The Board of Forestry (BoF) is proposing two new actions that would weaken necessary protections for wetlands and meadows during Timber Harvest Plan (THP) review. We need your support to let them know that these definitions are inadequate to protect important botanical sites. Thus we’ve created one action alert that addresses both problems simultaneously, making it easy on you to sign and share. But what exactly is the issue here? Let’s get into the details.
First, the BoF is proposing to define the terms “Meadow” and “Wet Area” in the forest practice rules. Meadows and wet areas are ecologically important places for many species and so the forest practice rules afford them additional protections. However, they currently lack one consistent definition within the rules.
The BoF has proposed the following definition: “‘Meadows and Wet Areas,” means those areas which are moist on the surface throughout most of the year and/or support aquatic vegetation, grasses and forbs as their principal vegetative cover.”
This definition falls short in 3 ways. 1) It won’t protect these areas during drought years when they may dry up for more than “most of the year.” 2) It doesn’t protect areas that are wet in the substrate soil (under the surface); and 3) it doesn’t adequately protect wet areas that lack vegetative cover.
Luckily for us, the State and Regional Water Boards already have a definition of Meadows and Wet Areas that is more in line with protecting these important areas. “Wet Areas” mean those areas where, under hydrologic conditions that are consistent with the long term precipitation record, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.” This definition adequately describes and protects these important areas.
Your letter will join the State and Regional Water Boards in calling on the Board of Forestry to adopt their definition.
Second, the Board of Forestry has proposed a new botany resource guidance document that fails to adequately protect botanical resources.
The proposed guidance document is full of permissive language that leaves the reader with the impression that the recommendations in the Guidance are optional when its
recommendations should be mandatory in all THPs. For example, the guidance document states that “botanical surveys are most helpful if submitted at the time of Plan review”. This permissive language allows RPFs to submit surveys after the plan has been reviewed which violates the fundamental premise of CEQA that information should be gathered prior to plan approval. Instead of issuing permissive guidance, the Board should formally augment the Forest Practice Rules to include botany-specific regulations that are robust and CEQA compliant.
Please click the button below to send a letter to the BoF to fix these issues and instead protect our biologically important wetlands and meadows before it’s too late.