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The Cost of Regulation in Pounds of Paper

The THP on the left was approved in 2010, the THP on the right was approved in 1987. Both of these THP's cover the same geographical area.
The THP on the left was approved in 2010, the THP on the right was approved in 1987. Both of these THP's cover the same geographical area.

The THP on the left was approved in 2010, the THP on the right was approved in 1987. Both of these THP’s cover some of the same geographical area.

August 2012, Ryan McKillop, Inventory Forester –

It should be no surprise to any of us who work in the forest industry that the cost of doing business here in California has done nothing but risen over the years.

Twenty years ago, guided by the Forest Practice Rulebook, Ray Whiteley and Paul Violett could spend a day in the woods, another day in the office, and put together a comprehensive timber harvest plan (THP) which would generally be approved by the State within a few weeks time. The costs were minimal, the protections were in place, and log values were significantly higher than they are today.

Since that time, the costs of doing business have risen dramatically, primarily due to a regulatory climate driven by special interest groups which back political campaigns while actively trying to halt our sustainable industry.

Each year, the Legislature, as well as the Board of Forestry,  saddle our industry with additional fees, one-size fits-all regulations which don’t take site-specific issues or common sense into account. These regulations burden the forest owner with a guilty-until-proven-innocent framework, slow the harvest plan permitting process, while adding very little if any actual protection to our resources. Unfortunately this regulation and agency infighting sometimes actually prohibits one from taking the course of action that is best for the land.

When the economy crashed in 2008, it set up the perfect storm where we saw timber values plummet, fuel prices escalate, and State Agency budgets cut. Yet the march of further regulation continues.

Because the THP process requires oversight by no less than five separate agencies prior to approval, budget cuts caused staffing shortages that quickly led to increased plan review periods, sometimes in excess of six months following the submission of a THP.

The “chips” had hit the fan, and there is no end in sight. At the same time, the number of THPs filed have dropped significantly.

I think that it’s important to note that there is certainly a cost savings to the various State Agencies, having fewer plans to review and administer.  Despite this, however, their “fees” continue to rise, and given the State’s fiscal irresponsibility, this trend will probably continue.

In order to demonstrate my point, pictured above are two timber harvest plans that cover part of the same area at Empire Creek near Clipper Mills.

One was approved in 1987 and consisted of 15 pages. The other, which was approved in 2010,  is 620 pages.

A good portion of the increased size comes from seemingly unending environmental analysis, mostly without any tangible benefit, while  little has actually changed operationally since  the 1987 THP.

The  comparison between the two timber harvest plans is that the new plan is over three pounds of paper heavier, almost seven times the cost per board-foot harvested and over four times the cost per acre as it was 23 years ago.

Should this trend continue, it seems reasonable to assume that small landowners throughout the State could be paying hundreds of thousands of dollars for an approved, encyclopedia-sized THP by the time I near retirement.

I suppose we can only hope that, at some point, the State’s woes will subside, people will realize that a sustainable, locally grown wood source is a good thing, and that logs will be trading like gold.

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