantiated See previous response and Cumulative Watershed Effects Background page.
87 Cynthia LeDoux Bloom 3/15/2002 Habitat Typing Use EMDS outputs to depict shelter suitability.  EMDS results not available for Gualala at KRIS Gualala press time.
88 Stephen C. Sterling 3/15/2002 NCWAP/KRIS There would be implied consent of approval  by CGS of the geologic data and conclusions presented Disclaimers from CGS appear on opening page of KRIS and where ever appropriate (i.e. Background pages).
89 Stephen C. Sterling 3/15/2002 Sediment Data compiled and interpreted by CGS to date conflicts with the Total Maximum Daily Load (TMDL) charts of contributing sediment source types on the KRIS Gualala CD. The Technical Support Document (TSD) to the Gualala TMDL produced a sediment source analysis which represents the best scientific  information available. CGS did not provide source information in the Gualala Synthesis Report. CGS reservations regarding TSD results will be noted in Chart captions and on Background pages.
90 Stephen C. Sterling 3/15/2002 Sediment The TSD assumes the geology is similar across the entire watershed (approximately 300 square miles).  The TSD Plate 4 is a geologic map indicating different terrain.
91 Stephen C. Sterling 3/15/2002 Sediment The TSD does not include mapping deep-seated landslides for development of the TMDL, which as a result, overlooks a potential major sediment source.  The TSD identified and estimated sediment from the active portions of large, deep seated slides, although they did not map the larger non-contributing portions of these features. Sediment from earthflows shows up in Natural and Bank Erosion in the TSD calculations. CGS interaction with NCRWQCB staff detailed to TSD and TMDL might be in order.
92 Stephen C. Sterling 3/15/2002 Sediment The landslide mapping for the TMDL study was not performed by a California licensed geologist with the knowledge and experience necessary to properly conduct such investigations.  NCRWQCB has geologist on staff.
93 Stephen C. Sterling 3/15/2002 Sediment Similar charts and discussion regarding sediment sources and their purported volumes of derived sediment have been removed from the Gualala Synthesis Report with consensus of all Gualala Team members The information stands as the best available for the Gualala, although CGS questions regarding TSD help understand the limits of its use. KRIS is science driven, not consensus driven.
94 Stephen C. Sterling 3/15/2002 Sediment TMDL charts should be removed from the KRIS Gualala CD or there should be a description of the limitations Reservations and qualifications offered by the CGS will be used in all captions or Background pages where TSD data is discussed.
95 Stephen C. Sterling 3/15/2002 Sediment Release of the TSD findings on a CD where the CGS is shown to be a “cooperator” is unacceptable Policy question.
96 Stephen C. Sterling 3/15/2002 Sediment Release of such information exposes CGS and the Resources Agency to future disputes and litigation. Policy question.
97 Stephen C. Sterling 3/15/2002 Sediment There is a lack of discussion (in KRIS) of natural causes of mass wasting.  Augmented discussions of mass wasting in Cumulative Effects Background page and other places where appropriate, but no data available from CGS and NCWAP Gualala Synthesis Report not our by KRIS Gualala press time (January 2003).
98 Stephen C. Sterling 3/15/2002 Sediment The KRIS Gualala CD cites numerous instances where timber harvesting and logging adversely affect sediment delivery to streams but few or none where natural landslide events have contributed sediment.  No quantitative data provided by CGS on natural sources.
99 Stephen C. Sterling 3/15/2002 Sediment Other potentially significant natural causes should be discussed as well.  Lack of attention to natural causes does not provide for adequate representation of  naturally occurring mass wasting phenomena and sediment derived from them. See comment #97-98
100 Stephen C. Sterling 3/15/2002 Sediment It is recommended that the CGS relative landslide potential maps be incorporated into the KRIS Gualala CD (replacing the SHALSTAB maps) when they are completed.  No data available from CGS.
101 Stephen C. Sterling 3/15/2002 Sediment KRIS products not be released until the CGS relative landslide potential maps are incorporated in the final KRIS products. Maps completed but data not provided for KRIS Gualala despite 12/02 and numerous previous requests.
102 Stephen C. Sterling 3/15/2002 Sediment “The parameter poor, topography-based SHALSTAB program falls well below the current standards of geologic/geotechnical practice.”  Does not meet standards for site specific land use decisions but serves well for risk assessment and as a reconnaissance tool at a watershed scale, which is how it is used in KRIS.
103 Stephen C. Sterling 3/15/2002 Sediment If released (KRIS) gives opportunity for geologic data and conclusions to be misconstrued and misused by community members, watershed stakeholders, and local and regional agencies Policy question. Can't we trust the public (and other agencies) to participate in an informed dialog?
