October 5, 2017
Mr. Robert Potts
Natural Resources and Planning Team Leader
National Forests and Grasslands in Texas
2221 North Raguet
Lufkin, Texas 75904
Ms. Theresa Mathis
Forest Planner
National Forests and Grasslands in Texas
2221 North Raguet
Lufkin, Texas 75904
Dear Rob and Theresa,
The Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) provide these initial comments regarding the U.S. Forest Service (FS) Wild and Scenic River Eligibility Study, Draft Report, 2016, and Wild and Scenic Rivers (W&SR) in general for the Assessment Phase of the National Forests and Grasslands in Texas (NFGT) Forest Plan revision.
Previous Wild and Scenic River Eligibility Study, Appendix E, Final Environmental Impact Statement, NFGT 1996 Land Resource Management Plan
The Sierra Club, in the early to mid-1990’s, when the Draft and FEIS’s for the 1996 Land and Resource Management Plan (LRMP) were prepared, criticized the FS for an eligibility study that was biased and inaccurate. The Sierra Club believed that the East Fork of the San Jacinto River should have been included as meeting eligibility and suitability requirements, that the scoring criteria were biased which artificially lowered scores, and that stream or river segment lengths were not prepared to best fit the part of each stream or river that flowed through the NFGT.
The Sierra Club is concerned that the recent 2016 W&SR Eligibility Study does not reflect the true number of stream or river segments that should be considered for suitability in the NFGT Forest Plan revision.
Comments on the Wild and Scenic River (W&SR) Eligibility Study, Draft Report, 2016
Page 1, Background, since this is the “initial comprehensive look” at W&SRs it is important for the FS to ensure that it does not assume that the results of the study are complete but ensures that analysis is done which makes the report better and unbiased.
Pages 2, Region of Comparison and 3, Angelina, Davy Crockett, Sabine, and Sam Houston National Forests, the Sierra Club is concerned that it was not alerted or invited to provide initial comments on the study which was done from July to December 2016. If this had happened many of the criticisms that are made in these comments would have been avoided. In the future, it would be helpful if the FS gave the Sierra Club and public an opportunity to make early comments before a document is used for decision-making.
Page 2, Eligibility Process and Overview, the reasons for the Interdisciplinary Team (IDT) choosing each Region of Comparison (ROC) specifically for the outstandingly remarkable values (ORVs) should be more carefully detailed so that the public can identify clearly what ORVs are considered most important for what type of stream or river in each national forest or grassland.
Page 5, Criteria for Eligibility, 1., refers to “immediate shorelines” within ¼ mile from either side of the river. It is important to remember that many floodplains crucial for the ecological and biological integrity of the stream or river, are wider than ¼ mile and therefore all of each floodplain should be used as beneficial criteria when assessing eligibility and suitability.
Page 8, Ranking of Outstandingly Remarkable Values, Table 2. Ranking of Outstandingly Remarkable Values, this table is inadequate because quantity and quality are inadequately addressed. There are no definitions given to differentiate locally common, locally significant, regionally significant, and nationally significant. This sets-up possible bias in the ranking process which does not give each stream or river an adequate opportunity to show its qualities.
Pages 9 and 10, Table 3. Rivers Identified as Potentially Eligible for inclusion into the National Wild and Scenic Rivers System on the Angelina, Davy Crockett, Sabine, and Sam Houston National Forests, the Sierra Club believes that this table is deficient and does not list all streams or rivers that are potentially eligible as our comments document.
Page 15, Table 5. Buck Branch, as an example (found throughout tables for streams in the report) of how the process can be biased, SHNF does not have the Sweetbay Magnolia Series with most of the plant species listed as indicators for this Series. This is because SHNF further west and south geographically than Angelina and Sabine National Forests. But the streams in SHNF are important and have spring-fed characteristics and vegetation that is similar to the Sweetbay Magnolia Series. SHNF should be judged on the characteristic vegetation that it has and not vegetation that it does not have. The same is true for the American Beech-White Oak Series. SHNF does not have this series but has similar vegetation, like American Beech-Southern Magnolia-Loblolly Pine Association, that serves a similar purpose.
SHNF has many good and high-quality bottomland hardwood forested wetlands that are indicators of good quality wildlife and vegetation habitat. However, it appears that this is forgotten in this rating and ranking process.
