Monday, October 5, 2009

Timber harvest non-compliance

The PA SGL has NO authority to carry out its mission by increasing our risk of fire loss. It has a myriad of techniques at its disposal--it can NOT pick the technique that puts us in danger of a catastrophic forest fire. It simply is not authorized to LESSEN our health, safety, and welfare.


I posted the pix of BLOCK 2's timber harvest results. They are at http://picasaweb.google.com/viragogretna/Block2TimberHarvestResults#


Here is the page of the timber harvest contract for that block:
http://docs.google.com/fileview?id=0B5ATkbVJQ0FiNjU0ZjE1ODAtNWExYi00ZmZkLThhNTEtNTkyZmE0MGE0NzY5&hl=en

(no spaces in the url)

It specifies the number of trees to remain standing, the number of den trees to remain, and the number of snags. The general terms of the contract also specify reseeding requirements and compliance with state environmental laws, including erosion and sedimentation control. Here is a comparison of the numbers on the contract against what is actually out there today:

approx 70 reserved trees (contract calls for 153)

approx 6 snags (contract calls for 44)

approx, oh, maybe a couple hundred den trees (contract calls for less than 20)


And here is the state's erosion and sedimentation control law that the State Game Land and the timber harvester are required to follow:

http://www.elibrary.dep.state.pa.us/dsweb/Get/Document-65564/363-2134-008.pdf


This law is known as "Chap 102" , and can be found at 35 P.S. §691.1 and 25 Pa. Code Chapter 102 & 102.1.

Via a Delegation Agreement with the State's DEP, our county's conservation office is contracted to enforce and investigate the SGL's and the harvester's compliance with the law. However, after submitting two written requests to the Lebanon County Conservation Office to investigate compliance with Chap 102, their director has failed to respond. Thus, the LCC Office clearly appears to be failing its Delegation Agreement. This is something the DEP would like to know about--an agency not working its delegation agreement. They can be contacted at 717-783-7577.

And, here is the State Game Land's mission:

Sec. 322. Powers and duties of commission.
(a) Duties. - It shall be the duty of the commission to protect, propagate, manage and preserve the game or wildlife of this Commonwealth and to enforce, by proper actions and proceedings, the laws of this Commonwealth relating thereto. (See http://www.pgc.state.pa.us/pgc/cwp/view.asp?A=478&Q=150972#322)
There is nothing in their enabling legislation that forces them to use any specific technique, and there is certainly nothing in their enabling legislation that allows them to pile fuel behind our homes.





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