Public Comment re-opened for “Dogwood” Logging Plan CalFire has announced the re-opening of public comment on the “Dogwood” floodplain logging plan (THP 1-15-042-SON) until Monday, May 16, 2016 at 5 p.m. CalFire says they are only re-opening the plan for public comment on the new material provided by the forester for landowner Gualala Redwood Timber (GRT). The recirculated timber harvest plan (THP) documents are located in CalFire’s THP Library: ftp://thp.fire.ca.gov/THPLibrary/North_Coast_Region/THPs/THPs2015/1-15-042SON/ The California Forest Practice Rules (FPRs) require THP submitters to provide maps of all roads proposed for use, but the “Dogwood” logging plan did NOT include maps of the skid roads in the floodplain until this past week, when Gualala Redwood Timber finally provided maps in response to public comments. Now Cal Fire must re-circulate the plan for additional public comment on those maps, among other new material. One of the most egregious flaws in the all-floodplain “Dogwood” logging plan is that it violates a basic Forest Practice Rule: the restriction on roads in water/lake protection zones (WLPZ), which includes flood-prone areas. Even the Dogwood THP document itself (Section 3, page 102) concedes that it needs an “exception” to this rule. The rule has exceptions, apparently for timber harvest plans (THPs) that encroach but don’t fully occupy floodplains, as “Dogwood” does. Exceptions are conditionally allowed for this rule IF two conditions are met: first, the THP has to justify the exception in the plan (not after approval), and the Director of Cal Fire has to approve it. And the explanation has to be reasonable (generally consistent) with respect to all of the Forest Practice Rules including the Anadromous Salmonid Protection Rules and flood-prone rules, and Cal Fire’s own guidance on flood-prone considerations, published in 2005. Dogwood THP tries to make the exception the rule, and a viciously circular rule: it proposes 100% floodplain logging roads, justifying them by saying GRT can’t log in the floodplain (which they aren’t supposed to do in the first place, under current rules) without the skid roads, so the roads are necessary! The message for Cal Fire: NO EXCEPTIONS that make the exception for skid roads in the flood-prone forest the rule! GRT has not reasonably justified a THP with 100% skid roads in flood-prone areas. GRT has not justified its failure to avoid or even minimize disturbances in flood-prone areas. It does not comply with the rules. The Director SHOULD NOT APPROVE the exception. Send your comments directly to: santarosapubliccomment@fire.ca.gov To find out more, here is the Friends of the Gualala River website link: http://gualalariver.org/forestry/floodplain-logging/public-comment-re-opened-dogwood-logging-plan/