Timber Havest Plan Submission and Review Process

California State Board of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244-2460

03/03/2003

Subject: Timber Havest Plan Submission and Review Process - Ciancio Petition ; in particular, related CLFA comments

Board members:

In three recent letters to Board members the CLFA has commented on the "broken" THP review process, and in particular upon plan submission. I will focus on a CLFA remark of May 20, 2002:

CLFA requests that the Board produce a clear standard or interpretation for CDF to use when applying the terms "accurate", "complete" and "in proper order". Standards for "submission" and "filing" should also be provided, and in so doing [sic], would climinate much of the confusion and uncertainty experienced by RPF's as they negotiate the maze of timber harvest regulations."

The minimal requirements for filing a THP are in fact specified in two and a half pages of detail in CFPR 1034, "Contents of Plan". It is difficult to imagine what could be possibly clearer instruction than those 36 items – which involve items as 'subjective' as a telephone number and address, or a map. Yet the CLFA suggests that these requirements are highly subjective, onerous and engender "complexity and confusion". I have heard heart-tugging rhetoric before now, but the CLFA's comments are absurd. These 36 items (which the CLFA neglected to mention) don't themselves constitute the criteria for acceptance of a THP (which may well involve contentious or difficult issues), but are merely criterial for a THP's intelligibility.

Still, a small percentage of THPs are found unacceptable for filing by CDF and are returned for 'fixing' -- for items as routine as missing telephone numbers, improper notification, and missing maps – as well as for inadequate explanation and justification. Yet RPFs are required, by law, to behave as professionals with many years of education and experience.

Surely, the solution to such problems is not in either additional regulation or additional oversight mechanisms, such as an ombudsman, but in continuing education of RPFs, and discipline where necessary.

Sincerely,

Jay Halcomb

Russian River Residents Against Unsafe Logging