BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 350
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           Date of Hearing:  April 29, 2013

                       ASSEMBLY COMMITTEE ON NATURAL RESOURCES
                                Wesley Chesbro, Chair
                  AB 350 (Wieckowski) - As Amended:  April 22, 2013
           
          SUBJECT  :  Timber harvesting plans:  exempt activities

           SUMMARY :  Expands the timber harvest plan exemption for fuel  
          reduction (La Malfa Exemption) by increasing the size of the  
          tree that can be cut from 18 inches in stump diameter to 28  
          inches in stump diameter.

           EXISTING LAW  :  Pursuant to the Z'Berg-Nejedly Forest Practice  
          Act (FPA):

          1)Prohibits any person from conducting timber operations unless  
            a timber harvest plan (THP) has been prepared by a registered  
            professional forester and approved by the Department of  
            Forestry and Fire Protection (CALFIRE).  The Secretary of the  
            Natural Resources Agency has certified that a THP is the  
            functional equivalent of an environmental impact report (EIR)  
            under the California Environmental Quality Act (CEQA).

          2)Requires CALFIRE to establish interdisciplinary review teams  
            to review a THP to assist in the evaluation of the plan and  
            its impacts on the environment. In general, each review team,  
            when possible, shall consist of  representatives from (1)  
            CALFIRE, (2) the appropriate California Regional Water Quality  
            Control Board, (3) the Department of Fish and Wildlife, (4)  
            the Department of Conservation, Division of Mines and Geology,  
            (5) a representative of county government (when the county  
            government so requests), (6) the California Coastal Commission  
            (for plans in the coastal zone), (7) the California Tahoe  
            Regional Planning Agency (for plans in the Tahoe Basin), and  
            (8) the Department of Parks and Recreation (for plans that may  
            affect values in publicly owned parks).

          3)Establishes the Forest Fire Prevention Exemption (which is  
            more commonly referred to as the "La Malfa Exemption") for  
            tree harvesting that meets specific conditions, including the  
            following: 

             a)   The harvesting must occur on parcels of 300 acres or  
               less;







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             b)   The harvesting must decrease fuel continuity (both  
               vertically and horizontally);

             c)   The harvesting must result in making the average  
               diameter of the trees that remain in the stand larger than  
               the average diameter of the trees in the stand prior to the  
               fuel reduction activities;

             d)   A registered professional forester must prepare the  
               notice of exemption;

             e)   The level of residual stocking must be consistent with  
               maximum sustained production of high-quality timber  
               products; 

             f)   The activities must comply with the regulations that  
               protect archaeological sites; and

             g)   Only trees less than 18 inches in stump diameter,  
               measured at 8 inches above ground level, may be removed.   
               However, within 500 feet of a legally permitted structure,  
               or in an area prioritized as a shaded fuel break in a  
               community wildfire protection plan approved by a public  
               fire agency, if the goal of fuel reduction cannot be  
               achieved by removing trees less than 18 inches in stump  
               diameter, trees less than 24 inches in stump diameter may  
               be removed if that removal is necessary to achieve the goal  
               of fuel reduction.

           FISCAL EFFECT  :  Unknown

           COMMENTS  :

           1)Background and Purpose of the Bill.  According to CALFIRE,  
            since 2004, the La Malfa Exemption has been used to achieve  
            fuel hazard reduction on 8,408 acres in the state.  This  
            exemption has been mostly utilized in San Bernardino, Plumas,  
            and Placer Counties, where, as of last year, 2,092, 1,913, and  
            1,305 acres have been harvested, respectively, over the life  
            of the program.  
             
            The author asserts that the La Malfa exemption is  
            "underutilized."  In response, this bill proposes to expand  
            the exemption by allowing a person to cut trees that are 10  







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            inches larger in diameter than what is authorized under the  
            existing exemption, in order to enable the harvesting of more  
            commercially valuable trees.  As such, with some limitations,  
            a person will be able to cut trees up to 28 inches in stump  
            diameter on a 300 acre parcel without the environmental review  
            process that is normally required for timber harvest plans.  

           2)Where's CALFIRE?   With regard to the two issues that this bill  
            deals with-fire prevention and timber harvesting-California is  
            fortunate to have an agency with expertise and responsibility  
            for both areas: CALFIRE.  Given the statutory mandate of  
            CALFIRE, one may reasonably assume that the agency had been  
            consulted to determine whether this bill would provide an  
            effective tool for reducing fire frequency and intensity.  
            Committee staff has discovered that CALFIRE has not been  
            consulted or involved in any way in the development of this  
            bill.  It seems prudent that if the Legislature wishes to make  
            meaningful fire prevention reform through timber harvesting,  
            that it should first consult the expert agency.

           3)What is the Role for the Agencies Under this Exemption?    
            Timber harvesting in California is subject to CEQA and is  
            governed by the FPA.  Harvesting is generally permitted via a  
            THP, which is considered the "functional equivalent" of an EIR  
            and is subject to inter-agency review by CALFIRE, the  
            Department of Fish and Wildlife, and the Regional Water  
            Quality Control Board.  These agencies collaborate in their  
            review of the proposed harvest, to ensure that the public  
            trust values for which they are responsible (fish, wildlife,  
            and water) are maintained.

