Ventana Wilderness Alliance
NEPA & CEQA Comment Letters

Ronald L. Pugh, Program Leader
Southern California Forest Plan Revisions
10845 Rancho Bernardo Road, Suite 200
San Diego, CA 92127

RE: South Fork Little Sur River
Monterey Ranger District, LPNF
Southern California Forest Plan Revisions

Dear Ron,

This is an amendment to our prior letter dated April 11, 2003 (copy attached). Listed below are several points we believe support inclusion of the South Fork of the Little Sur River in the current Wild and Scenic River suitability determination being conducted as part of the Forest Plan Revision process. Please give every consideration to these points and then include the South Fork in the suitability study.

1. The Los Padres Condor Range and River Protection Act of 1992 amended Section 5(a) of the Wild and Scenic Rivers Act by designating that the Little Sur River (among others) be studied for possible inclusion in the Wild and Scenic River System. The Los Padres Act identifies the river as, "Little Sur River, California - The segment of the main stem of the river from its headwaters downstream to the Pacific Ocean, a distance of approximately 23 miles." We believe it was the intent of Congress for both the South and North Forks of the Little Sur River to be included in this study because the only measurement of the Little Sur River that equals 23 miles includes both the North and South forks plus the main stem from their confluence to the ocean. This total of 23 miles is also specifically stated in the committee reports issued by the House Committee on Interior and Insular Affairs and Senate Committee on Energy and Natural Resources prior to enactment of the Los Padres Act. Recommendation for passage by these two committees, confirmed in these committee reports, was a prerequisite to the passage of the Act.
   
   It was clearly the intent of Congress under the 1992 Act to have both forks and the main stem of the Little Sur River (total of 23 miles) studied for potential inclusion in the Wild and Scenic River System. We believe that the suitability study now being conducted as part of the Forest Plan Revision process should be immediately expanded to include the South Fork of the Little Sur River to comply with this Congressional intent.
2. The Little Sur River has been identified as the most productive spawning stream for federally endangered steelhead (Oncorhynchus mykiss), south of the San Francisco Bay. It has also been classified as having a steelhead population that is a stock of special concern. The South Fork is an essential component of this spawning area because it does not have the history of seasonal impoundments that the North Fork has. [See: Titus, R. G., D. C. Erman, and W. M. Snider. History and Status of Steelhead in California Coastal Drainages South of San Francisco Bay. (In preparation - June 10, 2003 draft manuscript.) California Department of Fish and Game, Sacramento. See also: Nehlsen, W., J. E. Williams, and J. A. Lichatowich. 1991. Pacific Salmon at the Crossroads: Stocks at Risk From California, Oregon, Idaho, and Washington. Fisheries 16:4-21.]
   
   The presence of a significant spawning population of the endangered steelhead was not a qualifying ORV for the designation of the Big Sur River as Wild and Scenic. It is therefore appropriate to recognize this steelhead population as a qualifying ORV of the Little Sur River because it does not duplicate a qualifying ORV for the Big Sur River. And because the steelhead spawn in both forks, the suitability study should be expanded to include the South Fork of the Little Sur River.
3. An important archeological site exists along the South Fork of the Little Sur River recorded as (MNT 299) that was first surveyed by A. B. Elsasser of the University of California, Berkeley, in 1953. The site includes bedrock mortars and is evidence of early Esselen use and occupation. There are no recorded Esselen sites on the North Fork. This sole recorded Esselen site within the entire Little Sur drainage is a qualifying ORV for the South Fork which should be included in the current suitability study.
4. Portions of the South Fork are eroded into limestone and marble bedrock. In several locations, the river flow drains underground and re-emerges some distance downstream. There is also a significant gorge area eroded into the limestone and marble bedrock. By contrast, the North Fork of the Little Sur River is eroded primarily in granite bedrock. The limestone and marble of the South Fork qualify as an ORV because it compliments the different geology of the North Fork. The suitability study of the North Fork should be expanded to include the South Fork for this reason.

The most advanced river management recognizes that rivers are most effectively studied, analyzed and managed as complete systems within entire drainages. With the exception of rivers with existing impoundments, it is clear that Wild and Scenic River studies, at any level, should be consistent with this view and therefore be studied, managed and protected as complete drainage systems. We believe that no better example can be found of a river system that deserves to be studied and protected as a complete drainage that the North and South forks of the Little Sur River. Please include the South Fork Little Sur in the current study.

Sincerely,

Thomas A. Hopkins, Member
Board of Directors
Ventana Wilderness Alliance

Enclosure
Copy: Steve Evans, Conservation Director, Friends of the River