Page 45, Table 198. Lee Creek Segment 2, the Sierra Club finds it difficult to believe that Lee Creek has no ORV of interest except CCC structures and a historic sawmill.
Page 55, Table 23. Brittain Creek, the idea that a high bluff and geology is important for Brittain Creek makes sense. The same should apply to Harmon Creek, in the Trinity River Watershed, in SHNF, which has alkaline water quality, bank overlooks, and should be considered as eligible for the W&SR Study.
Page 91, Table 390. Big Creek, Henry Lake Branch has populations of Nodding Nixie and this fact alone should make it an eligible stream segment. Henry Lake Branch also has baygall habitat, extensive American Beech floodplain flat habitat, and bottomland hardwood forested wetlands habitat.
Page 103, Appendix A – Neches River Fish Value Review, this appendix does not mention that the Neches River has scenic, geologic, and recreational attributes via the Neches River Falls which is located alongside Upland Island Wilderness Area. These scenic, geologic, and recreational features should give the Neches River a higher ORV along this segment of the river.
Pages 105 through 128, Appendix B – Named River/Streams that Did Not Meet the Criteria, many of the streams listed in this appendix are given a “Rated very low on outstandingly remarkable values presence” rating but the FS fails to state how this rating process was structured, who rated the streams, and whether the people who rated the streams visited and walked them.
An example of the inaccuracy of the ratings process is Yellowjacket Creek in Angelina National Forest (Page 107) which in the 1996 LRMP is part of the Ayish Bayou Special Management Area, Management Area 8e, Special Bottomland Area, with a theme that includes “significant riparian or wildlife habitat characteristics where large old trees are maintained for aesthetics and wildlife needing old growth characteristics” (Page 247, Plan-MA8e, Standards and Guidelines). Yellowjacket Creek should have scenery that is at least as good as Cox Branch (Page 61) which has “Mature hardwoods”. You would think that inclusion in a Special Bottomland Area alone would qualify Yellowjacket Creek for eligibility as a W&SR.
Page 115, Piney Creek, is given the same low rating. The Sierra Club has walked this stream and its floodplain and rates the bottomland hardwood forested wetlands as good or high-quality. The Texas Conservation Alliance has submitted information to the FS that documents that Piney Creek in Davy Crockett National Forest should be a special management area. The Sierra Club supports this proposal and the eligibility of Piney Creek as a W&SR.
Pages 123 through 127, East Fork San Jacinto River, Winters Bayou, Henry Lake Branch, West Sandy Creek, East Sandy Creek, Boswell Creek, West Fork of the San Jacinto River, Alligator Branch, Harmon Creek, and Nebletts Creek, were rated low. The Sierra Club has walked these streams in SHNF and found that they have very high-quality bottomland hardwoods, or Nodding Nixie, or seepage streams with Sweetbay Magnolia, or other important high-quality features. The Sierra Club submitted comments to the FS on April 8, 2017 that included “Attachment 12, Special Management Areas and Sam Houston National Forest Ecosystems Information”, which documents that East Fork of the San Jacinto River, Nebletts Creek, Henry Lake/Double Lake Branches, and Winters Bayou should qualify for special management areas, specifically scenic areas, or special bottomland areas. This April 8, 2017 information documents that there are ORVs that make these streams or rivers eligible for W&SR Study. Attachment 1
Rivers That Should Be Listed as Eligible for a Suitability Determination and Recommendation to the U.S. Congress
Sam Houston National Forest – This national forest has streams or rivers that could be eligible for study for W&SR designation. These river or streams include:
West Fork of the San Jacinto River – In SHNF the West Fork of the San Jacinto River is near its headwaters which exists outside of the boundaries of SHNF in Walker County. The West Fork of the San Jacinto River is found within Compartments 25 and 46 on the northern and eastern boundaries of SHNF and by Stubblefield Recreation Area and Forest Road 215 on the south. There is potential Bald Eagle habitat in Compartments 25 and 46 and wintering and nesting Bald Eagles occur in the northern end of Lake Conroe, which lies just downstream where the West Fork of the San Jacinto River enters Lake Conroe. Over 400 acres of the best Forest Type 63, Sugarberry-American Elm-Green Ash forest, occurs in Compartments 25 and 46, in the West Fork of the San Jacinto River Floodplain.
