HomeMy WebLinkAboutMontgomery Report 1980
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Section B - DISCUSSION OF THE ISSUES
DISCUSSION OF THE ISSUES
EROSION IN THE WATERSHED
At the core of the disagreement between the City of Ashland and the
Forest Service regarding timber management and other activities in the
Ashland Watershed and their impact on erosion and sediment deposition in
Reeder Reservoir are the questions of how much erosion was originally
generated by man's activities, specifically Forest Service road construc-
tion and logging, and how much was natural. The answer to this question
depends on the percentages of the three main forms of erosion occurring
in the Watershed (mass erosion, surface erosion and channel erosion)
and the percentages of each that is related to man's activities. The
City maintains that a higher percentage is attributable to man's activi-
ties than the Forest Service. Most of the difference relates to the
degree to which surface erosion is integrated into the estimate of the
problem.
The significance of surface erosion is greater than it might appear at
first glance. If surface erosion is as important as batholith soil
research indicates and the City of Ashland estimates, then the question
of tolerable intensities of road use and maintenance becomes more critical.
If, as the Forest Service maintains, mass erosion is the predominant ero-
sion factor in the Watershed, most of the problems can be eliminated or
mitigated through design criteria. However, if the problem, as the City
maintains, is in the surface erosion of the road prism, particularly the
driving surface as affected by maintenance and blading activities, then
the problem is more than a design problem and relates to the actual use
and maintenance of the roads already in the Watershed.
Roads and logging were intensified in the Watershed in 1956, after which
the City of Ashland observed much higher rates of sediment deposition in
Reeder Reservoir. The deposition was particularly acute in 1964 and 1974.
The problem was so significant in 1974 that the Forest Service performed
a field estimate and general study of mass erosion in the Watershed fol-
lowing the '74 event. The mass erosion included landslides, large
gullies and the washout of roadfills at crossings. Based on this, the
Forest Service estimated that 59% of the erosion was man-related in the
1974 event.
JMM was retained by the City to evaluate the problem due to their concern
that the Forest Service was underestimating the impact of man's activities
on erosion and sedimentation. It was concluded that the Forest Service
did a good job estimating mass erosion, but had not fully considered sur-
face erosion of the road prism. This phenomenon has been extensively
researched on Idaho batholith soils by the Intermountain Forest and Range
Experiment Station. Since the phenomenon can only be field estimated over
relatively long periods by determining annual erosion rates, it was not
possible to collect field data regarding surface erosion, however it was
decided to perform a quantitative analysis of surface erosion over a 22
year period ('55-'76) which begins before the intense period of road con-
struction and continues through the then available period of record. The
critical factors in such an analysis are the erosion rates, and it was
decided to use the rates found in the research studies performed on the
Idaho batholith. This data was used because it was the only large body
of batholith surface erosion information available and because the two
areas have very similar soil/slope conditions.
In general, the various portions of watershed activities and developments
were broken into segments, primarily on the basis of the type of data
available (e.g., road prism during first year after construction). In
effect, a 22 year erosion (not sediment deposition) budget was developed
for the entire Ashland Creek Watershed of 14,500 acres for the following
erosion facets:
. natural watershed erosion
. road surface erosion base load (due to O&M)
. road prism surface erosion-first year
. road prism surface erosion-second year
. road cut/fill surface erosion base load
. ski area surface erosion
. mass soil movement (USFS data)
. timber harvest surface erosion
It is believed that this constitutes most of the erosion of long term
resident material occurring over the 22 year period. Channel erosion is
not included so the results only pertain to the relative percentages of
surface erosion versus mass erosion; however, channel erosion is primarily
viewed as a mechanism of transport, not a mechanism for eroding large
volumes of long-term resident material. The results of the analysis are
as follows:
JMM ESTIMATES OF SURFACE EROSION VS. MASS EROSION
Natural
Surface erosion of the road prism
Ski area surface erosion
Mass soil movement (USFS field data)
Timber harvest area surface erosion
3%
65%
9%
20%
3%
Surface and Mass Erosion Total
100%
The Forest Service estimates of mass erosion were apparently for only the
area above Reeder Reservoir. If mass erosion figures are extended to the
entire Ashland Watershed area on the basis of road mileage (probably a
worst possible case) the figures are as follows:
.,.~
This report was prepared to accompany a presentation by the City of
Ashland and James M. Montgomery, Consulting Engineers, Inc. (JMM),
consultants to the City, to the u.s. Environmental Protection Agency.
The subject concerns the problems and planning regarding erosion in
the Ashland Watershed and the resulting sediment deposits in Reeder
Reservoir, the City's municipal water storage facility.
The presentation was originally scheduled for December 18, 1980, but
rescheduled due to difficulties in air travel.
The report consists primarily of previously prepared materials (in
Section C) which are included as background information for the key
points in the presentation.
The contents are structured as follows:
Section A - Status Summary
Section C - C-I
Section B - Discussion of the Issues
C-4
C-S
C-6
C-7
C-2
Background Information Concerning Pertinent
Laws and Regulatory Provisions
Ashland's Concerns re USFS Interim Plan for
the Ashland Watershed
Statements of Allen A. Alsing, Director of
Public Works for the City of Ashland; and
Tom Davis, Montgomery Engineers, re Reeder
Reservoir DEIS
Comments and Responses on Ashland Report
Megahan Memo to Rogue River National Forest
Forest Service Comments on EPA Reeder FEIS
Forest Service Comments and Responses on
Forest Policy Report (indirect comments on
Ashland Study)
C-3
.
Section A - STATUS SUMMARY
STATUS SUMMARY
SUMMARY OF THE PROBLEM
The City of Ashland is the recipient of a serious sedimentation problem
in its municipal water storage facility, Reeder Reservoir. During the
high flow years of 1964 and 1974, very large volumes of sediment were
deposited and had to be flushed (through sluicing) out of the Reservoir
and into the Ashland/Bear Creek system. This was necessary in order to
restore the integrity of Ashland's water delivery system which was
threatened by blockage of the outlet works, and reduce the threat of
water quality/treatment plant impairment. This flushing resulted in
downstream sedimentation and water quality problems and precipitated
regulatory action by the Oregon Department of Environmental Quality.
It is the City's position, and the conclusion of an EPA/RVCOG/Ashland
sponsored study in 1976-1977, that the causes of the high erosion-
sedimentation rates are road construction and maintenance, logging
and ski area development which were done by, approved by and/or
encouraged by the u.S. Forest Service, which manages most of the land
in the Watershed.
To a degree, the Forest Service acknowledges its role in creating the
problem, and the City is in agreement with the Forest Service on a num-
ber of points. However, there are significant disagreements on certain
points that are of critical importance in planning the future of the
Watershed. The most important of these points are:
1. the relative contribution of sediment by the three basic
forms of erosion--mass, surface and channel,
2. the relative importance of the design of roads or road
improvements versus the maintenance of the existing road
system,
3. fire management,
4. the City's role in Forest Service planning,
5. planning priorities for the watershed, and
6. federal versus local authorities for protecting the
municipal water system from the impacts of activities
in the Watershed, and
7. who should pay for cleaning the reservoir.
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COORDINATION WITH EPA
The City realizes that the EPA has a number of important roles in solving
the Ashland Watershed and municipal water system problems. These relate
to the implementation of the RVCOG 208 plan, the general regulatory
programs concerned with the water quality of Ashland and Bear Creeks
and the quality of Ashland's drinking water. In view of this, coordi-
nation and mutual understanding between EPA and the City is essential.
RECENT PLANNING AND REGULATORY ACTION BY THE COUNTY
As required under various provisions of the Land Conservation and Develop-
ment Act, Jackson County has recently adopted a County Comprehensive Plan
and a Zoning Ordinance. The Ashland Watershed is designated as an Area
of Special Concern in the Zoning Ordinance. Key references are also
contained in the Environmertal Quality, Forest Lands and Land Resources
Elements of the Comprehensive Plan. Under the provisions of Section 313
of PL 92-500 (see C-I.a) and Section 61 of PL 95-217 (see C-l.b) the
Forest Service should be legally responsible for abiding by these local
requirements. Additional work is required to develop the necessary
performance criteria and procedural steps for implementing the plan
and ordinance, but the basic mechanism is in effect.
The City believes that such local regulatory protection is necessary
due to the areas of disagreement which remain between the City and the
Forest Service. In addition, the Forest Service appears to be unwilling
to fully involve the City in its current planning for the Watershed and
may only be committed to provide "treatable" water, which is not a
satisfactory objective for a number of reasons.
JMM ESTIMATES WITH MASS EROSION EXTRAPOLATED
Natural
Surface erosion of the road prism
Ski area surface erosion
Mass soil movement (USFS field data extended)
Timber harvest area surface erosion
3%
58%
8%
28%
3%
Surface and Mass Erosion Total
100%
It is obvious that when a long term period is evaluated, surface erosion
due to man-caused activities, specifically road construction and mainten-
ance, is a major factor in the accelerated erosion/sedimentation occurring
in the Ashland Watershed and Reservoir and in municipal water supply pro-
blems for the City of Ashland. On a short term basis, such as that used
by the Forest Service, mass erosion is not only the most noticeable, but
in some cases would be the largest contributor. When such short-term
periods are evaluated, it w~uld be reasonable to expect that the materials
originally eroded through surface erosion mechanisms in the watershed would
be moved downstream considerabl~ along with the mass eroded material. Thus,
it is understandable that a one year evaluation might lead one to conclude
that mass erosion and channel erosion were the dominant processes operating
within the Watershed.
As illustrated by the series of Forest Service comments pertaining directly
or indirectly to the JMM Ashland Watershed analysis, the Forest Service has
expressed concern about the erosion analysis methodology. The Forest
Service statements concerning the methodology appear to have become more
strident over time. Their primary concern involves the use of erosion
rates from the Idaho batholith research efforts. After the JMM analysis
was completed, the Forest Service consulted with Dr. Walter Megahan of
the Intermountain Forest and Range Experiment Station who has been the lead-
ing researcher and author concerning most of the Agency's batholith erosion
research. Megahan examined the Ashland batholith during a two day
tour in July of 1978. His conclusions are summarized in the following
paragraph:
"Thus, I would not hesitate to extrapolate the basic principles
found in the Idaho batholith to the Ashland Watershed. However,
the physical properties of the areas do vary somewhat, so I
would be reluctant to extrapolate erosion and sedimentation
rates directly from one area to the other without some on-site
data for verification."
There is no conflict between Megahan's conclusion and the statement of
results and limitations in the 1977 JMM report. From a research stand-
point, site specific research to determine erosion rates is an under-
standable recommendation. However, the JMM study was limited by both
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funds and time period, so while such data was recognized as being desir-
able, it was not within the scope or funding limits of the study.
However, such information .collection was recommended as part of future
research studies concerning the Ashland Watershed question. In Megahan's
memorandum which is included within this report in Section C, he also
recommends a research program to determine the necessary surface erosion
information in the field at a relatively modest cost. To our knowledge,
this program has never been initiated.
ROAD MAINTENANCE
It is generally recognized that highly erodible granitic soils are easily
eroded from the road prism of recently constructed roads. However, some
of the current research of the Intermountain Forest and Range Experiment
Station has indicated that another prime source of erosion within the road
prism is the freshly bladed (during maintenance operations) driving sur-
face. The reworking or blading of this driving surface reoccurs each year,
so a new souce of fine material subject to erosion is available each year.
This was the factor incorporated in the JMM Ashland Watershed analysis
which was probably of greatest concern to the Forest Service since little
if any documentation of this phenomenon is available in the literature.
However, the inclusion of the process was based on discussions with the
leading batholith soils specialists in the Forest Service Research Division.
Since the 1977 report current studies indicate .that.another major source
of surface erosion within the road prism is the cut-slope/ditch area.
Erosion rates in the general order of magnitude of recently constructed
roads have been observed on very old roads constructed on the Idaho
batholith. This process was not included in the JMM Ashland Watershed
analysis, but if it is operating as suspected, the '77 results would be
conservative.
The phenomenon of surface erosion points dramatically to the maintenance
of roads as an important, if not the most significant, source of erosion
in an area such as the Ashland Creek Watershed that has experienced logging,
road construction and other disturbances and contains relatively steep
slopes and erodible granitic soils. This is an important conclusion
since, if one concludes mass erosion and channel erosion are the most
significant erosional processes operating within the watershed, the ques-
tion of road maintenance is of minor importance. However, if surface
erosion of the road prism, particularly of the driving surface and the
ditch/cut-slope areas is a major factor, then the mere use and concomi-
tant maintenance operation on' the roads should be reduced or eliminated,
or the erosion/sedimentation impacts otherwise minimized.
FIRE MANAGE~:lENT
The City of Ashland agrees with the need for a fire management program in
the Ashland Watershed and is confident that a number of alternatives exist
that are compatible with municipal watershed protection, however the Forest
Service has appeared at times to be inclined to justify a number of inten-
sive activities within the Watershed in the name of fire management. The
basic fire management conclusions of the 1977 JMM study are summarized
below:
1. The history of fires and fire management in the Rogue River N.F.
indicates that the major problem fires were man-caused and
that natural fires were generally suppressed in a short time.
2. There is a high potential for increased erosion due to an
intense fire in the watershed. However, there is research
information available that demonstrates that wildfire in
unlogged watersheds can result in significantly less erosion
and sediment movement than wildfire (whether man-caused or
natural) in a logged watershed.
3. High levels of human activity such as that associated with
logging or extensive over-night camping could be expected to
increase the likelihood of a large man-caused fire.
4. Fire management involving intensive observation and quick
response in suppressing all fires is the most appropriate
program for the Ashland watershed.
5. Although the physical removal of fuel from the watershed
would present certain benefits, the extensive logging
activities required to do this effectively would present
far more hazards and potential for loss than for benefit.
Prescribed burning for fuel reduction may present oppor-
tunities if the air quality impacts are minimized.
ASHLAND WATERSHED MANAGEMENT PRIORITIES
It is the City of Ashland's position that the most important management
objective for the Ashland Creek Watershed should be to maintain and protect
the municipal water facilities and water quality currently depended upon by
the City. Although the Forest Service has implied that this is the case,
many of their actions and statements point in a different direction. For
example, in discussing the Forest Service policy regarding water quality
for municipal watersheds, the Forest Service stated (USFS, 1980 in a memo-
randum to the City of Ashland):
"Basically, we have the responsibility for providing raw water
that is capable of meeting standards in the Safe Drinking Water
Act (PL 93-523) after treatment. The treatment of the water to
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those standards is the responsibility of the purveyor and not
of the Forest Service. The Forest Service, recognizing the
importance of water quality in Municipal watersheds, will use
land management measures which will protect the quality of
the raw water. In most cases, this can be accomplished without
deviation from the concept of multiple use management.
This policy is stated in Section 2543.03 of the Forest Service
Manual and in interpretation of that Section."
This "treatability" criteria could be met by almost any water and appears
to be insensitive to the cost and operation aspects. It has little, if
any, relevance to the Ashland situation since the past problems involved
erosion/sedimentation that interfered with the operation and maintenance
of the water storage and supply system, not water quality or treatment
requirements per see
The Forest Service's refusal to date to withdraw the watershed from
mineral entry is another distrubing reflection of their management and
planning priorities, particularly in view of the low to non-existent
mining potential and the extremely high potential for damage which could
result from mineral exploration (which the Forest Service has little, if
any, effective control over). The City objects to this, particularly in
view of the reason stated in a March 27, 1979 Forest Service memo.
"The City of Ashland would prefer to have the Ashland Water-
shed withdrawn from mineral entry so as to prevent possible
contamination of the water supply due to mining activity.
Historically, there has not been much mining within the
watershed, nor is there much anticipated. The Forest
Service, while recognizing that a withdrawal of Ashland
Watershed from mineral entry may have little impact on
the mining in this area, are concerned that withdrawal
of a watershed per se to preserve a watershed's water
quality would have tremendous effects on the mining
industry nationwide."
This contributes to the suspicion that, for the Forest Service, municipal
water supply is below mining in priority, even when there is no signifi-
cant potential for mining.
CITY INVOLVEMENT IN FOREST SERVICE PLANNING
In discussing the City's role in Forest Service planning for the water-
shed with the former Forest Supervisor, it was apparent that the City was
viewed as one special interest facet in a multi-faceted public sector.
It was also apparent that the former Forest Supervisor considered his
authority to adopt plans and carry out management activities as a uni-
lateral function unless a specific appeal is made by an affected party.
.,.....
The City recognizes and encourages planning and management activities
that allow the fullest possible extent of public involvement, but as the
recipient of any sedimentation burdens which mistakes in Forest Service
management create, it is our opinion that Ashland has far more than a normal
public interest in the decisions made.
At a minimum, a City representative should be an ex-officio member of
the interdisciplinary planning team and meet regularly with the technical
planning group as it proceeds through the preparation of the 1982 plan.
FEDERAL VERSUS LOCAL RESPONSIBILITIES
The City recognizes that the Forest Service, as a federal land management
agency, has an important responsibility for protecting and managing the
Ashland Creek Watershed. However, the City and Jackson County have the
responsibility to include in their Comprehensive Plans and implementing
ordinances, land use provisions for protecting "non-conunercial" forest
lands within their jurisdictions. This is provided for under goal four of
the Statewide Planning Goals adopted in 1974 by the Oregon Land Conser-
vation and Development Commission under the authority of the Land Con-
servation and Development Act. Other goals also apply and have been
addressed regarding the Ashland Watershed in Jackson County's compre-
hensive Plan (see Section C of this report).
In Oregon, counties must address the Forest Land Goal in their compre-
sensive plan. One or more forest uses must be protected from the non-
forest uses such as residential development. However, "the production
of trees and the processing of forest products" does not have to be the
exclusive, or even one, of the uses protected. The forest uses which can
be protected through a County ordinance pertaining to the Ashland Water-
shed would be "(3) watershed protection and wildlife and fisheries habi-
tat; (4) soil protection from wind and water; (5) maintenance of clean
air and water; and (6) outdoor recreational activities and related support
services and wilderness values compatible with these uses:" (LCDC News-
letter, May, 1979). For additional background on the subject, see the
Oregon Attorney General's opinion and the LCDC Newsletter in Section C.
The question concerning whether or not the Forest Service would have to
abide by County or City requirements would appear to have been resolved
in PL 95-217 (the "Clean Water Act of 1977") which strengthened Section
313 of PL 92-500 relative to local jurisdiction over federal water pollu-
tion activities. In summary, the revised section states that all federal
agencies:
"(1) having jurisdiction over any property or facility, or (2)
engaged in any activity resulting, or which may result, in the
discharge or runoff of pollutants shall comply with ... local
requirements respecting control and abatement of pollution to
the same extent that any person is subject to such requirements,".
"The preceding sentence shall apply (a) to any requirement whether
substantive or procedural."
"'"T
Thus, the local (and state) jursidictions have an important authority and
responsibility to protect their interest regarding the "discharge or run-
off of pollutants" from federal lands. There would seem to be little
question that Ashland am Jackson County have such authority regarding
the management of the Ashland Creek Watershed and the impacts of Forest
Service activities on the Ashland municipal water system.
RESPONSIBILITY FOR REMOVING SEDIMENT FROM REEDER RESERVOIR
Historically the City of Ashland has borne the responsibility for sedi-
ment removal from Reeder Reservoir (see the 1977 JMM report and the 1980
EPA FEIS on "Reeder Reservoir Maintenance Operations"). This has been
accomplished through sluicing. The possibility of dredging the sediment
deposits was investigated in the JMM and EPA studies.
It is the City's position that if dredging is required, the federal
government should pay the cost, since Forest Service actions were the
primary cause of the problem, regardless of the relative mix of sediments
resulting from mass-, surface- and channel-erosion.
FUTURE RESEARCH
The following research should be initiated on the Ashland Watershed.
1. Surface erosion rates for the:
a. Road cut surface including the ditch.
b. Driving surface including the relationship to the ditch.
c. Road fill surface.
d. Ashland ski area.
e. Undisturbed areas.
2. Continual monitoring of mass failure areas.
3. Channel erosion using capacity, aggradation, degradation
methods as developed and used by Dr. William W. Emmett of the
U.S. Geological Survey.
4. Monitoring of the stream system just above the reservoir for:
. suspended solids
. turbidity
. bedload
5. Monitoring of total organic carbon at various locations in
the watershed and reservoir (for the purpose of determining
trihalomethane potential).
...
Section C
C-I Background Information Concerning
Pertinent Laws and Regulatory
Provisions
C-2 Ashland's Concerns re USFS Interim
Plan for the Ashland Watershed
C-3 Statements of Allen A. Alsing,
Director of Public Works for the City
of Ashland; and Tom Davis, Montgomery
Engineers, re Reeder Reservoir DEIS
C-4 Comments and Responses on Ashland
Report
c-s Megahan Memo To Rogue River National
Forest
C-6 Forest Service Comments on EPA Reeder
FEIS
C-7 Forest Service Comments and Responses
on Forest Policy Report (indirect
comments on Ashland Study)
C-l
Background Information Concerning
Pertinent Laws and Regulatory
provisions
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May 1979
Vol. 2. No. 5
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Henceforth the movement for the conserva-
tive use of the forest is to come mainly from
within, and not from without; from the men
who are actively interested in the use of the
lorest.
I
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I
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President Theodore Rooseveh
1905
With these words, President "Teddy" Roosevelt
launched the first major conservation movement
ever undertaken in the United States. Its mainstay
was to become government/industry cooperation.
and the names of Weyerhaeuser, Pinchot, Muir and
Roosevelt were to be its leaders. Admonishing
lumbermen who "skin the country and go some- '
where else. . . whose idea of developing the coun- .'
try is to cut every stick of timber off of it, and leave a
barren desert for the homemaker who comes in
after him," Roosevelt through Pinchot as head of
the U. S. Forest Service, forged a pragmatic pro-
gram of conservation, selective cutting and sus-.
tained yield.
Oregon's Land Use Program continues this
common sense approach to Forest Lands. Among
the original 14 Statewide Planning Goals adopted
by LCDC in 1974, Goal 4. "Forest Lands" seeks to
conserve the resource for forest uses. .
The Oregon economy relies upon its natural
resource base. The wood products and agriculture
industries each contribute $3 billion plus to, Ore-
gon's economy each year. Planning for the wise
use, conservation and preservation of these and
other natural resources requires the cooperative,'
and coordinated efforts of government and indus-
try. Historically, in Oregon, government/industry
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Newsletter
cooperation in managing the forests has worked
well; in like spirit, today they are planning together
to ensure the continued well-being of Oregon's
forest lands for forest uses. Editor
We have to settle lor a land not of plenty, but
a land of enough.
Governor Tom McCall
DtfJIJUf@~
Forest lands:
. -Oregon's Forest Resources
~oaI 4 "Forest lands".
-Forest Regulations . ,
-Industry Views-AOI .
. -Timber Shortage--State Forester'. <'
Meeting Highlights--4.llay 3 & 4 . . '. " .',
Appeals in Brief-April 20 . . . , , .: .
May 3f 4,.; ,;: ".
Back 40 .
. ;
OREGON'S FOREST RESOURCES
by .. . '.
Lloyd Chapman < .,
Plan Review Specialist .J:~. >: ~ :. !.';
More than half of Oregon, 30 millio'n acres, is
shaded by trees. The map below shows the extent
of the state's forest land by forest type. Moist
coniferous forest covers most of western Oregon.
Dominated by Douglas fir, these' are some of the
most productive timberlands in the world, The .
dryer eastern two-thirds of the State is forested
primarily with ponderosa pine and western juniper
with more fir !OrE;sts at ~igher elevations. :
Of these forest lands:-'approximately 24 million
acres are rated as' commercial forest land. The
following chart shows ownership of commercial
forest land.
0-. ':,..
