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ACTION ALERT: Tell Board of Forestry - No Logging in Watercourse and Lake Protection Zone

The Board of Forestry is pushing forward a controversial proposed rulemaking under the guise of wildfire risk reduction, which would allow logging and use of heavy equipment—including tractors and dozers—in Watercourse and Lake Protection Zones (WLPZ). This rulemaking is a dangerous attempt at deregulation that isn’t backed up by science.

The WLPZ is an area offered special protection under the Forest Practice Rules (FPR). It creates a buffer of 50–150 feet for waters from logging activity, depending on the steepness of slopes and the class of the watercourse (Class I=fish always present and domestic supply, Class II=fish seasonally present, Class III=no aquatic life present, Class IV=manmade). Under the standard rules the registered professional forester (RPF) is also required to identify and map unstable areas and spawning/rearing habitat for fish, mark trees that will be removed, retain a certain amount of surface and understory cover and large woody debris, provide erosion control, and establish equipment limitation zones and equipment exclusion zones where necessary. With the new proposed regulations—many of these requirements would be discretionary and deviation from the standard rules would require little to no justification by the RPF.

The proposed regulations are framed as a means to “reduce the impacts of wildland fire,” yet they fail to provide meaningful accountability or transparency regarding how wildfire risk is actually assessed. Specifically, there are no clear criteria or standards for evaluating existing fuel conditions that would justify vegetation treatment, especially within sensitive areas like the Watercourse and Lake Protection Zone (WLPZ).

While the proposed regulations require a RPF to “describe in the plan the specific vegetative conditions that may contribute to the spread of wildfire,” they offer no guidance on how such conditions should be identified or evaluated. The new rules do not require RPFs to consider crucial factors such as drought severity, stand density, species composition, and fuel moisture levels in their description of conditions. This creates a situation in which determinations of wildfire risk are entirely subjective and highly variable, depending solely on the discretion and interpretation of individual RPFs.

Without standardized metrics or a reviewable framework, there is no consistent or scientifically grounded way to assess whether a proposed treatment is warranted—or whether it might in fact cause unnecessary ecological disturbance. This undermines the stated intent of reducing fire risk and opens the door to inconsistent application and potential misuse of regulatory allowances.

Science on the behavior of fire and the function of trees in the WLPZ refutes the Board of Forestry’s proposed rulemaking. Trees and vegetation within the WLPZ provide important habitat for wildlife, they filter sediment and provide nutrients to ensure that water quality can support fish. Cal Fire claims that due to historic fire suppression and climate change, vegetation around streams are currently carrying high fuel loads. While this may be true, logging increases fire risk through creation of drier microclimates and the treatments would need to be repeated over and over again, with application of prescribed fire, to be effective. The WLPZ protections were established for a reason, if fire risk is truly a concern then it should be managed with thinning and vegetation management including prescribed fire outside of buffer zones.

An in person hearing on this proposed rulemaking will take place on September 24, 2025 in Sacramento, CA at the Natural Resources Building at 715 P Street. A VIEW ONLY webcast of the meeting will also be provided, registration required.

You can read the full proposed rulemaking notice, proposed amendments to the FPR, and Initial Statement of Reasons on the Board of Forestry website.

Read EPIC’s full comment here

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Environmental Protection Information Center (EPIC) is a tax-exempt non-profit organization, under the section 501(c)(3) of the Internal Revenue Code, and therefore all charitable donations are deductible to the full extent allowed by law.

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Senate Pro Tem

Subject: No Logging in Watercourse and Lake Protection Zone

Message:

Dear Board of Forestry, I am writing with regard to the Board of Forestry’s proposed rule package “Vegetation Treatment in the Watercourse & Lake Protection Zone.” I oppose this rule change as drafted because it is not supported by substantial evidence. The Board of Forestry must conduct a full Environmental Impact Report (EIR) to determine the environmental impact these rule changes will have. The EIR should identify significant impacts and include mitigation measures to counter such effects. Deregulated logging and heavy equipment use in the WLPZ will lead to degradation of riparian areas. One significant potential degradation impact includes increased sedimentation into streams. Fine sediments can enter stream pools—altering the shape of the stream channels and covering rocky stream bottoms, thereby impairing important food-producing, shelter, and spawning areas. Trees and vegetation in the WLPZ serve an important role as habitat for fish and birds. They also keep these areas cool and moist, which is critical to wildlife such as amphibians and also crucial for reducing the risk of unplanned fire ignitions. There are other ways to mitigate the risk of wildfire—such as prescribed burning and manual treatments—without causing unnecessary damage to riparian areas. This proposed deregulation will have lasting, irreversible impacts on California’s sensitive waterways and forests. Please do not approve this rulemaking as drafted and instead conduct a full environmental review. Thank you,