104 Stephen C. Sterling 3/15/2002 NCWAP/KRIS Release of KRIS Gualala and KRIS Big products increases the potential for litigation and disputes over land use proposals See comment #97
105 Stephen C. Sterling 3/15/2002 NCWAP/KRIS Conclusions and data presented on this CD do not necessarily represent the endorsement of all NCWAP departments, including the California Geological Survey.  See comments #88 and #94
106 Stephen C. Sterling 3/15/2002 Noyo Additional comments regarding content of the KRIS Noyo that may be applicable to the KRIS Gualala and KRIS Big products are presented on the enclosed memorandum dated June 19, 2000 from Mr. William Short, CEG to Mr. Gary Reedy.   See KRIS Noyo response to comments Excel database on the root of the CD (represents 500 hrs. of IFR work).
107 Robert Klamt 3/15/2002 Sediment Add in CFL’s D50 data Don't have access to these data. Will add to metadata for future updates.
108 Robert Klamt 3/15/2002 Sediment D50 graphics will change based on a meeting on 3-18.  Revised to show Knopp (1993) range bracketing recovered watersheds and revise Background pages appropriately. No threshold, which is the decision of the 3/18/02 meeting, gives no reference for users. Knopp's (1993) Index All brackets control watersheds and those not logged for forty years.
109 Robert Klamt 3/15/2002 Habitat Typing Displaying dominant substrate and pool depth as was done for embeddedness would be very helpful Pool depth has been added. Dominant substrate may  be added in future updates.
110 Robert Klamt 3/15/2002 System We are using the CalWater designations, so are now calling the ‘sub-basins’ “super planning watersheds”, KRIS should use the same names. KRIS projects all use Calwater Planning Watersheds and our sub-basins are similar to those in NCWAP Synthesis Report. Reference will be made to Syn Rpt Super Planning Watersheds in the opening page to KRIS and in sub-basin descriptions.
111 Robert Klamt 3/15/2002 Maps Gualala South Fork Location Maps: Delete the roads map from this topic Road map is slightly more detailed than map in basin wide Topic. Insufficient justification for removal.
112 Robert Klamt 3/15/2002 Climate It seems appropriate here to mention the change in the gage, date and unknown relationship of prior and post data. Discussion of change in rainfall pattern at Ft Ross rain gauge is available as note from Info Links and CWE page. NOAA indicates that gauge was changed in 1939 so nothing conclusive can be said about rainfall trends pre and post 1920.
113 Robert Klamt 3/15/2002 Climate A location map for all the rainfall sites would be nice Add when updated.
114 Robert Klamt 3/15/2002 Fish Adult Steelhead & Coho Catch: Be careful to indicate that these are estimates  Revised Topics as suggested
115 Robert Klamt 3/15/2002 Fish Presence/Absence of Coho Salmon Central Coast ESU: No info on Adams (2000) or Brown et al. (1994) Revised Info Links to give access to Adams (1999). Brown et al. (1994) out of date for Mendo Coast and removed from this version.
116 Robert Klamt 3/15/2002 Habitat Typing Add Habitat Maximum Pool Depth Graphs and Maps Added suggested Topics.
117 Robert Klamt 3/15/2002 Sediment Sediment: TMDL Source Analysis: Qualify as estimates Revised.
118 Robert Klamt 3/15/2002 Temperature We definitely need the EMDS range for temperature but other interpretations O.K. as well Both EMDS ranges and coho tolerance (Welsh et al., 2001) are displayed.
119 Robert Klamt 3/15/2002 Temperature Add maps of the sampling sites for temps Have done.
120 Robert Klamt 3/15/2002 Temperature Regression of MWAT vs canopy for the GRI sites Not feasible in current project, but good idea. Master's Thesis for someone?
121 Robert Klamt 3/15/2002 Temperature Temperature: Distribution of Temperature Readings in SF: state that represents all sites Removed redundant GRWC temp charts. Thought previous charts were of GRI only.
122 Robert Klamt 3/15/2002 Temperature Temperature: Exceedence of 62 F by Week in South Fork: Use EMDS instead The 62.3 F conversion of 16.8 C MWAT from Welsh et al. (2000) is valid because it shows suitability for coho, the keystone species. Use EMDS curves as separate Charts.
123 Robert Klamt 3/15/2002 Temperature Temperature: GRWC Site charts are redundant with other plots which include 2000 data See comment #122.
124 Robert Klamt 3/15/2002 Timber Harvest Timber Harvest: Percent Harvested SF/Main Gualala: Request for edit to clarify that THP's are permits and may not be cut immediately.  Edited appropriately
125 Robert Klamt 3/15/2002 Timber Harvest To identify the Calwater units on THP maps KRIS Gualala Map project available with both themes.
126 Robert Klamt 3/15/2002 Timber Harvest THP Info Link should mention that not all permitted harvests 1997-2001 have been cut due to delays in operations of up to 3 years Edited appropriately
127 Robert Klamt 3/15/2002 Timber Harvest THP graph captions and titles should convey that the data are for THPs filed, not actual timber harvest. Re: CWE. Edited appropriately
128 Robert Klamt 3/15/2002 Vegetation There is a lot of duplication: VegType vs. Riparian There are subtle but important differences between upland and riparian vegetation and comparing their relationship closely can be revealing..