~~:::.~('_~~ ::~~:'~~~~.~-~.~~~~~~~'1"~i.. ~
~->,~~,-,"-:=....~. :-~.:~: '-I:~..iJ~Z:i~t..~~= :.1..1 '=~..L,ll~ol-;='''':~,;'=.::~~=-~'d:i..:~~ ..~;..u<J~.~.~';l..".:-:;":;'.:..-;, :;--:~ '",-~~~- ~~'i~~>>t:,:':.'UI~~.[~~}';..J.~~.r-~.~~L.:
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Commercial Forest Land Ownership 1
, From I'o<1mr)' Program for Oregon, Stale Dept. of Forestry pp. A-59 through Ml3.
Urban forests and streamside vegetation are
also critical resources which provide vaJuable
assets.
Forest resources provide a multitude of benefits
to the State. Another article in this iSsue discusses
the scale and importance of the timber industry. In
addition, our forest lands provide a multitude of
less well known benefits.
Oregon forest lands supply rich and varied
habitat for hundreds of wildlife species. Deer.
mountain beaver, elk, racoons and cougar share
the forest with owls, eagles, grouse, reptiles and
hundreds of other vertebrates. The diversity of the
State's forest habitat results in an equal diversity of
wildlife.
1
Owner
Forest Service
BLM
Other Public
Forest Industry
Other Private
Total
Acres
Western OR
(Million)
4.8
2.0
.9
4.1
2.2
14.0
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Acres
Eastern OR
(Million)
6.8
.2
.4
1.6
1.2
10.2
Total
Acres
(MIllion)
11.6
2.2
1.3
5.7
3.4
24.2
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DOOUOL"" FIll DWEITE..... ,JUNI~Ul 0,.011 FORRft
CM'XED CO"'''EROUS CPO..DtERO.... ..,.._
Forest lands host dozens of recreational oppor-
tunities and activities and literally millions of per-
son days. From hunting to backpacking, scenic
vistas to fishing, virtually every Oregonian enjoys
the recreational opportunties provided by forest
land.
In Eastern Oregon, forest lands often support
grazing, as well as timber production( other forest
uses. These lands are particularly important to the
regional economy.- - ,_... . J '
Because of the 'extent a~d' value of Oregon's
forest resources, it is essential that they be used
wisely.
Forest lands also play a critical role in water
quantity and quality. Forest cover slows the move-
ment of rainwater down the hillside, lessening
erosion and the threat of downstream floods, and
maintaining water quality. The problems as-
sociated with a massive loss of the forest cover are
. seen in the Tillamook Burn. ~ ' .' . , .' '
.,: ,.
. . ;';,.
. '. ~ ;
. ~ :t. ;. . ~.
THE FOREST LANDS :GOAL '< ;, :.~ ;'" ,
One of the original Statewide Planning Goals
adopted by the Land Conservation and Develop-
ment Commission [LCDC] was Goal 4 "Forest
lands." Its purpose is to conserve forest lands for
forest uses. The Commission is curre~tJy consider-.
ing a position paper on the Goal "Common Que~
tions on the Forest lands Goat" Key elements of
the paper ar~ sum~arize<:!below. ....:.: '; '.: ~. .
As noted above. the purpose of Goal 4. "Forest ;',:'.
lands," is to conserve forest lands for forest uses. : '. ~
The Goal defines "forest lands" and "forest uses",' .. _.
broadly to include the widest spectrum of lands. '.
and uses. To achieve the Goal's purpose, a three-. :',
. _' step process isto be followed:.' .,' .'
. -.. 1. 1~1Ventory of ~xisting and potential forest
lands; ... :. -
. j, -:
...
.:
"
'---;
...-......:- -,. ~ ~
'-=-~ ':.~~ .~;'~ ft.-l.~~~ ~ t -. ~~:J~2.:i~~'::"::~~'~_ :.::~.:~~~ t~._~ ~i ~i~-12~~~~~~~~.:j~:-f:~~[{!=~-~~~._-: ~~~,:~~i-t:~~ 2~~7':~;'~;~~~{;
+- ...'. .... '~"'"'''~''_~'''~''' '" " "'''',~;'",''''.'' """'"";""'m__'''''~'' ", ,
_---J...~L.....;.~....."""''_..... :J:.L~ ~~... .... itA' ,--...~.'~'L:'-;:'~_
2. designation of forest lands on the com-
, prehensive plan map; and
3. protection of forest uses on forest lands.
Step One
It is the responsibility of each local jurisdiction,
especially counties, to prepare an inventory. of
forest lands. Two types of information should be
used in doing an inventory: .
1. general information identifying forested
areas based on aerial photog raphs,
visual surveys and vegetative cover
mapping, and
2. mapping of the forest productivity of the
land.
The first set of information should provide a gener-
alized map of forest land. The secondwill show the
relative productivity of that land. Productivity is
especially important when a change from forest
use to nonforest use is being considered.
;""~"~~d:;1>" :,;i~~~ri;:;Bl'~ ,,;;~;, ;2,}~'':
, ;:f;:"'~f~;~~"';'~;::', ;'"".E
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logging ope'ati~
Step Two
The second step is designation of forest lands
on the comprehensive plan map. Designation is an
important policy decision which should direct how
the land will be used in the future. If inventoried
forest lands are not designated as "Forest Land"
(or given another designation which protects forest
uses), the plan should state how these lands were
designated and whether or not forest .useS' are
protected. Where forest uses are not protected, an
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exception' must be taken to the Goal.
Designation in areas of intermingled agricul-
tural and forest lands is often difficult. Since forest
uses are allowed in exclusive farm use zones [ORS
215.213] and nonforest uses are limited, LCDC has
determined that an "agricultural land" designation
for these areas may comply with Goal 4.
Step Three
Finally, the Forest Lands Goal requires that
forest uses on forest lands be protected. This is
done primarily through the zoning ordinance allow-
ing one or more forest uses and limiting nonforest
uses such as residential use. For a more complete
discussion of forest regulations, see the "Forest
Regulations" article in this newsletter.
The Forest Lands Goal was developed recogniz-
ing the importance of these lands to the State. The
Land Conservation and Development Commission
is committed to seeing that it is implemented
through local plans and the resources thereby
conserved.
For more information, or a copy of the paper
"Common Questions on the 'Forest Lands' Goal"
contact Lloyd Chapman at the Department of Land
Conservation and Development, 1175 Court Street
N.E., Salem Or 9731o-PH: 378-4932.
, See Oregon lancia April 1979. Vol. 2 No. 4 for a description of the' exceptions
process. ,Editor ~ . : .
FOREST REGULATIONS
. Comprehensive plans are often criticized ~
cause of the tendency to have them sit on the shelf
and collect dust. To make plans effective working
tools, Oregon's Land Use Program requires. that
plans "be the basis for sPecific implementation
measures. These measures shall be consistent with '
and adequate to carry out the plans~" [Goal 2.
"Land Use Planni.ng'1 . '~':.' ~". ; .
Oregon statutes lORS 197.175] requfre cities
and counties to adopt zoning and subdivision
ordinances to implement the plans and these 'are
particularly important in regulating .!~r~t I~nds.
A zoning ordinance' identifies zoning districts
and regulates the uses of the land within those
districts. Uses are either permitted outright (requir-
ing a building permit at most), are conditionally
allowed (requiring a public hearing before the use
is allowed) o~ are prohibited. ,;". ~. I' ;,;.:' ~. ;;
. . ~~ '.. '-" .. " , .....,.
To comply with the' Forest Lands Goal, lands
which have been designated as .forest lands must
be zoned to provide for one or m'ore forest uses and
to limit nonforestuses. Forest uses are defined in
the Goal as:.~_." . ,," >.."-.' .-',:.: ..
"1.'. the production of trees and the' pi-~cess- ,"'.
ing of forest products; .' .:. . " . ,. .' ,
'.
~
.
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2. open space, buffers from noise, and
visual sepa~ation of. conflicting uses;
3. watershed protection and wildlife and
fisheries habitat;' .
4. . soil protectior:t from wind and 'water;
5. maintenance-of clean air and water;
6. outdoor recreational activities and re-
lated support' services and wilderness
values compatible with these uses; and
7. grazing land fo~ Iivestoc~~:
/
Probably the m~st' common nonforest use
which must be limited is residential use. LCDC in its
decision on Polk County's acknowledgment re-
quest,1 found that permitting residential develop-
ment outright in forest land on lots of record did
not comply with Goal 4. Limiting residential and
other nonforest uses can be accomplished by these
or similar controls:
1. Allowing development in forest lands only
if it is associated with forest uses
2. Allowing development only on less-
productive forest lands
3. Limiting total density and acreage of de-
velopment on forest lands
4. Allowing development only if it is compat-
ible with surrounding forest uses
5. Setting performance standards to be met
by proposed nonforest u~
The Commission's position on this
issue will be clarified when it reviews the "Common
Questions on Forest lands Goal" paper at its July
meeting. -
, All cltJes and counties are required by law to submll adopted comp,."hens/w plans
and implementing ordinances to La)C to be Nacknowledged" to be In compllanc:e
with the Statewide Planning GosIs and slate slaMas. Rx a complete dlscusslon 01
the NAcknowIedgment Prooess, N see Oregon Landa FebnJ8Iy 1979, Vol 2 No. 2. Editot
:.. ~."
i' .~
mil"? 11:)011111- .
"- Goal 15 'Wollama.. Greenway" ~
'.:1',
"~.......---~< ---,~..._._.._>.-."....._,.."._--,
VtCTOR ATIYEH
OO'V.""""
C-l.d
LCDC Memo re Forest
Lands Goal Policy
Land Conservation and Development Commission
1175 COURT STREET N.E., SALEM, OREGON 97310
" :--.. ~
/ i_,/ - 'J ~ ...
U G I~ 10 L~ IJ &" f
JUL ~
6 iSl9 IJlJ
M E M 0 RAN 0 U M
July 3, 1979
J i"viiV/
TO: Land Conservation and Development Commission
FROM: Commission Subcommittee: D. Gervais, A. Squier, and R. Smith
SUBJECT: ITEM 4.6: FOREST LANDS GOAL POLICY
I. BACKGROUND INFORMATION:
On June 13, 1979, the Commission Subcommittee met with staff to
review the Common Questions paper. The following unresolved pOlicy
issues were identified:
1. Commercial Forest Land--does commercial forest land need to be
defined in the paper?
2. Inventory Requirements--What does the Goal require? What is
reasonable, practical and useful? ----
3. Residential Use--Under what circumstances might future residential
development be allowed on inventoried forest land?
a. In areas committed to nonforest uses?
b. When an exception is taken?
c. When an adequate minimum lot size is provided?
d. In conjunction with and/or compatible with forest uses?
'\
4. Forest Practices Act--What is its relationship to the Forest
Lands Goal? Management of forest operations is a coordination
issue between local government and the State Department of
Forestry (DOF) and between DLCD and OOF as it relates to their
state agency coordination program. .
These issues were discussed by the Subcommittee with the Forest
Lands Goal Task Force on Wednesday, June 27.. Attending were:
... ....-...,
(
MEMO - ITEM 4.6
-2- Ju ly 3, 1979
Jerry Thurber
Dick Briggs
John Bennett
Dave Hi 11
Ken Cannon
Jack Stone
Dave Degenhardt
Mike Beyerly
R.ichard Benner
Kandy Smith
Dick Gervais
Jim Ross
Anne Squier
Lloyd Chapman
Lane Co.
Lane Co.
Lane Co.
OBPC
AO!
Small Woodlot Owners
DOF
DOF
1000 Friends
LCDC
LCDC
,OLCO
LCOC
OLCO
After lengthy discussion on each of the points, the Subcommittee
and Task Force reached general concurrence on each of the points,
as well as a couple of others. The Subcommittee directed the staff
to prepare a revised policy paper focusing only on the issues
discussed on the 27th. Since there was substantial agreement on
the other questions raised in the paper, it was felt that Commission
action on these points was unnecessary.
II. RECOMMENDATION:
.
The Subcommittee recommends that the attached paper be approved by
the Commission as policy. Staff is directed to continue to_provide
assistance to jurisdictions based on the May 29, 1979 draft of
IICommon Questionsll where the draft does not conflict with this
policy.
Testimony on this issue has been heard at three Commission meetings
spanning four months. Because of this, we recommend that additional
oral testimony not be taken at the meeting. If any reviewer has
additional comments, they should be submitted directly to Subcommittee
members. It will, of course, be at the Commission's discretion to
accept additional testimony at the meeting.
Subcommittee Members:
Richard Gervais
437 Orake Road
Bend, OR 97701
Randy Smith
18955 Bridgeport Road
Dallas, OR 97338
Anne W. Squier
5647 S. E. 38th
Portland, OR 97202
WJK:LC:krhjMC
--.
C-l.d
ON THE
rORtST LANUS GUAL
The purpose of the Forest Lands Goal is lito conserve forest land for
forest uses.1I Both "forest landll and "forest usesll are defined in the
Goal. These definitions refer to a wide variety of forest uses, only
one of which is commercial forest use. The Goal requires that all of
these uses be considered in complying with the Goal. Identification of
a primary forest use for forest land is not required.
To accomplish the purpose of conserving forest lands for forest uses,
the Goal requires: 1) an inventory of lands suitable for forest uses
and a determination and mapping of the productivity of these lands for
commercial use, 2) designation of these lands on the comprehensive plan -
map as forest lands, and 3) retention of forest uses on designated
forest lands.
Inventory
The Forest Lands Goal requires an inventory of 1I1ands suitable for
forest uses.1I This inventory must include a mapping of forest lands by
cubic foot site class. If, because of past uncertainty as to the goal
inventory requirement, a county is unable to complete a cubic foot site
class map prior to submission, it must: 1) provide an equivalent mapping
of productivity and 2) include plan policies to complete cubic foot
site class mapping-no later than the next plan update. However, with
the technical aid offered by the Department of Forestry, most counties
will be able to complete a cubic foot site class mapping. .
Designation
Inventoried lands suitabJe,.for forest uses must be designated to' retain
those uses or else an exception taken. Forest lands must be designated
to conserve forest lands for forest uses. The most common plan designation
is "Forest" or "Forest Land.1I In areas of intermingled agricultural and
forest lands an "Agricu1tuf'al/Forest Lands" designation may also be
appropriate. If some other designation is used for forest or ag/forest
1 and, it must nonethel css CulTY equivalent protection for forest uses.
When inventoried county lands suitable for forest uses are not designated
so as to protect forest uses, an exception is required.
In determining whether 1I1ands suitable for forest usesll will be designated
as "forest lands," all forest uses identified in the Goal must be considered.
Exceptions
The exceptions process defined in Goal 2 is used when lIit appears that
it is not possible to apply the appropriate goal to specific properties
or situations.1I An exception to Goal 4 is required when inventoried
lands suitable for forest uses are not designated on the plan map and
zoned to protect forest uses.
-.............--'~~--- '
('
Policy on Forest Lands Goal
-2-
July 3, 1979
Goal 2 and the Department's policy paper "Common Questions About the
Exceptions Process" explain how an exception is to be taken. Exceptions
to the Forest Lands Goal must justify that lands suitable for forest use
are either: 1) committed to nonforest use or 2) needed for nonforest
uses. The justification for lands committed to nonforest uses must be
based on the actual nonforest uses of the land, not simply current
parcelization and lot size.
Retaining Forest Uses
Forest lands are retained for forest uses by allowing one or more forest
uses and limiting nonforest uses (such as residential use). Where
nonforest uses are allowed (outright or conditionally) on forest land,
the jurisdiction must demonstrate in the plan that the forest lands will
be retained and protected for existing and potential forest uses, despite
the nonforest uses allowed.
Forest Regulation
The Forest Practices Act (FPA) (ORS 527.620-527.990) as implemented
through State Board of Forestry rules (OAR 629-24-101 through 629-24-
648) regulates forest operations on forest lands. The relationship
between the act and land use planning was addressed by the 1979 Oregon
Legislature through enactment of HB 3008:
SECTION 1. Sections 2 to 4 of this Act are added to and made a
part of ORS 527.610 to 527.730.
SECTION 2. (1) Except as provided in subsection (2) of this section,
no unit of local government shall adopt any rules, regulations or
ordinances regulating the conduct on forest lands of forest operations
governed by the Oregon Forest Practices Act or rules promulgated
thereunder.
(2) Notwithstanding subsection (1) of this section, a city may
adopt rules, regulations or ordinances regulating the conduct on
forest lands of forest operations within city boundaries if those
rules, regulations or ordinances establish standards equal to or
more stringent than those established by the Oregon Forest Practices
Act or rules promulgated thereunder.
SECTION 3. Any forest operations on forest lands within this state
shall be conducted in full compliance with the rules and standards
of the Environmental Quality Commission relating to air and water
pollution control. In addition to all other remedies provided by
law, any violation of those rules or standards shall be subject to
all remedies and sanctions available under statute or rule to the
Department of Environmental Quality or the Environmental Quality
Commission.
~.<.~,.",..~-_.,
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Policy on Forest Lands Goal
-3-
July 3, 1979
~
SECTION 4.
intended to
pursuant to
by:
(1) Nothing in sections 2 and 3 of this 1979 Act is
preclude counties from performing their planning duties
ORS 197.005 to 197.430 with respect to forested lands
a) Designating in comprehensive plans forested lands to be conserved
in accordance with the statewide planning goals;
b) Zoning forested lands for uses other than or complementary to
commercial growing and harvesting of forest tree species in
implementing a comprehensive plan; or
c) Adopting rules, regulations or ordinances regulating forest.
operations on those forested lands zoned for primary uses
other than the commercial growing and harvesting of forest
tree species in accordance with the use or purpose for which
those lands have been zoned.
(2) As used in this section, "forested lands" means those lands
upon which forest tree species are growing.
LC:krh/MC
074513/6926
I J J
'- {t' I '{ ( ,"' I ~'
j " '
I I I Lr-
C-l.e
~--L-
Oregon Sttorney
General's Opinion re
Zoning Regulations for
Forest Operations
~
No. 7894
a county uses "forested lands'"to .supply its water
needs, may .it adopt reasonable zoning regulations for the
conduct of forest operations on.those identified forested
lands which differ from Forest Practices Act regulations,
in order to protect its water supplies from the impact of
forest operations?
A: Counties may adopt rules, regulations, and ordinances
regulating forest operations on lands zoned for primary
uses other than the commercial growing and harvesting of
forest tree species. Counties may not adopt rules,
regulations, or ordinances regulating forest operations on
lands zoned primarily for the commercial growing and
harvesting of forest tree species.
No. 7895
1Q: Maya national bank having its charter address in Oregon
apply to its loans which correspond to the category of
loans regulated by the Consumer Finance Act, ORS ch 725,
the interest rates permitted by that Act, even though
those rates exceed the rate of interest permitted by ORS
708.480, regulating bank interest rates?
A: Yes.
2Q: If the answer to the first question presented is yes, may
the Superintendent of Banks adopt regulations under ORS
706.555 permitting state banks to charge similar rates of .
interest?
A: Yes, provided the superintendent makes the affirmative
findings required by ORB 706.555(1) and (2) as a
prerequisite to action under that statute.
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I A JOHN L. IMI1H. S.cI'.,or.,-Monog.,
C-l.f .. ~On~For~st _
~ ~-~'<J:~counCil
. n r\" 'dt fly /?
tJ ffU@Ql1DgU@~~@u ~y .?~!880 It/j)
(e/t indu/triel (OUrlen J~4?
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SLUIHERn ORfGOn limBER InOUSTRIES ASSOCIBTlOn
2680 NORTH PACIFIC HIGHWAY · MEDFORD. OREGON 97501
PHONE (503) 773-5329
HOME (503) 772..430
l:'~
Vol. 1. No. 7
May 9. 1980
MULTNOMAH PLAN
TAKEN TO COURT
BY OBPC
The Oregon Business Planning Council has filed suit in circuit
court against the Multnomah County Land Use Plan. The suit
challenges the county's failure to comply with H.B. 3008
(ORS 527.722) which was introduced at the request of Associated
Oregon Industries in the 1979 Legislature.
The county has overlayed their county plan with a Significant
Environmental Concern zone. Within this zone county permits are
required before logging or other forest operations may take place.
The purpose of H.B. 3008 was to clearly identify the Oregon
Forest Practices Act as the statutes regulating forest operations.
, The requirement of county permits for forest operations violates
H.B. 3008.
The action is an appeal of a ruling by the Land Conservation and
Development Commission upholding the county permit reGuirement in
connection with the Multnomah County comprehensive plan.
The suit seeks to overturn the LCDC decision and require Multnomah
County to revise the portion of its plan dealing with the overlay
zone.
AG'S OPINION
SUPPORTS 3008
On April 28 Attorney General Jim Brown issued an opinion on H.B. 3008
clarifying whether counties may adopt zoning regulations in land
use plans for forest operations on forested lands which differ from
state Forest Practices Act regulations in order to protect water
quality from the impact of forest operations.
rl, The attorney general stated that the counties may not adopt rules.
.Ji I jl~ tin t~ regulati~ns,.or ordinances regu~ating f~rest operation~ on lands
f{~_I_, _( 1 I zon. ed prlmarlly for the com~erclal growlng and harvestlng of forest
!f 4AJX-!J.~" 0 - tree speci es. However. counti es may estab 1 i sh regul ations fori
. ,\) L.lL. t forest operations on l~nds zoned for ~rimary us~s other than
'l . -. .II J) Roy' forest management. Thl s allows countl es to deSl gnate 1 ands as'
tytW 0. /'\A!~I~ special use if they wish to sidestep H.B. 3008. This makes it
~~A,C:1~~JStv.O critical that the forest industry work with local planners to
~or- 'insure that forestry is one of the primary uses for forest lands.
P~~~~E~~ A 1979 law t~a~ ~im~lified.P~blic ~tility District :ormation has
FOREST TAXES prompted an lnltlatlve petltlon drlve to replace prlvate utilities
with PUO's in 14 Oregon counties. Backers believe that PUO's will
be able to provide electricity at a lower cost to ratepayers.
(more)
Tr-oe Or."on Forullnllus,r'" Council Is a division 01 Aascx:ia,ell Oregon Inlluslries. For more Inlormallon write: Oregon Foresllncualrl.. Council, P.O. Box 12518, Salem,
nr.n,," _ Q71/)Q or cell !>8/l.OO5O.n Salem or 227.5636 In Porllanll. Me,.rlal in lhis ,epoll may be ,eproducell wlthoul permiuion. Normal c;,edlla would ba epp'.c~laCl.
"'> .,~..~.~..........
118
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Exerpts from the Jacksor
County ~oning Ordinance
ana C~mprehensive PJ.an
3) Fire S~fety Guidelines for Rural Develooment:
A) Areas within a five (5) road mile radius of a responding fire sta-
tion, which are located within rural fire protection districts, need
only consider the items listed above in section 2 as guidelines.
B) The following fire safety guidelines shoUld be cOnsidered in all
rural areas:
i) Automated sprinkler systems for the roof and/or interior of
the structure should be considered.
\
ii) Roads and/or bridge access should be constructed to support a
gross ve'hicle weight of 50,000 pounds to accommodate heavy fire
fighting equipment.
f
iii) Bridge access shoUld be - constructed of nonflammable
materials.
iv) Lakes, ponds, streams, and swimming pools should be installed
with a six inch line equipped with a valve or pump to enable fire
equipment to draught off water.for fire fighting, if the equipment
cannot easily move within ten (10) feet of the water source.
v) Public use areas such as parks, recreation sites, and picnic
grounds should be designed to prevent fires which may start in
them from spreading to adj acent or nearby wilcla.nds or
developments.