West Sandy Creek – West Sandy Creek is a major tributary of the West Fork of the San Jacinto River. It is found in Compartments 24 and 25 in SHNF. West Sandy Creek has a significant bottomland hardwood forest and includes Red Buckeye in the higher portions of the floodplain or just outside the floodplain on the slope.
East Sandy Creek – In SHNF, Compartments 45 and 48 contain the floodplain of East Sandy Creek, which flows into Lake Conroe. In Compartment 45, some of the most extensive, densest, and most well-developed Flatwood Hardwoods (as described by P.A. Harcombe and P.L. Marks in 1979 in the “Forest Vegetation of the Big Thicket National Preserve”) that exist in SHNF are found. Attachment 2 This type of vegetation is also called Palmetto-Hardwood. The floodplain is concave and it is very easy to get lost in this beautiful bottomland hardwood floodplain.
According to a study conducted to determine “Ecologically Significant Stream Segments” for the Region H Water Planning Group, East Sandy Creek, for “Biological Function” displays significant overall habitat value considering the high degree of biodiversity; “Riparian Conservation Area” is within Sam Houston National Forest. Attachment 3
Little Lake Creek – Almost the entire watershed of Little Lake Creek, above FM 149, is found in SHNF in the almost 4,000-acre Little Lake Creek Wilderness Area. “Realms of Beauty – The Wilderness Areas of East Texas”, by Edward C. Fritz, describes this area as follows, “Acre for acre and pond for pond, Little Lake Creek is as wild as any area in Texas … Down by the creek grow the biggest trees – water oaks and American elms with resurrection ferns riding their large horizontal limbs as in the tropical cloud forest. Here also loom the white ash, sweet gum, bitternut hickory, and loblolly pine up to one hundred inches in circumference, and some winged elm. Carolina basswood, sugar hackberry, and river birch almost as big, all joining limbs at the top to nurture a dense, cool shade over the creek and its entire floodplain.” Attachment 4 There are also Green Ash flat ponds in the Little Lake Creek Fllodplain. The Lone Star Hiking Trail follows and crosses the floodplain and channel of Little Lake Creek in the Little Lake Creek Wilderness Area.
Harmon Creek and Tributaries – In SHNF, Harmon Creek and its tributaries, Spring Creek, Tanyard Creek, Ford Branch, East Fork of Tanyard Creek, Wayne Creek, and East Fork of Harmon Creek, all come together in Compartments 58, 60, 61, and 62 or just off of SHNF. Harmon Creek is on the cusp of the Trinity River Watershed and divides the SHNF from the San Jacinto River Watershed. Many scattered blackland prairies of the Fleming Formation are found in this watershed and create a more alkaline water quality as well as a more savannah and woodlands ecosystem rather than strictly a forest ecosystem.
According to a study conducted to determine “Ecologically Significant Stream Segments” for the Region H Water Planning Group, Harmon Creek, for “Biological Function” has bottomland hardwood habitat displays significant overall habitat value; “Riparian Conservation Area” is within Sam Houston National Forest; and for “High water quality/exceptional aquatic life/high aesthetic value” has exceptional aesthetic value. Attachment 3
East Fork of the San Jacinto River – In SHNF, East Fork of the San Jacinto River (East Fork) runs through Compartments 87, 95, 96, 101, 102, 114, 115, and 116. The East Fork has important bottomland hardwood forested wetlands on the largest stream in SHNF, baygall and seepage wetland habitats, protects groundwater and surface water resources and recharge areas and allows for flood storage and water energy dissipation. The East Fork has important riparian areas and is a corridor where wetland plants, fish, mussels, insects, and birds migrate downstream toward Lake Houston. The Lone Star Hiking Trail follows and crosses the East Fork floodplain and channel. Elevated old logging tramways (historic rail lines) are found within the floodplain.
