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HomeMy WebLinkAbout1979-51 Watershed Mgt PlanRESOLU~ IO~ NO. 79- ~_~/ A R~SOLUTION OF THE CITY OF ASHLAND RELATIVE TO THE INTERIM MA2'[AGEMENT PLAN PREPARED BY THE U.S. FOREST SERVICE CONCERNING THE ASHLAND MUNICIPAL WATERSHED. WHEREAS, the Presidential Proclamations of 1893 and 1906 setting aside the Ashland Watershed, the Cooperative Agreement of 1929, and the Act of Congress of 1920, established provisions for the conservation and protection of the City of Ashtand's water supply; and WHEF~EAS, the City of Ashland and the U.S. Forest Service have coopera- tively pursued the adoption of an interim plan for the mnnagement of the Ashland MuniciDal Watershed; and WHEREAS, the U. S. Forest Service is in the process of developing an overall plan for the Rogue River National Forest as required by Presidential order; and WHEREAS, the City of Ashland concurs with the need for an interim plan to limit activities in the watershed until sufficient data is available to determine the effects of human activities on its water supply. NOW THEREFORE, BE IT RESOLVED as follows: SmC~ION ~ The City of Ashland hereby adopts the Interim Plan for the Management of the Ashland Municipal Watershed, conditional on the recognition o~ the matters set forth in the attached report entitled "Concerns of the City of Ashland Regarding the Forest Service Interim Plan" dated October 30, 1979, and labeled "Attachment A;" and further that the foregoing concerns be addressed to the satisfaction of the City of Ashland in the final Forest Management Plan for the Rogue River National Forest. SECTION 2. That the above concerns be added to the appendix of the approved copies of the Interim Plan so that all parties are aware of the City's position. SECTION 3. That the City of Ashland be advised, and given an adequate opportunity to respond, and its mutual agreement secured, prior to any proposed application of insecticides, herbicides or other chemicals. SECTION 4. That officials of the City of Ashland Water Utilit}~ be ~onsulted and kept fully apprised during the development of the final Forest Plan in those subject areas affecting the Municipal water qual- ity and supply. The foregoing Resolution was READ and DULY ADOPTED at a regular meeting of the City Council of the City of Ashland on the~f~~ day of / i . ~ ~/a~.~/~ , 1979 Nan E. Franklin City Recorder SIGNED and APPROVED this./~day ~L~ P/ickett, Mayor F()I~EST SERVICE ltO(;iJli R[VEi{ NATII)NAL FOREST INTERIM PLAN ASItLAND CREEK WATERSHED JACKSON COUNTY OREGON Forest S,~pervisr~r, Rog~e River National Forest P. O. Box. M,?df,~r:l, (;r,,gm~ 97501 r Date :,,y ', ~s~ a~, )regon Date * Subject to the conditions and exceptions contained in Ashland Resolution No. 79-51, attached hereto. October $0, 1979 ° ATTA CleMENT "A" CONCERNS OF ~{E CITY OF ASHLAND RECkRD ING 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 · Furest 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 ~as 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- ing: 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 conclusion 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 withdra~m 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 fie, fire management and the alternatives for controlling disease, insects and fire. The Interim Plan should present an objective discussion of fire, insects and disease, including their roles in natural forest ecology and their implications to water qualit)'. 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 hs 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 1982plan.. 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 Mr. 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 JN~ 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: "This, 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 co~mcides 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 coefficient§ 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 tim~ 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 road maintenance as also a potentially major contri- butor to erosion and sedimentation. The early batholith erosion s~udies 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 antithesis 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 in Roeder 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 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, 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 ~he 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. The implication of this would be that not only is the construction of roa'ds 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 vatins 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 granlt~c, batholith soils. The assumption of such relationships is also the only way to account for the large volmne 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 developed plan is produced. It is disturbing that ~he 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 research recommended 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 seme "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 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. '~rhe 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 watersh&d per se to preserve a watershed's water quality would have tremendous effects on the mining industry nationwide." ·his confirms the suspicion that, for the Forest Service, municipal water supply is below miniFg in priority, even when there is no significant poten- tial for mining. FIRE B~hNAGEMENT There seems to be some confusion about our concern and recommendations related to fire management in the watershed, so these are briefly summarized. 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. o 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 wildfire through unlogged watersheds can result in significantly less erosion and sediment movement than wildlife through a logged watershed. 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 of a large problem fire. We recommend that fire management involving intensive observation and quick response in suppressing all fires was the most appropriate program for the Ashland watershed. 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. 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. CITY INVOLVD4ENT ~mae 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. PLANMING 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 consider 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 Serx, ice. 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. PRIORITIES me 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. CH~d~NEL EROSION The Forest Service also expressed concern that the Montgomery analysis did not include channel erosion. It is our opinion that channel erosion, while undoubtedly occurring constantly in the Ashland watershed, is primarily an watershed proper, pJrticularly 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. FUTURE 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 including the ditch. b. Driving surface including the relationship to the ditch. c. Road fill surface. d. Ashland ski area. e. Undisturbed areas. Continual monitoring oi mass failure ~reas. 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 turbidity bedtoad Monitoring of total organic carbon at various locations in the watershed andreserw~ir (for the purpose of determining trihalo- methane potential).