C) Recommendations contained in the wildf ire section of the Jackson
County Comprehensive Plan and publications of the Northwest Int;eragency
Fire Prevention Group (available through the Planning Department),
should also be considered by those engaged in rural development
50S. ..:...---cxJ/~ . =f2r:mJOOGG
I 280.110 OF SPECIAL CONCERN: - --I
"- -
~reas of special concern may be recommended by the Planning Commission as deemed
necessary to provide consistent and specific policy direc~ion for land use
actions in specified areas of Jackson County. Upon approval by the Board of
County Commissioners, the maps and conditions specified in an ordinance creating
areas of special concern shall guide and direct staff and/or Hearings Councilor
Hearings Officer review of land development actions within such areas. Areas of
special concern shall be identified as such on the Jackson County Comprehensive
plan and Zoning Map by the letters (ASC) and an identification number referring
to the ordinance adopted by the Board of Commissioners which created the Ase may
also be indicated on the map.
179
C-l.g
1) Areas of special concern generally consist of the following:
,A) Areas where a distinction between the comprehensive plan designa-
tion and zoning designation is .necessary to accommodate a future
staging strategy for future land use actions, or to prevent conversion
of certain lands fram a resource to a nonresource use, shall be indi-
cated on the official plan and zonfng map with both plan and zoning
designations.
B) Areas
addressed by
the county.
of site plan
.
where specific policy concern (s) must be successfully
all applicants for a land. use action, prior to approval by
Such policies may be linked in addition to the impOsition
review requirements specified in Chapter 282.
C) Areas in. which planned unit development permits are required in
order to meet a specific concern identified by the Planning Commission.
D) Areas in which specific natural resource or environmental concern
must be addressed.
2) Areas of special concern .,shall be established only fOllowing public
hearings held pursuant to section 285.040.
3) Areas of special concern designated at the. time of adoption of this
ordinance, and the additional development criteria within each area are
listed as follows:
A) ASC-80-1: This area is located directly on Crater Lake
Highway 62, between Medford and the White City area, and for the
most part is committed to general commercial and light industrial
uses. Traffic volumes in this. area are high and access is
generally uncontrolled in many' areas. In addition to all other
development standards, development in this area shall also be con-
tingent upon the following:
i) The issuance of site plan reviews within this designated
area shall. be contingent upon the satisfactory arrangement
and development of . safe, adequate and efficient access to
Crater Lake Highway.
ii) When practical, Jackson County will provide technical
assistance in the development of an access management plan,
which may include creation of common access points, cul-de-
sacs, service roads, or other measures to improve traffic
safety.
180
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B) ASC-80-2: This area of special concern consists of the
Ashland Watershed.' The portion of the watershed designated ASe
., lies within the boundaries of the Rogue River National Forest.
The histor ic use of this land as a municipal watershed is w~ll
established and recognized.
The Ashland Watershed has been the subject of extensive study by
the Rogue Valley Council of Governments 208 Water Quali tv Study
and the USDA Forest Service. Water quality problems have occurred
over the past twenty-five years at Reeder Reservoir, primarily
from sedimentation. Since certain activities which take place in
a municipal watershed can have an adverse impact on that resource,
the county:
I
i) Recognizes domestic water supply production to be the
primary use of this land, and that other activities or uses
within the watershed are secondarY1 and,
ii) The county shall, to the extent of its legal authority,
provide for the protection of the Ashland Municipal Watershed
from uses which could impact the quality of. the water and
increase erosion.
280.120 STANDARDS FOR HOME OCCUPATIONS:
1) Purpose: To provide stand:;u-ds for rural or urban home occupations which
would permit the conduct of a part-time business for supplemental income
purposes. Heme occupations are limited to those uses which may be conducted
within a residential dwelling'(l)r garage in rural areas), without changing
the appearance or condition of the ..r esidence.
When a use is a home occupa t ton., 1 t means that the owner, lessee, or other
I
persons residing within the m~0115~J has a vested right to conduct the home
occupation without securing special permission to do so. However, such use
shall be Subject to all oonditio~s '~ntained in this section.
It is the intent of this section tc eliminate as home occupations, a1l uses
e~cept those that conform to the standards set forth in this sec~ion.
Custom and tradition are intentionally excluded as criteria.
The fo11owing criteria shall be used to determine if a proposed accessory
use qualifies as a home occupation.
A) In general, a home occupation is an accessory use so located and
conducted that the average neighbor, under normal circumstances, would
not be aware of its existence other than for a sign as permitted by
280.080.
, ...
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\.
D) Continue to monitor and work with the Department of
Environmental Quality and other appropriate agencies to designate
. alternative methods and systems for use in controlling water
pollution, including but not limited to: waste water recycling
plants and systems, solid waste disposal and recycling methods and
sites, sludge disposal and resource recovery methods and sites,
greywater treatment and reuse systems, and alternative septic.
systems.
E) Monitor the activities of, and provide input to, the local
decisions of the State Water Resources Department and the State
Water Policy Review Board, especially as they relate to the forth-
coming update of the Rogue Basin Water Plan scheduled for 1980.
F) Oppose the lowering of any water quality disCharge standards
into the riv~rs or streams within the county.
G) In cooperation with the Jackson County State Watermaster, and
well drillers/pump suppliers, develop a comprehensive, com-
puterized water well"lot survey to delineate groundwater availabi-
lity, quality, production and depletion rates on a Township,
Range, Section basis for determining the effects on such by land
development actions. Such data shoul.d be integrated into the
county's computer system for easy updating, storage and retrieval,
and should be utilized in environmental impact assessments
regarding water supply and quality. Seek out appropriate federal
and state grants to fund, or partially fund, such a project.
H) Investigate the feasibility of. establishing incentives to
encourage rehabilitation/Updating of old septic systems, which
might include tax credits, low interest loans, or some form of
credit system: and, explore the availability of existing programs
that could accomplish the above.
,%14~
/ 4 FJJi//RoV~-iElJ7Zj.L QU4UTY Cl.fl{.ciJr
FINDING:
Certain activities which take place in a minicipal watershed can have an adverse
impact on that resource. Such impacts include: mineral and aggregate
extractions: removal of any vegetation such as logging and fire break
construction: road construction and maintenance of roads in the watershed area,
including grading; use of chemicals such as herbicides, insecticides and fer-
tilizers in the watershed area. These uses not only affect the quality of the
water, but also increase the erosion 'of the soil and sediment load of t-..he
streams draining the area, resulting in increased sediment in, the Municipal
Watershed system.
Revised 9-10-80 by Board Order 1372-80
/
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72
\
POLICY: THE COUNTY SHALL, .'!'Q. ~ EXTENT Q!:. ~ LEGAL AUTHORITY,.-J
PROVIDE FOR THE PROTB:TION Q! l-roNICIPAL WATERSHEDS ~ ~ WHICH
COULD IMPACT ~ QUALITY Q! !!!! WATER ~ INCRFASE EROSION.
IMPLEMENTATION STRATEGY:
A) The county shall identify those areas which contribute to
water pollution and soil erosion.
B) The county may provide, if the need arises, for special pro-
tection of municipal watersheds, making such uses which may cause
erosion subject to a permit process.
C) The county may provide, if such a permit process is adopted,
for review in an appropriate public forum of the affected agency
and the land owner involved, and provide for an arbitration proce-
dure for settlements of disputes by persons of the proper tech-
nical capabilities.
5
FINDING:
Land resources, and in particu1ar, soils, support both domestic and natural
populations of flora and fauna... Since man is dependent upon the balanced rela-
tionship and proper functioning'of this resource to sustain his needs, the con-
servation of the county's seil .teSOULces and their inherent qualities is of
utmost concern to the continued -health, safety and well-being of county resi-
dents. Degradation of the soil resources of the county without consideration
for its environmental consequences may create public nuisances, is harmful to
both domestic and indigenous flura and fauna, and impairs uses of the land for
wildlife populations. Therefo~e,i:.he conservation, management and wise utiliza-
tion of the county's soil in a manner conducive to preserving its long-term
qua1ity is in the best interests of county residents. Of special concern are
manls activities as they relate to development actions affecting soil erosion
and sedimentation.
POLICY: SOIL EROSION AND SEDIMENTATION M:m. lli! UTILIZATION OF ~
SHALL BE CONSIDERED .m. ~ !!2! DEVEIDPMENT ACTIONS.
Revised 9-10-80 by Board Order 1372-80
.~-
18
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F) Complete cubic foot site class mapping for all forest
lands during the next comprehensive plan update, or when ade-
quate soils information becomes available.
G) Establish a procedure to allow for exception to the mini-
mum parcel size for the retention of a living area for the
retiring forest operator if the property is sold. This
exception may be granted once per conforming legal tax lot,
provided that such partitioning is reviewed by the Planning
Department for consistency with criteria relating to nonin-
terference.with forest management and harvesting practices on
adjacent land; fire prevention and suppression efforts;
county health and building standards; proximity to dedicated
public roads; keeping the parcel size as small as practical
to contain the dwellings and related uses, and at the same
time have minimal impact on . the harvest potential. of the
forest.
-'
JOPC<:r LLvuDs LLL/L{{}uT
Ja on County's forest lands pIovide amenities that are difficult to
measure in terms of dollars and cants. The attractive setting and
forest environment provide many recre'ational opportunities that serve to
attract both in-state and out-of-btate tourists to the area. Tourist
spending helps to strengthen the lacal economy by bringing in new
dollars. In addition to the scenic and recreational values of the
forest lands, forests serve to help..:.maintain local wildlife and fish
Populations. Maintaining such populations can also have a positive
effect on the local economy by attracting tourist trade directly related
to hunting and fishing.
Although the managing, growing and harvesting of timber will continue to
be the dominant use of Forest Resource lands, other recognized forest
uses may compete for primary o~ secondary importance in such areas.
Watershed protection can become a primary use of forest land where muni-
cipal water supplies are involved. Domestic livestock grazing, aquifer
recharge maintenance, wildlife habitat and recreation all share an
important position in the heirarchy of uses permitted within forest
lands.
.~_._.~ _..........~'...M~"_~.~_ ............_r.... ....__--
19
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r
State law allows agriculturalists to obtain certain real property tax
benefits by seeking the zone designation for Exclusive Farm Osee There.
are agricultural enclaves within Forest Resource lands. Owners of such ^
lands would benefit from tax, decreases provided through farm use
designations.
Federal and state legislation encourages grazing on forest lands.
Grazing of livestock within forest lands, particularly summer grazing at
higher elevations, is an established practice upon which local ranchers
depend. Ose of forest lands for grazing helps to prevent overgrazing on
lower elevation agricultural lands. .
POLICY I ACTIVITIES Q! FOREST LANDS SHOULD !! CARRIED ~ ~
~ BENEFIT OF FOREST PRODOCTION, DOMESTIC LlVES'roCK GRA:?;ING,
WATERSHED PROTE:TION ~ AQUIFER REX:HARGE MAINTENANCE, WILDLIFE
AND FISHERIES HABITAT, OPEN SPACE ~ SCENIC RESOURCES,
REX:REATION ~ CONTROLLED MINING..
IMPL>>!ENTATION STRATmIES I
A) Permit only those agricultural, recreational, residen-
tial, and min~ng uses which support or do not interfere
with Forest anqfor Woodland Resource management.
.B) Identify which lands within the general Forest Resource
area are predominantly ranching and agriCUltural, and provide
notice to these landowners regarding the zoning options
available. Land zoned Exclusive Farm Ose-3 (EFU-3) in a
forest land area shall maintain the same density. standard as
the p~~ de~ignation in which it is located.
C) Jo.reas of high scenic or recreational value should be
inventl"lcied and placed into a priority listing for reten-
tion ac; a public reso-urce. Methods and techniques for
scenic a."1d recreational land acquisition are addressed in
the general implementation element.
D) Forest practices within watersheds principally used
for municiPal water supply should be subject to environ-
mental . review procedures to assure protection of water
quality.
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~.",^,,,,,.',._.,_..
C-2
Ashland's Concerns re USFS
Interim Plan for the Ashland
Watershed
,.~
October 30, 1979
C-2 Ashland Concerns re
USFS Interim Plan
CONCERNS OF THE CITY OF ASHLAND
REGARDING THE
FOREST SERVICE INTERIM PLAN
This paper summarizes the concerns of the City of Ashland regarding the Forest
Service long-term objectives and Interim Plan for the Ashland watershed. The
Forest Service has requested "concurrence" by the City with the draft of the
Interim Plan which has been reviewed and previously commented on. However,
without certain revisions and additions to emphasize municipal water supply
as the number one priority and outlining certain aspects of the planning pro-
cess leading to the 1982.plan, we cannot concur in the Interim Plan.
Previously the City has attempted to come to agreement with the Forest Service
whenever possible. However, at this point, based on the Interim Plan and dis.-
cussions with the Forest Service, it appears to us that the Forest Service's
long-term objective in the watershed is to emphasize timber removal. This,
we believe, will seriously impair the municipal water supply values of the
watershed. We are also concerned that we are consistently reminded by the
Forest Service of past instances where we have "concurred" with management
activities recommended by the Forest Service that later resulted in major
problems. Consequently, we do not concur with the Interim Plan as drafted
to date and are concerned about the Forest Service's Ashland watershed man-
agement objectives related to municipal water supply.
Specifically, we have seven major areas of concern as summarized in the follow-
l.ng:
. Surface erosion: Much more emphasis is needed in the Interim Plan on
the phenomenon of surface erosion, particularly on the cut, ditch,
driving surface and fill areas of the road prism. The most important
conclusio~ in the Montgomery/Ashland watershed analysis was that this
process was very significant in the Ashland watershed, but it is hardly
mentioned in the Interim Plan. The Interim Plan should specify a pro-
gram to collect the needed surface erosion rate information and discuss
the relationships between road maintenance alternatives and surface
erosion of the road prism.
. Mineral entry: The Interim Plan should include a Forest Service recom-.
mendation that the watershed be withdrawn from mineral entry. The
Interim Plan should also summarize 1) the status of the applicable
mining laws, regulations and implementation success (particularly
involving mining claims and exploration) and 2) the process for
accomplishing mineral entry withdrawal of the watershed.
. Fire management: The Interim Plan as presently drafted presents a
biased discussion of fre, fire management and the alternatives for
controlling disease, insects and fire. The Interim Plan should present
an objective discussion of fire, insects arid disease, including their
roles in natural forest ecology and their implications to water quality.
C-2
Both the positive and negative aspects should be equally discussed.
Certain fuels management alternatives such as controlled burning should
at least be summarized.
. City involvement: A representative of the City of Ashland should be
included as an ex officio member of the interdisciplinary planning
team. Regular team meetings should be held to discuss the status of
planning for the watershed.
. The Interim Plan should briefly summarize the process and methodolo-
gies to be used in the preparation of the 1982 plan. Specifically,
the Ashland watershed should be treated as a seperate "Management
Area", and for each management activity considered, a full range of
alternatives, including those advocated by the City, should be pre-
sented and objectively analyzed.
. Impact analysis: The process and methodologies that the 1982 planning
process will utilize to analyze the environmental impacts, particularly
water quality, related to the management activities considered, should
be summarized in the Interim Plan since the Forest Service has men-
tioned the EIS as a major element of their planning process.
. Priorities and the 1982 plan: The Interim Plan should acknowledge that
the Interim Plan will be superceded in 1982 and specifically ensure
that the "Ashland Watershed Management Area Plan" will be the top
priority in the Rogue River National Forest plan development process.
BACKGROUND DISCUSSIONS
Surface Erosion
The 1977 JMM study concluded that over three-fourths of the sediment which
accumulated in Reeder Reservoir over a 22 year period resulted from surface
erosion due to road construction and maintenance, logging, and the Mt. Ashland
ski area. An additional man-caused contribution of approximately 10 percent
resulted from mass erosion. Based on the JMM watershed study and on the sub-
sequent years of exchanging ideas and information on the subject of erosion
with the Forest Service, it is still our conclusion that by far, the largest
percentage of sediments eventually deposited in Reeder Reservoir and subse-
quently released to Ashland Creek and Bear Creek, resulted from man-caused
disturbances. Specifically these include road construction, operation and
maintenance; logging; and ski area development.
The Forest Service expressed concern about the JMM erosion analysis method-
ology and consulted with their leading batholith erosion research specialist
who examined the Ashland batholith during a two day tour. His conclusions
are summarized as follows:
"ThUs, I would not hesitate to extrapolate the basic principles
found in the Idaho batholith to the Ashland watershed. However,
the physical properties of the two areas do vary somewhat, so I
would be reluctant to extrapolate erosion and sedimentation rates
directly from one area to the other without some on-site data for
verification."
...,.......--. ._...
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In effect, this statement c01ncides very well with the JMM description of
conclusionS/limitations. The primary difference is that from a research
standpoint, site specific research data to determine basic coefficients such
as erosion rates is a standard recommendation. JMM recognized that such data
would be desirable, but the options of increasing the funding level and
extending the time period of the study were not available.
Up until the last few years most of the concern about erosion of granitic
soils was focused on the construction of roads. Various research projects
have demonstrated conclusively that road construction, particularly during
the first 2 to 4 years after construction, results in very high rates of ero-
sion on the cut/fill and driving surfaces, and in the ditch. In discussing
this with Forest Service erosion specialists, it was found that current
research was examining r~ad maintenance as also a potentially major contri-
butor to erosion and sedimentation.
The early batholith erosion studies examined jammer roads which were con-
structed and used for a few years and then no longer used or maintained.
This was one of the primary reasons for the return of post construction
erosion rates to near natural levels after a few years. It was found that
this resulted from "armoring" of the road prism, of the removal of the fine
grain soils with the coarse material remaining. Such an armored condition
is the anti thesis of a "good" road surface and road blading and maintenance
operations are intended to resurface and reshape by replacing the fine grained
particles which have been lost. The likely results of road grading was dis-
cussed with various erosion specialists, and it was concluded that the pro-
cess, although understood qualitatively but not very'well quantitatively,
should be integrated into the JMM erosion model. This was done by adjusting
post construction erosion rates. The resulting contribution was a major
factor in the JMM erosion budget, which coincided reasonably well with the
larger estimates of material deposited irrReeder Reservoir during the 22 year
period examined.
It was JMM's conclusion in 1977 and it is still our conslusion that one of
the highest contributors of eroded sedim~nt in the Ashland watershed is the
annual maintenance or blading of the r04d system. Since maintenance is
required if any major activities such as logging 'occur in the watershed, JMM
recommended that as much of the road system as possible be put to bed and that
access, particularly involving motorized vehicles, be held to an absolute
minimum. In view of this and the other associated problems, logging or any
activity which requires road use does not appear to be appropriate if the
municipal water supply values of the Ashland watershed are to be maintained.
The Interim Plan, however, includes a full 0 & M program for the roads.
Concerning surface erosion on other parts of the road prism, it appears that
an additional process may be operating. Current research indicates that very
high surface erosion rates are probably occurring on the cut surface of the
road prism. In the JMM erosion budgeting, it was assumed that the cut sur-
face would return to near natural rates a few years after construction. If
this is not the case, and if the rates which appear to be occurring on the
cut surface are applied, the 1977 estimate of erosion over the 22 year period
would be even closer to the estimates of sediment removed over that period
from Reeder Reservoir.
C-2
The implication of this would be that not only is the construction of roads
and the maintenance of the road surface on batholith soils extremely proble-
matical from an erosion standpoint, but also the existence of the fill surface.
For watersheds and streams where sediment movement and downstream deposition
must be minimized or avoided, this would mean that very little, if any,
disturbance of the watershed involving roads could be tolerated.
Based on the Montgomery analysis of erosion in the watershed and all of the
other information sources concerning erosion of granitic soils, the most
important existing and potential problem in the Ashland watershed is, in our
opinion, surface erosion of the varius parts of the road prism. The phenome-
non is significantly increased by the blading of the road surface and ditch
area. The conclusion that this relationship exists in the Ashland watershed
conforms to processes found to operate on other granitic, batholith soils.
The assumption of such relationships is also the only way to account for the
large volume of material which was deposited historically in Reeder Reservoir.
Concerning specific provisions of the Interim Plan, it is noted that the
Forest Service assumes that with a "natural disaster" new roads might be
constructed. Since the watershed is relatively small, and helicopter or
vehicle access is possible in all portions of the watershed, it is doubtful
that such new roads would have any value during or immediately after a fire
and could only be expected, if planned and constructed on a rush basis, to
complicate the problems of water supply for the City of Ashland. The Forest
Service Interim Plan states that grading season controls will be in effect,
however, it is not stated how often grading is envisioned between now and
1982 when the fully developp.d plan is produced.
It is disturbing that the Forest Service in its Interim Plan deals with sur-
face erosion, particularly of the road prism and the implications regarding
maintenance of the roads, in such a cavalier fashion. The processes are
mentioned along with a literature search and an erosion study of the Ashland
ski area. However, the type of reser-Tch Te~omrnended by Dr. Megahan has appar-
ently not been initiated and is not included as part of the planned research
in the Interim Plan. In addition, an evaluation of listing of issues empha-
sizes numerous aspects of watershed concern; including some "straw-man"
issues such as minimizing wildlife production, but does not deal in any
detail with the issues related to surface erosion of the road prism, 0 & M
of the roads and-surface erosion of the ski area.
In summary, the entire concept of road maintenance as a potential problem was
glossed over in the Interim Plan. This aspect needs to be emphasized in the
discussion of issues and the subject of a major research and planning effort.
Before the City could agree to consider any kind of major surface-disturbing
activity within the watershed, the research should be completed and the results
integrated into the planning.
MINING
The Forest Service's refusal to withdraw the watershed from mineral entry is
particularly disturbing in view of the low to non-existent mining potential
and the extremely high potential for damage which could result from mineral
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exploration (which the Forest Service has little, if any, effective control
over). The City objects to this, particularly in view of the reason stated
in a March 27, 1979 Forest Service memo.
"The City of Ashland would prefer to have the Ashland Watershed
withdrawn from mineral entry so as to prevent possible contami-
nation of the water supply due to mining activity. Historically,
there has not been much mining within the watershed, nor is there
much anticipated. The Forest Service, while recognizing that a
withdrawal of Ashland Watershed from mineral entry may have little
impact on the mining in this area, are concerned that withdrawal
of a watershed per se to preserve a watershed's water quality
would have tremendous effects on the mining industry nationwide."
This confirms the suspicion that, for the Forest Service, municipal water
supply is below mining in priority, even when there is no significant poten-
tial for mining.
FIRE MANAGEMENT
There seems to be some confusion about our concern and recommendations related
to fire management in the watershed, so these are briefly summarized.
1. The history of fires and fire management in the Rogue Valley indicates
that the major problem fires were man-caused and that natural fires
were generally suppressed in a short time.
2. There is a large potential for increased erosion due to an intense fire
in the watershed. - However, there is also research information available
that demonstrates that willlfire through unlogged watersheds can result
in significantly less erosion and sediment movement than wi1d~_
through a logged watershed.~
3. We believe that high levels of human activity such as that associated
with logging or extensive over-night camping could be expected to
increase the likelihood ~f ~ large problem fire.
4. We recommend that fire management involving intensive observation and
quick response in suppressing all fi.;.'es was the most appropriate program
for the Ashland watershed.
s. We have concluded that, although the removal of fuel from the watershed
would present certain benefits, the extensive logging activities required
to do this effectively would present far more hazards and potential for
loss than for benefit. However, we are open to other methods of fuels
management, such as controlled burning. .
6. One of the most important deficiencies of the Interim Plan is the absence
of an objective discussion of all aspects of fire and fire management,
particularly as they apply to the municipal water values of the water-
shed. The discussions included are very one-sided.
....,._,.~---.
