August 9 (2000, 2003)
Timber Harvest Opposition ~ Letters to CDF

Date: Wed, 9 Aug 2000 09:26:01 -0800
To: Bill_Newsom
From: Russell Towle

Bill, it's not much, but this is what I sent to CDF:
August 9, 2000

6105 Airport Road
Redding, CA 96002

re: proposed timber harvest near Dutch Flat

Dear CDF,

I am writing to oppose the timber harvest plan involving the 125 acres near Dutch Flat in Placer County. The original harvest plan had a number, 2-99-239-PLA(3). The new harvest plan, which I have not seen, apparently involves extraction of the sawlogs by helicopter.

As I mentioned in previous comments, this property is contaminated with mercury to an unknown extent. The parcel(s) involved are adjacent to the town of Dutch Flat and include various historic mines. The timber to be harvested grows largely on steep slopes which received tailings from mines both on and off the property. Thus it is likely that these slopes are contaminated with mercury. Removal of trees and the consequent rotting of their extensive root systems, may lead to increased levels of mercury entering the Bear River and a tributary in the harvest area, the Little Bear River.

While this potential addition of toxic mercury to our rivers and streams does concern me, I would oppose the harvest anyway. I do not like to see timber stripped off such steep slopes. Dutch Flat is noted and valued for its scenery, not for its ugliness.

There was and there is considerable local opposition to this timber harvest. Yet very little has been done by CDF to keep the Dutch Flat community apprised of developments. Moreover, the public comment period seems to have been truncated. It looks a little underhanded and sneaky to me.


Russell Towle
Box 141
Dutch Flat, CA 95714

Date: Wed, 9 Aug 2000 15:05:39 -0800
To: "Terry Davis"
From: Russell Towle
Subject: Re: Placer County Potential Wilderness

Hi Terry,

The Auburn Library does not have a copy of the North Fork Wilderness Study. It seems to me that there ought to be a copy at TNF headquarters in Nevada City, haven't checked yet.

Tomorrow I will be scrambling through Giant Gap, in at Green Valley, out by way of Canyon Creek Trail.

Date: Sat, 9 Aug 2003 09:20:41 -0800
To: North Fork Trails
From: Russell Towle
Subject: Letter to CDF
Cc: Rex Bloomfield, Steve Hunter, "Steven T Eubanks"

Hi all,

Below, my somewhat hurried attempt at a letter to CDF re the Lost Camp timber harvest. The more letters we can get in to Schultz the better. Short letters are fine. Talk the historic townsite, the trail, the need for a longer public comment period, etc. Letters may also be faxed to 530.224.4841; but in any case, remember to use the THP number, 2-03-040-PLA.
August 8, 2003

William Schultz
6105 Airport Road
Redding, CA 96002

re: Timber Harvest Plan 2-03-040-PLA

Dear Mr. Schultz,

I have now had an opportunity to review the actual Timber Harvest Plan, and the CDF PHI, with respect to the "Andy Siller THP," THP 2-03-040-PLA. I have a number of comments.

First, however, I ask that the public comment period be extended through at least the end of August, and preferably, the end of September, so that many interested citizens can have a better chance to become acquainted with the THP, and offer comments.

Second, I ask that CDF conduct an archeological review of the site. Although I am unable to examine the RPF's archeological survey-it is kept secret, and with good reason-from my reading of the THP and PHI I am inclined to think that his survey was inadequate.

Although historic and prehistoric sites are likely to be scattered across the entire area, the locus of historic mining and occupation was at the town of Lost Camp, in Section 23. From Lost Camp several trails led away to different places. One, the so-called China Trail, is a particular favorite of many people, and gives access to Tahoe National Forest (TNF) lands encompassing the North Fork of the North Fork of the American River (NFNFAR), to the southeast of Lost Camp.