129 Robert Klamt 3/15/2002 LWD Woody Debris, LWD: Add GRI data KRIS IFR project never received any electronic data for LWD. Problems may exist with GRI Large Woody Debris surveys. They covered only a few reaches. Why were other reaches not surveyed and these selected? Is this a random sample? Is there a document or report that accompanies it?
130 Robert Klamt 3/15/2002 Temperature Info Links: Temperature should reference the EMDS dependency curve Temperature Background page will have discussion of EMDS and display of the curve. Associated bibliographic references?
131 Robert Klamt 3/15/2002 Sediment Sediment section has an image of the Big River TMDL targets.  The Gualala TMDL targets should be displayed instead Changed.
132 Robert Klamt 3/15/2002 LWD Large Woody Debris Information in KRIS, should include info from the GRI/GRWC surveys GRWC and GRI did not supply data. See comment #129 re: GRI.
133 Robert Klamt 3/15/2002 System TMDL Policy suggested change in language Incorporated.
134 Robert Klamt 3/15/2002 Hypothesis Analysis: State in the introductory part that NCWAP uses the same approach re the working hypotheses Link NCWAP Report on the Web. Report not available as KRIS Gualala goes to press.
135 Robert Klamt 3/15/2002 Hypothesis Analysis: NCWAP Team may have some additional hypotheses/alternate hypotheses Link NCWAP Report on the Web.
136 Robert Klamt 3/15/2002 Hypothesis Analysis: take out the TMDL Target line in the D50 plot See comment #108
137 Robert Klamt 3/15/2002 Sediment Analysis: David Leland in our office used a lower temperature threshold for coho than cited here Did not have time to adjust to Sullivan et al. (2001). Also, Welsh et al. (2001) and Hines and Ambrose (1998) are derived from northern California data.
138 Robert Klamt 3/15/2002 Temperature Hypothesis #3 (now #4): EMDS dependency curve and thresholds should be presented here.  Likewise the graphs should use that range, as well as the threshold mentioned above EMDS model outputs are also in review and Gualala Synthesis not complete as KRIS Gualala goes to press (Jan 2003). To mix the EMDS into KRIS Hypotheses at this time.
139 Robert Klamt 3/15/2002 Temperature Hypothesis 4 (now #3): The “mounds” mentioned in the alternative hypotheses have an effect that continues upstream, however D50 values from 9-10 miles upstream of the mouths of these streams are still small.  Those sites are surely out of the influence of the “mounds.” Noted.
140 Robert Klamt 3/15/2002 Sediment Hypothesis 4 (changed to #3): Add to the methods to test hypotheses the monitoring of D50 in sites above the “mounds” at the mouths, as well as analysis of the elevation changes between the “mounds” and D50 sites Added to discussion in Alternative Hypothesis for #3.
141 Robert Klamt 3/15/2002 Sediment Hypothesis 4 (now #3): Large wood information and riparian composition are available from some GRI sites, and may enhance the analysis Data never received by IFR.
142 Robert Klamt 3/15/2002 LWD Hypothesis 6: We have documented suitable water temperatures in some tributaries. Qualified.
143 Scott Downie 5/31/2002 Stream Order The IFR folks have chosen to use something more akin to the Horton scheme which goes well above the solid blue lines and thus changes the stream order considerably.  See Background page on Stream Order, off of Habitat Typing Background page. IFR is using the original Strahler method, while CDFG is non-standard.
144 Scott Downie 5/31/2002 Stream Order DFG first order streams are either second or third order streams according to the IFR scheme.  The same problem extends downstream, of course.  Rockpile, an IFR fourth order stream is a third order stream in the DFG scheme. CDFG method underestimates stream order and is less detailed than a USGS 1:100000 map. Kramer (2002) recommended that CDFG substitute watershed area because of too great a variability in their stream orders for analysis in EMDS.
145 Scott Downie 5/31/2002 Stream Order There is no right or wrong on this issue, but it would seem to be a bit easier on the audience shared by NCWAP and KRIS if we could achieve conformity. IFR composed the Stream Order Background page explaining their methods follow Strahler. CDFG stayed with USGS blue lines only. CDFG stream order assessment is invalid and creates problems in EMDS due to underestimation of stream size and power.
146 Henry Alden 4/14/2002 Edits The opening sentences should be modified to read; “The KRIS Gualala System (selectively) pulls together" KRIS team drew together any data provided. GRI selectively shared data (i.e., Entrix Hab Typing, see Hypothesis #3).
147 Henry Alden 4/14/2002 Edits Conclusions and data presented in KRIS Gualala (represent the views of IFR and do not reflect the conclusions of the NCWAP team.) Edits made on all pages. IFR certainly wants no confusion on differences with NCWAP conclusions. See new disclaimers at page headers.