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CITY INVOLVEMENT
The City has always been unsure as to its role in determining the future of
the Ashland watershed relative to Forest Service planning and management
activities. In discussing this with the Forest Supervisor, it is apparent'
that the City is viewed as merely one special interest facet in a multi-faceted
public sector. It is also apparent that the Forest Supervisor considers his
authority to adopt plans and carry out management activities as a unilateral
function unless a specific appeal is made by an affected party. The City
recognizes and encourages planning and management activities that allow the
fullest possible extent of public involvement, but as the recipient of any
sedimentation burdens which mistakes in Forest Service management create, it
is our opinion that we have far more than a normal public interest in the
decisions made.
In discussing the problem of City involvement and role in the planning process,
it appears to us that a City representative could be an ex-officio member of
the interdisciplinary planning team and meet regularly with the technical
planning group as it proceeds through the preparation of the 1982 plan. We
feel that such involvement is the minimum good faith gesture by the Forest
Service to involve the City in its planning for the Ashland watershed.
PLANNING PROCESS
The Forest Supervisor has informed City representatives that the Ashland water-
shed can be treated as a separate "Management Area" in the development of the
Rogue River National Forest Plan. This we enthusiastically support since we
believe the problems within the Ashland watershed require planning with a
different type of emphasis than the rest of the forest.
We are also concerned that the Interim Plan tends to focus on a few major
directions for each type of use and then emphasizes those limited objectives
in terms of the background information and analysis presented. It is our
opinion that a sound planning process treats a full range of alternatives
for each use seriously considered for the resources involved. For example,
road maintenance should CV!ls..lut:r in a fair and impartial manner a full range
of low-to no-maintenance alternatives as well as the more intensive 0& M
alternatives preferred by the Forest Service. This was not done in the
Interim Plan, and we believe that at least the framework describing suCh
alternatives should be included.
IMPACT ANALYSIS
In discussing the Interim Plan with the Forest Supervisor, a high importance
was assigned to the environmental impact statement process which will accom-
pany the 1982 plan. We encourage such an impact analysis based on the best
methodologies and research information available. We urge the Forest Service
to not gloss over surface erosion as they have done in' the past. We recommend
that the Interim Plan should contain at least an outline of the general analy-
sis methodologies to be used in the assessment of impacts and a description of
the categories of impact which will be emphasized.
......,........'''.."--.-
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PRIORITIES
The City believes that the Forest Service should clearly indicate that the
Ashland watershed will be the top priority in its planning process leading
to the 1982 plan. The City also encourages the Forest Service to acknow-
ledge that the Interim Plan would be superceded in 1982 and that management
activities will be held to an absolute minimum in the watershed until the
adoption of the 1982 plan.
CHANNEL EROSION
The Forest Service also expressed concern that the Montgomery analysis did
not include channel erosion. It is our opinion that channel erosion, while
undoubted~y occurring co~stantly in the Ashland watershed, is primarily an
intermediate process involving the movement of sediment eroded in the
watershed proper, particularly from areas of man-caused disturbances, to
some downstream location such as Reeder Reservoir. There are methods
whereby the channel erosion phenomenon can be better understood and these
should be explored. However we suspect, based on field inspection, that the
volume of material eroded from the channel after long-term residence in the
channel will be very low and that most of the channel material eroded will
have been at its last location for less than 10 years.
FurURE RESEARCH
The following research should be initiated on the Ashland watershed, and
the "Interim Plan" should specify the process to be pursued in implementing
such a program:
1. Surface erosion rates for the:
a. Road cut surface incl~ding the ditch.
b. Driving surface including the relationship to the ditch.
c. Road fill surface.
d. Ashland ski area.
e. Undisturbed areas.
2. Continual monitoring of mass failure areas.
3. Channel erosion using capacity, aggradation, degradation methods
as developed and used by Dr. William W. Emmett of the U. S. Geo-
logical Survey.
4. Monitoring of the stream system just above the reservoir for
. suspended solids
. turbi di ty
. bedload
5. Monitoring of total organic carbon at various locations in the
watershed and reservoir (for the purpose of determining trihalo-
methane potential).
C-3
Statements of Allen A. Alsing,
Director of Public Works for the
City of Ashland; and Tom Davis,
Montgomery Engineers, re Reeder
Reservoir DEIS
Al AIsing's statement
to EPA re Reeder
Reservoir EIS
Stateoent of Allen A. Alsing, Director of Public Works, City of Ashland
at the Augu~t 23, 1979, public hearing concerning the draft EIS on Reeder
Reservoir maintenance operations.
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My name is Al Alsing and I'm the Public Works Director for the City of
Ashland. This statement presents the City's position concerning the
operation and maintenance of Reeder Reservoir, the management of the
Ashland l~atershed and the general future of Bear Creek. I appreciate
the opportunity to present our views at this hearing. As part of the
City's testimony, Mr. H. Tom Davis, Supervising Engineer for MontgoIDery
Engineers, ~~ll present a statement which we ask to be included in the
hearing record.
It is the City of Ashland's position that any EPA recommendation at this
time promoting dredging over sluicing of Reeder Reservoir would be prema-
ture. We feel strongly that continuation of the City's present approach
to cleaning the Reservoir utilizing draw-down and sluicing in the early
spring during high snow-pack years is the most reasonable alternative given
our present knowledge. It is our opinion that our current program should
be continued until more is known about the future erosion of the Ashland
watershed; the hydrology and sediment movement characteristics of Ashland
Creek and Bear Creek; the relationships between potential sediment reductions
and fisheries associated with the various alternatives; and the relative im-
pacts 0: other sources of Bear Creek water quality and fishery problems such
as agriculture, construction, and industrial runoff. We believe the draft
EIS supports this position. We believe that the emphasis should be on main-
taining and restoring the Ashland watershed and on examining Bear Creek in
a cOiuprehensive manner followed by non-point source controls applied equitably
to each source. If EPA wants to do the maximum they can to reduce the Reeder
Reservoir impact on Bear Creek fisheries, we suggest that they join the City
of Ashland and Rogue Valley Council of Governments in encouraging the Forest
Service to solve the eyisting watershed problems and to not create new ones.
I would now like to expand briefly on the question of dredging versus
sluicing in the spring as alternatives for maintaining the Ashland water
supply facilities. As stated in the "Summary" of the draft EIS, very little
is known about the fisheries benefit associated with the dredging versus
spring sluicing alternatives. In the surmnary it is stated that "dredging
has the greatest potential for reducing the severity of water quality viola-
tions" and goes on to point out. that "sincE: quantification of sediment move-
ment is beyond the scope.of this DEIS, the degree to which these differences
would benefit or adversely affect the fisheries is unknown". As states on
page 25 of the DEIS, Ashland Creek does not stand'alone as a contributor
of sediment to the. Bear Creek Syste~. Neil Creek also conta~ns granitic soils.
On page 45 of the DEIS, referring to data collected during the study, it is
stated that "Neil Creek, which drains part of the eastern slope of the' Ashland
stock batholith, may contribute significant amounts of fine granitic sediment
to Bear Creek." Furthermore, the hyd~ology of the Bear Creek/Ashland Creek
systems is inadequately understood at the present time to assess the movement
and impact of sediments. As the DEIS states "thus the hydrologic information
'. --.,.,...._..____. ....___. __.._.... _'_'_'_"_'_m"_.~_._",.,_,...~~
, ,.~",.~C."", ........
C-3.a
necessary to estimate a relationship between stream flow and sediment
volumes is lacking" (p. 54).
We would also like to point out that the DEIS states under the dredging
alternative that the dredging would be carried out at times of high stream
flow. It should be noted that high water is not defined in the DEIS and
during most years the highest flows are in the spring of the year when
normal sluicing operations take place. It seems unreasonable to expend
extra monies for purchase, operation, and maintenance of a dredg~ to be
used, for the most part, at a time of year when sluicing is normally done.
In view of the above, it would seem very inappropriate to us for EPA to recommend
the high cost dredging alternative, particularly when our experience has indicated
major problems with dredging. At some point, when the contribution from other
sources is understood relative to the contribution from Ashland Creek it may be
that a dredge would be worth the effort. However, at the present time we do
not believe that this is the case. We feel that the draft EIS substantiates
this.
We do not mean to give the impression that we gloss over the importance of
reducing Ashland Creek sediment contribution to the Bear Cree~ system,
for just the opposite is true. We simply don't want to be forced into
being the first to take action when that action involves high cost methods
of doubtful benefit. In that light we suggest that the EPA, Oregon Depart-
ment of Environmental Quality, the Rogue Valley Council of Governments and
its local participants continue to devel~p an understanding of all Bear Creek
nonpoint sources of water pollution. At the same time ~e urge that progress
be made on developing comprehensive programs of non-point source control and
we understand that this has been started.
One thing which cannot be overemphasized is the need for continued stream
flow and sediment mcvement monitoring in Ashland Creek and Neil Creek. In
addition, more Ashland watershed research is needed concerning the role of
channel erosion, which we believe to be minimal in the Ashland watershed.
One of the most ililportant needs is for Ashland field data concerning surface
erosion rates in'the various pprtionsQf the road prism, the logged areas-
and the Ashland ski area.
It seems clear that road construction/maintenance and logging in the Ashland
watershed are the sources of the Reeder Reservoir sediment releases. Weare
unaware of any EPA pressure being exerted on the Forest Service to remedy
past mistakes and avoid future ones. To the contrary it seems that the
City of Ashland and the Rogue Valley Council of Governments have been left
somewhat alone to challenge a major federal agency to do what is needed in
the watershed. To date our working relationship with the Forest Service
has been good but our success in getting needed management decisions has
been very limited. The Forest Service seems to be changing direction in
their current planning on the minor points but changing very little on the
major points. For example, it was pointed out in a March 27, 1979, memor-
andum from James B. Wolf, Range, Wildlife and Watershed staff member to the
Forest Supervisor, Rogue Valley National Forest that there are certain areas
of agreement and nonagreement between the Forest Service and the City. Areas
of agreement can be summarized as follows:
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.. ~,-,,-...............~-"
--,:""...~........"'~'.'~~"".'.,..c..",,..=
C-3.a
1. No grazing within the watershed.
2. No expansion of the Ashland ski area without a DEIS.
3. Recreation activities such as skiing, fishing, hunting and hiking
would continue under present constraints with no ORV use or over-
night camping.
4. Fire protection practices wcu1d continue.
5. Minimal road maintenance of certain roads.
6. Certain types of restoration for the road system.
7. Fuel break construction of selected breaks.
It is pointed out that these are somewhat minor concessions. On the
other hand the areas of nonagreement, which are summarized as follows,
represent the major factors contributing to the degradation of the Ashland
watershed, the interference with the City of Ashland's water supply system
and eventual impairment of downstream fisheries habitat, irrigation facil-
ities and recreation potential.
1. The City's position is that logging should be eliminated from
the watershed and the Forest Service "has not agreed to this
approach to managing the watershed".
2. The City does not agree with salvage and sanitation logging
and the Forest Service continues to discuss this as an alternative.
3. It is the City's position that no more roads should be built
within the watershed and most of the current roads should be
"put to bed" except for minimal custodial and fire protection
uses. We feel that the available information and analyses
support this position. The Forest Service states that "this
option should be kept open".
4. The City has strongly recollill1ended that the watershed be withdrroyu
from mineral entry in view of the enormous impact that even mini-
mal exploration activities could have on our facilities and the
do\v.nstream waters. The Forest Service acknowledges that littles
if any, mineral potential exists in the watershed but states that
"the Forest Service while recognizing that a withdrawal of Ashland
watershed per se to preserve a watershed's water quality would
have tremendous effects on the mining industry nationwide".
5. There is some disagreement between the Forest Service and the
City concerning the type of fire management necessary for the
watershed. We feel that our approach of minimizing human
activities within the watershed and maximizing fire obser-
vation and quick control is not only the most logical but
backed up by the history of fires within the Rogue River area.
In summary, it is the City of Ashland's opinion that we are presentiy
operating on a program which represents the most cost effective and en-
vironmentally sound solution to the City's water supply problems and the
problems with downstream fisheries, water quality, irrigation systems .
and recreation. We do not disagree with the contention that much needs
to be done in the Bear Creek basin to restore and enhance the water resource
values which have been lost. However~we feel that before a capital and
energy intensive program is recommended, definite progress should be made
-3-
C-3.a
in 1) knowing that a comprehensive coqtrol program can result in the desired
benefits and 2) that the other needed control elements, particularly in-
volving nonpoint sources, will also be implemented. We don't mind doing our
part, but we don't want to spend money foolishly ')r embark on costly programs
of questionable merit.
Again, let me thank you for the opportunity to present the City's position
concerning the operation of Reeder Reservoir.
-4-
, ............;,'.'.~',....__. ,_ """_.,*"'"..w..._._.,_'",_ "..~_. .'"____..+-
C-3.b Torn Davis's statement to
EPA re Reeder Reservoir EIS
. JAMES M, MONTGOMERY , CONSULTING ENGINEERS, INC., 7000 S.W. Hampton Street, Suite 215, Portland, Oregon 97223 (503)620'9053
Statement of H. Tom Davis, Supervising Engineer, Montgomery Engineers,
for the City of Ashland concerning the Draft Environmental Impact
Statement on Reeder Reservoir Operation and Maintenance.
I'd like to briefly describe certain aspects of our 1977 report and sub-
sequent work with the City of Ashland as related to the draft EIS and
the relationships between Bear Creek, the Ashland watershed and Reeder
Reservoir. I believe the draft EIS adequately dealt with the full range
of alternatives for removing sediment from Reeder Reservoir. My presenta-
tion will cover six general topics including 1) existing problems and the
future of Bear Creek, 2) streamflow and sediment relationships in the Ash-
land/Bear Creek systems, 3) logging in the Ashland watershed, 4) road
maintenance in the Ashland watershed, 5) surface erosion and 6) fire
management.
EXISTING PROBLEMS AND THE FUTURE OF BEAR CREEK
I believe the draft EIS did a good job of pointing out that there are numerous
sources of Bear Creek sediment, turbidity, bacteria and nutrients. The
discussions and analyses concerning the fishery and stream gravels on pages
39 through 47 is well worth reading as background for planning future waste-
water management programs in the basin. As was mentioned in this portion of
the draft EIS, timber harvesting, roads, reservoir operations, agricultural
practices, gravel mining, urbanization, domestic and industrial wastewater,
and numerous other developments have resulted in detrimental changes in
Bear Creek's temperature, hydrologic and nutrient regimes; and increased the
input of sediment, bacteria, warm water predaceous fish and turbidity caused
by fine colloidal suspensions. In addition, as the draft EIS points out,
much of the stream habitat has been directly destroyed, various migration
barriers are in the stream, flows are often inadequate and vegetation en-
croachment on the channel has become more pronounced primarily because of
the managed flow regime. In addition, as is pointed out on page 31, the
water quality standards for coliform bacteria and nutrients are insufficient
to protect the beneficial uses of the stream from point sources.
To complicate the Bear Creek situation, many of the most important sources
of pollution are nonpoint in nature. Thus any solution will have to deal
with complex physical interrelationshjps and probably involve high levels
of public education, extensive best management practices and non traditional
wastewater management techniques. All of these can be accomplished but
often require more time to develop. come to agreement on and implement.
The reason for bringing this out is to emphasize what Al Alsing has stated
previously, that a capital intensive program for Reeder Reservoir, which
may not even bring about significant benefits, would be inadvisable at this
time until additional progress is made on some of the other pollution con-
trol and research programs needed in Bear Creek basinr In spite of the
complexity of problems, Bear Creek can be restored and enhanced for both
fisheries and recreation, provided that the steps taken are justified and
the early programs demonstrate more success than failure.
~.."".__..<
C-3.b
JAMES M. MONTGOMERY, CONSULTING ENGINEERS, INC., 7000 S.W. Hampton Street, Suite 215, Portland, Oregon 97223 (503)620-9053
STREAMFLOW AND SEDIMENT RELATIONSHIPS IN
THE ASHLAND/BEAR CREEK SYSTEMS
As it is pointed out on pages 47 through 54 of the draft EIS, the 1974
flood hydrology is not well understood. As evidence to this, recent esti-
mates concerning recurrence intervals for that event have ranged from 30
years to 800 years. It is very likely that the two extremes in this
range are both incorrect. Certainly the 800 year recurrence interval is
not in line with the City's observations concerning Ashland Creek flooding
and the DEIS recognizes this on page 51. The authors acknowledge that an
understanding of the Ashland Creek hydrology, particularly involving flood
frequencies, is necessary to understand sediment volumes, movement and
deposition. However the limitations to realize this for Ashalnd Creek is
recognized and it is concluded that "the hydrologic information necessary
to estimate a relationship between stream flow and sediment volumes is
lacking". To compound the difficulty, the relationships between downstream
sedimentation originating in the Ashland watershed, and the Bear Creek
fisheries is also presently unknown.
In view of these unknowns, which are well pointed out in the draft EIS,
it would not seem prudent for the City of Ashland to commit to a dredging
program which they are reluctant to undertake because of economic and
o & M considerations. Although our 1977 repor~ recommended dredging, the
major reasons were to conserve water storage in the Ashland municipal
water system and give fishery protection the bpnefit of any doubt. Given
Ashland's understandable reservations about a dredging program, and the high
degree of uncertainity concerning fishery benefits which was brought out
in the EIS it seems inadvisable to us for Ash 1 and to implement such a pro-
gram. At least not until the storage needs and fishery benefits become
far more evident than they are today.
~.. .....:"'.
LOGGING AND ROAI1:,SJNSTRUCTION
IN THE ASHLANIl.JJiATERSHED
We concluded in 1977 that over three-fourths of the sediment in Reeder
Reservoir, which eventually had to be rt:leased into Ashland Creek, resulted
from road construction and maintenance, logging and the Mt. Ashland ski
area. During the last 2 to 3 years.r,..we ,have exchanged information and ob-
servations with both the forest administration and research divisions of
the Forest Service concerning the Ashland watershed. They have examined
and critiqued our evaluation and we have examined and critiqued their's.
Based on our original watershed study and on the subsequent years of ex-
changing ideas and information on the subject of erosion, it is still our
conclusion that by far, the largest percentage of sediments whicll eventually
were deposited in Reeder Reservoir and subsequently released to Ashland
Creek and Bear Creek, resulted from man-caused disturbances. Specifically
these included road construction, operation and maintenance; logging and
ski area development. If this is the case, and we believe it to be,
Reeder Reservoir is no more than a "middle man" in the process of watershed
erosion and Bear Creek sedimentation.
C-3.b
JAMES M. MONTGOMERY , CONSULTING ENGINEERS, INC., 7000 S.W. Hampton Street, Suite 215, Portland, Oregon 97223 (503)620-9053
As pointed out on page 55 of the draft EIS, the Forest Service has expressed
it concern about our erosion analysis methodology, This methodology is
discussed in Attachment A. After expressing that concern the Forest
Service consulted with their leading batholith erosion research specialist
who examined the Ashland batholith during a two day tour. His conclusions
ar~ summarized as follows:
"Thus, I would not hesitate to extrapolate the basic principles
found in the Idaho batholith to the Ashland watershed. However,
the physical properties of the two areas do vary somewhat, so I
would be reluctant to extrapolate erosion and sedimentation rates
directly from one area to the other without some on-site data for
verification,"
In effect this statement coincides very well with our description of the
results and limitations of our 1977 analysis. The primary difference is
that from a research standpoint, site specific research data to determine
basic coefficients such as erosion rates is a standard recommendation. In
our case we recognized that such data would be desirable, but, the option
of increasing the funding level and extending the time period of the study,
both of which would have been required to obtain such information, were not
options open to us.
The Forest Service also expressed concern that the Montgomery analysis
did not include channel erosion. It is our opinion that channel erosion,
while undoubtedly occuring constantly in the Ashland watershed, is primarily
an intermediate process involving the movement of sediment eroded in the
watershed proper, particularly from areas of man-caused disturbance, to
some downstream location such as Reeder Reservoir. There are methods where-
by the channel erosionphenomonon can be better understood and these should
be explored. However we suspect, based on field inspection, that the volume
of material eroded from the channel a.fter long term residence in the
channel will be very low and that most of the channel material eroded will
have been its last location for less than 5 years.
ROAD MAINTENANCE
Up until the last few ye~rs most of the concern about erosion of granitic
soils was focused on the~onstruction of roads. Various research projects
have demonstrated conclusively that road construction, particularly during
the first 2 to 4 years after construction, results in very high rates of
erosion on the cut/fill and road surfaces, and in the ditch. In discussing
this with the Forest Service erosion specialists we found that current
research was examining road maintenance as a potentially major contributor
to erosion and sedimentation. .
The early batholith erosion studies examined jammer roads which were
constructed and used for a few years and then no longer used or maintained.
This was one of the primary reasons for this return of post construction
erosion rates to near natural levels after a few years. It was found that
this resulted from "armoring" of the road prism, or the removal of
the fine grain material. Such an armored condition is the antithesis of
c- 3 . b
JAMES M, MONTGOMERY . CONSULTING ENGINEERS. INC.. 7000 S,W. Hampton Street, Suite 215, Portland, Oregon 97223 (503)620-9053
a "good" road surface and road blading and maintenance operations are
specifically intended to resurface and reshape by replacing the fine
grained particles which have been lost. We discussed the likely results
of road grading with various erosion specialists and concluded that the
process, although understood qualitatively but not very well quantitavely,
should be integrated into our erosion model. This was done by adjusting
pos't construction erosion. rates and was a major factor in our erosion
budget which coincided reasonably well with the larger estimates of
material deposited in Reeder Reservoir during the 22 year period examined.
It was our conclusion in 1977 and it is still our conclusion that one of
the highest contributors of eroded sediment in the Ashland watershed is
the annual maintenance or blading of the road system. Since maintenance
is required if any major activities such as logging occur in the watershed
we recommeded that as much of the road system as possible be put to bed
and that access, particularly involving motorized vehicles, be held to an
absolute minimum. In view of this and the other associated problems,
logging does not appear to be an appropriate use if the municipal water
supply values of the Ashland watershed are to be maintained.
SURFACE EROSION
Concerning surface erOS1on of the road prism, we believe that an additional
process may be ope~ating. We find that current research indicates that
very high surface erosion ,rates ar~ probably occurring on the cut surface
of the road prism. In our erosion budgeting we assumed that the cut
surface would return to near natural rates after a few years. If this is
not the case, and if the rates which appear to be occurring are applied,
our 1977 estimate of erosion over the 22 year period would be very close
to the estimates of sediment volume removed over that period from Reeder
Reservoir.
The implication of this would be that not only is the construction of roads
and the maintenance of the road surface on batholith soils extremely
problematical from an erosion standpoint, but also the existence of the
fill surface. For watersheds and streams where sediment movement and
downstream deposition must be minimized or avoided, this would mean that
very little, if any, disturbance of the watershed could be tolerated.
FIRE MANAGEMENT
There seems to be some confusion about our conclusions and recommendations
concerning fire management in the watershed, so I would like to briefly
summarize those conclusions.
1. The history of fires and fire management in the Rogue Valley indicates
that the major problem fires were man-caused and that natural fires
were generally suppressed in a short time.
2. There is a large potential for increased erosion due to an intense
fire in the watershed. However there is research infonnation available
'"~~~-
C-3.b
JAMES M. MONTGOMERY , CONSULTING ENGINEERS, INC., 7000 S.W. Hampton Street, Suite 215, Portland, Oregon 97223 (503)620-9053
that demonstrates that wildfire through unlogged watersheds can
result in significantly less erosion and sediment movement than
wildfire through a logged watershed.
3. We concluded that high levels of human activity such as that associated
with logging or extensive over-night camping could be expected to
increase the likelihood of a large problem fire.
4. We recommended that fire management involving intensive observation
and quick response in suppressing all fires was the most appropriate
program for the Ashland watershed.
5. We also concluded that, although the removal of fuel from the watershed
would present certain benefits the extensive logging activities required
to do this effectively would present far more hazards and potential
for loss than for benefit.