I saw no reference to Lost Camp as a townsite-it "boomed" in 1858-and I saw no reference to the China Trail, in the THP. In fact, in the copy of the THP I obtained from Auburn-Bowman CDF, the trail seemed to have been, somehow, deleted from the more-detailed maps.

This trail is a very important component of our historic trail system in Placer County. The more southern part, across the NFNFAR from Lost Camp, climbing to the summit of Sawtooth Ridge, has already been effectively obliterated by timber harvests, on private lands, administered by CDF.

Concern for this trail goes back to at least 1953, when it was one of sixty historic trails listed in a Placer County ordinance, enacted by the Board of Supervisors, all formally declared to be public trails, and assigning misdemeanor-type penalties to whomever might block such a trail.

I do find the trail on page 30.2 of the THP, which shows the entire extent of the 600 acres involved in the plan, and distinguishes areas of tractor yarding, from areas of helicopter yarding, proposed in the plan. The trail and trailhead can be seen on this map, with difficulty, in the more southeastern portion of that part of Section 23 involved in the THP.

We have had tremendous problems, in Placer County, with our historic trails. They have been gated closed; they have been obliterated by timber harvests; and this process began before 1953. In the Placer County ordinance, each of the sixty trails is referenced to one or more old USGS maps, which depicted that trail. In this case, the China Trail shows clearly on the 1866 GLO map T16N, R11E. So does the town of Lost Camp.

In addition to the various intervening USGS maps of this region, the trail is also depicted on the 1962 TNF map of the Big Bend and Foresthill ranger districts. It is also shown on the current USGS 7.5 minute Westville quadrangle.

Because I am both interested in Placer County history, and concerned about the preservation of our historic trails, and public access to these trails, I have urged, for a number of years, that TNF seek to acquire all private lands in Section 23. By purchasing these lands, both the historic townsite, its associated mining areas, and the China Trail could be protected. They form an important part of Placer County's heritage.

By a twist of fate, as I understand it, the leader of the movement to protect our historic trails, in 1953, was Wendell Towle Robie, of the Auburn Lumber Company; and either Robie himself, or his lumber company, owned the very lands now involved in THP 2-03-040-PLA.

I have been informed by CDF archeologist Rich Jenkins that rather narrow conditions must be met for a historic trail to be treated as a historic trail, in the context of a timber harvest. Perhaps the China Trail does not meet the narrow criteria. However, I asked Rich, and he offered no response: where in the Forest Practices Act does it condone the destruction of "trails," whether they meet the narrow criteria or not?

Now, as to more specific components of the THP.

The Lost Camp mines, within Section 23, are of several types, but all involve placer deposits, likely Eocene in age, and the largest mining areas are relicts of hydraulic mining. Add to these a complex of gullies which look to have resulted from a related method, known as ground-sluicing. I believe there were some drift mines in the area. In both methods, the auriferous gravels were washed through sluice boxes charged with mercury. This mercury not only leaked directly from the sluice boxes, through cracks between the boards, but also leaked out the ends of the sluice boxes, where the tailings were discharged.

Hence many of the smaller ravines in the area are very likely contaminated with mercury, as are the larger streams below, such as Blue Canyon, Texas Canyon (not so named in the THP; Texas Canyon is identified as a Class II watercourse in the THP, and is that stream across which one of the new roads is proposed in the THP. It is to the east of Lost Camp, the town, and has many small tributaries, and many of these tributaries are likely to be contaminated with mercury), the NFNFAR itself (not within the THP boundaries), and Fulda Creek (partly within the THP boundaries, but not actually contaminated from the Lost Camp mines, but rather-and this is an outright guess-by placer mining on the creek itself, upstream.

Therefore, construction of roads and skid trails in the small tributaries of Blue Canyon and Texas Canyon in particular, may remobilize mercury, causing it to move downstream, or have local biological effects.

I have found it difficult to understand the THP, and have had little time to read it and make adequate notes. So, I sometimes recall reading some statement within the THP, but do not remember where in the THP that statement was made. Hence I will not reference many of my comments to page numbers in the THP.