148 Henry Alden 4/14/2002 Timber harvest Photos and captions of timber harvesting are biased against forest management and particularly even aged silviculture.  The captions need to be edited. Clear cuts cause greater surface erosion and potential for landsliding because of loss of root strength. Concerns over erosion are real and captions remain.
149 Henry Alden 4/14/2002 Photos North fork section, the same photos are labeled differently and used in both the North Fork and Little North Fork sections Corrected. Comments would be more helpful if specific photos were referenced and locations provided.
150 Henry Alden 4/14/2002 Charts Graphs and tables were prepared by GRWC and provided to the NCWAP team and should be included in the graph sections. Added some of GRI charts in KRIS (ie. D50/old growth, see Hypothesis #2 and #3) at the request of Cathy Bleier. GRI open access to writing and placing information in the NCWAP report shows problem with process. Data from GRI are incomplete and raw data were not made available for audit (ie. Macroinvertebrates). Washington DNR WA requires all parties to supply raw data for anything used in WA.
151 Henry Alden 4/14/2002 Bibliography Bibliography fails to list four very important works concerning riparian condition and function Added some of GRI suggestions from CDF but not Cajun James riparian thesis because it has not been peer reviewed and she will not provide data to other researchers to check her results. Madej (1999) in journal not available because of copyright restrictions.
152 Henry Alden 4/14/2002 Hypothesis Analysis section should present the NCWAP teams report in a web friendly way.  IFR’s analysis and hypotheses should be removed NCWAP report still in draft at KRIS Gualala press time. Links to web site for NCWAP and report will be provided.
153 Henry Alden 4/14/2002 Charts Complaint is that GRI Charts comparing Gualala results to old growth streams are wrongly maligned by IFR. "I am a registered professional forester and I personally supervised the vegetation mapping and stream monitoring of these watersheds." Alden used Bull Creek and tributaries Cow and Squaw as an old growth controls. Actually all have been logged more than 25% and Bull Creek is a well recognized cumulative effects case study with more than 30 feet of aggradation at the mouth of Cuneo Creek.
154 Henry Alden 4/14/2002 Thalweg IFR doesn't have thalweg data from GRI. Thalweg data collection methods are carefully detailed in GRI’s monitoring guidelines and the GRWC monitoring guidelines that are in final review by NCRWQCB IFR never received data. Thalweg data is only useful if it is done over several years and GRI study was just starting. GRWC monitoring methods manual never received despite requests. Thalweg data can also be misleading in that bedload transport can occur but settles at same level. Should be using scour chains (see Nawa and Frissell, 1993).
155 Henry Alden 4/14/2002 Data Raw data collected in the GRI/GRWC cooperative monitoring program was provided to the NCWAP team in an Access databases in April 2001. IFR never received data. Kathleen Morgan of GRWC withheld all monitoring data from IFR. Summary data sets received as pdf files are in KRIS, but they are only summary data.
156 Henry Alden 4/14/2002 Canopy IFR seems to ignore that GRI/GRWC measured and reported canopy 50’ inside the riparian zone and measured riparian vegetation along the monitoring reached IFR never received data from GRWC. It conflicted with CDFG for same reaches in Gualala River Synthesis May 2002 Draft and would have required metadata on methods for use in KRIS had it been received. Commenter continues to mistake canopy for riparian conditions and their effect on streams.
157 Henry Alden 4/14/2002 Riparian Ignores CDF’s Monitoring Study Group’s reports on riparian condition and Cajun James’ work See comment #152.
158 Henry Alden 4/14/2002 Riparian All of the quantitative data that has been collected indicates that in general, canopy cover and riparian zones are in good condition and continue to recover from 1960s and 1970s logging No data ever presented by GRI or CGS to show quantitatively that riparian conditions were improving. Riparian assessment using Landsat show trees on GRI land often less than five inches in diameter when using USFS one-hectare scale data (see USFS Veg). Extensive riparian logging is active and on-going. Canopy dominated by deciduous trees is another corroboration of same. Riparian conditions indicate potential problems with increase in air temperature over streams  (see Hypothesis #4) and lack of large wood for recruitment to streams.
159 Craig Bell 9/15/2002 Hypotheses Hypotheses supported by evidence. Personal experience confirms on-going problems with sediment and temperature. No revisions or response required.
160 Rich DeHaven 8/15/2002 Fish There is a minor error for the bar graph for “Britain Creek”  in Topic on basinwide redds. Corrected.
161 Rich DeHaven 8/15/2002 Hypothesis #6 I would propose that “Reduced surface flows are limiting salmon and steelhead production in the Gualala River” would be a more appropriate (based on the supporting data) and informative hypothesis." Made change in Hypothesis #6 statement.
162 Rich DeHaven 8/15/2002 General I devoted about 5 hours to this review.  I found it to be an outstanding piece of work, which is well thought-out, displayed, and supported (by the available literature).  I was particularly impressed by the responses of the IFR team to previous agency review comments. No revisions or response required.
