Timber Waiver for Non-Federal Lands

Timber – Forestry and Fish Folk
Below – is a summary of outcomes (from Bob Klamt ) and issues (with Background below that) of the Timber Waiver for Non-Federal lands.
The waiver went through – mostly as written. This sets new guidelines, under the Waiver, for Timber Operations (including NTMPs).  This helps keeps stands in place that help fish and forestry values (also enforcing Threatened and Impaired Rules).
Concerned parties, while reviewing timber plans, should not hesitate to bring issue to all Review Team Agency (promptly in the review process). This helps attain a more successful review process and outcome. As advocates for water quality and forestry values we often fail to do this in a timely manner.
Timber operations not under the Waiver are subject to Waste Discharge Reporting and related fees.
Under the current budget crisis, severe reorganization of Forestry and Fish and Wildlife Agency organization, including permitting fees, is being considered by the legislature.  Be aware – and – Stay on top of this. These proposals can be an opportunity or they can be a disaster – depending how they are organized.
Bob and Cat:
Thanks for the update(s).
As we know, NTMPs are forever and should undergo intense scrutiny.  I have reviewed many small NTMPs with big issues. In fact they are still open Wortley NTMP on Signal Port Creek (reviewed by Jim Burke),  Ricolli Ranch NTMP (Sheephouse Creek), Martinelli NTMP (Basin Plan violations).
Also the Bohemian NTMP has extensive issues and is still open. Sheri did a great job.
Then, there is the Raul Hernandez NTMP on the Gaulala (Anapolis – Old Growth Again or Forever?) – this is approved with ongoing problems.
Seems like we have plenty of work to do.
It has been a hectic Monday!
The Board adopted the waiver with one addition to the grandfathering piece (Section III).  Recall that exisitng NTMPs have at least 5 years to develop an ECP and road plan.  Based on testimony regarding costs and the variable size and complexity of NTMPs, the EO was given the ability to be flexible on those requirements for existing NTMPs, by taking into account the acreage of the NTMP, the conditions, other mechanisms in effect (like a ranch plan), that sort of thing.  I’m fine with that–gives us the opportunity to work through this stuff with folks.
We are to go back to the Board and report on the T/I rules modifications and how we might amend the waiver considering those.
Primary issues were:
the cost of preparing ECPs and road plans, ostensibly when the FPRs already require these things
increased canopy is not necessary and not supported by the science and not needed, because the CalFire monitoring found 84% canopy on Class I streams on average (only 29 sites sampled in this region), and because the T/I rules already are good enough, and the revisions will include the same for Class IIs
regulations are duplicative–CalFire already has this covered, DFG already covers this for coho streams,  CalFire will have to enforce 2 sets of rules (theirs and ours)
existing NTMPs will require major amendments, because of changes to canopy that alter the yield modelling (interesting, since they argued that there was 84% canopy there anyhow…)
Major testimony was from CalFire, CFS, landowners, RPFs, Tom Walz (wearing the BOF hat), and Daniel Meyers and Richard Gienger.  It went from about 10 am to 4:30 pm with a lunch break.
That’s about it.
Bob
Timber – Forestry and Fish Folk
Below – is a summary of outcomes (from Bob Klamt ) and issues (with Background below that) of the Timber Waiver for Non-Federal lands.
The waiver went through – mostly as written. This sets new guidelines, under the Waiver, for Timber Operations (including NTMPs).  This helps keeps stands in place that help fish and forestry values (also enforcing Threatened and Impaired Rules).
Concerned parties, while reviewing timber plans, should not hesitate to bring issue to all Review Team Agency (promptly in the review process). This helps attain a more successful review process and outcome. As advocates for water quality and forestry values we often fail to do this in a timely manner.
Timber operations not under the Waiver are subject to Waste Discharge Reporting and related fees.
Under the current budget crisis, severe reorganization of Forestry and Fish and Wildlife Agency organization, including permitting fees, is being considered by the legislature.  Be aware – and – Stay on top of this. These proposals can be an opportunity or they can be a disaster – depending how they are organized.
Bob and Cat:
Thanks for the update(s).
As we know, NTMPs are forever and should undergo intense scrutiny.  I have reviewed many small NTMPs with big issues. In fact they are still open Wortley NTMP on Signal Port Creek (reviewed by Jim Burke),  Ricolli Ranch NTMP (Sheephouse Creek), Martinelli NTMP (Basin Plan violations).
Also the Bohemian NTMP has extensive issues and is still open. Sheri did a great job.
Then, there is the Raul Hernandez NTMP on the Gaulala (Anapolis – Old Growth Again or Forever?) – this is approved with ongoing problems.
Seems like we have plenty of work to do.
It has been a hectic Monday!
The Board adopted the waiver with one addition to the grandfathering piece (Section III).  Recall that exisitng NTMPs have at least 5 years to develop an ECP and road plan.  Based on testimony regarding costs and the variable size and complexity of NTMPs, the EO was given the ability to be flexible on those requirements for existing NTMPs, by taking into account the acreage of the NTMP, the conditions, other mechanisms in effect (like a ranch plan), that sort of thing.  I’m fine with that–gives us the opportunity to work through this stuff with folks.
We are to go back to the Board and report on the T/I rules modifications and how we might amend the waiver considering those.
Primary issues were:
the cost of preparing ECPs and road plans, ostensibly when the FPRs already require these things
increased canopy is not necessary and not supported by the science and not needed, because the CalFire monitoring found 84% canopy on Class I streams on average (only 29 sites sampled in this region), and because the T/I rules already are good enough, and the revisions will include the same for Class IIs
regulations are duplicative–CalFire already has this covered, DFG already covers this for coho streams,  CalFire will have to enforce 2 sets of rules (theirs and ours)
existing NTMPs will require major amendments, because of changes to canopy that alter the yield modelling (interesting, since they argued that there was 84% canopy there anyhow…)
Major testimony was from CalFire, CFS, landowners, RPFs, Tom Walz (wearing the BOF hat), and Daniel Meyers and Richard Gienger.  It went from about 10 am to 4:30 pm with a lunch break.
That’s about it.
Bob