One rationale given for the timber harvest is that, by removing overstory, the smaller trees will be released. This is true. However, this site has been harvested in the not-too-distant past, overstory removed, smaller trees released, and the result, in many areas, is a drastically overstocked stand of small conifers, such that high mortality is now occurring, and a tremendous fuel loading of dead and dry woody material exists. I see this especially within Section 23. The THP also asserts that harvest will reduce fuel loading and thus protect against wildfire. I see no provision for removing the existing dead and down small trees, and suppose that with further overstory removal, i.e., the harvest of the remaining larger trees, even more fuel loading will ensue. If anything, the larger trees should be left alone, and smaller trees removed.

In contrast to Section 23, lands in Section 24 to the east, on the ridge between Texas Canyon and Fulda Canyon (let us call it the Fulda Ridge), contain a nice stand of timber which has been more lightly logged, by selective means, in past decades. The forest canopy was left intact, and there is much much less understory, little brush at all, and every chance that a "cool" fire would leave the larger trees alive. However, being within the THP, this ridge-top stand will likely be decimated, sunlight will flood in on soils disturbed by tractor logging, and a very dense and overstocked stand of small conifers will ensue.

I have explored part of the east side of Fulda Ridge, and have found, on the steeper slopes, and along the area of inflection between gentler and steeper slopes which roughly coincides with the boundary between tractor yarding and helicopter yarding, as depicted in the THP, various old trails and ore-cart haul trails associated with hard-rock gold mining. I saw many large Douglas Fir, one ancient tree near six feet in diameter, and one Ponderosa Pin with an old blaze, and the large bark plates typical of an old-growth tree. I would call these trees "old-growth." There was never any commercial logging down there, only a minor taking of trees, principally Incense Cedar, I believe, for mining purposes, around a century ago.

Taking an educated guess, the lands within the THP, across Fulda Creek to the east, have likewise never been logged to any appreciable extent, and there might be regarded as old-growth stands. However, the THP specifically states that no old-growth stands are involved in the harvest.

The THP also declares that no scenic values are at stake, and that no one would even see the harvest area, except from a plane or helicopter. This is not true. I have been hiking in this area for thirty years, and the scenic qualities are very important to me. Much of this area, for instance, can be seen from Sawtooth Ridge. Fulda Canyon itself is quite remarkably beautiful, with many waterfalls. I much enjoy the views from the China Trail, for instance.

Please create a buffer zone around the China Trail, in which no harvest takes place. I suggest a radius of .25 mile from the trail.

I have been told, by someone long familiar with this area, that the trout fishery on the NFNFAR has been ruined by sedimentation on the main stem and tributaries. I do not doubt but that this is true. It is not mentioned in the THP.

The THP mentions probable negative impacts upon raptors, and states that no Northern Goshawk nests were found in the area. Two days ago, on Fulda Ridge, I was startled by a sharp peeping much like that of a Northern Goshawk, in a stand of pines. I could see no nest, and the bird moved away, down the slope, and I never saw it. It much reminded me of the peeping I heard last summer from Goshawks at a nest site in the North Fork American River canyon.

The THP does not mention the existence of Foothill Yellow-legged Frogs in the project area. I have seen these frogs in the NFNFAR, and in many other streams, large and small, and based upon my experience, would expect these frogs to live in Blue Canyon, Texas Canyon, and Fulda Canyon, and their tributaries, wherever accumulations of cobbly sediment are found, and also, in some areas of bare rock (adult frogs will inhabit bare rock areas). A better survey of both raptors and amphibians seems called for.

Finally, with respect to the proposed new roads, I am quite concerned. This seems an extremely heavy-handed component of what is in any case, in my terms, a rather drastic timber harvest. I have examined the course of the proposed road across Texas Canyon, with its associated steep slopes, where a very large culvert will be needed. This haul road is needed only because, it seems, the existing road over to Fulda Ridge, to the east, has been gated closed. I suggest that all harvest east of the main Lost Camp Road be yarded by helicopter; in fact, the entire project should be yarded by helicopter.