163 Kathleen Morgan 7/31/2002 General To date, I have spent over 20 hours reviewing the various iterations of the Gualala KRIS and in my opinion; the process has been very difficult due to the lack of a finished product that includes quality-controlled data. Finishing KRIS Gualala was problematic because of data acquisition difficulties.  See Notes on Data Sharing from the Home Page. All data in KRIS Gualala has qualifications about quality and restrictions on fair use in Metadata system.
164 Kathleen Morgan 7/31/2002 D50 It has been decided by NCWAP and others, that because the GRWC d50 data have primarily been collected from sites that are less than 1% in slope (none over 2%) it is inappropriate to compare GRWC d50 results to the Knopp Study and/or thresholds.   O'Connor's objection to D50 and Knopp (1993) are noted in Hypothesis #2 and #3 as are NCWAP other reservations in Background pages. Knopp (1993) is the only region wide assessment of sediment and land management. Until further data are collected to assess O'Connor's hypothesis, use of Knopp data by IFR will continue.
165 Kathleen Morgan 7/31/2002 General KRIS should represent the findings of the NCWAP Synthesis Report.  To date it does not.  As Dr. O’Connor states “IFR, apparently on its own initiative, develops conclusions regarding cause and effect that the NCWAP process rejected.”  Content of KRIS and NCWAP discussed in response above to Bleier, Rutland, Sterling and LeDoux-Bloom.
166 Kathleen Morgan 7/31/2002 General The fact that the Department of Fish and Game (DFG) and the California Geological Society (CGS) are requesting disclaimers to be included on the KRIS Gualala Homepage is troubling and a number of steering committee members have express their concern over this issue. Disclaimers from CGS and CDFG will appear on opening page of KRIS and where ever appropriate (i.e. Background pages). CDFG NCWAP disagreed with its own Department's 2002 Coho Status Review findings. CGS contributions to Gualala Synthesis are contradictory to field reports from Tom Spittler related to timber harvest and sediment yield.
167 Kathleen Morgan 7/31/2002 Stream Order To date, a number of changes requested by the NCWAP review team have not been incorporated into the program.  As one example, the stream order classification is based on an “IFR” methodology. The GRWC needs the DFG stream orders as already requested by the Department. CDFG did not provide compelling scientific evidence to cause changes. See response to Downie above and Stream Order page off Habitat Typing in Background matrix.
168 Kathleen Morgan 7/31/2002 NCWAP/KRIS And finally, because IFR did not wait to release this product until the NCWAP Synthesis Report was concluded much of the GRWC and NCWAP data sets are incomplete. NCWAP report not ready as IFR went to press in January 2003. Web links to NCWAP site to be provided. (See note on data sharing off Home page.)
169 Matt O'Connor 7/9/2002 General Hypotheses authorship should be provided on the home page, including any disclaimers requested by State agencies who’s work and conclusions might be confused with IFR’s work and conclusions Changes made.
170 Matt O'Connor 7/9/2002 General IFR, apparently on its own initiative, develops conclusions regarding cause and effect that the NCWAP process rejected.  IFR follows a science-based method and scientific justification for NCWAP conclusions were not sufficiently supported for IFR to accept them in KRIS. See NCWAP/KRIS responses to Bleier, Rutland, Sterling and LeDoux-Bloom.
171 Matt O'Connor 7/9/2002 Sediment Consequently, sediment characteristics in the lower portions of major tributaries c. 2000 in the Gualala where data are available cannot be attributed to recent management influences in isolation.  O'Connor and CGS avoid responding specifically to patterns in data offered by IFR, such as fines (<0.85mm) increasing from around 10% to upwards of 28% in the Little NF between 1992 and 1997. Fines are well above background and transitory. Suggests active contributions. Argument that small particle size distribution is owing to factors other than recent contributions is only hypothetical, not supported by data.
172 Matt O'Connor 7/9/2002 CWE IFR concludes that because there have been recent harvest activities, any sediment characteristics that might be deleterious to fish habitat are in fact attributable to recent management activities, and ignores evidence to the contrary.  No data on natural mass wasting versus human caused provided by any source for the Gualala Basin except the North Coast Regional Board Technical Support Document for the TMDL, which is used in KRIS. Increased sediment related to timber harvest is well documented in other northern California watersheds (Higgins, 2001). See Hypothesis #3. See also SF Ten Mile at krisweb.com where 76% of the watershed was logged in less than ten years (1990-1999). Pools filled in (<3 feet) and fines went up to 20% (<0.85 mm) or more and coho disappeared. The arguments that all the sediment was from older features, from bed-stored sediment or was natural due to gradient were never supported by data.
173 Matt O'Connor 7/9/2002 D50 Knopp data could not be compared to the Gualala data because of significant differences in the channel gradients where the data were collected. O'Connor offers a hypothesis but no data to support contention. Knopp (1993) is scientifically rigorous and represents widespread field data from Northern California; it will remain in use by IFR. Also see revised Hypothesis #3.
