Northeastern California Ethanol Feasibility Study
Environmental Effects Report

Contents

General
Key Environmental Issues
Soils
Water Quality
Wildlife
Monitoring
Environmental Analyses

General

The potential environmental effects of operating a commercial-scale biomass-to-ethanol plant include both the on-site and off-site impacts surrounding the production facility.

The on site environmental impacts (as well as local community impacts) are discussed in the site-specific evaluations conducted by the California Energy Commission (CEC) in the Site Characterization Study issued in April 1997. The CEC study is a component of this overall ethanol manufacturing feasibility study. The CEC study reviewed various environmental and infrastructure factors at six sites in or adjacent to the Sierra Nevada mountain range in Northeastern California. CEC also defined the permits required for siting such a facility. The prospective sites for the ethanol manufacturing facility are:

Loyalton in Sierra County,
Greenville and Chester in Plumas County,
Westwood in Lassen County,
Martell in Amador County, and
Anderson in Shasta County.

The types of potential effects that might occur in the forestlands from which biomass is harvested are outlined in the report that follows, as well as the prospective monitoring program for U.S. Forest Service (USFS) lands and the environmental reviews that are required by state and federal law. This report can be used to help frame the USFS's environmental analyses on federal lands, which must comply with the National Environmental Policy Act (NEPA) and other laws and regulations. Environmental analyses on private lands must conform with the California Environmental Quality Act (CEQA) and other laws and regulations, primarily under the California Forest Practices Act, which by law is considered to be the"equivalent" of CEQA. This report is a statement of what the key environmental issues are expected to be and how serious these issues are considered to be.

Cellulose biomass material will be generated from both public and private forestlands within at least a 25-mile radius of the ethanol facility. The cost-effective transportation distance will vary with the market price of the ethanol product and other factors such as type of road, harvesting costs, slope, access to roads and season. Projected amounts of biomass feedstock available from forest lands within a 25-mile radius of each of four potential facility locations in the Quincy Library Group area are shown (Tables 1.14 and 1.15 on page 26) in the report prepared by TSS Consultants: Feedstock Supply and Delivery Systems, June, 1997. The report predicts an available and sustainable, annual supply of between 187,000 and 336,000 Bone Dry Tons (BDT), dependent upon site. Sources of biomass will be timber harvesting by-products, certain lumber mill residues as well as forest fuels reduction treatments. The same report, using the Forest and Resource Assessment Program (FRAP) of the California Department of Forestry and Fire Protection, defined that USFS holdings (within 25 miles of the four QLG sites) ranged from 53% to 64%. This includes all lands, not just forested lands. Federally managed forest lands are expected to be a higher percentage.

Environmental reviews and public participation processes that are prerequisites for authorizing biomass harvest differ between land ownership types. On private timberlands, California Forest Practice Rules govern timber harvest practices. The California Department of Forestry and Fire Protection (CDF) is primarily responsible for regulating and enforcing timber harvests, with the regulation of stream crossings or alterations performed by the California Department of Fish and Game. CDF has an environmental checklist for CEQA compliance, requires a Timber Harvest Plan for each project over a certain size, and enforces Best Management Practices (BMPs). Such precautions address timber production sustainability, water quality, soil erosion and other concerns.

Biomass harvest activities on National Forest System lands Ò the presumed primary source for any ethanol facility within the Quincy Library Group's area of interest, since the majority of the forest lands are federally administered Ò must be subjected to National Environmental Policy Act (NEPA) reviews and public participation processes of the U.S. Forest Service. Like CDF, the USFS typically requires the use of BMPs to prevent or mitigate environmental impacts.

