Require Licensed Forester Approval and Signature for All Harvesting Plans:
Fact – in 2009, 80% of cutting plans were prepared by a licensed forester. All cutting plans were acted
upon (approved/ disapproved) by a licensed forester.
Lines 1173-1174, page 31: Our interpretation is that the TSC may have meant the preparation of
cutting plans should only be allowed by licensed foresters. The current wording to “eliminate
the current exclusion in Chapter 132 that allows a landowner signature to replace that of a
licensed forester” is confusing. The landowner signature on the cutting plan does not replace a
licensed forester it simply acknowledges that as the landowner they have the right to a carry out
the harvesting plan and are aware of their responsibilities and options.
We request that the references to foresters in this section specify either DCR Service Foresters or
private licensed foresters (and potentially other public foresters) to clarify the roles/
responsibilities of each group.
We agree with the principle that Cutting Plans are generally best executed when they are drawn
up and overseen by licensed foresters. However, this requirement would impinge upon private
landowner’s rights without adding any further protection against poor harvesting practices, since
our current system already requires Service Foresters to assure the law is followed. Furthermore,
as we are on the front lines of enforcement, we must warn that an unintended consequence may
be that some landowners and harvesters stop filing cutting plans rather than hiring foresters. The
role of the Service Foresters would then shift to enforcement for unauthorized harvests and to
remediating rather than preventing damage to streams, wetlands, vernal pools and threatened and
endangered species.
We are concerned that shifting oversight responsibility to private licensed foresters will result in
an enforcement burden to: Service Foresters under the auspices of MGL Ch132 which is does
not have strong enforcement language; the forester licensing board which is all volunteer and
according to the chair, Matt Kelty, does not have the capacity for a substantial increase in
complaints and Conservation Commissions, that according to a 2008 UMass Survey,
a. 45.5% of Commissions report difficulty in finding people to serve
b. 30.4% of Commissions report that they have little or no access to staff and
rely on Commission members for technical review and ensuring that proposed
projects meet the regulatory requirements of the WPA
c. 23.1% of Commissions report being engaged in a dispute with political
leaders over the past two years; 15.8% report being subjected to inappropriate
political pressure/interference in Commission decision-making
The taxpayers of Massachusetts are benefiting from the active participation of DCR Service
Foresters on private woodlots throughout the landscape of Massachusetts. DCR Service
Foresters ensure that “shortcuts” are not taken in harvest plans and harvest planning, an effort
routinely made by individuals engaged in business. As a result, the taxpayers of Massachusetts
gain clean water, intact Natural Heritage habitats, and a continuance of forests statewide.
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