174 Matt O'Connor 7/9/2002 D50 It is possible, if not likely, that sediment sizes in the lower gradient reaches of the Gualala where most of the data currently available have been collected are controlled to a large extent by declining stream gradient. Possible yes. Needs to be field tested before upheld. Actually proposing a hypothesis. IFR proceeds with wide ranging field results from Knopp (1993) until more science in the field has been done. Commenter ignores Dietrich et al. (1989) that indicates small particle size of stream bed indicates recent contributions of sediment.
175 Matt O'Connor 7/9/2002 General In summary, the IFR hypotheses and the argument presented to support them are built on selective use of data and ignore substantial, credible data contrary to their hypotheses.  Hypotheses are based on data that support them and countervailing evidence presented with the alternative hypotheses. IFR was openly soliciting data from CGS, GRI and GRWC but did not receive data. Lack of open sharing of data is serious fundamental flaw in NCWAP report and process. Science is an open process. See Metadata system in KRIS Gualala re data sharing.
176 Matt O'Connor 7/9/2002 General KRIS Gualala may tend to undermine conclusions based on interdisciplinary analysis of the data conducted in the NCWAP process; it appears that this is the intent of IFR’s presentation of alternative hypotheses.  KRIS' objective is to capture the best scientific data available and follow scientific methods of analysis to reveal patterns in the data. IFR worked to try and influence the NCWAP report and improve its scientific content and to improve conformance between KRIS and NCWAP. Instead IFR was not allowed to help report writing and NCWAP agents rejected offers to discuss KRIS hypotheses and reconcile differences.
177 Matt O'Connor 7/9/2002 Hypothesis #2 Elevated levels of fine sediment limits production - clearly salmonids need coarse sediment for spawning.  The presence of gravel-textured deposits in the lower reaches of Gualala River tributaries is ordinary and expected; why is this construed as detrimental to fish habitat McHenry et al. (1994) showed through field experiments that fines greater than 13% (<0.85 mm) inside redds caused almost 100% mortality of eggs and alevin of coho and steelhead. Fines in the Little North Fork were as high as 28%. Fine sediment of this size is highly mobile on minor storm events and likely to intrude into redds because of their Venturi-like design. Likely a factor, with shifting bedload, in lack of coho recovery using artificial supplementation from 1995-1997. See also Hypothesis # 3 and loss of pool depth.
178 Matt O'Connor 7/9/2002 Hypothesis #2 O'Connor charted all fines (<0.85 mm) results from GRI in the NF:  "No clear temporal trends are evident from this graph, but it does suggest that enough fine grain material is present to degrade the quality of spawning gravels. Regardless of TMDL target levels, historic or natural levels of fine sediment in the bed are unknown." See previous response. Regional data are available for background sediment levels in streams. See Notes on Regional Baseline Values for Fine Sediment from off the Sediment Information in KRIS Gualala page. Also, fine sediment increase to average of 18-22% (<0.85 mm) in the SF Ten Mile River was sufficient to cause major reduction in coho success.
179 Matt O'Connor 7/9/2002 Hypothesis #2 If smaller size bedload is being moved “during low recurrence interval storms”, one could just as well make an argument for a coarsening of the bed or bed armoring? Exactly. If there wasn't more supply of sediment, the bed would become more coarse (Dietrich et al., 1989).
180 Matt O'Connor 7/9/2002 Hypothesis #2 The graph that shows D50's sampled from '97 to '01 is difficult to interpret with respect to time trends; it does not show any clear trends in terms of coarsening or fining.  True. But most locations remain extremely small and in the category indicative of moderate to high watershed impairment. Dietrich et al. (1989) noted that small median particle size was indicative of recent sediment contributions. Small gravel is also more subject to shifting bedload, which is very deleterious to salmonids (Nawa and Frissell, 1993).
181 Matt O'Connor 7/9/2002 Hypothesis #2 Pool data (V* and lack of pools over 3 ft deep) appears to be the most compelling data that supports the hypothesis See additional data from Entrix (see new NF Habitat Topics, revised Hypothesis #2 and #3).
182     Hypothesis #2 O'Connor use figure of D50 from LNF and Dry Cr only and says his chart "does not show any clear trend in either direction of coarsening or fining of particle sizes at sampled sites with a complete 5-year record."  In fact, 5 of these 6 sites have coarser surface textures in 2001 than they did in 1997. O'Connor selectively ignores NF Gualala mainstem results where D50 ranged from 11-42 mm. The NF Gualala is a fifth order stream according to Strahler and should have larger substrate. Pool filling information (1994 Entrix vs. 2001 CDFG) confirms an over supply of sediment and high sediment transport. Confirms small median particle is indicative of bedload mobility. See previous comments for Dry Creek results. Little North Fork also filled between 1994 and 2001. 
183 Matt O'Connor 7/9/2002 Hypothesis #4 (now #3) It seems that overbank flows in this type of environment would be welcome - floodplains are being inundated like they should be, with attendant unspecified ecological benefits. Floodplains are being inundated to the depth and frequency that redwoods are dying where they have thrived for thousands of years (Hope, 2001). That is outside the normal range of variability and a strong inference that management is altering the flow regime.