If I had more time I could do a better job of relating my comments to specific pages and sections of the THP. Please do extend the public comment period.

Thank you very much for your consideration of these issues.


Russell Towle

Ladybugs (Coccinellidae Family)
along the NFNFAR near Lost Camp
Date: Sat, 9 Aug 2003 20:40:50 -0800
To: North Fork Trails
From: Russell Towle
Subject: Lost Camp THP Breaking News

Hi all,

I have this, from a good source:

>CDF reports that, as a result of the 2 comment letters they've received on
>this THP raising concerns relative to the plan's impact on historical and
>archeological resources, the public comment period is remaining open
>In response to these two public comment letters (presumbably one of them is
>Russell's), CDF has (1) requested the RPF that prepared the THP to respond;
>and (2) assigned its inhouse archeologist from Redding to investigate for
>the presence of archeological and historic sites, and how the proposed plan
>would affect these resources.
>I think Russell's efforts are having an impact, although it is unclear how
>long CDF will keep the public comment period open.

Also, Jim Ricker has found, in recent conversations with CDF officials, that the public comment period is expected to remain open for as many as ten more days.

If anyone wishes to see Lost Camp and hike the China Trail, let's meet tomorrow, Saturday, 10 a.m., at the Alta Store, north of the Alta exit on I-80.


Russell Towle

[I missed the post below on Aug 7; I'm putting it here so the content will get into the searchable database of this blog, and will sort it properly later —Gay ]

Date: Thu, 7 Aug 2003 11:47:58 -0800
To: North Fork Trails
From: Russell Towle
Subject: Lost Camp THP reconnaissance
Cc: Rich Jenkins, "Bill Slater", Steve Hunter

Hi all,

I joined Steve Hunter of Colfax for a reconnaissance of the Lost Camp THP area yesterday. We left at 8:00 a.m. and drove up to the Blue Canyon exit on I-80, proceeding south and across the railroad tracks to the road fork leading east to the ridge (let us call it Fulda Ridge), in Section 24, between Fulda Creek and Texas Canyon (Texas Canyon is not so named on the modern USGS 7.5 minute Westville quadrangle, but is named on the 1866 General Land Office map of that area). We found this road gated closed with a sign reading "no trespassing" and "if you enter you will be shot."

Another road forked left near the gate and we tried it. It almost immediately leveled out and I realized it had been cut into the line of an old ditch, which could only be the historic Bradley & Gardner Ditch, or Placer County Canal, which drew from the East Fork of the North Fork of the North Fork, and went to the hydraulic mines of Dutch Flat and Gold Run, arriving in 1859. It was following almost exactly the 4680' contour where we met it. In a while we reached a locked gate, and, knowing the ditch must swing around Fulda Ridge, followed the road in. We passed a group of small cabins of recent construction, and then suddenly the road ended and we could follow the ditch itself. It is about five feet deep, and six or eight feet across at the top, and was said to have a capacity of 5000 miners inches, in the olden days.

A little less than a mile along the sinuous course of the ditch brought us to Fulda Ridge. Immediately below us to the south, a fine stand of coniferous timber had shaded out the brush, and made for easy going. We noted flagging where we left the ditch, marking it as a "truck road," and knew we were just entering the Lost Camp THP, on the north line of Section 24.

This forest had been logged at least twice, decades ago, we believed, but by a "selective" method, in which only the largest trees had been cut, and the forest canopy had remained largely intact, and no brush and relatively few small trees had become established, in the shade. So, it was a pretty patch of forest, and easy to walk through, and as we descended, the crest of the ridge flattened out to a dead level. Unfortunately this forest will be pretty well all harvested, according to the THP.