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Assemblymember

Subject: Oppose CEQA Rollbacks in SB 131 and Demand Clean-Up Legislation

Message:

Dear Assemblymember Rogers: Thank you for abstaining and raising concerns about Senate Bill 131. Unfortunately, despite the concerns raised, this bill was signed into law this month and will result in the loss of important habitat in California and the siting of toxic manufacturing facilities next door to already overburdened communities. To remedy these two issues, I urge you to tell Speaker Rivas that the legislature must pass legislation before the end of session to do the following: Add habitat and lands important for Natural Community Conservation Plans/Habitat Conservation Plans to the definition of “natural and protected lands.” Habitat must be added to the list of “natural and protected lands” to ensure that the CEQA exemptions in SB 131 are subject to avoiding and mitigating impacts on important habitat lands for endangered and threatened species. No mitigation for loss of important habitat would lead to an overall loss of habitat in California, potentially pushing declining species closer to extinction. This outcome directly undermines the state’s statutory goal of achieving 30x30. Remove the Advanced Manufacturing CEQA exemption. Advanced manufacturing is defined in Public Resources Code Section 26003(a) as any manufacturing process that “improves existing or creating entirely new materials, and processes” in a number of technological areas. This broad and vague definition also could include semiconductor facilities and other extremely risky facilities like nuclear, lithium compound, heavy metal, chemical recycling, battery manufacturing, or any manufacturing facility if it is using new materials and/or processes. I also urge that you oppose future efforts to roll back environmental protections in subsequent legislation. I am deeply concerned about proposals to exempt oil drilling and other energy projects from environmental review, particularly CEQA. California’s biodiversity is already at risk with federal proposals to remove important protections to our endangered species and public lands. California should be enacting laws to protect communities and the environment, not roll them back. Thank you for your attention to this important matter. Sincerely,

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Govenor

Subject: Oppose CEQA Rollbacks in SB 131 and Demand Clean-Up Legislation

Message:

Dear Governor Newsom, I am writing to express my deep disappointment with your decision to require budget trailer bill SB 131 in order to ratify the state budget. Despite the concerns raised about this bill and its impact on important habitat and overburdened communities, you signed the budget, signing this bill into law. Since this bill sidestepped the regular legislative process and provided little time for legislators to review and understand its impacts, I hope that you will take the time to understand our concerns and tell Senate Pro Tem McGuire and Speaker Rivas that the legislature must pass legislation before the end of session to fix two critical issues: Add habitat and lands important for Natural Community Conservation Plans/Habitat Conservation Plans to the definition of “natural and protected lands.” Habitat must be added to the list of “natural and protected lands” to ensure that the CEQA exemptions in SB 131 are subject to avoiding and mitigating impacts on important habitat lands for endangered and threatened species. No mitigation for loss of important habitat would lead to an overall loss of habitat in California, potentially pushing declining species closer to extinction. This outcome directly undermines the state’s statutory goal of achieving 30x30. Remove the Advanced Manufacturing CEQA exemption. Advanced manufacturing is defined in Public Resources Code Section 26003(a) as any manufacturing process that “improves existing or creating entirely new materials, and processes” in a number of technological areas. This broad and vague definition also could include semiconductor facilities and other extremely risky facilities like nuclear, lithium compound, heavy metal, chemical recycling, battery manufacturing, or any manufacturing facility if it is using new materials and/or processes. I also urge that you oppose future efforts to roll back environmental protections in subsequent legislation. I am deeply concerned about proposals to exempt oil drilling and other energy projects from environmental review, particularly CEQA. California’s biodiversity is already at risk with federal proposals to remove important protections to our endangered species and public lands. California should be enacting laws to protect communities and the environment, not roll them back. Thank you for your attention to this important matter. Sincerely,

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Environmental Information Protection Center (EPIC) is a tax-exempt non-profit organization, under the section 501(c)(3) of the Internal Revenue Code, and therefore all charitable donations are deductible to the full extent allowed by law.

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ACTION ALERT: Tell Board of Forestry - No Logging in Watercourse and Lake Protection Zone

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