February 27, 2004
Board of Forestry and Fire Protection
Attn: Christopher Zimny
Regulations Coordinator
P. O. Box 944246
Sacramento, California 94244-2460
Re: Notice of Proposed Rulemaking, Napa County Rules 2004
Dear Forestry Board Members,
When we attended the first hearing here in Sacramento on September 3, 2003, addressing these new overlays, many concerned property owners brought up the ever increasing costs that were making it impossible to pursue pragmatic thinning programs. The County’s response to concerns of Fire Hazard Intensification [response to Comment 8-Stu Smith and comment 3- George Bachich]: Nothing in the proposed rules would directly limit a property owner’s ability to manage their forest for the purposes of fire protection or prevention. Moreover, even now the economic incentive is not high enough to promote proper forest management that would decrease the danger of fire” Charles Wilson, Director, Napa Co.
If this is already true, and property owners cannot even now afford to manage their forests, then any additional costs and regulations seem not only counterproductive but putting the County at risk for inevitable liability in the event of a catastrophic fire.
The management of our natural agricultural resources should not be dictated by special interests and politicians. It is insulting to real forest managers for Supervisor Dillon to tell concerned property owners that she has spent one day in Sacramento and is now “up to speed” on forest management practices. Obviously, if that were the case she would be here today arguing for a streamlining of the processes necessary for thinning and managing our forest lands instead of her push for 32 additional costs and burdens to county property owners. Emerging science in Washington State, especially studies finished as recently as July 2003 by the Rural Technology Initiative, a pilot joint venture by Washington State College, University of Washington, the Extension Program and the Division of Forestry, illustrate that healthy habitat along our creeks and streams and eventual stands of large diameter old growth conifers depend on regular and in some cases, aggressive thinning. I have included the studies on Emerging Consensus for Active Management of Old Growth Forests, and Market and Non-Market Values of Fire Risk Reduction, Case studies of Impacts of the forest and Fish Rules on Non-Industrial Private forest Landowners in northeastern Washington where politics and special interests have created many parallel situations and finally an article from the Smithsonian. I urge you all to take the time to read these studies.
Please note, nowhere in any of the new proposed rules are any that help foster healthy stands of trees. On the contrary, formulas for how many trees may and may not be cut have nothing to do with forest health, and only make sense to someone sitting in an office far away from a heavily treed hillside.
Laws that refer to the nuisance of timber harvests are sorely shortsighted, ignoring the “nuisance” of devastation from fire, hellish erosion, threat of flooding, loss of topsoil, terrible greenhouse gases and all the loss of life of wildlife and habitat that will take decades to repair if we do not begin an aggressive thinning of the overstocked, fuel loaded hillsides of Napa County.
We trust the State Forestry Services. We implore you to stop the madness. If you approve even one of the requested overlays you open the door for the County to stop every attempt at forest management in Napa County.
In their continued pattern of dishonesty, County Supervisor Diane Dillon came to you with the claim that the citizens of Napa County want more regulations. In fact, the citizens of Napa County had just successfully completed the first referendum in the county’s history to fight the increasing counterproductive regulation that is strangling owners of timbered property and putting us in ever increasing risk of the devastation that has befallen Southern California.
Tell the Supervisors to go back to politics and leave the managing of forested lands in Napa County to property owners and the professionals.
Sincerely,
Denise Seghesio Levine
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