Fire Safety, not Clear-Cutting! Stop the Logging! Stick to Defensible Space! Save the Trees - Napa, Sonoma and Mendocino
The state is about to do excessive logging as part of post-fire "emergency tree removal". The state is about to clear 300 FEET of trees around any permitted building! This is far in excess of what science recommends: the research shows 100 FEET of clearing is sufficient. PLEASE email or fax the Office of Administrative Law (OAL) to stop this excessive and unnecessary clear-cutting throughout Sonoma, Napa and Mendocino. Haven't Sonoma, Napa and Mendocino been through enough??
*** Deadline extended to at least Monday 1/22 ***
They finally say the comment period is now open but ONLY for the next five days. If they mean business days, then I suppose it means by Monday, Jan. 22. But I'm just guessing. So it would be good to get your comments in as soon as possible.
firstname.lastname@example.org and Eric.Hedge@bof.ca.gov (Cal Fire)
OAL Reference Attorney
300 Capitol Mall, Suite 1250
Sacramento, California 95814
RE: Public comment on the “Emergency Rulemaking to Facilitate Post-Fire Recovery Efforts within Counties of Napa, Sonoma, and Mendocino”
Dear OAL Staff Members:
We are concerned about the level of clear-cutting (“harvesting”) being proposed by the Board of Forestry and Fire Protection, dated January 5 2018. Removals proposed in the Emergency Tree Removal Documents are well beyond the level required for public safety, and would result in the removal of stored carbon, trees that could have survived, and valuable wildlife habitat, including habitat that supports wildlife protected under the Endangered Species Act (ESA). We urge you to reduce the area to be cleared around permitted structures from 300 feet to 100 feet of defensible space, as 100 feet is the current standard recommended by CalFire and many fire scientists who have studied the subject in depth.
We understand that your stated intent is to protect the post-fire environment. However, the proposed removal footprint appears to be more economical that ecologically relevant to a system that is currently in the process of regenerating after the fires. Therefore, the proposed actions do not represent good intent.
There are several fundamental issues related to the proposed removal of “all dead or dying trees” within 300 feet of any permitted structure, and there is inherent lack of balance between safety measures and environmental damage resulting from the proposed post-fire salvage logging. Proposed removal of “all dead or dying trees” could also include dead or dying trees being “chipped or piled and burned within forty-five (45) days from the start of Timber Operations.”
Our major concerns include (a) the excessive removal of trees around each structure, (b) the preliminary evaluations that are likely to underestimate the number of live and recovering trees, (c) massive amounts of carbon lost due to burning (e.g., for biomass) and other harvesting products, (d) the elimination of great swaths of wildlife habitat due to excessive removal of snags as well as trees that could be still alive, and (e) the elimination of natural regeneration and carbon sequestration processes that are already vigorous, and (f) massive erosion impacts resulting from mechanical operations.
Your document includes an appreciation of the wildlife habitat created by stating the intended plan to “retain an average for the Harvest Area of not less than one (1) Decadent and Deformed Tree of Value to Wildlife, Snag, or Dying Tree per acre that is greater than sixteen (16) inches DBH and twenty (20) feet tall.” Many wildlife species, including species protected by the ESA, use the “snags” and one per acre is insufficient to provide adequate wildlife habitat that has been created by the October 2017 fires.
In a recent document, Dr. Richard Hutto stated that it is “abundantly clear that salvage logging has uniformly negative ecological consequences for the very species that are most restricted in their distribution to burned forest conditions (Hutto 1995, 2006, Hutto and Gallo 2006, Hutto 2008, Lindenmayer et al. 2008, DellaSala et al. 2014, DellaSala et al. 2015, Hutto et al. 2015, Lindenmayer et al. 2017, Thorn et al. 2017).”
Please note: there is a nine-fold difference (almost an order of magnitude difference) between tree removal operations conducted within with 100 feet around a permitted structure (approximately 31,400 square feet) to retain acceptable defensible space, and the proposed removal of 300 feet around a permitted structure (approximately 282,600 square feet). Our concern is that these operations are going to result in a massive loss of stored carbon and complex wildlife habitat created after the fires – habitat that is currently being documented by scientists. As summarized in your documents, 185,000 acres burned around approximately 9,200 homes, and damaged approximately 790 additional structures in Sonoma, Napa, and Mendocino Counties.
You also state the removal of dead and dying tree can “reduce the risk of fire to timberlands” and also “increase forest vigor and vitality of surviving stands of trees…” These notions have recently been disproved in the scientific literature by many empirical studies (e.g. 12-year study by Sarah Hart and others, 2015), and the Governor’s Scientific Advisor was informed about the results of those empirical studies.
In summary, we have well-founded concerns about the level of clear-cutting (“harvesting”) being proposed in your Emergency Tree Removal Documents, which is well beyond the level required for public safety, and will result in the removal of valuable stored carbon that also serves as excellent wildlife habitat, and natural carbon sequestration processes that are currently in progress. In addition, clear-cutting operations are very likely to result in the removal of trees that could have survived the fires.
Please consider clearing within the acceptable 100 feet to maintain defensible space.
Christy Sherr, John Muir Project of Earth Island Institute
Denise Boggs, Exec. Director, Conservation Congress
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