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___________________________________________________
Board of Forestry and Fire Protection
Attn: Christopher Zimny
Regulations Coordinator
P.O. Box 944246
Sacramento, CA 94244-2460
Dear Mr. Zimny and Board Members,
I am writing to ask you to please reject the proposed amendment to the California Forest Practice Rules in their current form. The amendment, if passed, would severely inhibit the ability of experts to appropriately monitor, assess and ameliorate potential hazards to the few remaining Northern Spotted Owl breeding pairs and their incredibly fragile old-growth forest habitat.
Northern Spotted Owls have suffered near extinction from uncontrolled exploitation of their commercially-attractive habitat. These birds are elusive and shy, and respond poorly to stress and disruption. Their continued survival is far from assured, and improper management of the few remaining resources available to them will ensure their demise and the collapse of the unique ecosystem that sustains them.
The requirement for state-employed biologists to oversee the granting of Timber Harvest Plans makes sense. The proposed redefinition of "state-employed biologist" to "spotted owl expert" paves the way for timber company consultants and other biased parties to be placed in charge of assessing harmful impact on the birds. There is no way to guarantee the impartiality of scientific review by a "spotted owl expert" under the proposed definition.
The proposed rule changes would also eliminate the requirement that the Department of Fish and Game review Timber Harvest Plans before they are approved.
The State has a mandate and a responsibility to protect endangered species for the public trust. Allowing the proposed amendments to pass would clearly violate this mandate and is unacceptible.
Further, the claim that the proposed amendments are necessary due to fiscal restrictions and tight budgets sets a dangerous precedent for the future protection of imperiled species. California supports a large variety of ecosystems and numerous at-risk wildlife. Allowing the California State Board of Forestry and Fire Protection to eliminate the requirement for unbiased state-employed biologist oversight means none of these habitats or animals are safe from exploitation.
The State of California's legislative mandate for the Board of Forestry and the Department of Fish and Game is to work together "to protect and enhance the state's unique forest and wildland resources." Undermining the protection for Northern Spotted Owls by loosening the requirements for qualified scientific oversight does not accomplish this mandate.
I hope you will honor your commitment -- and legal duty -- to protect imperiled wildlife in California and reject the proposed changes to the California Forest Practice Rules.
Thank you for your consideration and attention to this matter.
Sincerely,
Your Name
Your Address
Your City, State Zip
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