Comment Log Display

Gentlemen,

Please be advised, my physical address is:

Richard A. Wheeler
3927 Adelheid Way
Sacramento, CA 95821-2828

Yes, I would like a hard copy of the regulatory items that my
comment  
mentioned.
And that is: Why do the EPA and CEQA Laws pertain to Timber Land 

Management, since it is
an Agricultural Practice?

No other Agricultural Practices require an approved Environmental 

Impact Review/Report
before Harvesting or Planting Activities can be conducted.

Why the difference? Timber Harvesting PRACTICES are already under
the  
jurisdiction of
the California Forest PRACTICES ACT. Why the duplication?

Why is the U.S. Forest Service and the U.S. National Forests under
 
the jurisdiction
of the U.S. Department of Agriculture if their Administration and 

Management is not
Agriculture and recognized as Agricultural Practices?

I would also suggest an investigation of the CDF's Archeological 

Program and see
if the Archeological Reports as submitted to the Archeological  
Information Centers
meet the standards of Significance.

Is this possible?

This program is not being implemented correctly as required by the
 
EPA or CEQA.
Many if not most of the Historical and Archeological Sites do not 

meet the
requirements of Significance.

During my employment as a Registered Professional Forester, I was 

required to
register sites that had been almost entirely destroyed. And the
Law  
states that
damaged sites do not and should not be registered or reported.

Why is this additional expense required of Forest Land and its  
Agricultural
Practices?

I would appreciate your answer to my questions.

Regards,

Richard



On Dec 12, 2008, at 12:39 PM, owner-ceqa-general- 
ws@listserv.arb.ca.gov wrote:


Thank you for taking the time to send the
Air Resources Board (ARB or Board) your
views concerning an issue under consideration
by the ARB.

If your comment concerned a regulatory item, you
will receive notice of additional public comment
periods, if any, on that item. However, this
notice will be exclusively via email unless you
provide ARB with a physical address to which you
would like a hard copy of the notice to be mailed.

Thanks again for your input.

Sincerely,

/s/
Ombudsman
California Air Resources Board

----------- Your comment follows -------------


Comment 31 for ceqa-general-ws (2nd Workshop).

CONTACT INFORMATION:
First Name: Richard
Last Name: Wheeler
Email: rwheeler@surewest.net
Phone:
Affiliation:
File (i.e., Attachment):

Subject: Destructive 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