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Comment 30 for General comments on ARB staff's overall approach on interim GHG significance thresholds under the CEQA. (ceqa-general-ws) - 2nd Workshop.


First Name: Richard
Last Name: Wheeler
Email Address: rwheeler@surewest.net
Affiliation:

Subject: Distructive Forest Management
Comment:
Forest Land occupies about 40% of California and it is being
mismanaged or not being managed at all.

I was a Professional Forester for 58 years. Forest Management and
Forest Product Production i.e. Timber Harvesting is an Agricultural
Practice not a project that is changing the character or use of the
land.

I recently questioned the CDF about Overcutting of Forest Land and
they had no records of any overcutting. The California Forest
Practice Act requires reforestation of Clear Cuts, so that is not
overcutting.

I also questioned the amount of Erosion as Overcutting and Erosion
are the two most important socalled Impacts on Forest Land. They
answered that all of their studies showed there was NO SIGNIFICANT
EROSION due to Timber Harvesting.

An Investigation of the Archeological Centers Reports and
Inventory would reveal that few if any of the Sites that have been
recorded meet the description of Historical or Archeological Sites
as defined in EPA or CEQA. They have been recorded because
otherwise your Timber Harvesting Plan would not be recorded.
Damaged sites do not qualify as Historical or Archeological Sites.
Mining ditches made into roads are no longer historical sites.

There is no real evidence that Timber Harvesting affects any
Wildlife as only about 1% of Forest Land is harvested per year,
meaning 99% is left undisturbed for wildlife and Oxygen
Production.

On the other hand, Carbon Dioxide has been increased by the lack
of effective and efficient Forest Fire Fighting. Air Tankers and
Fire Truck just don't cut it!

And the number of Dead & Dying Trees create more Carbon Dioxide as
they cannot not be gathered or salvaged due to the expense of the
Harvesting Permit.

Such a permit in California costs 3X as much as one in Oregon,
that's why Oregon is shipping in most of the lumber. This situation
has reduced the Forest Product Economy by 78% costing Billion of
Dollars of Income to California along with thousands, maybe
hundreds of thousands of jobs.

Deforestation is increasing as Judges determine that Burned Areas
can not be planted to Forest Seedlings and produce more Oxygen
Erosion Control than brush.

So EPA & CEQA are reducing the production of Oxygen and increasing
the production of Carbon Dioxide.

Forest Fires like the Angora Fire at Lake Tahoe could have easily
be prevented but the individuals responsible are obviously
incompetent as were the personnel sent to fight it.

Regards,

Former USFS District Ranger

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Date and Time Comment Was Submitted: 2008-12-12 12:39:55



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