A. Key Environmental Issues

The QLG plan intentionally reduces the environmental impacts of the large scale-thinning program that is proposed (approximately 40,000 acres per year for five years on U.S. Forest Service lands) through adoption of various measures designed to reduce those impacts. These measures include:

• Use of the Scientific Assessment Team (SAT) riparian standards for timber harvest activities, which typically preclude timber harvest within two"site tree" lengths of a perennial stream;

• Precluding timber harvests on the primary old growth forest and anadromous fish stream areas of the forest by defining those areas as"Off-Base" or"Deferred" from timber harvests;

• Adoption of the California Spotted Owl guidelines (1993), which preclude trees over 30 " from harvesting as well as limit basal area and tree canopy reductions from thinning programs; and

• Precluding timber harvests in so-called "Spotted Owl Protected Activity Centers" (PACs) and "Spotted Owl Habitat Areas" (SOHAs).

The typical kinds of environmental concerns that arise from timber harvest and biomass harvest activities include the effects of roads and landings, riparian zone and water quality impacts, fuel loadings, wildlife disturbances, and changes in suitability of wildlife habitats. Generically, these are grouped here into soil, water and wildlife impacts. The Plumas, Lassen, and Tahoe National Forest Plans have standards and guidelines applicable to the protection of soil, water, and wildlife resources and the USFS region has adopted a series of BMPs.

1. SOILS

Soil concerns are expected to be heightened for biomass harvest and thinnings at the proposed scale. Merchantable logs (generally between 10" to 30" dbh (tree diameter at breast height) will be harvested by conventional methods. Subsequently, biomass operators using (for example) feller bunchers and chippers will take the smaller trees and logging slash and chip them on site. These operations will then either transport some of the chips for further use (e.g., ethanol, electric generation, particleboard, etc.) or broadcast the chips on site. Future fuels maintenance treatments, at appropriate times of year, will unusually include prescribed burning.

Soil compaction, soil surface disturbances, introduction of soil pathogens such as tree root rot diseases, accelerated erosion, and loss of nutrients are issues that require special attention and monitoring.

An example of the fuel treatments advocated by QLG is the "Highway 89 Defensible Fuel Profile Zone" currently underway south of Sierraville on the Tahoe National Forest's Sierraville Ranger District. This project, using funds allocated to the QLG area national forests by the Secretary of Agriculture, has currently (10/97) completed 300 of the 1341 acres scheduled in the project. 18,000 green tons of biomass material (chips) have been removed (average yield has been 60 tons per acre). From an administrative standpoint, it uses"service contracts" (biomass operators are paid to remove the material) and hand thinning by USFS crews to accomplish the project goals, prior to the reintroduction of prescribed fire. A"before and after" look at this project's tree density and size classes is illustrative of the type of thinning (on a larger scale) that is contemplated by QLG.

Highway 89 Defensible Fuel Profile Zone

The two primary national forests in the QLG area (Lassen and Plumas) discuss soils issues in their land and resource management plans and have also developed information subsequent to the adoption of those plans.

Lassen National Forest

The Lassen National Forest Plan and Final Environmental Impact Statement was finalized in 1992 adopted.

According to the plan, Lassen soils "have formed in weathered volcanic rock material" (pages 3-56 and 3-57 of the EIS) and "over the eastern portion the volcanic bedrock is highly fractured (and water normally sinks directly to groundwater with little overland runoff." The Lassen Plan adopted "Soil Quality Standards" that set specific objectives in the following soil areas: cover, porosity, organic matter, moisture regime, hydrologic function and environmental health. The plan also noted that the forest has 252,000 acres of soils with a high erosion hazard rating. The majority of the high hazard soils are due to steep slopes, but some are erosive rhyolite soils. The plan also noted that new sources of compaction such as biomass removal need to be analyzed and based upon research results determine standards on compaction.

The plan called for "a complete survey . . . to identify and prioritize areas requiring restoration. A Watershed Improvement Needs (WIN) inventory is scheduled for completion during the Plan decade" (p. 3-61). The Lassen Plan (p. 3-56) mandated specific practices on timber sales that included:

• Designing roads to reduce erosion,
• Locating skid trails to minimize compaction in other areas,
• Prohibiting heavy equipment in wet areas,
• Restricting heavy equipment from cinder cones and slopes steeper than 35%,
• Logging steep slopes by cables or helicopters to reduce erosion.