In summary, it is our conclusion that the Ashland watershed is extremely
sensitive to any man-caused disturbance. We are confident that if the
needed research on surface erosion rates, sediment transport and channel
erosion is done and another erosion budget performed, that the general
conclusions we made in 1977 would be found to be correct. The construction,
maintenance and even existence of roads in a watershed such as the Ashland
watershed is incompatible with keeping downstream sedimentation to a minimum.
There may be ways of-removing some timber from such a watershed without
risking high increases::in downstream sedimentation but even these should be
viewed very cautiuusly. If downstream fisheries or municipal water facilities
are involved such timber removal should be attempted only if it can be
accomplished with fewJ or preferably no, roads.
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.JAMES M. MONTGOMERY . CONSULTING ENGINEERS. INC.. 7000 S.W. Hampton Street, Suite 215, Portland, Oregon 97223 (503)620-9053
ATTACHMENT A - MONTGOMERY EROSION ANALYSIS
For the purposes of our watershed evaluation, we developed a methodology
which can generally be described as an erosion budgeting. We simple
catagorized various aspects of watershed conditions in a way that allowed
us to assign erosion rates for each category. To a large degree the
catagorization depended upon the type of surface erosion rate data that
was available. We were familiar with the very high erosion experi-
enced in the extensive Idaho batholith. 'We were also aware that most of
the erosion research on batholith soils had been done at the Inter-
mountain Forest and Range Experiment Station of the U. S. Forest Service
in Boise. Ironically, ~he soil scientist who classified most of the Idaho
batholith also classified the Ashland batholith. Based on information
and conclusions supplied by our soils consultant, Earth Sciences, Inc.,
and on discussions with erosion specialists of the Intermountain Research
Station, we concluded that while certain differences in soil characteristics
and meteorology existed, the two batholith formations could be expected
to involve similar erosion processes. Thus we concluded that in spite of
the minor differences, and in view of the lack of any Ashland batholith
surface erosion data, the research information collected on the Idaho
batholith concerning surface erosion would be generally applicable to the
Ashland batholith.
In reviewing the Forest Service's analysis of Ashland watershed erosion,
we found that they had concentrated their efforts on the phenomenon of
mass erosion (or landslide-type events). They"had estimated the volumes
of material eroded based on the volume.'of eroded depressions observed in
the field. We reviewed their work and concluded that for the mass erosion
which had occurred in the watershed, th~ FOFest Service had done an ~xcellent
job . However, we were concerned that surfac,;) erosion, which had played
such a major role on other batholith formations, was not considered. We
concluded that in our analysis we would estimate the oyerall contribution
of the various man-caused and natural proce~ses, including surface erosion,
using a modeling or budgetting technique. However to do so we had to have
surface erosion multipliers to complement.the Forest Service's estimate
of mass erosion. No such data was available for the Ashland watershed and
the scope of our study was not such that this information could be collected,
since it requires a considerable study period of from one to three years.
In view of this and in view of the information available from the Inter-
mountain Research Station and the need to make at least rough estimates
of relative contribution, we "modeled" the Ashland watershed erosion
for mass and surface erosion over a 22 year period.
We do not pretend that this analysis is perfect. Furthermore, we have
emphasized that surface erosion rate information should be collected
specifically for the Ashland watershed. We believe that our analysis
procedure is sound and that our conclusions are correct, but recognize
that any fine tuning would require site specific surface erosion rates.
An evaluation of channel erosion may also be useful.
.........."..-".".-.-
C-4
Comments and Responses on
Ashland Report
.'
1'~
C-4.a
USFS Comments on
Ashland Draft Repol
1Rl~~~~~{EID)
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(f) f.\PR 22 1977 - It
g 0
JAME.S M, MONTGOME.RY
CONSULTlNG ENGINEERS, INC.
r
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
ROGUE RIVER NATIONAL FOREST
P. O. BOX 520, MEDFORD, OR 97501
2540
April 19, 1977
James M. Montgomery, Consulting Engineer, Inc.
Attn: Mr. John Somerville
1301 Vista Avenue
Boise, Idaho 83705
L
e
Dear Mr. Somerville:
Thank you for the opportunity to review your firm's draft report,
"Water Resources Management Plan and Facility Study". We have not had
time to analyze and prepare an in-depth review of all the data and
interpretations. Initially, we believe it is more important to provide
a prompt response to the P9ints contained in each recommendation which
is rough drafted in the Report's Section 2. In general, we agree with
the aims and probable intentions of most of the recommendations.
I have organized my critique in the enclosed "Comments on Recommen-
dations". These comments are listed by "exception". I have commented
on only those recommendations where I feel a change in wording is
needed in line with my responsibilities to administer laws and
executive orders which are not necessarily reflected in the recom-
mendations. Some of my comments may appear to be "nit-picking", but I
think some minor changes in the recommendation wording may help the
City of Ashland and the Forest Service avoid misunderstandings.
Finally, some changes are directed at clarification of in-house jargon
and terms.
I also have a question regarding the "si1vicultura1 study" mentioned
in Section 1 (Pages 1-3). Within the Forest Service, a "si1vicu1tura1
study" would be an analysis of all environmental factors with emphasis
on the culture of trees. Obviously, your report emphasizes the manage-
ment of the Ashland Watershed for production of water. Perhaps it
would be useful to delete the reference to "si1vicultural study" or
further define what you mean by use of the term.
In addition to the enclosed report, I am preparing a second response
entitled "Technical Analysis of Data and Interpretations". I have
separated the two in order to facilitate an early response. I will
forward this to you soon.
6200..11 (1/69)
...............'......._..... '_.~"'_"'~"'>""__'''''''''~..., ...._.4..~.
C-4.a
2
Our specialists have been stimulated by your data and interpretations.
You may wish to consider their expertise and ideas in reference to
your recommendations for proposed actions. We have some well qualified,
knowledgeable scientists on our staff and we will all profit from
their observations and recommendations. And we would like to review
and comment on the next revision before it becomes final.
In closing, it appears to me that we are "going down the road
together" with the City of Ashland. We have recognized past problems
in the Ashland Watershed by placing a moritorium on harvest and road
construction and by classifying the area as "marginal" (lands upon
which further knowledge is needed before harvesting will be authorized)
in our new "Timber Management Plan". We are presently proposing a
meeting with Jeff Gibbs to develop and implement a joint water monitoring
program. Internally, we are requesting funds to do additional monitoring
of Neil Creek and Ashland Watershed. I think your report is very
supportive of the many things we would like to do in managing the
Ashland Watershed. I am also hopeful that we can soon resolve any
differences, revitalize our agreement with the City of Ashland, and
continue working together to develop and implement an action plan for
the watershed's management.
);::Y~\ iK<:~~
DONALD H. SMITH
Forest Supervisor
Enclosure
C-4.a
COMMENTS ON RECOMMENDATIONS
1. Institutional Agreements
a. The existing cooperative agreement forms part of the framework for
Forest Service management of the watershed. There are other laws
administered by the Forest Service which must be taken into account.
There are also other Federal and State Laws and Executive Orders
which the Forest Service is required to follow (The "report" mentions
the "Water Quality Act"." The "Multiple Use Act", "1976 Forest
Management Actll and "NEPA" are some others.) It is not possible, then,
for the Forest Supervisor to agree that the agreement with Ashland be
the (sole) basic institutional mechanism...."
b. The 1929 agreement shall be reviewed by the City of Ashland and the
Forest Service and the intent clarified.
2. a and b Monitoring Program
We agree in general, but, of course, all parties would need more specific
objectives and an action plan to assure understanding. We want to do
more monitoring and can agree to a set of desirable objectives.
3. Watershed Management
a. We believe this recommendation is too restrictive. The City of Ashland
and the Forest Service may wish to construct roads for future water
developments, access, or fire control purposes as examples.
a. "Minimum road maintenance" is not definitive enough. We suggest
wording to the effect that: "The U.S. Forest Service road maintenance
program be improved to provide maximum possible stabilization of
related soil disturbances" (1972 DEQ Report, P. 12, item 8).
b. Again, "chemical-use" may be too broad a term. We suggest the
control should be via environmental analysis or impact reports
with the City review being a part of the process.
c. We are in accord with the intent of this provision. Since the City,
as well as the Forest Service, may be the cause of such need, we
suggest wording like "causitive agency or party" do this and, also,
that it be done "where practical and possible."
g. Too restrictive. The City of Ashland may want to harvest timber to
make way for a water development. Our existing agreement with the
City should provide adequate control of any future proposals by the
Forest Service or City to harvest timber.
h. We are not sure the present level of fire protection will continue
to be adequate. However, apparent needs are well outlined in the
"Rogue River National Forest Fire Plan." Perhaps this recommendation
should say "fire protection will be carried out in accordance with
this plan." The plan is available for review.
,-,-._.-"',,,,, ......
, .
. " \.'
C-4.a
i. We are presently~ and on a continuing basis, reviewing the effectiveness
of our sediment control measures. We suggest the recommendation call
for "continued control as indicated from evaluation of the ongoing
programs."
4. Reeder Reservoir
b. We suggest that monitoring sediment in Reeder Reservoir be done
cooperatively.
f. We suggest a recommendation that the City monitor the streams below
Reeder Reservoir.
5. a. As required under PL 566.
-2-
,~,..",.. ,..~ PO. o.,._..........._~,.._.__~_."...__..~...............'_""~__
C-4.b
BIBLIOGRAPHY
Anderson, H. W. Major flood effects on subsequent suspended sediment
discharge. 49th Annual Meeting American Geophys. Union,
Washington, D.C., April 8-11, 1968. (Abstract) Trans. Amer.
Geophys. Union, 49(1):175. 1968.
Anderson, H. W. Relative contributions of sediment from source areas,
and transport processes. In: Proceedings of a Symposium:
Forest Land Uses and Stream Environment, J. T. Krygier and
J. D. Hall, eds. Oregon State University, pp. 55-63. 1970.
Brown, G.
W. and J. T. Krygier. Clearcut
tion in the Oregon Coast Range.
1198. 1971.
logging and sediment produc-
Water Res. Res. 7(5):1189-
Helvey, J. D. Watershed behavior after forest fire in Washington. Pro-
ceedings of the Irrigation and Drainage Division Speciality
Conference at Fort Collins, Colorado, by the American Society
Civil Engineers, pp. 403-422. 1973.
Klock, G. Impact of fire post-fire salvage logging systems on soils and
vegetation. J. Soil and Water Conservation 30(2):78-81. 1975.
Megahan, W. F. and R. A. Nowlin. Sediment storage in channels draining
small forested watersheds in the mountains of central Idaho.
In: Proceedings of the Third Federal Inter-Agency Sedimentation
Conference., Denver, Colorado, pp. 4-115 - 4-126. 1976.
Swanson, F. J., G. W. Lienkaernper, and J. R. Sedell. History, physical
effects and management implications of large organic debris
in western Oregan streams. USDA Forest Service Pacific North-
west Forest and Range Experiment Station, Gen. Tech. Rep.
PWN-56. 1976.
L
. -
.' C-4.c
(
JMM Response to USFS
Comments on Ashland
Draft Report
ENGINEERS, INC.
.
.JAMES M. MONTGOMERV, CONSULTING
1301 Vista Ave" Boise. Idaho 83705/ (208) 345-5865
JOHN E. SONERVILLE
IL roN DAVIS
DENNIS ECKHARDT
PAUL L FUODLEY
ROIlEJtT G, JOSSIS
July 18, 1977
Mr. Allen A. Alsing
Director of Public Works
City of Ashland
City Hall
Ashland, Oregon 97520
Subject: Comments on Study of Ashland Creek Watershed
Dear AI:
The attachment summarizes our response to the Forest Service
comments. Where these comments resulted in significant
changes in the report, we have included a brief statement
concerning the changes made.
In the May 4, 1977, letter from Donald H. Smith, Forest
Supervisor for the Rogue River National Forest, it was
stated that the Forest Service specialists had two major
concerns:
1. Use of data from the Idaho Batholith to obtain
estimates of erosion rates for the Ashland
Creek Watershed.
2. The erosion-sediment routing procedure used.
Concerning the Idaho Batholith data, it is our opinion that
this is the best source of comparable research information
to the Ashland Watershed. In fact, the two areas are very
similar. Concerning the erosion-sedimentation routing pro-
cedure, we pointed out in the draft report that we did
not attempt to route the eroded material; however, we did
make reference to sediment accumulation in Reeder Reser-
voir. Since this apparently resulted in confusion, we
have now revised the erosion evaluation and write-up to
explicit ly exclude any reference to Reeder Reservoir
accumulation.
We have considered the Forest Service comments and revised
the report where appropriate. We did not respond in the
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.JAMES M. MONTGOMER'( CONSUIrl --; ENGINEERS, me.
I
C-4.c
.01 Vlata Av... Bois.. Idaho 83705 I (208) J.45-5865
Mr. Allen A. Alsing
2 .
July 18, 1977
attachment to every comment since some were stating opinions
which we had no disagreement with, but which would not
require or suggest revisions to the report. We enjoyed
working on the project and found the Forest Service person-
nel to be constructive in their comments.
We hope this will answer any questions concerning our
method of responding to the Forest Service.
Sincerely yours,
~:!=:~~;y
gv
Enc.
..
PAGE
5-18
5-21
5-22
5-27
to
5-30
(.
C-4.c
JMM RESPONSE
TO
FOREST SERVICE COMMENTS
ASHLAND WATERSHED STUDY
The statement that the Ashland Creek Watershed has
not experienced erosion from road surfaces continuing
at the initial post-construction rate should be
documented by research data. We have reviewed the
available information on surface erosion from
batholith soils and discussed the subject with
various researchers. Based on this, we believe
that our assumption is on target. The rates may
not go completely up to first year rate, but they
would probably approach it rather closely. The
fact that the road was graded more than once per
year, in many years, would tend to counteract the
mitigating effect that would occur if it was graded
only once. We suggest that the Forest Service confer
with their surface erosion/batholith soils specialists
regarding this subject.
We considered this comment and reduced the road
surface rate to 90% of the first year rate.
Fredriksen's work is of limited interest for the
Ashland Watershed. The soils are dissimilar since
they are derived predominantly from tuff and breccia
parent material. Also, in Fredriksen's study the
greatest soil loss was attributed to land slides
and the scouring action of high velocity mud flows
moving down the stream channels after a landslide.
While some of this probably occurred in the Ash-
land Watershed, it is our opinion that surface
erosion of the granitic soils was a major process
involved, and would operate essentially as des-
cribed by Megahan on the Idaho Batholith.
The difference in road mileage tributary to Reeder
Reservoir is an important consideration and was
used to revise the final report. Both the original
and final information was provided by the Forest
Service.
Based on our review of the literature concerning
batholith soils, it appears that the 80 percent
attributed to man-related activities may actually
be low. One of our primary premises is that while
channel erosion may have occurred, most of it would
not have occurred had it not been for the unusually
large amounts of man-caused sediment moving into,
.- <.,. .....
5-31
5-34
5-37
(
C-4.c
being deposited in, and subsequently entrained
from the channel and overbank areas.
There is very little difference in surface erosion
characteristics between Megahan's watershed and the
Ashland Creek Watershed. Erosion rates are certainly
not the same as sedimentation rates and this was
emphasized in the report. We do not agree that the
roads in the Ashland Watershed would not have a high
delivery ratio, since most of the roads are now in-
sloped and all of the cut and road surface area would
drain into a ditch. Since the high post-construction
surface erosion rates were applied only to the road
surface, we believe that the delivery ratio would
be quite high, probably in excess of 90% over a 10-
to 20-year period.
What "field evidence" is available to the Forest
Service that disproves the assumption that major
flood events would move most of accumulated sedi-
ment downstream to Reeder Reservoir? No such data
has been provided. It is realized that sediment
coming from the fill slope in certain years may
take a considerable time to get into the reservoir.
However, events such as in 1964 and 1974 would
most likely be enough to move a large percentage of
the sediment lying in transition throughout the
watershed into a defined water course and subse-
quently to Reeder Reservoir.
This was considered and in the revised report only
surface and mass erosion for the entire watershed
was considered. Routing through the watershed was
not attempted so the accumulation in Reeder is not a
comparison.
It is stated that no data is offered to support the
contention that maintenance efforts keep erosion
rates at the first year level indefinitely. This
is true since no such site-specific data is available.
However, faced with the economic and water supply
consequences for the City of Ashland if past sedi-
mentation rates continue in Reeder Reservoir; this
assumption is viewed as reasonable. Keep in mind
that we are referring only to the annual grading
and surfacing activities, not to the cleaning of
culverts or removal of large debris barriers in
the ditches as long as it is done only at the loca-
tions requiring it as opposed to the entire length
of the road. .
What is the basis for stating that the estimates of
the ski area's contribution to sediment yield is too
high? The alluvial fan mentioned would have a
maximum capacity for trapping sediment. In viewing
this area from the air, and on the basic topographic
^ c:.__';'.^._~,"-"",-.,,';'_""_'" ,-;.-.".........,...",..... u ~..__'_".__'_....,
5-38
5-41
5-42
5-44
(
C-4.c
maps available, it does not appear to have a very
large capacity. It would certainly slow down sedi-
ment movement but its long-term retention is
questionable.
In the revised draft the ski area contribution is
reduced.
The Forest Service statement that "Bank erosion plus
channel degradation is a major source of sediment in
a watershed. It appears to provide at least as much
material, if not more, as all other sources combined,"
is not documented. Bank and channel erosion would
certainly be one of the primary mechanisms for moving
sediment through the watershed, but the original
source of much of that material, if not most of it,
would be surface and mass erosion in the watershed
outside the natural water courses.
The question of channel erosion contributions is an
important one and it is proposed in the report that
this be further evaluated (using the general metho-
dology developed by Bill Emmett of the USGS). We
believe that if it is a major contributor to the
sedimentation of Reeder Reservoir, most of that con-
tribution is the result of increased scour due to
entrained material originating in the watershed
proper (as opposed to channel or bank erosion of
material that has resided for a long period in the
channel or bank areas).
It appears that we are reasonably close in our
analysis of the difficulties of routing the material
through the watershed. The question of whether or
not the flood in 1974 would have moved most of the
material through the watershed needs to~further
analyzed. However, this appears to us to be a
reasonable assumption.
Table 5-4 does not include a routing procedure. It
is a mass balance or erosion budget and throughout
the report it is explicitly stated that routing was
not, and at this time cannot, be performed with much
confidence. However, regardless of the annual trans-
port volumes, we believe a very high percentage of
the eroded material reached Reeder in 1974.
We do not agree with the implication of this state-
ment. Most of the material entering- Reeder Reser-
voir may have at one time or another been subject to
channel erosion processes. However, most of the
material was most likely derived from surface erosion
and mass erosion in the watershed. The statement by
the Forest Service that the greatest sediment yield
......~__..w.,............'. _~._...~"...._..__......__.
5-52
5-58
(
C-4.c
is from channel erosion is not documented for the
Ashland Watershed or for any other granitic soils
watershed, and does not appear to us to be valid.
In the paper by Megahan and Molitor (1975) it is
stated that "the fire burned very hot consuming a
large amount of fuel on the heavily timbered water-
shed." Also, an important point is that "none of
the eorded material left the uncut drainage as
shown by the lack of deposition in the collection
trough and by the erosion pin data." The important
point is that wild fire (due to natural causes) in
an unlogged area of the Ashland Watershed would not
necessarily be expected to result in high erosion
and sedimentation rates. This we feel, based on
Megahan's and Molitor's research and the history of
fire in the Ashland Watershed, is an adequate and
accurate observation. Anything, of course, could
occur. Our main point is that the often proffered
scenario of mass devastation and erosion due to some
combination of insects, disease and fire isn't
necessarily valid.
It is stated that "one important thing to remember
is that soils from the same geologic source react
differently in different areas. Erosion rates be-
tween areas can be and are highly variable. This
must be remembered when applying study results from
one area to another." This is true. However, we
believe the processes in the Ashland Watershed are
very similar to the Idaho Batholith watersheds
studied by Megahan. The Forest Service may also
wish to review its previous statement concerning
the applicability of Fredriksen's (1970) work on
soils which were significantly different than the
Ashland Watershed.
This statement does not agree with the information
provided originally by the Forest Service (Mel
Dittmer, see attachment).
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C-4.b
USFS Comments on
Ashland Draft Report
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
ROGUE RIVER NATIONAL FOREST
P.O. BOX 520, MEDFORD, OR 97501
RRNF
REPL Y TO: 2510 Watershed Surveys and Plans
May 4, 1977
TO: James Montgomery I Consulting Engineer I Inc.
Attention: John Somerville
1301 Vista Avenue
Boise, Idaho 83705
e
SUBJECT: Specialists comments on Study of Ashland creek Watershed
Enclosed is a compilation of our specialists' comments on the technical
aspects of your "Water Resources Management Plan and Facilities Study"
for the Ashland Creek Watershed.
To save your time and ours, I asked the specialists to comment only
about those items they felt needed clarification, changes, etc. Con-
sequently, their comments are not balanced by positive observations and
agreements. I hope these were adequately covered by my previous letter
and comment that".. . your report is very supportive of the many things
we would like to do in managing the Ashland Watershed".
Our specialists had two major concerns:
1. Use of data from the Idaho batholith to obtain estimates of erosion
rates for the Ashland Creek Watershed.
2. The erosion-sediment routing procedure used.
Their specific comments are in the
i:~WOUldbe
enclosed "Technical Analysis of Data
glad to discuss any of them with you.
DONALD H. SMITH
Forest Supervisor
\fi IE ~ IE U ~ IE O.~
1.JJ 'IIY.ft -
~ MI\Y 9 mC-" \t
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ID JdlfS 16. ,,(J(IGOMER'l uC.
tOJSlIl-l'AlS ~
Enclosure
<~""."'''-
Page
5-4
5-8
5-9
5-13
5-18
5-21
5-22
C-4.b
TECHNICAL ANALYSES OF DATA AND INTERPRETATIONS
The Forest Service has closed the watershed to all vehicle use
off roads, not just to motor bikes.
Add "Time since previous major flood event" to Section "a",
Channel Erosion. Anderson (1968) shows this to be a major
factor in channel stability.
The discussion of deposition and erosion in stream channels is
an oversimplification of a very complex process. Swanson,
et.al., 1976 and Megahan and Nowlin, 1976, can be used as
references for discussing this process.
Bethalmy should be Bethlahmy.
The Ashland Creek Watershed has not experienced erosion from
road surfaces continuing at the initial, post-construction
rate for more than a couple of years after construction. This
assumption will lead to unrealistically high erosion rates
(about 10 inches by your calculations) from the roads.
Fredriksen (1970) found that timber harvesting operations
involving high-lead cable yarding to a system of logging roads
may increase sediment in streams draining these areas by an
average of 100 times the undisturbed condition over a period
of years. He further states that the "initial effect of
skyline logging had little or no effect on sedimentation
rate" . The same is true of a patch cut watershed in his
study. These results are supported by Brown and Krygier, 1971,
and Klock, 1975.
A clarification about the length of roads and acres harvested
within the watershed is needed. While there are about 53
miles of road within the Ashland Creek Watershed, only 33.5
miles are within that portion tributary to Reeder Reservoir.
Of this total, only 21.2 miles have been constructed since
1956. Information from past Forest Service reports may have
been misleading on this fact.
The breakdown of harvested areas is as follows:
Clearcut
Shelterwood
Thinning
269 acres
577 acres
154 acres
1,000 acres
These figures are important since they have a bearing on
calculated sediment yields later in the report.
,......~'_.....-._,.,.._,.--..
Page
5-24
5-27 to
5-30
5-31
5-34
C-4.b
There needs to be a discussion of the accuracy of the "rough
estimates" of sediment removed following the 1964 storm..
