If you haven’t already, we recommend you take a moment to check out “Tackling Timber Harvest Plans“
Comments submitted on a THP serve a few purposes. First, they make Cal Fire (or whoever submitted the THP) aware that X number of people are not in favor of this THP either at all or as it was submitted. This puts Cal Fire on notice that they will face opposition. A heartfelt comment is sufficient for this, but if you are trying to slow down or stop a THP, or gearing up for later litigation, you will need something more concrete.
For that second type of comment, you do not have to be an expert, but you do need to do your research and include citations. THPs are not usually stopped because of new studies—at least not by laypeople—but they can be slowed or cleaned up.
Procedural issues have a more direct impact on the regulatory process. These include: missed deadlines for public or agency notification and the like.
As you prepare your submission try to develop and stick to a theme. Identify the specific factual and legal issues you will address, then research each issue to determine what supporting evidence you can present. While you write, remember to tie your arguments to the evidence. When you write your comments, consider the following:
Include citations from:
- “substantial evidence”
- relevant rules
- relevant State and Federal laws
- items from the THP itself
- best available science
- agency reports, including past statements
- alternative resources (e.g. CNDDB, CALWatershed Mapper, DPR database)
And finally, make sure to use letterhead with the date, your means of transmission, agency contact address and email.
Formatting Your Comment
For a formal comment, we recommend a classic essay format using the following guidelines:
- On whose behalf the comments are being submitted
- Agency proposed action
- Summary position statement on the proposed project
Body Paragraph(s) for each main point:
- For each paragraph: Topic sentence for key issue/supporting evidence/conclusion
- Endangered Species
- Cumulative Impacts, etc…
- Restate position/ summarize argument
- Make an “ask”
- Request future updates on projects
End the comment as you would a letter- with your name, title (if applicable), contact info, and signature.
Submitting Your Comment
All comments must be emailed to:
Make sure to cc the Registered Professional Forester who wrote the plan, and please also include firstname.lastname@example.org so that they have it for their records.