Lassen National Forest issued a Forest Plan Monitoring and Evaluation Report for fiscal years 1993-1996 in August 1997. That report's section on soils (p. 36) reported that no soil productivity monitoring has yet been accomplished but that some compaction monitoring (with a long shafted penetrometer) was accomplished in 1994 and 1995 on individual timber sales. No evaluations were given, other than a recommendation to amend the Forest Plan to incorporate monitoring strategies for soil compaction and soil productivity. Pacific Southwest Research Station of USFS is currently conducting field tests of soil compaction at its Blacks Mountain Experimental Forest in the Lassen NF that may provide strategies in this area.

Plumas National Forest

The Plumas National Forest Plan and EIS were issued in 1988 and finalized in 1989. The Plumas, in contrast to the Lassen, has "a wide variety of rock types (including)( metamorphic, granitic, volcanic and sedimentary" (p.3-3 of the EIS). These rocks"have resulted in diverse soils on the PNF. Generally, the warmer and more humid westside has deeper, more productive soils; the cooler, arid eastside has shallow, less productive soils." These conditions led to management prescriptions that focused upon use of"the field verified Soil Resource Inventory (SRI) ...the evaluation of productivity potential (total biomass production) and erosion hazard. ...Management focuses on limiting disturbances to reduce soil erosion and compaction. Management practices include maintenance of ground cover to reduce soil loss, limitation of heavy equipment use on moisture sensitive soils to reduce compaction and use of low and moderate intensity fires during prescribed burning to reduce loss of nutrients and soil structure." (p.3-85) The EIS showed 33% of the forest (387,000 acres) as having high or extreme soil erodibility potential. The 44,000 acres having extreme erodibility were defined as losing 0.96 inch of soil per year and over 150 tons per acre.

The Plumas National Forest is in the process of printing its monitoring report (10/97) entitled Plumas National Forest Monitoring and Evaluation Report FY 1989-1996. Along with the Lassen National Forest's monitoring results, the Plumas's monitoring data are expected to be useful in identifying specific soil-related concerns for further attention and adaptive management.

2. WATER QUALITY

The Plumas National Forest Plan addresses the myriad and often competing uses of water in the area."Water supports timber, range, fish and wildlife and other resources. Runoff is used for power generation, recreation, irrigation and domestic consumption both on the forest and downstream. {Water} consumption occurs as far south as the Los Angeles metropolitan area." (p.3-79). The condition of waters in the Quincy Library Group area thus have implications throughout California. The Feather River is the largest river emanating from the Sierra Nevada mountain chain. It drains the Sierraville Ranger District and most of the Plumas National Forest. The Feather, gathered at Lake Oroville, provides more than half the water for the State Water projectÌs aqueducts to Southern California. The Feather is also used at Lake Oroville and upstream for major hydroelectric facilities. The Middle Fork of the Feather is also a federally designated Wild and Scenic River. Certain westside streams on the Lassen NF (Deer, Antelope and Mill Creeks) also are the lone remaining spawning streams for spring run Chinook salmon in the Sacramento River system.

The QLG proposal and bill, as has been discussed earlier, take two steps (SAT, off-base/deferred lands) that should have important implications for water quality in the QLG area.

Adoption of SAT Standards

The Scientific Assessment Team (SAT) standards (adopted as part of the President's Northwest Plan) have five components relating to timber harvest practices in riparian areas. These are included in the QLG bill and agreement. Absent a site-specific watershed assessment that recommends tree removal for aquatic ecosystem purposes, the SAT standards preclude timber management in streamside zones and other aquatic resource areas as follows:

