Fire Safety, not Clear-Cutting! Stop the Logging! Pls comment by Fri 1/12
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Hoai-An
Jan 11, 2018, 11:00:06 AM1/11/18
to OSC Earth Action
Fire Safety, not Clear-Cutting! Stop the Logging! Stick to Defensible Space!
Save the Trees - Napa, Sonoma and Mendocino
Save the Trees - Napa, Sonoma and Mendocino
HI folks,
This is urgent: It looks like the state is about to do excessive logging as part of post-fire "emergency tree removal". PLEASE email or fax the Office of Administrative Law (OAL) to stop this excessive and unnecessary clear-cutting throughout Sonoma, Napa and Mendocino.
A letter just about this issue came across the new climate activists - Sonoma County mailing list (we don't have a name for the group yet). So, sorry for the very short notice. Full text of the letter is below, plus email & fax info. I've also included a Facebook and web link that you can share.
Note: the language in the docs stated that comments were due "within five (5) calendar days of OAL’s posting of the proposed emergency regulations on the OAL web site." That sounds a bit vague, as a clear date was not provided, but the doc (dated Jan 5) is going to be "submitted to the Office of Administrative Law on January 12, 2018."
Please send comments right away - hopefully by this Friday 1/12/18. Thank you!
If you click the Facebook link below, this links to the a post with the letter. Remember to 'like' and share the Facebook post.
Here's a link to the full letter in case you want to share it:
Here's the letter itself PLUS how to email & fax the OAL at the top of the letter - Thanks!
Mail:
OAL Reference Attorney
300 Capitol Mall, Suite 1250
Sacramento, California 95814
Fax:
E-mail:
Dear OAL Staff Members:
We are concerned 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 which will result in the removal of stored carbon, trees that may have survived, and valuable wildlife habitat.
We urge you to reduce the area to be cleared around permitted structures from 300 ft to 100 ft of defensible space, as recommended by CalFire and many fire ecologists and other scientists who have studied this subject in depth.
We are writing to express concerns with the “Notice of Proposed Emergency Action” and the “Emergency Rulemaking to Facilitate Post-Fire Recovery Efforts within Counties of Napa, Sonoma and Mendocino,” (Emergency Tree Removal Documents) drafted by the Board of Forestry and Fire Protection, dated January 5 2018. There are several fundamental issues related to the proposed removal of “all dead or dying trees” within 300 feet of any permitted structure; 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” within 300 feet of any permitted structure goes far beyond the standard Defensible Space recommendations of 100 feet protective area around each structure (recommended by Cal Fire and others). Furthermore, the proposed action includes that the trees would be “removed, 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 essentially 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 rare species, 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 has already been documented by many 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. Those numbers represent the scale of clear-cutting being proposed in the Emergency Tree Removal Documents.
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.
Best regards,
Maya Khosla
Jenny Blaker
Neil Hancock
Christy Sherr, John Muir Project of Earth Island Institute
Denise Boggs, Executive Director, Conservation Congress
Hoai-An Truong
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