Volumetric measurements of quantity of material removed from
the reservoir by dredging requires either accurate profiles
showing volume removed or monitoring of suspended and coarse
material. Without either of these, dredge volumes are at best
a very rough measurement of material removed. To a lesser
degree this also applies to the water saturated sediment
hauled by truck.
The rationale in attributing over 80 percent of the sediment
accumulation in Reeder Reservoir to man-related activities as
opposed 'to channel erosion neglects to take into account that
during the 1956-1974 period there was an intense rainstorm in
1962, a 100-year flood in 1964 and a flood of greater magnitude
in 1974. These three storm events would greatly increase any
average, pre-storm sediment yields. This would cause the
97,000 yd.3 estimate of natural sediment yield to be low and
that attributed to man's activities to be high. The effects
of floods on sediment yields is reported on by Anderson, 1968~
Anderson, 1970~ and Megahan and Nowlin, 1976.
Erosion rates are not the same as sedimentation rates. In
order to use Megahan's 1972 data, you need to note both the
similarities and differences between his study watersheds and
Ashland Creek watershed.
Megahan studied watersheds ranging in size from 1-5 acres. In
these small areas, the total road surface area is extremely
close to stream courses and, consequently, has a high delivery
ratio of surface erosion material to the stream channel.
Because of their location with respect to streams, the roads
in the Ashland Creek watershed do not have this high delivery
ratio.
Megahan' s data showed that about 84 percent of the sediment
yield from surface erosion was realized the first year and 93
percent was realized within 2 years. This is also supported
by Fredriksen, 1970, and Brown and Krygier, 1971.
Field evidence disproves the assumption that major flood
events (1964 and 1974) are forceful enough to deliver most or
all accumulated sediment downstream to Reeder Reservoir.
2
'-'--"~...~_..~..._,_._.....,~,._.-.--.,...,_..,_._-
Page
5-37
5-38
5-41
C-4.b
No data is offered to support the contention that all mainte-
nance efforts will keep erosion rates at the first-year level
indefinitely. Insloped roads require maintenance at the
culverts and cross-drains to avoid severe sediment production.
Mass failures have resulted when culverts have plugged divert-
ing water onto unstable ground. Severe gully erosion has
resulted from the same cause.
The estimates of the ski area's contribution to sediment yield
are too high. Any sediment originating at the ski area must
pass through a large alluvial fan located on the East Fork
approximately midway between the ski area and road #3903.
This are~ acts as a trap for coarse sediment restricting the
theoretical potential volume from the ski area to the fine,
suspended material. The limited data available from our East
Fork sediment samp~ers indicates that this contribution is
small.
The application of surface erosion rates from harvested areas
are based upon clearcut units which comprise only 26.9 percent
of the harvested area. A reduction in the estimated rate
needs to be made after considering the rates from the shelter-
wood and thinning units.
Bank erosion plus channel degradation is the major source of
sediment in a watershed. It appears to provide at least as
much material, if not more, as all other sources combined.
The lack of acknowledgement of this fact leads to the attribu-
tion of the total amount of sediment to the remaining sources
causing them to be overestimated by at least 100 percent.
Reference column 10, Table 5-4. At the bottom of the table
you state that the totals in column 10 do not represent input
into Reeder Reservoir. "Routing of material is not possible
with existing data". In addition, on page 5-51, you state
that "to simulate sediment input to Reeder Reservoir the
eroded material would have to be routed through the watershed,
which, due to current knowledge limitations, is'impossible to
estimate." We can agree with these statements. However, it
is not correct to use the statement that "it is reasonable to
expect that most, if not all, of the eroded material reached
Reeder Reservoir in 1974 (if not before) due to the very high
flushing action that year". This statement discounts the two
previous expressions that sediment routing cannot be estimated
without clear rationalization and qualification of the small
amount of data available. Specifically, it is incorrectly
implied that all material leaving an erosion or failure site
3
'''.....4.___~_.",.."_.,,._......"' "<"'~..M'_._._..,. '"___
Page
5-42
5-44
5-46
5-49
5-52
5-55
C-4.b
is instantaneously transported downstream to the reservoir.
In addition, any routing system which does not treat sediment
storage volume and channel erosion cannot be verified.
The table does not assume any volume percent for the channel.
This technique is inaccurate and misleading when volume
contributions from various sources are being studied. All
sediment routing studies highlight the importance of under-
standing the change in sediment storage volume. The deletion
of this factor invalidates the whole routing procedure used in
Table 5-4.
The process yielding the greatest amount of sediment is channel
erosion.
The 1970 transportation plan was based upon a planned program
of full timber yield from the watershed. Changes in classifi-
cation of the watershed to the marginal component will necessitate
considerable changes in this plan.
Mt. Ashland Corporation no longer operates the ski area. It
is operated by Southern Oregon Ski Association and the permit
is held by Jackson Oounty, Oregon - Mt. Ashland Winter Parks
Recreational Facility, Inc.
Fire. This is an oversimplification of the problem. Megahan
and Molitor (1975) reported on a fire which did not destroy
the canopy. A high energy fire would destroy the canopy
depriving the soil of the protective cover of needles. In
this type of fire the sediment yields would be approximately
equal from logged and unlogged land. The research by Helvey
(1973) in the Entiat Experimental Forest show that considerable
sediment yield is realized following fires on undisturbed
watersheds.
One important thing to remember is that soils from the same
geologic source react differently in different areas. Erosion
rates between areas can be, and are, highly variable. This
must be remembered when applying study results from one area
to another.
Snowpack in a ski area can be either more or less than in an
adjacent forested area depending on the orientation of the ski
trails to the wind pattern.
While it may be true that construction of the ski area' has
resulted in an increase in runoff in the East Fork, no mention
is made of how large this increase is.or whether it causes any
problems. It is doubtful that the increase in flow is statis-
tically significant or that it causes any problems downstream.
4
C-4.b
Page
5-58
The roads in the watershed were originally designed with an
inslope; the inslope was not undertaken as a repair measure.
5-61
Revegetation. All the clearcuts are revegetated, but not all
are satisfactorily reforested.
5-65
The Neil Creek study was designed to monitor the background
sediment production and trace its source to natural or man-
caused sources. The stability study is only one part of the
overall study. The full plan includes suspended and bedload
sediment monitoring, channel characteristics, surface erosion
characteristics and surface erosion measurements. It is
designed to show the effects of a timber sale on erosion and
sediment. production.
The following diagram presents an example of a process to follow in
sediment routing. In order to develop the volumes of material trans-
ported through the Ashland Creek system to Reeder Reservoir, a parallel
analysis must be made using a schematic similar to the attached. Any
attempt to route sediment through the watershed which does not use such
a system cannot be substantiated.
5
...
9
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Page
6-11
The recommendation for the city to purchase a dredge to clean
the reservoir must more fully explore the volume of dredgeable
fines entering the reservoir. This volume has been overestimated.
7-2 Prior to further development of plans to construct a new
reservoir upstream from Reeder Reservoir, some specific
questions must be answered:
1. What will be the volume of sediment into the reservoir
due to construction?
2. What is the effect of channel aggradation on stream
meander and bank undercutting upstream from the dam?
3. What is the rate of sediment input to the new reservoir?
4. What is the channel capacity below the dam?
5. What will be the effect of releasing impounded water
on the stability of the West Fork channel?
Generally, in chapter 7 there are no cost estimates on most of the
alternative supply sources so there is no way to compare the alterna-
tives.
7
/A
(
C-4.c
SUMMARY OF ROADS IN THE
CITY OF ASHlJUID WATERSHED
ROGUE RIVER NATIONAL FOREST
j
There is an existing network of about 53 tuiles of road within the Ashland
Watershed. With the exception of roads #3925 and #3963, which are very old
roads, most of the roads within the watershed were constructed by the
Forest Service 10 to 20 years ago to access the land for fire protection
reasons and to facilitate timber harvest. Most of the roads in the watershed
lv-ere severely damaged in the fall of 1962 during the "Columbus Day" storm.
Since then, other high intensity rain storms have caused extensive road
damage.
One of the first repair measures
taken wast~~=:pe~ll~d~he
'-- -r_--'
directed runoff toward the ditch instead
" .
watershed. Insloping pointed or
of allowing it to spill off the outside road shoulder'and onto embankment
and waste slopes. This technique was effective in reducing embankment
erosion and in maintaining a seed bed on slopes until covered with grass
end other growth. However, all water on the roadbed was directed inward
and this additional runoff appeared to increase roadbed rilling and ditch
scour resulting in perhaps 'as much total soil movement as before. To solve
.---' .':- ---------. --'- --~-'-"
/' '.
this problem spot rocking, adding cross drainage and further erosion control
',,---..
measures were undertaken. This program appeared to work well - rock surfacing
-c.--.....,>.
arrested rilling. Ad_<l.:lt:ion....~ulvertsreduced ditch and embankment erosion
~~~.,.....-. -'~- - .
and further seeding and mulching established sufficient growth on fill
"
-'. ---~---..-_.._~_.-------
slopes to prevent sheet erosion and gullying.
-,."._"~-.._--_..._..,-"... _._~.~ -'_'_._._..,-...~,..,.".,.._........._,-..._--
1L_1o~
/'
C-4.d
Brown Corranents on
Ashland Draft
""'I
Department of
Forest Engineering
Oregon
U~ tate .
mverslty Corvallis. Oregon 97331
April 19, 1977
r G0. r -, .-- ~,._. - ..' - ~."l
'\ nU' ! ~ ~.;(~:.: :;;'. :.;: ,- . -, \
I I '.i~ - _u .u____..
l r ( ;, ......,...
! \ \. ~ A P R 2 O. 1;" JJ
i \ J .
,-! . o. ._'_'. . . _ ...
~~~~;;..>~=:~ ,:..,:~~i
. ,
Mr. Jeff Gibbs, Coordinator
Water Quality Management Planning
Rogue Valley Council
of Goverm!len ts
33 North Central
Suite 211
Medford, OR 97501
Dear Jeff:
Thank you for the opportunity to review Section 5 of the draft Water
Resources Management Plan for Ashland. Due to the fact that I am present-
ly busy with the Forest Practices Act review, I will be unable t~ provide
detailed commentary by April 29. I did a very quick scan of this section,
however, and have some serious reservations about the data andrecommenda-
tions. Very briefly, these are as follows:
1. I see no substantiation of the claim that the road surface
and maintenance activities produce the erosion attributed
to them. The assumption that these roads continue to
erode at the rate expected immediately after construction
is not documented in any scientific sense. Colleagues in
Civil Engineering who are specialists in soil mechanics
concur that such rates are unreasonable. Table 5-4 is
thus highly suspect.
2. Disregarding the Forest Service estimates of channel d~-
gradation and assuming it proceeds as part of the natural
rate oversimplifies the erosion process. From experience,
we find that once a channel has become "destabilized" by
mass failure or flood, the system takes s leng ti~e to
equilibrate or restabilize. I tend to agree with the
Forest Service.
3. If the chief source of sediment is not the road surface then
the conclusions about corrective action are not correct.
And seriously so. I believe that a good maintenance pro-
gram on roads is a key to maintaining stability. I agree,
however, that additional road development should be post-
poned until we have better stability data and construction
methods.
-fH
- - -------- ------
. ..
-,
C-4.d
Mr. Jeff Gibbs
- 2 -
April 19, 1977
I see a great deal of re~etition with what I read as Forest Service
recommendations and conclusions. I'm not sure you got a great deal for your
money, Jeff. Particul~rly since the issue about surface erosion from roads
seems poorly resolved. I'm sorry I don't have time for a more detailed
review.
Sincerely yours,
~~rown. Head
Forest Engineering Department
djm
-~,,-~~,-,":....~.._-<,.. -~.. .I,~
C-4.f
JMM Response to
Brown Conunents
Jb1W!I
..JAMES M. MONTGOMERY, CONSULTING
1301 Vista Ave" Boise, Idaho 83705/ (208) 345-5865
ENGINEERS, INC.
10HN E. SOMERVILLE
H. TOM DAVIS
DENNIS ECKlIARDT
PAUL L. FINDLEY
ROBERT G, IOSSl5
July 29, 1977
Mr. Allen Alsing
Director of Public Works
City of Ashland
City Hall
Ashland, Oregon 97520
Subject: Watershed and Facility Study
Dear AI:
This is in response to the letter dated April 19, 1977, from
Dr. George Brown, Or~gon State University to Mr. Jeff Gibbs,
Coordinator Water Quality Management Planning, Rogue Valley
Council of Governments.
Regarding the first point,- the "substantiation" Dr. Brown
refers to concerning the road surface and maintenance ac-
tivities is the erosion budget (Table 5-4) and is based
on the best applicable research we could find? from other
areas. Since no research of that type has been done on
the Ashland watershed this was our only alternative. The
hypothesis was tested through an erosion budget for the
22-year period of observation at Reeder Reservoir. We
certainly cannot demonstrate that the erosion occurred
in exactly this manner. However, we tested other methodo-
logies and erosion rates and no other approach simulated
anywhere near the amount of material actually eroded in
the watershed. Since we do not have the option of open-
ended research this appears to be the only analysis avenue
open, given current levels of available information.
While the findings were never advocated as final and
absolute, I personally have confidence that they are es-
sentially correct. I believe that the general implication
regarding the effect of maintenance activities on water
quality is valid, and for this and other reasons timber
harvesting in the Ashland watershed is an inappropriate
use.
Dr. Brown's comment concerning the views of his "colleagues"
in civil engineering is of interest to us. Montgomery
Engineers employs over 100 civil engineers and I have
questioned a few of them concerning the type of surface
PLANNING...RESEARCH...ENVI RONM ENTAL ENGIN EERING
-__...._,,___....., ._. '.~.N_._'_._.,........,_'_,_~_"'
C-4.e
JAMES M, MONTGOMERY, CONSULT,JNG ENGINEERS,INe.
(
'01 Vista Ave., Boise, Idaho 83705 I (208) 345.5865
Allen A. Alsing
2
July 29, 1977
erosion background they obtained through civil engineering
soil mechanics courses (including a recent Oregon State
graduate). With no exceptions, their soil mechanics courses
and texts were the same as mine - surface erosion was
examined very superficially, if at all. I doubt, with
possibly a few exceptions due to the field experience of
individual practitioners, that many civil engineering soil
specialists would pretend to be very knowledgeably con-
cerning the processes of surface erosion. Civil engineering
soil mechanics generally examines soils as a structural
medium with emphasis on foundation design and mass failure
(generally of cut or fill areas). As Dr. Brown should
recall from his "very quick scan" of Section 5, these two
subjects were not dealt with except to directly incorporate
Forest Service estimates of mass failure.
Since Dr. Brown is apparently interested in the subject, I
suggest he confer with surface erosion specialists in agri-
cultural soil science and possibly with individuals such as
Walt Megahan or Paul Packer of the U. S. Forest Service
Intermountain Forest and Range Experiment Station. I
We found Dr. Brown's suggestion to Mr. Gibbs that he may
not have "got a great deal for (his) money" a bit unusual.
Particularly since his comments were based on a "very quick
scan" of the report, supplemented by advice from unidentified
"colleagues in Civil Engineering who are specialists in
soil mechanics," who reportedly find the road surface and
erosion rates presented in the report as unreasonable.
We have asked our consultant, Richard Meehan, who holds
degrees from University of London and MIT in soil mechanics,
and is a consulting professor at Stanford University, to
comment on the soil mechanics aspects of these estimates;
his comments are a~follows:
"There is nothing to my knowledge in the soil mechanics
literature which would ~ndicate that erosion of less
than 0.5 inch of material annually from a freshly
bladed road surface in granitic soils is unreasonable.
Common sense would suggest that rates could be even
greater than this if the upper several inches of
material were disturbed during annual grading. But
it may be that Oregon State's Soil Mechanics Depart-
ment has data on this subject which I am not aware
of. It would be helpful if you could identify the
source of Mr. Brown's information, particularly in
view of the fact that he bases a rather categorical
condemnation of the report largely on such unidenti-
fied sources."
_.-......_~......._._^-"-_...~..,.,~.-.. .'~ --'---'_~_';'-'-""-"""~"-""-'---~--"'''''~'~''~-~-.'~''' -, -- .""'~- """""'"
JAMES M. MONTGOMERY, CONSULTING ENGINEERS, INC.
C-4.e
1301 Vista Ave., BoIse. Idaho 83705 I (208) 345-5865
Allen A. Alsing
3
July 29, 1977
Concerning channel erosion and channel destabilization
(Dr. Brown's second point) I might point out that our analy-
sis did not disregard the subject. However, a detailed
study was not possible, given the scope of the project.
Certainly this is a significant area for future analysis.
I suspect however, that while some erosion of material
that has resided for a long period in the channel and
overbank area (native material) may occur, its contribution
to the total sediment load is slight. This is not to say
that channel erosion isn't an important process; there is
probably a continual and accelerated degradation and ag-
gradation of the Ghannel due to mass and surface erosion
in the watershed. However, this would make such channel
erosion essentially an interim process acting to move
material originally eroded in the watershed through the
streams to eventual deposition in the reservoir. This is
of course a process which we don't pretend to be able to
fully understand for the Ashland watershed in the short
time available. We believe, however, that through methods
such as the one developed by Bill Emmett of the u.s.
Geology Survey a good estimate can be made of the relative
amount of sediment generated through channel erosion of
long-term resident material.
Since, as Dr. Brown points out, he had limited time for
review before commenting on the draft report, I hope that
he will "scan" the report a bit more in detail and call
upon his vast store of intuitive knowledge (possibly
tempered by additional information review concerning Batho-
lith soils) before making additional observations.
Sincerely, yours,
8~~~
H. Tom Davis
gv
cc: Jeff Gibbs
Dr. Brown
____~...._..._.__~_.,...__,_._., 'm ".__.".,~"_._....___",,.___,....,..........
,;~-<~
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-~~~.,-,,,.,"'.""-~~
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C:_,
C-4.f
.Megahan Comments
on Ashland Draft
Report
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
INTERMOUNTAIN FOREST AND RANGE EXPERIMENT STATION
31. EAST MYRTLE STREET
BOISE. IDAHO .370.
1630
May 16,
196)
r Mr. Tom Davis
Civil Engineer
James M. Montgomery, Consulting
Engineers, Inc.
1301 Vista Avenue
L Boise, ID 83705
Dear Tom:
Thank you for the opportunity to review your interesting study
of the Ashland watershed. Although I have not had time for an
indepth review, I have included a number of comments directly on
the draft copy for your information.
Please feel free to call me if you have any questions.
Sincerely,
w~ ~L-,-
WALTER F. ME~AHAN {/
Research Hydrologist
Enclosure
.'
!if It/ If C lEU WIE!IJ
~ MAY 17 1911 'If
lAME.SIIAl . EE
CONSULnNr;" n.~ER.r 0
".I.IGINf1:Dct. - , I
~-
..,.,.T
c-s
Megahan Memo to Rogue River
National Forest
.~
.~
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
c-s Megahan Memo to Rogue
River National Forest
INT Boise
.
REPL Y TO: 2540 Water Uses and Development
August 16, 1978
TO: Donald H. Smith, Forest Supervisor
Rogue River National Forest
SU~EC~ Ashland Creek Watershed
On July 6 and 7, 1978. I visited the Rogue River National Forest
to review watershed conditions on the Ashland Creek catchment.
The purpose of my visit was to assess the potential for extra-
polating research results from the Idaho Batholith to the Ashland
watershed (a representative section of the Ashland Batholith).
Accompanying me during my visit were:
July 6
Don Gray, Professor of Civil Engineerin~, University of
Michigan; Jon Brazier. Hydrologist, Rogue River National
Forest; George Badura, Soil Scientist, Rogue River National
Forest; Billy Hicks, Geologist, Rogue River National Forest;
Courtney Cloyd, Geologist, Rogue River National Forest;
Susan Blumenthal, Soil Scientist, Rogue River National
Fores t.
July 7
Jon Brazier, Hydrologist; George Badura, Soil Scientist;
Susan Blumenthal. Soil Scientist; Margaret Holman, Snow
Ranger; Glendon Jefferies, District Forest Ranger.
We visited the areas marked in red on the attached map.
The observations reported herein are based solely on my two-day
visit in the area. Many of the comparisons between the Idaho
and Ashland Batholiths provided below could be subject to revision
if I had time for a detailed comparison of available reports (for
example. soil and geology surveys, climatic data, stream flow
data, etc.).
Basically, the two Batholiths are very similar in their hydrologic
function and responses to land use. Batholiths are relatively
large masses of various kinds of granitic rocks. In 'general. soils
on batholith areas are shallow and coarse textured. Because of this.
soils are low in cohesion and thus are highly erodible When subjected
to surface erosion forces, especially following disturbance. Steep
~..."'.^..".,--
/:
C-5
slopes, coupled with large volume water inputs from rainstorms
and/or snowmelt, cause high mass erosion hazards as well. Eroded
material transported to stream channels is also coarse-textured
causing sediment transport with a relatively high proportion of
poorly graded bedload material. These erosion and downstream
sediment processes are characteristic of batholiths in the western
U. S. and are what make such areas unique. Thus, I would not
hesitate to extra~olate the baslc_~inciples found in the-1D~-
Bathol1thto the Ashland watersQe.dL-_~o.~ever L!h~_.p1!Ysical pro.Q.erties
oJ___t~~ tw~ areas do Yar.y_.sQrg~...:wb3!tJ-!'>P I would be reluctant to
extrapol.a_t~_._eJ::Qs_ioD-and__s_edJ.!1l~ntation rates directly from O!l_~ a;:ea
to -the other without !?_opl~_on:-...s..it!Ldii..q f9rverification.
-'. -,_...,.~._---_......_~_..-.- -. -. --------------
On the average, the bedrock in the Ashland watershed appears to
be more weathered and fractured than that found in the Idaho
Batholith: However, there is little evidence of hydrothermal
activity causing extreme mineral alteration as is common in many
locations in the Idaho Batholith. Finally, the rocks in the Ashland
watershed tend to be more mafic than those in the Idaho Batholith.
The combination of greater average weathering and more mafic
materials causes finer textured soils in the Ashland watershed.
Because of this, the 60ils there are probably less erodib~e. Soil
depths appeared to be fairly similar in both~a~,--aS-did topography.
Climate is quite similar in both areas with respect to average
annual precipitation and snowfall occurrence. However, I suspect
the probabilitY-Qf-1~!E~ ~torms i~~reateL~n the Ashland watershed
as compared to the Idaho Batholith. Finally, vegetation densities,
including overstory trees and understory shrubs, forbs, and grasses,
average greater on undisturbed areas on the Ashland watershed as
compared to the Idaho Batholith. Also there appears to be better
vegetation growth on disturbed areas.
On balance, it is my opinion that surface erosion hazards are less
and mass erosion hazards are greater on the Ashland watershed as
compared to the Idaho Batholith. I say this so you can see why
I am reluctant to extrapolate erosion and sedimentation rate
information from the Idaho Batholith to the Ashland watershed. -1--
don't want to imply that surface erosion is not an importa~~~os!~~__
process on th~Qland-wat~x$~~~-- it is.
. --~'_._,-
,
I recommend that a cooperative administrative study be developed to
gather some erosion data on the Ashland watershed. Such 8 study
would help you to manage the area and would benefit us by expanding
our knowledge ~f erosion processes on batholiths. Both surface and
mass erosion should be monitored. Surface erosion can be measured
using bordered erosion plots and small debris basins. We have used
such techniques for a number of years and are satisfied with the
results. I reviewed the details of construction with your staff
during my visit. Erosion plots should be used to measure on-site
surface erosion on portions of the ski area, on roadfills and on
~ . . . \ .. ~4
~ . . ,
...,....~..;..."....""'-
/'
. '.. ;
C-5
fire lines. Small debris basins provide a means to measure sediment
movement off larger areas and should be used on the ski area and to
measure erosion occurring from the total road prism on roads constructed
in micro (less than 5 acres) watersheds. Mass erosion (landslide activity)
can be monitored by an annual inventory to document the location and
volume of new landslides. In order to validate downstream sediment
delivery, the two small reservoirs at the mouths of the east and west
forks of Ashland Creek should be surveyed annually for sediment accumulation.