184 Matt O'Connor 7/9/2002 Hypothesis #5 Data does suggest that current conditions would lead to higher instream temperatures, but the watershed is on a trajectory towards recovery.  The evidence shows that there has been rapid depletion of large trees in the riparian zone of the NF Gualala, Rockpile Creek and Buckeye Creek. Site potential for soils in riparian zones on the Gualala should have allowed the growth of a thick canopy of conifers over 100 feet high in the 40-60 year period since post WWII logging. See Cumulative Effects in the Gualala page for direct evidence from CDF FRAP change scene detection that timber harvest is taking place in the riparian.
185 Matt O'Connor 7/9/2002 Hypothesis #5 GRI/GRWC data regarding riparian stand conditions demonstrate the presence of well-stocked and/or recovering riparian stands. Canopy measurements are only one indicator of riparian health. Influence of water temperature is from opening airflow (see Temperature Background page).
186 Matt O'Connor 7/9/2002 Hypothesis #5 It should be clearly stated that current management practices are restoring riparian forest conditions Not the case. See above. Also photograph and graphics from NMFS on Hypothesis #5 page.
187 Matt O'Connor 7/9/2002 Hypothesis #5 Forestry impacts on streamside shade and instream temperature that were likely to have unambiguous, significant impacts occurred in past decades. Reviewer fails to understand riparian air temperature effects of timber harvest that opens canopy overstory yet maintains shade. See photos in NF and SF KRIS Gualala sub-basins and Temperature and Riparian Background pages.
188 Matt O'Connor 7/9/2002 Hypothesis #5 The riparian zone of Robinson Creek is now 8 years older than when the data was collected. It seems reasonable to assume that today more than 25% of the trees will be greater than 12" diameter; 45% of the trees in 1994 were medium to large which suggests that there should be a fair amount of shade cover already Restoring microclimatic effects to buffer stream temperature will take decades as will growing conifers of sufficient diameter to provide lasting, large wood to streams. Change scene detection and THPs show major harvest in these zones between 1994 and 1998.
189 Matt O'Connor 7/9/2002 Hypothesis #5 Unclear why the SHALSTAB model results are presented to support this hypothesis Pacific Watershed Associates (1998) showed that 80% of sediment contributed to Bear Creek (Humboldt County) was from clear cuts on steep slopes in the previous 15 years, many in inner gorges. The SHALSTAB model overlain with timber harvests on Rockpile Creek shows a similar situation to Bear Creek. Loss of root strength and evapotranspiration from harvests increases likelihood of slides which will lack large woody debris. PWA (1998) showed this to cause inordinate run-out distances for torrents. If slides occurred naturally, they wood have huge quantities of LWD. While SHALSTAB is only 70% accurate, the model is indicative of elevated risk of sediment yield.
190 Stephen C. Sterling 7/15/2002 General The hypotheses and conclusions proposed in the KRIS Gualala website are different from those presented in the NCWAP Report.  In some cases, the conclusions in the KRIS Gualala contradict the conclusions in the NCWAP report. See previous response to O'Connor, Bleier, LeDoux and Sterling.
191 Stephen C. Sterling 7/15/2002 Sediment The NCWAP team has determined that natural sediment sources are the largest contributor in the Gualala River watershed.  However, the KRIS website maintains that anthropogenic factors are the largest contributor of sediment in the basin.  IFR makes no assertion as to sediment budget overall, only uses TMDL results (see NCRWQCB comments below). Specifically in the western  Gualala and its tributaries, yes sediment contributions are recent and likely related to >50% disturbance by timber harvest in less than 15 years and more than eight miles of roads per square mile in some sub-basins, which CGS did not properly evaluate. KRIS IFR staff attempted to get CGS covers of landslides to check versus SHALSTAB and timber harvests and roads. As of 1/15/03, IFR does not have CGS data.
192 Stephen C. Sterling 7/15/2002 General This discrepancy has large implications for future land management decisions and it will be difficult for the Gualala Watershed stakeholders to formulate land use policy and practice if this ambiguity is not resolved.   IFR tried to resolve differences through scientific discussions with NCWAP team but was unsuccessful. An attempt on Feb 5, 2002 to present and discuss KRIS Hypotheses w/ Gualala NCWAP team in Santa Rosa was rejected by CGS and CDFG, although IFR was invited to the meeting by Gualala NCWAP team leader Robert Klamt.
193 Stephen C. Sterling 7/15/2002 General The KRIS Gualala website should be in agreement and compatible with the NCWAP findings rather than presenting information and conclusions that are not supported by the most complete set of data See above. Data were never provided to IFR on geology. NCWAP staff refused to use KRIS or share information through use of the software. IFR would gladly accept any quantitative data offered by CGS, with sufficient metadata, that might be suitably represented in a graph. CGS never responded to data based arguments about channel conditions in KRIS. For example, CGS offered no counter evidence to show that small particle size distribution (D50) was not indicative of recent sediment contributions (Dietrich et al., 1989).
