Respondnet Views

Information Collection, OMB #: 0596-0167, Urgent Removal of Timber
Documentation of consultation with Larry Duysen, of Sierra Forest Products by
Contracting Officer Paul S. Miller.
Sierra Forest Products purchased approximately 35,574 Mbf of salvage timber from
private land in Southern California, specifically Riverside, San Bernardino, and San
Diego Counties. This occurred during the time periods, 2002 through 2006.
The availability of data,
Sierra Forest Products (SFP) indicated that the data was readily available. Data gathering
consisted of asking salvage loggers from San Bernardino, Riverside and San Diego counties where
the salvage logs came from, eg. private land or national forest land.
Frequency of collection,
Sierra Forest Products would compile scale data twice a month to track delivered volume from the
identified salvage sales. SFP estimates that this took 20 minutes per month. or 4 hours per year.
The clarity of instructions,
Sierra Forest Products stated that the Contracting Officer’s request for information and
instructions on how to submit extensions requests, were clear.
Record keeping responsibilities,
Sierra Forest Products record keeping consisted of creating and updating a spreadsheet to track
and account for salvage volume received from the three (3) Southern California counties affected
by the Catastrophic drought induce mortality.
Disclosure,
Disclosure came in the form of a letter to the Contracting Officer accompanied by the data
spreadsheet.
Reporting Format,
Sierra Forest Products used a letter every six (6) months to request contract term extensions. The
letter was supported by the above mentioned spreadsheet.
Data elements to be recorded, disclosed, or reported,
The letter coupled with the spreadsheet, provided both a request for extension and
documentation that their mill capacity was being impacted by the influx of salvage from non
National Forest System lands.
Sierra Forest Products lumped these last four questions into a single time estimate. SFP, every 6
months would populate a spreadsheet which contained information such as the Logger, Sale
Name, Volume in Mbf and County from which salvage was harvested. In addition, SFP would
write a letter every 6 months formally requesting contract term extensions based on 36 CFR
223.53. As documentation, SFP would enclose an accounting of the salvage logs received from
the Southern California counties. This would be in the form of the spreadsheet mentioned above.
Sierra Forest Products estimates that it required 45 minutes every 6 months to complete these
tasks. Annual burden for items 4-7 is 1 hour and 30 minutes.

Sierra Forest Products was made aware that our consultation and their response to this data call
would be part of the official record. The total annual burden upon the respondent mentioned
above is 5 hours and 30 minutes.

Joseph Franco/R5/USDAFS
06/22/2009 05:57 PM
To
Lathrop P Smith/WO/USDAFS@FSNOTES
cc
bcc
Subject
Comments concerning 36 CFR 223.53

I interviewed two parties. Jared Tappero, and Jay Francis, Forester's
from Collins Pine in Chester, CA, were the first contacts. Bruce Olsen
from Franklin Logging Inc in Bella Vista, CA was the second party
interviewed. Collins Pine did request and receive an extension based on
urgent need to harvest about 3 years ago. Franklin has never requested an
extension based on urgent need of harvest.
Collins Pine, Chester, CA
The information requested from the FS was relatively easy to obtain but
was depended on how accurate the data was from the private landowners
inventory. Large commercial timber companies normally have accurate
inventories and therefore their estimated volumes coming off their lands
is reasonably accurate. Small land owners not in the timber business,
like ranchers, do not have accurate inventories and require the purchasing
mill to send in Foresters to try to obtain a sample cruise to estimate
volume so mill can control volume coming into the mill.
Normally mills must control inventory so no more timber is brought in
during the season than is planned to be sawed during the year. It is
harder to estimate volume coming into the mill from a salvage sale since
there are many variables such as quality of timber, how quickly it is
deteriorating, how efficiently is it being logged, etc. Normally a mill
receives from the scaling company bimonthly reports. The mill can
request data more often at a cost. The mill has a good feel for how many
logging sides are necessary to have operating to assure adequate volumes
are delivered to the mill. As a result it is relatively easy to
accurately articulate to the FS on how logging capacity can be exceeded by
logging both private salvage and green FS volume. There is no accurate
way to show how this is done other than to explain to the FS what a mills
logging capacity is since there is no documentation that clearly
demonstrates their situation.
It takes about one day to pull the data together to request an urgent need
of harvest extension. It is still rather subjective on the part of the
FS on whether or not the company requesting the extension has provided a
compelling argument to meet the criteria in 36CFR 223.53 to obtain an
extension.
Franklin Logging, Bella Vista, CA
I interviewed Bruce Olsen and he was not as cooperative as Collins Pine.
He can be very critical on how the FS conducts business and you can see by
the quality of his response that he is not a fan of the process.
The proposed collection of information is not necessary to make an

informed decision, and it certainly does not have any scientific utility.
The Regional Forester is required by 36 CFR 223.53(b) to verify that a
catastrophe has occurred and that significant resource loss will occur if
it is not harvested promptly. Most all catastrophic damage is the result
of fire, and that a fire occurred is not hard to verify. The CO ought to
be able to verify that the “XYZ Fire” burned on Joe Bloe’s land last week
without collecting any data.
I do not support the statement that substantial deterioration can be
avoided if the timber is harvested within 1 year. Time is of the essence
in salvage. After a catastrophic event private landowners and purchasers
try to begin salvaging as soon as the smoke clears. The most important
consideration is “urgent removal” and to recover as much value as possible
to pay for rehabilitation.
I do not care about the accuracy of the agency’s estimate of the paperwork
burden of collecting information. It is all a waste of time.
Eliminate all data collection and use a little common sense. The “XYZ
Fire” burned Joe Bloe’s timberland. Some of your people named the fire
and helped fight it. Joe would like to postpone the harvest of the NFS
“ABC Green Sale” to allow him to salvage the dead trees.
As you can read from Bruce's response he is very critical of any FS
process used to make decisions. Normally Franklin logging does not
purchase salvage sales so it is not a priority to provide meaningful
comments. My guess in summing up Bruce's comments is to take the
purchasers word for what they are claiming and get out of their way so
they can log.
I have processed urgent removal requests from purchaser's and it is
difficult to convince the FS on exactly if what is claimed is accurate
information. At the outset of a request there are many assumptions that
are made by the requesting party and it may be difficult to document
beyond a reasonable doubt the actual affect logging private salvage may
have on the purchaser. In many cases it is the reputation of the
purchaser that has a bearing on whether or not I would support the request
from the purchaser. It is relatively easy to provide information that
appears to meet the criteria of 36CFR223.53 and is difficult to
verify...."My two cents whatever its worth".

Joe Franco, Province Timber Sale Contracting Officer
Telephone (530) 252-6439, Fax (530) 252-6428
Email: jfranco@fs.fed.us