Some additional data collection in cooperation with the city may be
necessary to check the sediment trap efficiency of the reservoirs (also
discussed with your staff).
A wild guess for st~dy installation could be as much as $15,000.00,
depending on the type of labor and the number of study sites. Annual
data collection costs, including field time, drying and weighing samples,
and data compilation should be on the order of perhaps $4,000.00. If
you are interested in pursuing this study, please let me know and we
can discuss the best way to proceed.
One other point comes to mind. One of your staff inquired about the
potential for damage from wildfire on the Ashland catchment. Apparently
there is some feeling in the Ashland vicinity that wildfire would have
little effect on erosion and subsequent sediment production from the
watershed. Nothing could be farther from the truth! The potential for
damage is tremendous, given a large, intense wildfire and a moderate to
intense storm. There is ample evidence for this occurring in the Idaho
Batholith and at many other locations with granitic rocks in the western
United States.
I enjoyed my visit to the forest and the opportunity to meet your staff.
Please relay my thanks for their time and effort in conducting the
tour and for their hospitality during my visit. I hope my observations
are of some use to you; please don't hesitate to contact me if you have
questions or comments.
~.~
WALTER F. MEG~~4~~t1
Research Hydrologist
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C-6
Forest Service Comments on EPA
Reeder FEIS
,
.
"A~--\\ Untied Stales
-e- ;1 Department 01
~~ AClrlculturp
Forest
Se rvlce
~o~ue River NetiorteJ Fores~
P.O. Box 520
Medford, Oregon 97501
C-6.a
USFS Memo to EPA re
Reeder FElS
Replf 10
1950 Environmental Statement Process
0..,.
September 17, 1980
~ Final EIS - Reeder Reservoir
To Regional Fores ter, R6
Following are our comments on the EPA's final environmental statement on the
operation of Reeder Reservoir.
To a large degree, the environmental statement uses data from a report written
by James M. Montgomery, Inc. for the City of Ashland entitled, "Water Resources
Management and Facilities Study". As the EPA states on page 50, the Forest
Service disagreed with the methods used and conclusions drawn by Montgomery.
Nothing has changed our opinion of that report and we think that the use of
Montgomery's data limits the usefulness of this statement. Our comments on
Montgomery's report are attached.
Page 4. - Nothing in President Cleveland's proclamation refers to Ashland's
water supply. In fact, there is nothing in Section 24 of the Act
of Congress dated March 3, 1891, (cited by President Cleveland as
his authority for issuing the proclamation) about the management or
purpose for lands thus reserved.
President Roosevelt's proclamations refer to the Cascade Range Forest
Reserve and the Ashland Forest Reserve. The purposes for the lands
reserved in these -procl.amat10ns as well as those reserved..under the
Act of 1891 are contained in the Organic Administration Act of 1897.
Majntenance of favorable conditions of water flow is only one of these
purposes.
The EPA's text in this section implies that the purpose for reserving
the lands in the Ashland Creek Watershed was solely to protect Ashland's
water supply. We do not a~ree with this implication and refer the EPA
to the Act of March 3, 1891; the Organic Administrati~n Act of 1897;
and the proclamation of President's Cleveland and Roosevelt to support
our contention.
J
J
Page 45 - In discussing the flow of water over the spillway during the 1974
flood, reference is made to a Corps of Engineers estimate of a dis-
charge of about 2,000 cfs.. As is stated in the text, this estimate
cannot be documented and it should be deleted.
Page 49 - There are no references in the bibliography to USFS 1974, Hicks 1975
or Hicks and Wilson 1975. These should be included in the bibliography.
Page 56 - The statement relies on an estimated average sediment inflow in its
analysis of alternatives. Our letter on the draft statement (see pg. 137)
addressed the use of averages, but apparently did not fully explain our
concern. While we are concerned about the use of average amounts of
sediment, we are more concerned abou the method used to calculate the
average, and thus, about the specific average itself.
8
_....."~~c:;"..,..,.,~~.". ...~.>..,-."",;rc:;
C-6.a
Regional Forester, R6
page 2.
The EPA has used 1956-1976 as its period of record. This period
includes the large events in 1964 and 1974 which dominate the records.
The EPA has calculated an arithmetic average for this period by dividing
the sediment inflow (508,000 yd3) by the period of record. This method
ignores the return frequencies for events such as 1964 and 1974 and
results in an overestimate of the annual inflow of sediment. The use
of this estimate causes an overestimation of the costs involved in
removal and affects the economic analysis.
Construction of a sediment rating curve relating sediment to stream
discharge would be useful in calculating average sediment inflow.
This would allow the proper weight to be given to large, infrequent
events and prevent them from dominating the figures. This would
result in a more accurate estimate of sediment inflow and would greatly
aid in the analysis of alternatives.
Page 127 - The Forest Service has not compromised the Ashland Creek Watershed.
Management of the watershed has been and continues to be in accordance
with laws and regulations pertaining to the National Forests. The
EPA1s statement is an opinion which is not supported anywhere with
facts and as such, has no place in this document.
Page 132 - The final decision criteria for the Rogue River National Forest Plan
do not cover sedimentation or contamination in the Ashland Creek
Watershed. Therefore, the last sentence on the page should be deleted.
YPiiii1imments
ROBERT J. DEVLIN
Forest Supervisor
will assist you in making comments to the EPA.
cc: R.O. - Watershed w/Ene.
Ashland RD w/Ene.
City of Ashland, City Manager ~/o Ene.
Brazier w 0 Ene.
Wooding wlo Ene.
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C-6.b
~
USFS Internal Memo re
F;PA' 'Reeder.FEIS..::.
:".. - ......
UNITE:) S;- ~ TES D~f'A"p.,nlT OF AGRICULTURE
FOr<[~T 51 11VtCE
Re<;UE ilIVSR !;i.THli:^L FUREST
P. O. Box 520, 1-led::orrl, Oregon 97501
REPL Y TO: 1950 Forest Service t:EPJ\ ProceS5
September 5, 1980
--,
I
TO: Watershed Staff, Jim Wolf
SUBJECT: EIS - Reeder Reservoir Maintenance Operations
Below are my comments from my revi~w of the final EIS on the Reeder
Reservoir Maintenance Operations:
J
~
1. On page S and page 54, the EIS discuDoes the construction of 40 to
4S miles of logging road from 1956 to 19nJ. All road eronion calcula-
tions derived in the "Erosion and Sedimelltation in the Ashland
~"aten;hed" section of t.hl! EIS are based on these estim3ted road
mileagos. Nowhoro docs .1t expla in what roads mllke up t.hc:ne cst tmatC!l.
Road erosion estimates make up 66% of tho total volume of sediments.
'l'he report says, "The toIontgomcry study (1977) developed estimates of
erogion in tho watershed which correlate reasonably well with the
estimates of sediment quantities physically removed from Reeder
n.es~'1oir l3i nce the dam WllS completed in 1928. II These ~ediment calcu-
lations are used as a key basis for analynis of the activities ~ithin
the Ashland Watershed.
~
-..
If the figures used to do the analysis of this section are erroneous,
then the conc~usion5 based on th~s analyols may be wro~9 an~ subt;cr to.
reir.terpretat~on. The 40 to 4S m~les of rr,ad construct~on f~gure!i"~o
calculate sedimentation are in serious er~. There are only 21.2
miles of road above Reeder Reservoir conntructed since 1956 that could
add sediment to the reservoir. The use ~f this correct mileage will
have a significant reduction in the calculation of sediments from the
rOdd areas. The cstimates of crosion Bhollld no longor "correlate
reasonably well with the estimates of sedIment quantities physically
removed from Reeder Reservoir...since 192r!." Findings and recommen-
dationn based on this correlation are very weakened or wrong. ,
The estimated 40 to 45 miles of constructl!d logging road figures used
in the report appear to be made up of the following:
",.
Fl.. 21.2 miles' of road built since 1956 within the Ashland
Watershed that could possIbly contribute r.ediments to Reeder
Reservoir.
B. 8.5 miles of road built since 1~~~ in the Ashland Watershed,
below the dam. These sediments could not ~nter the reservoir.
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C-6.b
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",;C
Wateshed Staff, Jim Wolf
2
C. 18.2 miles of road built in the Neil Creek and Tolman Creek
drainages since 1956. These roads are outside the Ashland Creek
drainage and nonc of these sediments could enter the reservoir area.
The sum of l\. + B. ... C. "" 47.9 miles. The mileage calculations used
to build road sedimentation figures are wrong by approximately 26.7
miles. This is a serious error. It has distorted what is actually
happening in the Ashland Watershed and has created a false picture of
the results of our management practices within the area. It must be
corrected.
2. The !:lcdiment removal data stated within the r::IS and in Table 5-2
on page 53, does not report the volume of the sediments removed from
the original stream banks along l,shland Creek within the area utilized
by r~cder Reservoir. The original stream ~lnks werc reported to be 5'
to 7' high along the original stream channel.
The inclusion of t.his material, as Ucing part of thc m.c1n-lll:ld\.l .1n<1 :;t,)!'m
sediment!) washed into the dam that have to be removed, could be anoth~r
serious error in the calculation of sediments washed into the darn.
3. The statements, "The harvesting of timber and other recent
watershed uscs have compromised the water supply purpose of the
i\shland Wa tershed. In re trospect, the disruptions consti tute an
unwise, short-term use of the watershed lands at the expense of ;;":.]in-
ten.:lnce and enh.:lnccmcnt of the water supply use of the wat.ershcd. It
is hoped that new U.S.F.S. management policies will correct this
unwise use in favor of protection and enhancement of the water supply
uses of the watershed." are found on page 127.
These are opinions stated as fact. They can cause us serious problems
in future discussions with the City agencies. The EPA should be ~ade
well aware of this misuse of their powers.
These opinions .'lre based on the Montgomery report discussion On sedi-
ment production on which I have commented in item #1 above. It points
out the seriousness of Montgomery's mistakes and the conclusions that
can be derived from them.
4. The key evaluation criteria for finding the preferred alternative
is the method and timing of sediment discharge from Reeder Reservoir
to Ashland Creek to (.1) minimize tlamage to the fisheries and (2) to
minimizc the loss of stored water from Reeder Reservoir during
cleaning. Cos.ts are also considered (pg. viii).
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,
Watershed Staff, Jim Wolf
:I
The damage Lo the fisheries expected on clean-up years could be
mi.tigated by planting needed fingerlings into both Ashland and Bear
Creeks after the dredging and/or sluicing activities are over. This
would maintain the fisheries for those critical years involved until
a full study of the Bear Creek drainage is made.
The City of Ashland has had no problem achieving a full dam after
clean-up years. . Water flow predictions from U.S.F.S. snow courses and
other sources, combined with the technical expertiso of the city
managers, have prevented this problem from occurring in recent years.
Other downstream effects Appear to be very minimal, from discussions in
the EIS.
It appears that a simple alternative of continuing the present sprin~
draining and sluicing and the replacing of the lost fisheries with
needed fingerlings \.JQuld also be a viable alternative and should have
been discussed.
~~ .
.(. ~~~ Cl~Quq -
GEORGE \vOODING \
forest E.A. Coordinator
cc:~
I-Iheeler
Wooding
Devlin
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C-7
Forest Service Comments and Response
on Forest Policy Report (indirect
comments on Ashland Study)
C-7.a
Letter re FPP
r .
Report from USFS
Research Soil
Scientist
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
INTERMOUNTAIN FOREST AND RANGE EXPERIMENT STATION
316 EAST MYRTLE STREET
BOISE. IDAHO 83706
July 2, 1980
r-Mr. William E. Bruner
Forest Policy Project Director
3600 Main Street, Suite I-A
Vancouver, Washington 98663
e
L
Dear Mr. Bruner:
I have reviewed the complete report, SOCIO-ECONOMIC AND ENVIRONMENTAL
IMPACTS, prepared by Montgomery Engineers as you requested. I found
it to be factual, complete, and well written. It is not clear to me ,
who will be using this report to analyze environmental impacts of .
alternative forest activities, but I aSSlwe it is policy makers with
varying levels of expertise in this field. Any broad overview of such
diverse material must make sacrifices toward simplicity, however, I
feel it is unbiased and will well serve policy makers needs.
Since:.~ ~
r::. CUYTON~
~~~r~h Soil Scientist
JUl 7 1980
~
~
C-7.b
USFS Comments on JMM
Forest policy-
Environmental Report
I
.,..
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
Region 6
P.O. Box 3623, Portland, Oregon 97208
1950
August 21, 1980
Mr. William E. Bruner, Project Director'
Forest Policy Project
Washington State University
3600 Main Street, Suite I-A
Vancouver, Washington 98663
L
~!E~fEUW
AU G 2 6 19.8-0_
r
Dear Mr. Bruner:
JMM
Thank you for extending the time available for us to review the
Environmental Assessment portion of the Draft Report for Study
Modqle IV. Specific Forest Service comments are enclosed.
In general, what is in this document on air quality is reasonable
if one considers what is and is not known.
However, we can not endorse the whole report, because of the
liberal use of personal opinions and the tone of the writing
detracts from its credibility. The Montgomery Report cites some
of the poorest examples of land management and represents them as
the normal or standard practices.
Again, my thanks for the opportunity to extend the review of this
document. If we can assist you further in this project, please
let me know how.
Sincerely,
~ -1~~ b ~ t1 c.-L)"
ft~i. l~~fNG;tbN
~ Reg10nal Forester
Enclosure
AUG 2 2 1980
6200-11 (1/6')
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C-7.b
FOREST SERVICE COMMENTS tlW
DRAFT REPORT FOR MODULE IV
ENVIRONMENTAL ASSESSMENTS
2-14. The reference that there are pulp ~ills in the Medford-Ashland
area is misleading.
2-16. The "conflict between municipal watersheds and timber harvesting"
is overstated and is not a supportable statement. For example, in the
Portland Watershed there is substantial monitoring data available to show that
there was no increase in sediment in the period from 1962 through 1976.
Though monitoring capability has greatly improved, the mean turbidity levels
are essentially the same as they were in 1911 when a year-long monitoring
program was conducted by an independent Federal agency. Yet, the Montgomery
Report states that a proble~ of increased sedimentation and turbidity as a
result of timber harvesting exists in the Portland watershed. With very few
exceptions, the occasional high sediment measurements in the Bull Run watershed
have been the result of the activities of the City Water Bureau in developing
impoundments or of high intensity storms or a combination of the above. This
fact is supported by data collected by the City Water Bureau and evaluated by
the City's Water Quality Engineer. The reference to the Ashland watershed and
the statement that IItimber harvest does not appear compatiole with municipal
watersheds protectiorr' is based on a report prepared by the author of this
Module and was prepared in the same style as used in this paper. There are
many erroneous conclusions supported by little factual information. The JMM
Ashland Report is not only rejected by the Forest Service and forest industry,
but it is not endorsed by the city fathers in Ashland. The Ashland Report
ignored such important points as channel erosion (one of the largest sources
of sediment in the area). The report did not develop statistically sound
information on surface erosion to tbe point where knowledgeable statements
could be made. The poor quality of the Ashland Report should be stated as
part of the reference if it is to be cited as a reference.
,..~'t
. ,
1 '\
3-36. The inclusion of fertilizers and fire retardants under "Herbicide
Use in Western Oregon" is unwarranted. }.ittle information regarding herbicides
is included in the report, but lots of "newspaper" level statements and some
opinions are included.
4-57. The information in,Table 4-15 gives some impTessive, though
unsupported, erosion rates. Some of the ~vicus omissions are sen~itivity of
the watersheds, erosion control efforts, culvert spacing, soil types, and even
more important, the contribution of sediment to live streams at critical
points. without this type of information, such tables are meaningless to
professional hydrologists, soil scientists, or water quality specialists, and
what is worse, they are misleading to the layman.
4-60. The mitigation measures are quite inconclusive. There are a
number of publications concerning roads, timber harvesting, range management,
and a municipal watershed management that have more comprehensive lists of
mitigation measures.
" '_e".'''._.~.----..
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C-7.b
4-68. Again, inadequate and misleading information from
Ashland Report. The table does not include channel erosion.
admits that collecting supportable data is outside the scope
and that information used came from the Idaho Batholith with
to correlate erosion rates.. The statement does not consider
trol measures~ The statement considers only erosion and does
de,li very rates or any conversi on to get to sedimentation.
\
the (JMM77)
The statement
of the JMM Report
no attempt made
any erosion con-
not address
\,
4-73. This is an additional statement of opinion laced with an out-of-
context quote. The fast paragraph contains a very controversial assumption,
that is still unresolved. Most of the major municipalities in the Northwest
derive their water from surface sources that are all or in part on federally-
managed lands. Most of these systems receive only minimal treatment" consist-
ing of clorination, because water flowing from these lands is of such high
quality that they meet al~ standards for turbidity. Filtration systems are
expensive and naturally the communities are resisting the expense of the
installation. This is the type of information that should be provided in the
rc port.
.'
"
.--- :', .
4-76 and 4-80. On page 4-76, the author indicates that knowledge is
inadequate to determine the effects of grazing on fiSheries, but on page 4-80, ~
the report advocates that three-fourths of the fishery must be lost if grazing,
even with acceptable mitigation, is allowed. The importance of grazing on
federal lands is much too important to the ~egion to have such misleading
information used in this report. There are IItnnerous areas where documented
range management practices have shown little effect on such important param-
eters as water temperature or intergravel sedimentation. ~,. I, _ ,of-\)o .
. ~~~~
4-91. The implication is made and a case is presented (for california~
Utah, and Nevada) that all O.R.V. use is damaging to the soil and that it must
be limited to only light use to prevent significant erosion and sedimentation,
etc. No evaluation is made of the value to the Region of the O.R.V. form of
recreation.' Also, no evaluation is made of "factual, measured" impacts
O.R.V.'s have on the environment. ",
During the course of evaluating eros~on sources in the Tillamook River Basin
Study, the impact of O.R.V.'s was considered bec~use of political pressure
from an interest group. The findings were that though i~ some instances where
use was concentrated measurable erosion was evident, the contribution of sedi-
ment resulting from O.R.V.'s was so insignificant it 'was dropped from the
report. This is the' result of an on-site study in Oregon, not an extrapolation
. of reports without;: data from another Region.
,.
The following general comments are in response to the section on Water Quality
Impac ts due to Mass Erosion:'
1. This section is not a complete review of the state-of-the-art efforts
to classify land types by mass wasting potential, as is implied elsewhere in
the report. The implication that the landslide susceptibility factors' listed
on pages 4-64 and 4-65 are commonly accepted is incorrect. There is some
debate about the importance of some of the criteria among leading workers in
the field of study.
-2-
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C-7.b
2. Much more detailed work in land type and landslide Classification,
than that shown here, is now being done by Forest Service personnel.
3. The Mass-Wasting Units may be of use for planning purposes. The
Units ?re very broad, and generarry only able to define high or low landslide
hazard potential for different rainfall rates. .
4. There is no field data 'to confirm the use of Idaho Batholith data as
a model for erosion on the Ashland Pluton. Certainly, those erosion rates
could not be extrapolated to other areas of the State without a great deal of
evidence.
5. The erosion model described in the section on impacts to water sup-
plies from municipal watersheds does not stress the importance of sediment
(and organic materials) routing to the development of an accurate picture of
the erosion process. Nl?_ ~idiment routit\g _st1.1dy has been done for the Ashland",
Watershed; the implication of this report is thQt all the sediment volumes go
directly into the water supply,_ and that is erroneous.
The following comments cover environmental assessments of Range~ Forest Insect
and Disease, and Fire Management situations:
Ran~e
1. Broad general statements are used and are mostly those expressed by
"Anti-grazing" views. It is not recognized that many of the examples used are
those of extremely overgrazed areas. For instance, we have personal'knowledge
and observation of the area in Rock Creek in Montana. There is no relationship
to managed grazing!
2. One of the problems, is':''''lhat grazing interests have not documented
examples of, where ~anaged grazing is protecting 'or enhancing water quality-
fishery values.
3. We must point,out thatpunmanaged excessive grazing can and will
result in the examples cited. However, all grazing can not be condemned
because of this. Well managed grazing, which may include 'controlled access to
stream sides, can result in maintenance and/or improvement of streamside condi-
tions.
Forest Insect and Disease Management
If I see no mention of the importance of insects and diseases even though
case histories (section 3) were chosen '......the most significant constraints
on market uses of forest resources such as timber or intensive recreation.'
It might be well to point out that insects and diseases cause about 4 billion
board feet of growth loss and mortality annually and that this is about 30% of
the annual allowable cut in the Region (for lands of all ownerships). Much of
the growth loss and mortality is preventable through the practice of intensive
forest management which includes pesticide use and slash production.
, '
-3-
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C-7.b
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Insects and diseases also affect recreation uses bv killing trees in recrea-
tion a~eas or causing defect that can result in ha~ardous conditions for
recreationists. Again, problems are preventable through tree and stand manage-
ment.
Effects of insects on range resources are alsq not mentioned. The grasshopper
control program being carried out by APHIS to prevent range damage is quite
si zeable in Oregon and Washington this year."
Fi re Management
2-3
to grass
forestry
Paragraph 1.
burning. Not
burning.
Says that eastern Washington particulated due primarily
sure where this came from but could be a ~roblem for
2-4 Same in paragraph 1, paragraph 2.
2-8 Para~raph 4. Note that particulates are a problem in Umatilla
County.
2-15 Paragraph 3, last sentence, optimistic but very probably true. Is
anyone going to attempt to quantify trends, i.e., how much less slash to be
burned 1985, 90, 2000, etc.
3-13 Paragraph 3, data does not support statement that slash burning is
a major factor.
Last paragraph, vegetative burning may be second largest source but it includes
grass fields, space heating, bac,kyard b11rning, and slash. And, these produce
less than 10% of particulates. See comment below regarding Table 4-7 on page
4-25. "u
3-14. Good.
4-2 to 4-6 Good.
Table 4-7, page 4-25 note that area sources Eugene-Springfield account for
49% of particulates; open and field burning 0.4%.
4-44 to ,4-50 Good.
I
6-7 and 6-8 Good~
"""4-
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DE,.ARTMENT OF PUIlUC WORKS
~J A... Ahln.. DI..ctor
C-7.c
Ashland Response to -
CITY HALL
Cormnents on JMM S-~3-412.3Z"
Forest Policy Report
ASHLAND. OaEGON
97120
IR? iE~IED WIE rm
SEP 12 1980 J);
I
.
~
mity Df i\!llJlaull
September 9, 1980
v."""'
Mr. William E. Bruner, Project Director
Forest Policy Project
Washington State University
3600 Main St., Suite I-A
Vancouver, Washington 98663
Dear Mr. Bruner:
A letter transmitted to you on August 21, 1980, by Mr. R.E. Worthington,
of the U.S. Forest Service, concerning the Environmental Assessment portion
of the Draft Report for Study Module IV has recently come to my attention.
I must point out several gross inaccuracies in the Forest Service
comments:
1. The letter states that the J.M. Montgomery Report on the Ashland
Watershed was not accepted by the "City Fathers." The report was in fact,
not only accepted by the ^s~nd City Council but by the Forest Subcommittee
of the Rogue Valley Council of Governments 208 Water Quality Review Committee,
the 208 Water Quality Review Committee itself, and the State of Oregon Dept.
of Environmental Quality. The Environmental Protection Agency has recently
completed a final EIS on Reeder Reservoir Cleaning Operations which reinforces
the findings of the JMM Report.
