Calfire Caught Abusing Public Comment Process

Documents unearthed through a Public Records Act request show that
CalFire has been secretly editing questions submitted by the California Department of Fish and
Wildlife on timber harvest plans submitted for the Jackson Demonstration State Forest, which is
managed by CalFire. Edits were frequently made both to substance and tone of questions in
ways that appear to blunt criticism of logging proposed by CalFire. In this way, not only does
CalFire write and approve the timber harvest plan for the Jackson Demonstration State Forest,
CalFire also manipulates the public record to deflect criticism. In response, the Save Jackson
Coalition and EPIC are urging the state Attorney General’s Office to investigate.
Timber harvest plans (THPs) are subject to review by the California Department of Fish and
Wildlife (CDFW) for potential impacts to plants and wildlife. The Forest Practice Act and Rules
have multiple opportunities for agencies to ask questions and submit their concerns with
logging. The first of these opportunities for agency feedback is called “first review” and is an
opportunity for state agencies to ask clarifying questions and to offer initial concerns and
suggestions to the registered professional forester responsible for the THP.
Documents related to THPs are uploaded to the “CalTrees” website, maintained by CalFire.
CalFire has used its control of CalTrees to edit questions submitted by other resource agencies
in a way that escapes public scrutiny. CDFW and other agencies submit their questions to the
forester through a form on CalTrees that is not publicly accessible. CalFire then, in theory,
collects all of the questions submitted and poses these to the forester responsible for the THP in
a document publicly posted on the CalTrees website. But CalFire has taken to altering
questions submitted by the resource agencies prior to releasing the questions to the public. Not
only does CDFW not receive answers to the questions they drafted but the public is also unable
to see the actual questions and concerns of the agency entrusted with wildlife protection.
In a Public Records Act request, the Environmental Protection Information Center (EPIC)
obtained all questions as submitted by CDFW to CalFire. By comparing these questions against
those ultimately posted on CalFire website, EPIC has discovered that CalFire has altered
questions for at least three THPs in the Jackson Demonstration State Forest.
“It’s just shocking to see CalFire push around CDFW in this way.” said Matt Simmons, an
attorney with EPIC. “A state agency tasked with ensuring that logging operations are not

environmentally destructive is censoring the state agency tasked with protecting wildlife in order
to make it appear these logging operations are less destructive than they are.”
By editing the questions submitted by CDFW, CalFire has violated the law. The Forest Practice
Act envisions a system with robust engagement by sister agencies to help avoid impacts and
provides specific opportunities for engagement. CalFire does not have permission to edit
feedback to be more favorable to the agency. The matter has been referred to the California
Attorney General’s Office for review.
By altering questions to its benefit, CalFire has also violated public trust and confidence in the
agency to meaningfully review its own work. The Save Jackson Coalition has long highlighted
the conflict of interest inherent in CalFire management of the Jackson Demonstration State
Forest, as both the plan applicant and the plan reviewer. With this new revelation, the Coalition
reiterates its call that the Jackson Demonstration State Forest be managed for values other than
timber production

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