194 Stephen C. Sterling 7/15/2002 Geology The geology across the watershed varies and should be reflected on the KRIS Gualala website.  IFR never received any electronic data from CGS on geology, with the exception of images files which are impractical to use in any application. There are no USGS data for geology for the Gualala Basin.
195 Stephen C. Sterling 7/15/2002 Geology If the geologic map used in the TSD is included on the website, a qualifying statement must be added that indicates the assumption that the geology across the watershed is not similar and the newly completed CGS maps are more complete.  See comments from NCRWQCB regarding TSD. IFR never received Geology maps from CGS.
196 Stephen C. Sterling 7/15/2002 Geology The TSD identified and estimated sediment from the active portions of large, deep-seated slides, although they did not map the larger non-contributing portions of these features. TSD was concerned with portion of sediment capable of being delivered. See Leland comments below on KRIS and TSD.
197 Stephen C. Sterling 7/15/2002 Geology CGS’s findings identified active and dormant deep-seated landslides (earthflows, rock slides and composite slides) cover approximately 40 percent of the entire watershed, which indicates the total area of natural mass-wasting is notably underestimated in the TMDL.  See comments from NCRWQCB (Leland) regarding TSD.
198 Stephen C. Sterling 7/15/2002 Geology The NCRWQCB’s underestimation of deep-seated landslides and the use of rates less than most published values results in underestimation of natural mass wasting by approximately an order of magnitude or more. See comments from NCRWQCB (Leland) regarding TSD.
199 Stephen C. Sterling 7/15/2002 Geology No licensed engineering geologist for TSD. See comments from NCRWQCB (Leland) regarding TSD.
200 Stephen C. Sterling 7/15/2002 Sediment CGS’s conclusions deviate significantly from the conclusions in the Gualala TSD/TMDL.  CGS maps and final geologic report (an appendix to the NCWAP assessment report) will be finalized with the NCWAP Gualala assessment report and available October 1, 2002.  See comments from NCRWQCB (Leland) regarding TSD. IFR never received data regarding sediment delivery from CGS.
201 Stephen C. Sterling 7/15/2002 Sediment The KRIS Gualala should include the limitations of the TSD data and conclusions to provide a more complete picture of the data set.  The assumptions used including the geology and hydrology are homogenous across the watershed and that only shallow land slides were mapped should be included. Not proper characterization of TSD by CGS. Qualifications added to KRIS Topics. See comments from NCRWQCB (Leland) regarding TSD.
202 Stephen C. Sterling 7/15/2002 Sediment Remove SHALSTAB or add comments regarding SHALSTAB modeling from Technical Advisory Committee (TAC) on Forest Geology from the State Mining and Geology Board, which were provided with the March 15, 2002 comments. Not provided except excerpt in email.
203 Stephen C. Sterling 7/15/2002 SHALSTAB SHALSTAB was used as a quality control check as well as other models in developing the (CGS) relative landslide potential map.... It does not consider the geologic formation or address deep-seated landslides, which are significant factors in slope stability. SHALSTAB was not built to assess deep landslide movement or sediment contributions from them. It does well on predicting shallow debris slides of which there are a number in the recently disturbed, highly unstable western Gualala basin. CGS fails to address linkages of land use and sediment contributions (Kramer, 2002). There are many roads crossing very unstable features and THPs on them as well yet nothing in the NCWAP report about associations. See Metadata record Sediment_CGS.
204 Stephen C. Sterling 7/15/2002 General Presenting incomplete information and not including the limitations of existing data and conclusions (e.g. TMDL, TSD and SHALSTAB) does not provide the public with a complete foundation to make informed decisions.  Providing only part of the information is not scientifically based and can be misleading and biased. No data provided by CGS. How can it be included? KRIS Gualala included all scientifically valid data provided.
205 David Leland 9/6/2002 Hypothesis 2,4 (changed #4 to #3) Both hypothesis pages reviewed present sound reasoning and the hypotheses agree with the conclusions of the TSD and our experience in the watershed. No revisions or response required.
206 David Leland 9/6/2002 General KRIS Gualala content accurately represent the TSD. No revisions or response required.
207 David Leland 9/6/2002 Background The page titled "Assessment of Water Quality for 303d List" should not be included. Revised TMDL Background Page
208 David Leland 9/6/2002 Tours Left out photos provided by the NCRWQCB staff during scoping Photos added.
209 David Leland 9/6/2002 Sediment Y-axis of the sediment source analysis chart should be in units tons/square mile/year. Done.
210 David Leland 9/6/2002 General Bryan McFadin's name is mis-spelled. Corrected
211 David Leland 9/6/2002 Maps Red roads are difficult to pick up on hillshade background. Map CD of ArcView, ArcExplorer project will be available as a companion CD with the database. Any backdrop the user chooses can be selected.

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