It is very difficult tohe:lieve that the Forest Service is unaware of these
actions since it is represented on many of these committees.
2. The JMM Ashland Watershed was not "rejected" by the Forest Service.
There were many areas of agreement and a few areas in which the Forest Service,
JMM, and the City of Ashland agreed to disagree.
3. Information concerning extrapolation of the basic principles found in
the Idaho batholith to the Ashland watershed came directly from the Forest
Service leading batholith erosion research specialist who examined the Ashland
watershed while the JMM study'was under way. This has been covered in several
background discussions.
-"~""~",,,::,.......,",,"<
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~ ~
Mr. William E. Bruner
September 9. 1980
Page Two
The Forest Service letter notes a number of other criticisms and
inaccuracies which do not appear to be warranted or supportable. It is
rather disappointing to see this kind of review.
The City of Ashland has found James M. Montgomery's work to be of
superior quality and continues to utilize their experience in forestl
engineering related problems.
Very truly yours.
Allen A. Alsing, P.E.
Director of Public Works
AAA:dp
bcc: Tom'Davis. James M. Montgomery. Consulting Engineers
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James M.. Montgomery, Consulting Engineers, Inc..
This brochure introduces the
firm of James M. Montgomery,
Consulting Engineers, Inc. Since
our founding in 1945, we have
provided a variety of pro-
fessional consulting services to
over 1000 separate clients, with
over 80 percent of our work for
repeat clients.
Our firm is recognized
internationally as a leader in
environmental engineering,
particularly in the design of
water, wastewater and storm-
water systems. Complementary
to this capability are the wide
range of planning and environ-
mental specialists on our staff
and the hundreds of monitoring,
laboratory analysis, policy
evaluation and planning studies
we have completed which enable
us to offer in-depth services for
planning and impact assessment
projects. Since prospective
clients may be unaware of our
background in these fields, this
brochure focuses on planning
and analytical studies.
We believe that planning studies
and impact assessments should
be integrated with each other, as
well as with the design and
decision making processes.
Unfortunately, this doesn't
always happen, but where it has
been accomplished, we have
seen implementation schedules
shortened and large savings in
construction costs.
We invite you to review this
brochure, taking time to
concentrate on the areas of
greatest interest. No brochure,
however, can completely reflect
our 35 years of experience. So
should you have any questions
regarding the firm and our
capabilities or wish more
information on specific areas,
please contact us.
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Fields .of Activity
Comprehensive Planning
Land Capability Studies
Facilities Siting Studies
Water and Wastewater
Master Planning
Capital Improvements Planning
Rate and Fiscal Impact Studies
Wastewater Management
Planning
Water and Wastewater
Engineering
Toxic Waste Management
Solid Waste Management
Nonpoint Source Studies
Passive Wastewater Treatment
Lake Restoration
Water Quality Monitoring
and Laboratory Analysis
Stormwater Management
Hydrology and Flood Control
Hydrogeology
Environmental Studies
Water Resources
Watershed Management
Natural Resources
Hydropower
Comprehensive Planning
Our planning staff includes land
use planners, geologists,
hydrologists, hydrogeologists,
water resources planners, fiscal
specialists, biologists and
environmental scientists. JMM
planning projects have covered
land use, improvement/expan-
sion of public facilities,
conservation of natural
resources, lakeshore develop-
ment, recreation, flood plain
management, fish and wildlife
protection, water quality and
water resources and the
determination of future growth
areas. Land use planning
services have been provided to
communities in Oregon,
Washington and Idaho. In
addition, we assisted the State
of Washington, Department of
Natural Resources, in the
development of a state renew-
able resources plan and
prepared a water resources plan
for southern Nevada for the
Nevada Division of Water
Resources. Our recreational
planning has included a parks
plan for the Tualatin Hills Park
and Recreation District at
Beaverton, Oregon, and a
component of the Oregon State
Outdoor Recreation Plan for the
Oregon State Parks Branch.
Our land capability studies have
included erosion hazard and
septic tank suitability maps for
the Flathead River Basin in
northwest Montana and
mapping and analysis of soils,
utilities, facilities, and land use
for a major water transmission
line at Portland, Oregon. Four
State of Idaho agencies con-
tracted with us to prepare land
impact/use maps covering 10
land characteristics for the entire
state. Another planning study
included the mapping of land
ownership, groundwater
characteristics, fish and wildlife
habitat, irrigated and irrigable
land and grazing quality in
eastern Idaho,
We have found that com-
prehensive siting studies are
economically efficient com-
ponents of engineering design.
As part of a design project
involving a water treatment
plant at Kennewick, Washington,
our staff performed an in-depth
analysis of four alternative sites
in which 93 variables were
considered. For the Portland
Bureau of Water Works, we
compared 55 variables against
19 route segment alternatives
for 10,000 feet of 50-inch
diameter pipeline. The Portland
study area involved rugged
terrain; commercial, residential,
park and industrial develop-
ment; and numerous utilities
and public facilities which could
be severely impacted by
construction of the pipeline. We
believe that such studies not
only assist in the determination
of the most economic locations
for development but assure the
public that a range of relevant
alternatives have been
thoroughly considered.
1
Water
astewater Master Planning
Over 200 master plans and
feasibility reports concerning
water, wastewater, stormwater
and industrial waste systems
have been prepared by our firm.
These studies have involved
alternative sources of ground-
water and surface water supply,
the siting and sizing of facilities,
alternative water and wastewater
treatment processes, computer
modeling of piping systems,
preliminary engineering design,
cost estimating, the evaluation
of financing alternatives,
management and implementa-
tion options, corrosion
monitoring and the evaluation of
the adequacy of existing
facilities. We prepared master
plans for both sewer and water
systems at Forest Grove,
Oregon. The plans provided not
only programs for capital
improvements, but were
integrated into the Forest Grove
Comprehensive Plan as major
future development considera-
Capi
Impro'vements Planning
tions. Other projects include
water system master planning at
Kennewick, Washington and
Canby, Oregon; sewer, water
and stormwater master planning
at Stayton, Oregon; and a sewer
master plan for the Unified
Sewerage Agency of Washington
County, Oregon. All of these
projects included the use of
computer modeling for systems
analysis.
JMM has been responsible for a
number of capital improvement
plans and fiscal impact studies.
A recent study was conducted
for the Arch Cape Water Service
District concerning the develop-
ment of a capital improvement
program for 5, 10 and 20 year
periods. Such capital improve-
ment programs were important
elements in planning studies for
the Tualatin Hills Park and
and
seal Impact
Our firm has an extensive back-
ground in evaluating institu-
tional and financial considera-
tions. This includes revenue
programs, federal/state loan and
grant applications, prospectus
preparation, fiscal impact
assessments and economic
feasibility reports. JMM has
completed over 65 financial
studies concerning water, storm-
water and wastewater systems
including, for example, our
water system rate study for the
City of Canby, Oregon. A
comprehensive analysis of
Recreation District; the Oregon
State Parks Branch; the cities of
Forest Grove, Canby and
Stayton, Oregon, and a number
of other communities through-
out the Northwest.
financing alternatives for waste-
water projects was completed
for the Idaho Department of
Health and Welfare (IDHW)
which included an evaluation of
funding programs in Oregon,
Washington and four other
western states.
astewater jManagement Planning
JMM has been responsible for
18 major areawide water quality
planning projects and 20 on-site
treatment studies for unsewered
communities. In Oregon these
include a watershed manage-
ment study for the City of
Ashland, a feasibility study of
passive treatment systems along
Bear Creek for the Rogue Valley
Council of Governments
(RVCOG) and an industrial waste
analysis for the Mid-Willamette
Council of Governments. In
Montana we prepared water
quality, land capability,
silviculture, urban runoff and
groundwater plan elements for
the Flathead Drainage and
developed mining, silviculture,
and construction source
management criteria for the
Mid-Yellowstone area.
We also prepared eight
preliminary community waste-
water facilities plans, a
management plan for the "sole-
source" Rathdrum Aquifer and a
lakeshore management plan for
the Panhandle Area Council at
Coeur d'Alene, Idaho. In Boise,
r
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JMM has a 35 year history in
the design of water treatment
plants, transmission and
distribution systems, storage
facilities and pumping stations,
as well as wastewater treatment
plants and sewer systems. We
have designed over 65 water
treatment plants, 3,700 miles of
pipe in diameters up to 144
inches, over 180 municipal
water reservoirs-the largest of
which has a capacity of
1,000,000,000 gallons, over 200
water and wastewater pumping
stations and 85 wastewater and
JMM offers expertise in the
many facets of managing toxic
and hazardous wastes. We per-
formed, for example, a study of
the Stringfellow Class 1 Disposal
Site for the California Regional
t
Water Quality Control Board
concerning leakage from the
confinement barrier. This
affected domestic wells and
required contaminant removal
and site rehabilitation. Other
We have completed 15 solid waste
management studies covering site
designs, groundwater, leachate and
gas control, flood studies,
financing, land appraisals and
environmental impacts. Examples
t
include the development of a
hazardous waste management and
disposal plan for the Ventura
Regional County Sanitation
District in California, preparation of
an EPA technology transfer report
Idaho, a management plan for
their underlying groundwater
reservoir was developed for the
Ada Planning Association (APA).
In addition, we prepared the
Idaho state-wide 208 plan for
IDHW and a water quality policy
plan for the APA which dealt
with construction runoff, urban
stormwater, future growth and
development, in-stream manage-
ment, the protection of sensitive
soiVslope and water-influence
areas, and performance criteria
for wastewater facilities.
industrial waste treatment
plants. JMM has been respon-
sible for over 75 EPA 201 grant
program reports and the design
of stormwater management
projects totaling over $60
million in construction costs.
JMM hazardous waste projects
have involved chemical analysis,
treatment and disposal, toxicity
classification and the develop-
ment of management plans.
on landfill gas migration and
energy recovery, and the
assessment of environmental
problems at sanitary landfills for
Phoenix, Arizona,
Nonpoint Source Studies
Our non point source back-
ground and experience is based
on over 35 studies involving on-
site wastewater systems, roads,
ski areas, silviculture, grazing,
mining, solid and toxic wastes,
agriculture, ORV's, herbicides,
hydrographic modifications, and
urban stormwater. One project
for the EPA summarized water
quality protection measures
related to timber harvesting in
the Northwest. Roads, recrea-
tion, timber harvesting, grazing
and mining were included in a
nonpoint source study for the
RVCOG at Ashland, Oregon. An
example of the firm's on-site
astE~water
s
Many JMM projects have been
concerned with passive waste ,.
water treatment. This innovative
approach utilizes marshes,
sedimentation basins, grassed
waterways and aquatic treatment
lagoons which have low require-
ments for energy, capital invest-
ment and operation/mainte-
Lake Restoration
nance. In one unique study, we
investigated the feasibility of
passive treatment along Bear
Creek in Jackson County,
Oregon. Forty-five sites were
evaluated involving existing
ponds, marshes or gravel
excavations. Pre-engineering
plans were prepared for two of
wastewater facility experience is
our study of groundwater
impacts and on-site systems
versus central treatment in
southwest Idaho. For the IDHW
we evaluated all existing non.
point source regulatory
programs in Idaho.
the sites. The Fairfield-Suisun
Sewer District in California
selected us to prepare feasibility
and pre-design analyses of
constructing a marsh to utilize
tertiary treated effluent and
provide fish, wildlife and
recreation benefits.
During the past ten years, JMM
has completed over ten lake
management and restoration
projects. These have included
the evaluation of Bay Lake for
Walt Disney World, Florida and
two preliminary lake restoration
studies in Montana. Other
examples were the monitoring
and restoration program for the
Lake Forest development, a
restoration plan for a 200-acre
lake at Spring Valley, and a
basin management plan for
Lake Casitas in California. For
the Metropolitan Water District
of Southern California, we
evaluated water quality and
biological data and
recommended a management
and recovery program for the
San Joaquin Reservoir.
onitoring and
JMM has been responsible for
over 100 water quality studies or
monitoring programs ranging
from waste stream monitoring
to highly sophisticated viral
analysis. These studies have
concerned lakes, reservoirs,
estuaries, marine ecosystems,
groundwater, surface waters,
effluent discharges and
industrial process streams. One
example of our experience is the
establishment of a 46-station
water quality monitoring and
evaluation program in the
Flathead Drainage of Montana.
We have our own EPA certified
environmental research
laboratory which contains gas
chromatographs, a mass spectro-
photometer, several atomic
absorption spectrophotometers,
total organic carbon and total
organic halogen analyzers, a
particle size analyzer, an electron
microscope, incubators for viral
and bacteriological tests, and
other analytical equipment.
Our firm has completed storm-
water management projects for
approximately 40 clients which
total over $60 million in
construction costs. These
projects have generally included
computer modeling using
programs such as HEC I, HEC II,
SWMM, and STORM; cost
analysis; facilities siting and
sizing; the development of
regional and on-site "best
management practices";
retention and detention ponds;
channel capacity and flood
profile analysis; public involve-
ment and the institutionall
ydrol
JMM has a staff of experienced
hydrologists who have been
responsible for over 100 hydrologic
studies. These include stream
routing, water budgets, runoff and
unit hydrograph analysis, flow
frequency determinations, flood
plain and inundation studies,
hydraulic and hydrologic modeling,
Our firm is experienced in a
wide range of groundwater
studies that have included the
preparation of mathematical
models to simulate future
groundwater conditions, analysis
of point and non-point source
contamination, monitoring and
data analysis, water yield studies
and the installation and testing
of municipal, industrial and agri-
anagement
financing aspects of implemen-
tation. Water quality improve-
ment is also an important
component of many stormwater
projects, and JMM has extensive
experience in this area.
Our stormwater projects include
a stormwater runoff and flood
study along Pringle Creek and
the Shelton Ditch for the City of
Salem, Oregon and stormwater
master plan for the City of
Stayton, Oregon. Other
stormwater projects were
performed for the Flathead
Drainage 208 Agency in
Flood
Montana, the Union Pacific Rail-
road Company, the North
Central Texas Council of
Governments, the San Diego
Regional CPO and San Diego
County. Stormwater projects
were also completed for 12
cities in California, 11 cities in
Utah and for the 11 th U.S. Naval
District's Point Mugu facility in
California. JMM's background in
urban hydrology and the exper-
tise of 15 staff hydrologists
provides added strength
to our capabilities,
JMM study evaluated the
hydrologic data collection, runoff
computation methods, flood
control programs, storm operations
procedures, and the use of
computers in data processing for
San Diego County, California,
Keizer, Woodburn and Canby,
and the Wickiup Water District
in Oregon. Other hydrogeologic
projects have been completed in
the states of Washington, Idaho,
Montana, Nevada, California,
Arizona and Wyoming. We have
utilized computer analysis
through in-house programs as
well as those developed by the
U.S. Geological Survey.
collection of flow data, water
resource inventories and feasibility
studies. We have been responsible
for four FEMA/FIA flood insurance
and hydraulic profile studies
including one for selected
waterways in Clackamas County,
Oregon utilizing the Corps of
Engineers HEC II model. Another
cultural wells. JMM studies have
also dealt with recharge
potential, waste disposal by
injection, groundwater basin
management, water budgets and
inventories, source analyses,
water master plans, groundwater
movement and storage, and
groundwater development plans.
We have performed groundwater
studies for the cities of Salem,
Environmental Studies
We have prepared over 55 major
environmental assessment or
EIS reports during the past 5
years. These studies have
evaluated the impacts of pipe-
lines, roads, fish hatcheries,
hydropower facilities, wastewater
systems, municipal water
facilities, flood control
programs, mining operations,
timber harvesting, grazing,
recreation facilities, hazardous
waste disposal, land develop-
ments and sanitary landfills. We
have prepared environmental
impact statements in
conformance with and under the
regulatory requirements of the
National Environmental Policy
Act and State Environmental
Policy Acts of Washington and
California. We emphasize the
integration of the environmental
assessment process with the
planning or siting of the
facilities which would generate
the impacts.
Our environmental studies have
been concerned with a wide
range of impacted resources
including marine and freshwater
fisheries, wildlife, water quality,
vegetation, soils, minerals,
public utilities and facilities,
energy, transportation systems,
residential and commerciall
industrial developments, air
quality, construction materials,
community growth and develop-
ment, institutional conditions,
and socioeconomic factors. In
order to assure comprehensive
evaluation, JMM has developed
and applied a normalizing
matrix methodology on 15
environmental assessment and
planning projects. This ensures
a consistent comparison of
positive and negative impacts
and provides a format for the
study process and report writing.
An example of JMM's
environmental experience is the
Idaho Environmental Overview
Study which was prepared for
the Idaho Departments of Water
Resources, Health and Welfare,
and Fish and Game, and the
Division of Budget, Policy
Planning and Coordination.
Environmental conditions were
inventoried throughout Idaho
including air quality; water
quality; land resources; fish and
wildlife species of special
concern; habitat areas for fish,
water fowl, upland game, fur
bearers and big game; rare plant
areas; high quality wild lands;
outstanding rivers and lakes;
and scenic, natural or
recreational lands. As part of the
inventory of land resources, we
mapped areas of flood hazard,
critical soil and slope,
geothermal potential,
earthquake zones, deteriorated
range conditions, mining
impact, deteriorated forest
conditions, second home sub-
divisions, accelerated change,
and solid waste disposal sites.
Water- Resources
Our firm has a long history in
domestic and international water
development projects_ They
have included power generation,
municipal and industrial water
supply, recreation, fish and wild-
life, public safety, low flow
augmentation, the modeling of
hydraulic/hydrologic systems,
inventory and analysis of water
and related land use, flow and
water quality monitoring,
regional water development,
irrigation and flood control. As
an example, one JMM water
resources development plan for
anagement
an 800 square mile area in
eastern Idaho included a water
use inventory and water budget,
an inventory and analysis of
existing land use and the
development of a water
resources plan. A similar study
was done for southern Nevada.
JMM is experienced in
developing watershed
management plans that deal
with the use of groundwater and
surface water, timber harvest,
roads, recreation, grazing,
mining, surface and mass
erosion, sediment transport and
deposition, and watershed
ural Reso
rehabilitation. The city of
Ashland, Oregon, retained us to
evaluate past and on-going
watershed management
practices in the Ashland water-
shed which is the City's sole
source of municipal water
supply. The primary emphasis
was on modeling erosion over a
22 year period and recommend-
ing a rehabilitation and
management plan. A JMM study
for the Pacific Northwest
Regional Commission examined
the impacts of forest manage-
ment on municipal watersheds.
Many of our firm's studies have
focused on natural resources.
We assisted the State of
Washington, Department of
Natural Resources, in the
development of a renewable
resources plan which is used as
a guide for the management and
development of the State's
natural resources. Other JMM
studies of this type have dealt
with land capability, mining,
natural resource areas,
lakeshore development criteria,
recreational resources, open
space, fish and wildlife, energy,
construction materials, and
human resources. We also
provided assistance to the
Northern Energy Resources
Company in the management of
baseline monitoring studies and
permit applications related to
coal mining in Wyoming and
Montana.
JMM has performed a number
of hydropower studies,
particularly involving the
rehabilitation of hydropower
facilities or the installation of
generators on existing dams.
One study for the City of
Hyrum, Utah, involved the
rehabilitation of a hydropower
facility on the Blacksmith Fork.
Because of the involvement of an
exceptionally high quality fishery,
an environmental assessment was
required. A similar study was
performed for Duchesne, Utah.
For Gillette, Wyoming, we
evaluated the hydropower
potential of the Keyhole Reservoir
on the Belle Fourche River
and for the City of
Bellevue, Washington, the
value of power generation
facilities on the water
transmission system was
analyzed. We also studied the
feasibility of reactivating a
power generating station and
have performed annual
inspections for the Alaska
Electric and Power Company.
Representative List of Clients
Ada Planning Association (Idaho)
Alaska Electric Light and Power Company
Aluminum Company of America
Arch Cape Water Service District (Oregon)
Ashland, City of (Oregon)
Atlantic Richfield Corporation
Bellevue. City of (Washington)
Boise, City of (Idaho)
Bremerton, City of (Washington)
Buhl. City of (Idaho)
California and Hawaiian Sugar Company
California State Water Resources Control
Board
Canadian Superior Mining Ltd.
Canby, City of (Oregon)
Canby Utility Board (Oregon)
Carnation Company
Caterpillar Tractor Company
Central Utah Water Conservancy District
(Utah)
C1atsop County (Oregon)
Clark County (Nevada)
Clark County (Washington)
Colorado River Commission (Nevada)
Colville Confederated Tribes (Washington)
Dallas. City of (Oregon)
Disney World, Florida
Douglas County (Oregon)
du Pont de Nemours, E.I. and Company
Eastside. City of (Oregon)
Elk River, City of (Idaho)
Eugene.Springfield Metropolitan Wastewater
Commission (Oregon)
Everett. City of (Washington)
Flathead Drainage 208 Project (Montana)
Forest Grove. City of (Oregon)
Fred Meyer, Inc.
General Electric Company
Gervais, City of (Oregon)
Gillette, City of (Wyoming)
Grand Central Stores
Helena. City of (Montana)
Idaho Department of Health and Welfare
Idaho Falls. City of (Idaho)
Independence, City of (Oregon)
International Paper Company
OFFICES LOCATED AT
Portland and Salem, Oregon
OTHER LOCATIONS
Arizona International
California Louisiana
Colorado Nevada
Florida Utah
Idaho Virginia
Jackson, City of (Wyoming)
Jet Propulsion Laboratory
Keizer Water District (Oregon)
Kennewick, City of (Washington)
Kooskia, City of (Idaho)
Las Vegas Valley Water District (Nevada)
Los Angeles County Sanitation District
(California)
Los Angeles Department of Water and
Power (California)
Mandan, City of (North Dakota)
Marion County (Oregon)
Metropolitan Water District of Southern
California (California)
MidWillamette Valley Council of
Governments (Oregon)
Mid.Yellowstone Areawide Planning
Association (Montana)
Molalla, City of (Oregon)
Montgomery Ward Company
Mountain Home. City of (Idaho)
Nampa, City of (Idaho)
National Science Foundation
Nestle Company, The
Nevada Division of Water Resources
Northern Energy Resources Co.
Oregon State Health Division
Oregon State University
Pacific Northwest Bell Telephone
Company
Pacific Northwest Regional Commission
Panhandle Area Council (Idaho)
Pocatello, City of (Idaho)
Portland, City of (Oregon)
Provo, City of (Utah)
Provo Canyon Sewer District (Utah)
Reedy Creek Improvement District
(Walt Disney World, Florida)
Rogue Valley Council of Governments
Sacramento. City of (California)
Salem. City of (Oregon)
Salt Lake County (Utah)
San Diego County (California)
San Francisco. City of (California)
Sea World, Inc.
Skidmore, Owings and Merrill
Smucker, J.M. Company
Southern California Edison Company
Southwest Gas Corporation
Stauffer Chemical Company
Stayton Canning Company
Stayton, City of (Oregon)
Sunkist Growers Association
Sweet Home, City of (Oregon)
Texaco Oil Company
Tigard, City of (Oregon)
T owmotor Corporation
Tualatin Hills Parks and Recreation District
(Oregon)
Twin Falls, City of (Idaho)
Unified Sewerage Agency of Washington
County (Oregon)
U.6. Air Force
U.S. Army Corps of Engineers
U.S. Department of Housing and Urban
Development
U.S. Department of the Navy
U.S. Energy Research and Development
Agency
U.S. Environmental Protection Agency
U.S. Federal Emergency Management
Agency
U.S. National Park Service
U.S. Office of Surface Mining
U.S. Veterans Administration
Washington State Department of
Natural Resources
Western Idaho Potato Processing
Company
Western Oil and Gas Association
Weyerhaeuser Company
Wickiup Water District (Oregon)
Woodburn. City of (Oregon)