Off Base and Deferred Areas

A major proposed change in each of the three National Forest Plans would have certain areas (beyond current wilderness areas) precluded from timber harvest for at least the five-year term of the Quincy Library Group project. The proposed land allocation (as well as a digitized map) was included in the 1993 QLG agreement. The map was developed by VESTRA Resources (Redding, CA) and is also a component of the QLG bill. The QLG map was based upon mapping done in the 1980's as components of the three"environmentalist" alternatives to the three Forest plans (which were then under development). These earlier maps were not adopted by the national forests in question in their final forest plans. The QLG land allocation proposal is as follows:

The QLG Landbase

Current forest plans, law and regulations mandate that logging be precluded in wilderness areas and spotted owl sites (SOHAs and PACs). The QLG proposal would add 21 % of the national forests (slightly less than 500,000 acres) to areas where logging is precluded, at least during the five years of the QLG project proposal contemplated in the bill and the original 1993 QLG agreement.

These additional areas are primarily in large blocks of"Late Seral/ Old Growth" stands, high elevation red fir zones, botanical or special interest areas as well as important fisheries. Areas where logging would be precluded include, for example,

• the upper tributaries of Independence Lake on the Sierraville Ranger District,
• all of the Lakes Basin area above Graeagle on the Plumas National Forest,
• the entire canyon of the Middle Fork Feather River, ridge to ridge, from south of Quincy to Oroville Lake,
• the entire watershed of Nelson Creek (a tributary to the MFFR), and
• the entire watersheds of Deer, Mill and Antelope Creeks on the Lassen National Forest.

It is anticipated that these logging provisions, as well as the active watershed restoration activities called for in the QLG proposal and bill, will have beneficial and protective effects upon the waterways in the QLG area, immediately and over various time scales. The QLG thinning program itself is intended to lessen the propagation of large, stand-destroying fires and their attendant accelerated releases of sediments and debris in precipitation events.

The national forests themselves have adopted various protections in their forest plans to improve and protect water quality.

Lassen National Forest

The Lassen National Forest Plan (1992) states that"water quality is acceptable in all streams and lakes( road construction and clearcutting tend to cause sedimentation, which lowers their water quality. (Other potential problems are(giardia contamination,(nutrient loading, bank erosion and shade reduction from livestock grazing,(hazardous spills from highways and septic tank drainage,(temperature and sedimentation effects from geothermal and small hydroelectric development." (pp. 3-84-85). The Lassen Forest Plan calls for 1,500 acres of watershed improvements per year on the forest.

The previously noted Lassen National Forest monitoring report (8/97) states that Lassen water quality meets the standards set up in the 1992 plan. The report notes that BMPs were applied on 77% of sampled sites and that those were 90% effective. The same report calls for improved project planning and implementation. The riparian and watershed sections of the same report suggest amendments to the Forest Plan in the areas of changes in watershed condition and cumulative watershed effects (pps. 61-62). The same report (p.59) recommends"amendments to the forest plan to provide long term direction for anadromous watersheds [e.g. Deer, Mill and Antelope Creeks] and an ACS for areas outside existing ACS [Aquatic Conservation Strategy] areas"

Plumas National Forest

The Plumas National Forest Plan (1989) paints a different picture of water quality than the Lassen National Forest Plan."An estimated 70% of the water draining PNF lands meets State Water Quality objectives. However, due to degradation of water from private lands outside of the PNF boundaries, only 40% of the water flowing through and from the PNF meets State Water Quality objectives" (p. 3-82).

"Mine waste discharge and sediment from roads, mining and overgrazed meadows have been the most persistent degraders, but sediment yields from other sources are now causing additional degradation. The current average sediment yield from Feather River watersheds is about triple that of the Sierra Nevada Mountains in pristine condition. Sediment yield in the most degraded watersheds is seven-fold that of the pristine condition. Erosion and sedimentation are important problems in Spanish and Indian Creeks, the South Fork of the Feather River, and Slate and Canyon Creeks. Sedimentation damages aquatic habitats, hydroelectric facilities, and the State Water Project and increases flooding potentials." (pp. 3-82-83).