            The proposed expanded exemption is a ministerial process that  
            specifically eliminates the ability of the reviewing agencies  
            to make any modifications to the proposed harvest.  The  
            exemption paperwork is submitted to CALFIRE, and if it is  
            deemed complete, logging can begin immediately.  This proposal  
            would facilitate widespread commercial logging, while  
            eliminating the ability of the public trust agencies to review  
            or modify the logging project.

           4)What is the Difference Between an 18 inch tree and a 28 inch  
            Tree?   A tree that is 18 inches at the stump has only marginal  
            commercial value in the current market, while a tree that is  
            28 inches stump diameter is commercially desirable.  It is  
            useful to note that just as the area of a 28-inch circle is  







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            nearly 2.5 times that of an 18-inch circle, the lumber volume  
            of a tree increases dramatically as the diameter increases.   
            Increasing access to commercially valuable trees to increase  
            the area impacted by this exemption is the author's intention.

            It should be noted that larger trees tend to have greater  
            wildlife and habitat value, and expanded application of the  
            exemption has increased likelihood of adverse environmental  
            impacts.  

           5)Is the La Malfa Exemption Underutilized?   The legislative  
            history of the LaMalfa Exemption suggests that it has been  
            utilized in a manner that the Legislature intended.  Because  
            the LaMalfa Exemption is a THP exemption, it was meant to be  
            used in limited circumstances where the environmental impact  
            of timber harvesting is minimal.  In fact, the author of the  
            LaMalfa Exemption, now-Congressman Doug LaMalfa, emphasized  
            the exemption's success when justifying subsequent bills to  
            extend the sunset of the LaMalfa Exemption.  

           6)Why is it called the La Malfa Exemption?   In 2004, AB 2420 (La  
            Malfa) created the timber harvest plan exemption that is the  
            subject of this bill.  AB 2420 contained a sunset date of  
            January 1, 2008.  In 2007, this exemption was extended to  
            January 1, 2013 by AB 1515 (La Malfa).  In 2012, the sunset  
            date was removed and the exemption became permanent by SB 1541  
            (La Malfa).  Given this legislative history, many in the  
            forestry community refer to the  
             exemption as the La Malfa Exemption.
             
          REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Amador County Air Pollution Control Board
          Amador County Board of Supervisors
          Associated California Loggers
          BlueRibbon Coalition
          The Buckeye
          Byng Hunt, Mono County Supervisors, District 5
          California Biomass Energy Alliance
          California Cattlemen's Association
          California Chamber of Commerce
          California Fire Safe Council
          California Forestry Association







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          California Forest Pest Council
          California Licensed Foresters Association
          California Farm Bureau Federation
          California Ski Industry Association
          California Women for Agriculture
          California Women in Timber, North Coast Chapter
          Central Coast Forest Association
          Collins Pine Company
          Del Norte County Board of Supervisors
          El Dorado County Board of Supervisors
          Family Water Alliance
          Forest Landowners of California
          Forest Products Industry National Labor Management Committee
          Glenn County Air Pollution Control District
          Green Diamond Resource Company
          Humboldt County Board of Supervisors
          Humboldt Redwood Company
          Lassen County Air Pollution Control District
          Lassen County Board of Supervisors
          Madera County Board of Supervisors
          Mariposa County Air Pollution Control District
          Mariposa County Board of Supervisors
          Matt Rexroad, Yolo County Supervisor, 3rd District
          Mendocino County Air Quality Management District
          Mendocino Redwood Company
          Modoc County Air Pollution Control District
          Mojave Desert Air Quality Management District
          Northern California Society of American Foresters
          Northern Sierra Air Quality Management District
          Personal Insurance Federation of California
          Placer County Air Pollution Control District
          Plumas County Board of Supervisors
          Plumas County Fire Safe Council
          Recreation Outdoors Coalition
          San Diego Adventure Riders
          San Joaquin Valley Air Pollution Control District
          Shasta County Board of Supervisors
          Sierra Pacific Industries
          Stewards of the Sequoia
          Sustainable Forest Action Coalition
          Tehama County Board of Supervisors
          Trinity Lake Revitalization Alliance, Inc.
          Tuolumne County Alliance for Resources and Environment, Inc.
          Yuba Watershed Protection and Fire Safe Council








                                                                  AB 350
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           Opposition 
           
          California League of Conservation Voters
          California Native Plant Society
          Center for Biological Diversity
          Central Coast Forest Watch
          Ebbetts Pass Forest Watch
          Foothill Conservancy
          Forests Forever
          Forest Issues Group
          Friends of Lassen Forest
          National Resources Defense Council
          Planning and Conservation League
          Sierra Club California
          97 Individuals
           

          Analysis Prepared by  :  Mario DeBernardo / NAT. RES. / (916)  
          319-2092