How to comment on a
Timber Harvest Plan
in JDSF
A timber harvest plan (THP) is a legal document, both a plan and a form of environmental impact statement. Comments must be submitted within a set period of time, beginning with the date of the original filing and ending thirty days after the Pre-Harvest Inspection (PHI). For comments to be entered into the public record, they must have the THP name and number in the subject line, and be emailed to
SantaRosaPublicComment@fire.ca.gov
It is also important to cc the forester who wrote the plan, and we ask you to bcc mendocinotrailstewards@gmail.com so we can archive it.
These articles from the Environmental Protection Information Center may be helpful:
2018 harvest off of Road 408 in the Caspar Creek Watershed—photo by Art Mielke
Letters to the Editor:
Often what you have to say about a timber harvest plan is on the emotional side and may have nothing to do with the text of the plan itself. You might not feel qualified to comment on the science, might not understand the terms. Like so many people, you could believe that, no matter what you write, the people who have the power to change the timber harvest plan are not going to listen. You could be correct; but you should submit your comments anyway. Cal Fire is only required to respond to and consider comments on the legal text of the THP. But they will still know you are there, one of a large group of people who disagree with their treatment of a place that you love.
And this is when it is so important to also send your letter to a local newspaper or two. Letters to the editor are a time-honored tradition of political engagement. Being published sends a signal to our legislators that this is an important topic. In the end, the battle could be won in the court of public opinion, but the public must actually know enough about what is happening to have an opinion. Send your comments to Cal Fire and all the other addresses on the THP concerned, but then email it to your local newspaper. It doesn’t have to be perfect, doesn’t have to address the fine points of one section or another of a document you can’t even download. You just have to speak your peace. Be respectful. Don’t demonize others, even if you are angry. Here are some addresses:
Fort Bragg Advocate and Mendocino Beacon: editor@advocate-news.com
Willits News: editorial@willitsnews.com
Santa Rosa Press Democrat: letters@pressdemocrat.com
Most papers have a limit of 200 words or less for letters to the editor.
Spent oil left behind—photo by Art Mielke
To find a timber harvest plan, go to
Cal Trees Online Timber Harvesting and Forest Regulation
You don’t need an account, just go to the ‘Search Plans’ button beneath the ‘Everyone’ heading, and enter the name of the plan or location, and the most likely span of dates during which the information was filed. Most of the time a slew of documents are available, pieced out and not word-searchable, so you have to pick and choose. Section 2 of the THP contains the most information. The geo-referenced map is valuable, but needs to be opened with an app such as Avenza. The following basic term and acronym-decoding cheat sheet will help as well.
Caspar 500 THP--marked to cut for the Summer of 2021—photos by Art Mielke
THP Terminology & Decoding for the Layperson:
A Silviculture Glossary
JDSF—Jackson Demonstration State Forest
ATV—All-terrain Vehicle
BAA—Biological Assessment Area
Cal Fire—the California Department of Forestry and Fire Protection
CCR—California Code of RegulationsTHP—timber harvest plan
CDFA—California Department of Food and Agriculture
CEQA—the California Environmental Quality Act
DFW—Department of Fish and Wildlife (Formerly Department of Fish and Game)
EHR—Erosion Hazard Rating
ELZ—Equipment Limitation Zones
Even-Aged Management—clearcutting
FPA—Forest Practice Act
FPR—Forest Practice Rules
LTO—Licensed Timber Operator
NSO—Northern Spotted Owl
PHI—Pre-harvest Inspection
PRC—Public Resources Code
RPF—Registered Professional Forester
Silviculture—the growing and cultivation of trees
SOD—Sudden Oak Death—Pytophthora ramorum--an algae responsible for large-scale die-offs of oaks and other tree species
WAA—Watershed Assessment Area
WLPZ—Watercourse and Lake Protection Zone
WPOP—Winter Period Operating Plan
Timber Harvest Plan Sections
Section 1 = Legal Description and Information
Section 2 = Operational Provisions of the Plan
Section 3 = Supporting Materials and Explanations (including the determination of baseline and the alternatives analysis)
Section 4 = Cumulative Impacts Analysis
Section 5 = Subject Specific Attachments
Section 6 = Confidential Archeological Info (location and nature not disclosed to prevent vandalism or disturbance)
THP Comment Cheat Sheet from the Environmental Protection Information Center in Arcata, California:
For more info, check out the Environmental Protection Information Center
Comments submitted on a THP serve a few purposes. They first make Cal Fire (or whoever submitted the THP) aware that X number of people are not in favor of this THP either at all or as it was submitted. This puts them on notice that they will face opposition. In this respect, a heartfelt opinion is sufficient. However, comments can also be used to either slow down or stop a THP, or as material in later litigation. In these cases, comments are only valuable if they are authoritative. You do not have to be an expert, but you do need to research and include citations. THPs are not usually stopped because of new studies—at least not by laypeople—but they can be slowed or cleaned up. More importantly for the regulatory process are procedural issues, ie: missed deadlines for public or agency notification and the like. As you prepare your submission develop and stick to a theme; identify the specific factual and legal issues you will address; research each issue to determine what supporting evidence you can present; remember to tie your arguments to the evidence. When you write your comments, consider the following:
~Cite “substantial evidence”
~Cite relevant rules
~Cite relevant State and Federal laws
~Cite items from the THP itself
~Cite best available science
~Cite agency reports, including past statements
~Cite alternative resources (e.g. CNDDB, CALWatershed Mapper, DPR database)
~Use letterhead with date, means of transmission, agency contact address and email
THP Comments Format
If your comments are to be more than a heartfelt plea, then they are best written in essay format, with the following guidelines:
~It should have an opening paragraph:
On whose behalf the comments are being submitted
Agency proposed action
Summary position statement on the proposed project
~The body of the essay needs one solid paragraph for each main point:
For each paragraph: Topic sentence for key issue/supporting evidence/conclusion
Endangered Species
Watersheds
Cumulative Impacts, etc…
~The conclusion should:
Restate position/ summarize argument
Make an “ask”
Request future updates on projects
~End letter with your name, title, contact info and signature
For more info, check out the Environmental Protection Information Center