The erosion problems identified in the Forest Plan have led to increased activity in this area by the Plumas National Forest and others. Plumas National Forest was a charter member of the Feather River Coordinated Resource Management (CRM) group, active since 1985 and formalized in 1989. The CRM includes 21 distinct entities (e.g. Plumas County, Pacific Gas and Electric Co., Central Valley Regional Water Quality Control Board, etc.) that have entered into a long term cooperative agreement. The CRM goals include:

Identifying erosion sources,
Coordinating between public and private landowners,
Implementing erosion control projects where practical,
Ensuring project cost-effectiveness for contributors, and
Developing a cooperative regional erosion control plan.

The CRM (with USFS involvement) developed a variety of documents designed to guide activities to address erosion (and other riparian issues) in the Feather River. These commenced with :

U.S. Soil Conservation Service, East Branch North Fork Feather River, Erosion Inventory Report-1989.

This report categorized the various creeks according to their sediment contribution and identified Spanish, Wolf, Indian and Last Chance Creeks as the largest sediment sources. The CRM followed up this study with a more detailed look at two of the creeks:

Plumas Corporation, East Branch North Fork Feather River, Spanish Creek and Last Chance Creek, Non Point Source Water Pollution Study, 1992 and its companion publication

US Forest Service, Stream Classification and Channel Condition Survey, with an Inventory of Sediment Sources from Roads and Stream Crossings, Conducted in the Spanish and Last Chance Creek Watersheds, 1992.

These two studies developed detailed information for these creeks and a priority mechanism for restoration.

The CRM, based upon these previous studies, then developed an overall strategy designed to guide restoration work in the broader East Branch watershed (600,000 acres covering 24 subwatersheds- approximately one half of the national forest):

US Forest Service, East Branch North Fork Feather River Erosion Control Strategy, 1994 .

This report, signed by the agency heads of the cooperators, is guiding restoration work on the East Branch. The report has been used on the other Feather River areas in the Plumas National Forest (e.g. Middle Fork, South Fork). The overall strategy is also used, preliminarily, on the Feather River drainages in the Lassen National Forest (North Fork) and Sierraville Ranger District of the Tahoe National Forest (Middle Fork).

The Feather River CRM has also accomplished forty stream restoration projects since 1985 on both public and private lands. Cooperatively funded and designed projects have included fish ladders, restoration of an urban stream and abandoned mine tailings, meadow rewatering, bank fencing, revegetation and check dam building. These projects have used over $5 million from the cooperators, including, since 1995, funds provided to the local national forests by the Secretary of Agriculture for QLG-related activities.

Plumas National Forest also did resource assessments for all 48 subwatersheds across the PNF from December 1993-mid 1994. These unpublished resource assessments used standard criteria for assessing conditions, documented assumptions and criteria, developed"vision statements" for the subwatersheds and finally ranked watersheds for priority of work.

3. WILDLIFE

The three national forests in the QLG area have a great richness of wildlife in general and also contain a variety of wildlife (and flora) that have state or federal protections. Federal and State Endangered Species on the two main national forests (Lassen and Plumas) include the peregrine falcon, bald eagle, northern spotted owl (only on the Lassen NF, north of Hwy. 299 and outside of the QLG boundary), Shasta crayfish (Hat Creek and Pit River on the Lassen NF), spring run Chinook salmon (Antelope, Mill and Deer Creeks on the Lassen NF) and red legged frog . Sensitive species include the California spotted owl, goshawk, great gray owl, fisher, Sierra Nevada red fox, American marten and willow flycatcher (Sources: Lassen Plan pp. 3-99 to 3-101, Plumas Plan p. 3-41).

Each of these species is generally recognized to have habitat associations (although different studies continue to debate the implications of these habitat associations for different species). The Lassen Plan (3-98) and the Plumas Plan (3-39 to 3-54) note the habitat associations and forest successional stages apparently preferred by these species. These associations and stages are listed in the following chart along with an explanation of how the overall QLG project (as proposed in 1993) would treat these particular species.