Steve has explored this area almost incredibly thoroughly over the past fifty years. He and his friends have pulled off some amazing adventures. For instance, Fulda Creek, below us to the east, has a steep gradient which only gets steeper as it approaches the North Fork of the North Fork, to the south. There is a series of high waterfalls along the creek, and essentially no way to hike up or down this section. Steve and his friends brought ropes and rappelled down the cliffs beside each waterfall in turn, all the way to the river, and then came back up the China Trail.

But this was only one of Steve's forays into lower Fulda Creek. On other occasions he had found an unusual old mining railroad. Since this is within the THP we wished to document it. I myself also hoped to discover some shred of the old trail from Lost Camp to Monumental Camp, constructed in 1862. However, in this I failed. The logging of decades ago had involved bulldozers, and the usual disruption of the land surface had effaced any sign of the old trail.

Reaching the southern end of the flat top of Fulda Ridge, where it drops away in ragged cliffs of the Shoo Fly Complex metasediments, into the main North Fork of the North Fork canyon, we veered east and began working down towards Fulda Creek. Almost immediately we struck a broad old trail or wagon road, which led back to the north and east. Following it, for a time I hoped it was my lost trail from Lost Camp, but soon it was obliterated by bulldozer skid trails from, what, 35 years ago. So we just angled on down the ever-steepening canyon wall, through a thinning mixed coniferouse forest increasingly dominated by Canyon Live Oaks, until another segment of broad trail or wagon road was reached, this, very nearly on a level.

Following it south, we passed sections of dry-laid stone walls, and finally reached a small mining area with abundant chunks of angular quartz scattered around. There the road-trail seemed to end. A sort of gully choked with angular talus was above the terminus, but no tunnel was visible. We made a short scramble beyond to some cliffy outcrops with fine views out into the main canyon, and we could see all the tributaries which make the Gorge of Gorges: Fulda, Sailor Ravine, the North Fork of the North Fork, the East Fork of the North Fork of the North Fork, Burnett Canyon and Wilmont Ravine, and Texas Canyon. Across the main canyon, Sawtooth Ridge rose steeply to Helester Point. There, a drastically ugly SPI clearcut made a square hole in the forest cover.

Fair-weather cumulus clouds graced the pure blue sky. It was cool, perfect for hiking.

Retreating north along the road-trail, I saw a faint old human trail leading down, and we followed it a short distance to a smaller trail, also about level, perhaps one hundred feet lower. This we followed south until it appeared to end at some cliffs. A bit of iron strapping stuck out of the trail at one point, of the sort one sometimes sees in old mine tunnels, a sort of poor man's railroad track, used for moving ore carts along the tunnel. Also, we saw an ancient cable stretching straight down the hill. Steve's recollection was that this cable led down to his mining railroad. However, our level old trail must be explored first, so we turned and followed it north.

It too had its dry-laid stone walls, and we walked it for a long distance, well, a quarter-mile perhaps, and saw Douglas Fir trees of increasing size, one, perhaps six feet in diameter. Strangely, the THP specifically states that there is no old-growth forest within the plan area. These large trees are clearly old-growth. The only logging which had ever occurred at this depth within Fulda Canyon (we were near the 4200' contour), was minor harvest of medium-sized trees, for mining purposes, around 100 years ago.

Suddenly, though, the old trail was crossed by what seemed to be a skid trail, which had been undoubtedly made by a bulldozer, and yet which looked very old. No stumps in the area signalled that it had been made for logging. Its rough steep bench cut had been much softened by the passage of decades. We tentatively ascribed an age of fifty years to it. The level old trail did not seem to continue, so we followed the steep bulldozer trail down a short distance. There we found large stockpiles of quartz ore, and a variety of mining equipment, including an ore cart, a sort of crucible, and several odd tubes of galvanized metal, something like water heater tanks, but meant to rotate on a longitudinal axis, some still having their axles. We could not imagine what they were for, but, clearly, it had to do with gold mining. They were of several different diameters.