According to a study conducted to determine “Ecologically Significant Stream Segments” for the Region H Water Planning Group, East Fork of the San Jacinto River, for “Biological Function” has aquatic habitat displays significant overall habitat value considering the high degree of biodiversity; for “Hydrological Function” has groundwater recharge of the Chicot Aquifer; “Riparian Conservation Area” is within Sam Houston National Forest; and for “High water quality/exceptional aquatic life/high aesthetic value” is an ecoregion stream with high water quality, diverse benthic macroinvertebrate and fish communities”. Attachment 3
Winters Bayou – In SHNF, Winters Bayou flows through Compartments 75, 84, 118, 119, and 120 (Compartments 118 and 120 make-up Winters Bayou Scenic Area). There are large areas of Palmetto Hardwood Flats in the floodplain of Winters Bayou. Some of the Palmettos are very large, about 8-10 feet tall. There are numerous water features like swales, oxbows, sloughs, abandoned channels, which create diverse topographic, geologic, and hydrologic regimes. The Lone Star Hiking Trail crosses the floodplain, channel, and scenic area along Winters Bayou. Winters Bayou is in the Winters Bayou Protected River and Stream Corridor.
According to a study conducted to determine “Ecologically Significant Stream Segments” for the Region H Water Planning Group, Winters Bayou, for “Biological Function” displays significant overall habitat value considering high degree of biodiversity; “Riparian Conservation Area” is within Sam Houston National Forest; and for “High water quality/exceptional aquatic life/high aesthetic value” has high water quality. Attachment 3
Henry Lake Branch – Henry Lake Branch flows through Compartments 89, 90, and 91 and Big Creek Scenic Area (formally Compartment 106). Nodding Nixie is found on Henry Lake Branch along with baygall habitat and springfed water and seeps. The Double Lake Mountain Bike Trail runs along part of the Henry Lake Branch Floodplain.
Nebletts Creek – Nebletts Creek is found in Compartment 98 in SHNF. This stream has extensive baygalls, is springfed, and has co-mingled and highly connected ground and surface waters. Both Northern Burmannia and Nodding Nixie have been found in baygalls on Nebletts Creek.
Davy Crockett National Forest – This national forest has streams or rivers that could be eligible for study for W&SR designation. See the report included with these comments entitled “Ecologically Significant River and Stream Segments of Region I (East Texas) Regional Water Planning Area”. Attachment 5 These river or streams include:
Upper Neches River (alongside Big Slough Wilderness Area and Alabama Creek Wildlife Management Area)
Alabama Creek (in Alabama Creek Wildlife Management Area)
Austin Branch
Camp Creek
Cochino Bayou (in the Cochino Bayou Archeological Area)
Hackberry Creek
Hager Creek
Hickory Creek
Lynch Creek
Piney Creek
San Pedro Creek
Sandy Creek
Big Slough (in Big Slough Wilderness Area)
Angelina National Forest – This national forest has streams or rivers that could be eligible for study for W&SR designation. See the report included with these comments entitled “Ecologically Significant River and Stream Segments of Region I (East Texas) Regional Water Planning Area”. Attachment 5 These river or streams include:
Upper Angelina River (in Upper Angelina River Special Bottomland Area)
Lower Angelina River
Upper Neches River (alongside Upland Island Wilderness Area and in the Neches River Corridor Protected River and Stream Corridor)
Ayish Bayou (in Ayish Bayou Special Bottomland Area and Ayish Bayou Archeological Area)
Attoyac Bayou (in Attoyac River Special Bottomland Area and Attoyac Bayou Archeological Area)
Boykin Creek (in the Old Aldredge Mill Site Special Management Area)
Falls Creek (in Upland Island Wilderness Area)
Graham Creek (in Upland Island Wilderness Area)
Big Creek (in Upland Island Wilderness Area)
Oil Well Creek (in Upland Island Wilderness Area)
Sabine National Forest – This national forest has streams or rivers that could be eligible for study for W&SR designation. These river or streams include:
Hurricane Bayou (in Indian Mounds Wilderness Area)
Bull Creek (in Indian Mounds Wilderness Area)
Indian Creek (in Indian Mounds Wilderness Area)
Patroon Bayou
Bear Creek and Pomponaugh Creek (in Bear Creek Special Bottomland Area)
The Sierra Club appreciates this opportunity to provide our initial comments on Wild and Scenic Rivers for the Assessment Phase of the NFGT Forest Plan revision process. Thank you.
Sincerely,
Brandt Mannchen
Forest Management Issue Chair
Lone Star Chapter of the Sierra Club
5445 Braesvalley Drive Apt. 738
Houston, Texas 77096
832-907-3615
brandtshnfbt@juno.com