Threat to California’s forests – Working Forest Management Plans

 

STEALTH ATTACK on California Forests. STOP AB904

AB 904 authorized a new form of Timber Harvest Plan – Working Forest
 Management Plan (WFMP),  The legislation would permit large long term
 timber harvest plans  “Working Forest Management Plans” (up to15,000
 acres)  – where the plans would  forever (in perpetuity – one could
 question anything  land use plan with no horizon). These plans could (and
 likely would – eventually) comprise up to 2 million acres of forestlands
 in California. Additionally, once approved – the WFMP may  not be
 upgraded to comply with new advanced management criteria.

Time to write your state representatives and stop this ill conceived plan. You can also

donate to Coastal Action Group, one of the last defenders of our forests.

There are serious problems here that represent a very large threat to
statewide forestry management issue.  The ownership combining issue (as
per Bill Craven and Paul Mason – who helped write the legislation) – was
specifically a no-go – due to too many complex management issues. Calfire
has their own reservations.  And – in fact – the original NTMP
legislation did not intend ownership combining –  the Board of Forestry
Rule Writing process hijacked the language to make “A forest land owner”Â
to “Forestland owners”  (everything was made plural – and nobody
challenged this change). It would not be a good thing to let this happen
again – 15,000 acre THPs permitted forever.  There are other serious
problems – read below.

If this goes unchecked – the public and responsible agency will be,
 forever, removed from the process of managing private (non-industrial)
 forests in our State.

New rules (approved by the Board of Forestry May, 2017 for the forests of
the State of California – Statewide – creating Working Forest Management
Plans – where combined acreages can be put into a single plan – where a
simi-CEQA  process is applied once –  the plans are good forever –
 without future review of harvest plans or updates in new rules governing
 forest management.  This will occur (the rules are approved) – even
though these rules  allowing for forever WFMPs are not consistent with
other State Code (as mandated in the authorizing legislation).Â

This is a very large problem and significant threat to our forests. . CAG
is currently working with Sharon Duggan this litigation. .

See brief summary (and note on combining properties from BoF) of the WFMP
issues – below.  We need to hear from you about your thinking on this
 issue – before we make any financial decisions.

AB 904 authorized a new form of Timber Harvest Plan – Working Forest
 Management Plan (WFMP),  The legislation would permit large long term
 timber harvest plans  “Working Forest Management Plans” (up to15,000
 acres)  – where the plans would  forever (in perpetuity – one could
 question anything  land use plan with no horizon). These plans could (and
 likely would – eventually) comprise up to 2 million acres of forestlands
 in California. Additionally, once approved – the WFMP may  not be
 upgraded to comply with new advanced management criteria.

The benefit to the environment would be  the goals of: long term planning
that would allow un-evenaged management (no clear-cutting), rigorous
standards applied to inventory management attain a goal of Long Term
Sustained Yield – allowing for recovery of watersheds, forest stands,Â
wildlife and water quality values – with carbon benefits.

The legislation required the  California Board of Forestry to promulgate
rules consistent with the legislation and consistent with “all applicable
code.”  To a great extent the Board of Forestry did not follow the plain
language or the intent of the legislation.

The Nature Conservancy staff  and others that supported AB 904 – not
knowing how forestry works in California – left the rule writing
unattended with the result (final rules)  that none (zero) of the stated
goals (stated above – and – below – brief summary) can be meet.

The Legislation called for:

 Rule writing by the Board of Forestry – Consistent with all California Law
 – The newly approved rules do not comply with Cal Water Code, Forest
 Practices Act, and  Federal Clean Water Act

Rule writing by the Board of Forestry – Providing for Erosion Control
Management Plans to address existing and potential sediment sources  –
The newly approved rules do not include potential sediment sources and
allow for workarounds to this requirement – thus not consistent with
Porter-Cologne (Cal Water Code), regional Basin Plans, and the federal CWA
(not TMDL compliant)

Rule writing by the Board of Forestry –  that plans provide  analysis
that assures and measures the intent to meet long term Sustained Yield –
Growth and Harvest analysis.  The current approved rules do not assure
 and do not provide  capability for rigorous analysis (stated by the
 California Board of Forestry and Fire Protection – see file on agency
 comments).  In fact, current rules make the goal/task impossible. 

Rule writing by the Board of Forestry – to provide a 5 year periodic
review process that includes public participation.  The public may write
 letters but is locked out of any meaningful position to review data and
 have any say in the future of these plans

Rule writing by the Board of Forestry is supposed to protect forest
resources as well as water quality resources.  Nope ! – the rules
circumvent these responsibilities – including compliance with TMDLs and
Porter – Cologne.

Rule writing by the Board of Forestry – does not assure un-evenaged
forestry management or Long Term Sustained Yield.

Rule writing by the Board of Forestry – revised the intent of the
legislation that the lands comprising a Working Forest Management Plan be
owned by a single entity (“A person” or a single ownership entity).
Combining ownerships was explored and found impossible to manage due to
 differences in land types, inventory bases, management styles and goals,
 types of silviculture used – and/including – effects of potential changes
 of ownerships complicating issues. Calfire sees issues in apply rigorous
standards, assessment of compliance,and other issues (see – Calfire
comments at the Rule Making Website).  This all can turn into a huge
 problem – subjecting much more than the 1,200,000 acres (projected) that
 could be combined in these plans. Please understand that i ndividual and
 grouped landowners can keep Notices to Harvest open for 7 years (with no
 acreage limitations) on multiple ownerships with varying types of
 management goals and silviculture (with no assurance of  un-evenaged
 management – while not being consistent with other State Code or rules
 upgrades).

Alan  Levine
Coast Action Group
Affiliate of Redwood Coast Watersheds Alliance
126 Steiner Ct.
Santa Rosa, CA 95404

Leave a Reply

Your email address will not be published. Required fields are marked *