We were now close to the creek, on a small flat, everywhere sloping, but not too far from level, and with a find stand of large Douglas Fir. Steve's sense was that we were far to the north of the mining railroad, which broke out onto the sunny cliffs we had visited earlier. So, with considerable difficulty, we contoured along to the south, while the creek fell away below us, and reached increasingly rocky areas with some rather large outcrops, almost house-sized. At one point Steve climbed up some shattered rock above me, and as I followed, I came within inches of a rattlesnake, which he had passed already. It was a calm snake, half-hidden in a hole, and did not rattle. I stepped away a few feet and climbed up after Steve.

After a time we found a great viewpoint and stopped for lunch. We reviewed the situation. It was impossible that the mining railroad had disappeared. It was virtually impossible that it could be below us. I suggested that perhaps his mining railroad was just the same as our lower level trail; but Steve recalled, vividly, railroad tracks crossing a cliff, and hanging into space. We had followed the entire length of the lower level trail, and had checked the slopes well for hundreds of feet below its line. So, what then?

As we continued, Steve saw a familiar-looking outcrop above us, and as we made for it, he saw a rail. A steep climb brought us to a gully where, perhaps a hundred years past, a trestle had supported narrow-gauge track. The trestle was gone, the track hung in the air, supported by cliffy outcrops at one side. So, we climbed over to the cliffy area, and, voila! There were the railroad tracks, winding sharply around a blasted-out bench on the cliff, and hanging into space at either end of this curved reach. Old cedar ties were still in place, with small railroad spikes, and round nails, and square nails too. It all suggested a turn-of-the-century date, around 1900. We had, again, tremendous views, very similar to those we'd enjoyed earlier.

It was hard to see how far the original line of trestle and track might have continued, to the west, but, as we climbed up above the tracks, the question was likely answered, for we caught sight of a steep-walled, steeply-plunging gully, which I recognized as a quartz vein complex which had been "stoped out" along the surface, to a depth of nearly if not more than twenty feet, measured perpendicular to the overall steep rocky slopes. This may well have been because the material closer to the surface was more weathered, and the gold easier to extract by ordinary, gravity-based methods, i.e., crushing followed by of a sluice box. Sometimes at greater depths, the gold is far harder to separate from other minerals.

We followed the stoped-out vein complex on up the cliff. I have seen very similar workings in the Stanislaus river canyon. At the top of the cliff, the stoped area continued down the far side, and we realized that we had returned to the southern end of our first, highest, level road-trail. Thus Steve's mining railroad was really part of the lower old level trail; and we had just been mistaken, when we thought it had ended at some rocks, earlier.

Thus, the two parallel, almost-level trails are ore cart runs leading from the stoped-out vein complex, north to the ore stockpiles in the little flat with the old mining equipment and the old bulldozed steep road.

Steve says there are other mining artifacts down along the creek itself. I want to emphasize that, not only are these artifacts on private property, but in any case, all such things should be left alone. Carry nothing home, no old railroad spikes, no arrowheads, nothing. Photograph them if you like. Be careful about even mentioning such sites to anyone. It is a shocking fact that many archeological sites have already been looted. This has to stop.

We climbed back to the level summit of Fulda Ridge and retraced our steps back to the ditch and to Steve's jeep.

Later in the day we took a look at various parts of the Lost Camp area, including the proposed new road, to cross Texas Canyon, which is detailed in the THP, and which will require rather extreme cuts on steep slopes and a huge culvert, and, all in all, I would like to see this and other new roads *not* constructed, for this timber harvest, instead, if any harvest occurs, let there be much more in the way of helicopter yarding, much less tractor yarding, and no new roads.

Later we drove down the Lost Camp Divide out of the THP area and into some horrible clearcuts on what I presume is SPI lands.

Such was a very interesting day.

Russell Towle

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