Quincy Library Group Wildlife Review (USFS Lands)

Specific prescriptions must address specific habitat concerns (see also SNEP, Ch.56). The QLG bills mandate an EIS process as well as initiation of the process for amendment or revisions to the Land and Resource Management Plans on the pertinent Forests. The planning processes must identify the protocols, standards and guidelines for fuels management prescriptions to minimize potential impacts upon these species.

The extent to which the use of BMPs and other standard forestry management practices will effectively mitigate the effects of mechanical removal of vegetation is arguable, and will probably vary greatly with different practices, specific resources and different equipment operators. Implementation monitoring, training, and adaptive management will be used to improve mitigation efforts.

Monitoring Plan

Monitoring the results of biomass harvest will be critical to the overall success of the biomass removal program. The Quincy Library Group calls for an active and comprehensive monitoring program at various temporal and landscape scales. The USDA Forest Service has received funds from the Secretary of Agriculture, as part of the USDA support of the Quincy Library Group proposal, to develop and implement these monitoring programs. The QLG bills call for a"science based assessment"

The three National Forests (after discussions with QLG) presented a draft monitoring program to the QLG in March, 1997 (see attached Forest Health Pilot -Draft Monitoring Plan, version 2.6 -36 pps.). The three forest supervisors are currently (October, 1997) reviewing this plan in order to determine whether further revisions to the draft plan are advisable in order to comport the final monitoring plan with the monitoring and reporting requirements contained within the proposed QLG legislation.

The outline of the draft plan is an attachment to this report. The plan is designed to answer a series of questions:

Implementation

Are projects implemented as designed?

Effectiveness at Site Scale

Are soil quality standards met?
What are the impacts in streamside zones?
Are BMPs implemented/effective?
Is fire behavior modified?
How is vegetation modified in short term and long term?
How are fuels modified in short term and long term?
How is terrestrial habitat modified in short and long term?
Are watershed restoration projects effective?
Are Hypogeous fungi modified?
What are air quality effects of controlled burns?

Larger Scale Effects

Is aquatic habitat improved?
What are vegetation trends?
What are size and intensity of wildfire trends?

For the national forests in the QLG area, the road systems are pretty much already in place, and currently roadless areas will be not be entered under the QLG management proposal.

Environmental Analyses

Any particular project on federal lands has its environmental review conducted within the current regional or national context, which must take into account the latest and best available scientific information. The Sierra Nevada Ecosystem Project Report (Davis: University of California, Centers for Water and Wildland Resources, 1996)---referred to as SNEP--- was a multi-year, Congressionally mandated, interdisciplinary, scientific review of the status of the Sierran ecosystem. It is the most recent science on a broad scale. The SNEP Summary notes that:

Live and dead fuels in today's conifer forests are more abundant and continuous than in the past. (p.26).

...
Timber harvest, through its effect upon forest structure, local microclimate, and fuel accumulation, has increased fire severity more than any recent human activity. If not accompanied by adequate reduction of fuels, logging (including salvage of dead and dying trees) increases fire hazard by increasing surface dead fuels and changing the local microclimate. Fire intensity and expected fire spread rates thus increase locally and in areas adjacent to harvest. However, logging can serve as a tool to help reduce fire hazard when slash is adequately treated and treatments are maintained. (p.26).

...
Human activities, particularly timber harvest(and fire suppression, have drastically reduced the extent of late successional forests through the removal of large trees((p.6).

...
The DFPZs reduce the extent of [severe] fire by up to 1/3 over fifty years. (Johnson, Sessions, Franklin: Initial Results from Simulation of Alternative Forest Management Strategies for Two National Forests of the Sierra Nevada, SNEP Addendum, Chapter 6, p. 187.)

As hinted at in these brief quotes, the SNEP Report provides substantial scientific and professional support for the forest fuels management strategy proposed by the QLG. SNEP documents, along with other recently available scientific information, may be drawn upon for background and guidance in identifying and evaluating environmental effects associated with the forest biomass production side of the biomass-to-ethanol project.

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