Northwest CT Sportsman's Council
April 9, 2004
Dear Members of the Appropriations Committee;
Re: File 366 HB 5588:
I write you concerning your upcoming deliberations regarding HB 5588, An Act
Concerning Forestry Management, as favorably reported out of the Environment
To qualify my comments, I would like to state that I am primarily representing
the interests of the Northwest CT Sportsman's Council; a coalition of approximately
7,000 sportsmen and women from 26 clubs and associations. I serve as President
of the NWCSC. I will also note that I currently serve as vice-chairman on the
State of Connecticut's, Citizen's Advisory Council to the DEP's Bureaus of Natural
Resources and Outdoor Recreation. I also serve on the Connecticut Statewide Forest
Resource Plan, Advisory Committee. This committee has helped in developing the
next ten-year statewide forestry management plan throughout 2003. We will be
meeting again this month to review the final draft of the plan.
I testified before the Environment Committee during last year's session regarding
a Forestry Management Bill similar in many respects to HB 5588. I spent the day
at that public hearing and listened to many speakers, representing a diverse
spectrum of public interests speak to that bill. There was no opposition to the
basic premise of the bill; that of increasing and enhancing forestry management
of state owned lands. The only dissent to the provisions included in last year's
bill was to the concept of forest and forest product certification under the "Smart
Wood Program" as administered by “The Rainforest Alliance”.
As I read the current HB 5588, I see two significant aspects to the bill. The
welcome change is that section which provides annual proceeds in excess of $875,000
from the sale of wood or timber from publicly owned land be deposited in the
Conservation Fund, as established in section 22a-27h. (By the way, I think that
fund should be referred to by its proper title: Environmental Conservation Fund).
It is my understanding that the intent of this provision allows surplus funds
to the ECF to be used to hire more state foresters in order that the approximately
200,000 acres of publicly controlled lands can be more effectively managed in
an environmentally beneficial manner. However; we proponents of Forest Management,
would appreciate seeing in the bill a statement directing the Commissioner of
DEP to use any ECF funds generated through forestry management be used specifically
to further enhance forestry efforts in this state. As we all know, intent is
sometimes not enough to guarantee funds to the intended recipient. Let's spell
it out so that there be no confusion later on.
The unwelcome change contained within the bill is the continued adherence to
certification and licensing of our forestry practices by outside organizations.
HB 5588 does broaden the choice for certification from last year's single selection, "Rainforest
Alliance". HB 5588 also attempts to address some of the criticism engendered
last year; specifically, costs associated with certification and licensing. This
time around, we will fund application through donations, gifts, and bequests.
I note that the bill provides only for the certification application through
donations. As your own OFA has reported, there will be costs to the state incurred
with certification and licensing: $34,500 for full review of practices, $5,000
annually for reviews, and $12,000 for five-year re-certification! (Under, Smart
Wood Program). These expenses are substantial when considering the financial
picture of our DEP.
I have been involved in discussions on the Citizen's Advisory Council to DEP
and within the CT Statewide Forest Resource Plan, Advisory Committee regarding
the benefit and need to seek certification and licensing of our state forestry
practices. Never have I heard a meaningful case made for the need of this program
in Connecticut. Please keep in mind the fact that in 2003, our state forest managers
treated only 1484 acres of woodland in some way! Even if the number of acres
treated is eventually doubled or tripled on an annual basis; certification costs
seem unjustifiable. Before seeking outside certification and the complexity and
expense it will add to an already understaffed and under funded division, we
should focus on an effort to correct the deficiencies that already exist.
In our discussions on the Statewide Forestry Plan, only the representative of
the Nature Conservancy made any attempt to justify certification. In the end,
after all points had been discussed, the major points made in defense of certification
were that it might serve to appease that faction of society that is opposed to
forestry in general, and that we could justify timber harvests in Connecticut
as a process that alleviates over-harvesting elsewhere in the world, such as
the rainforests of Central and South America.
The consensus of the members of the CT Statewide Forestry, Advisory Committee
was to observe that our state has a professional forestry division, program and
personnel. Our managers are fully capable of creating and justifying a forest
management plan that is environmentally sound. You may want to check with State
Forester; Helene Flounders, who is writing the statewide forest plan to inquire
as to whether state forest certification will be included in the final plan.
To the best of my knowledge, this concept was rejected as a viable element of
Another issue that should be brought up in your deliberations regarding state
certification of forest practices; and one not addressed in the OFA report on
costs, is the impact of certification on private foresters and commercial forest
operators working on state lands. If a full certification program is instituted,
it extends to all practices and practitioners working on state lands. This too
was brought up in our committee discussions. We were informed that, (discussing
the then current, Smart Wood proposal) each private entity would also have to
be certified by the organization and that there would be costs incurred at the
private level that would be substantial. The result of such private certification
to work on state land would prove to be a burden to otherwise willing contractors.
We may see an unintended reduction of commercial contractors willing to participate
in state forest projects. Private foresters informed our committee that there
is little demand for certified forest products of the type typically produced
from our forests. Certification is looked at as an unnecessary, recurring, (annual
fee) cost to the commercial operator with no discernable benefit.
Speaking for the sportsmen and conservationists of my organization; we want to
see any additional funding made available through passage of HB 5588 go directly
to the forestry division of the DEP, and dedicated to the forestry enhancement
issues that need to be addressed. We will soon see the new Connecticut Statewide
Forestry Resource Plan. This plan will constitute the working document for forestry
practices and environmental balance in our state for the next ten years. It should
provide the vision and planning for an all-encompassing forestry plan. Passage
of HB 5588 in a dedicated form will ensure our state DEP has the resources necessary
to implement this plan.
As regards the proposals for certification and licensure of state forestry practices,
we ask that the committee review carefully the total implications and costs involved,
both public and private. If the provision for certification and licensure must
remain in the bill, we ask that the "Smart Wood Program" under the
Rainforest Alliance be eliminated from consideration for the following reasons:
1; Rainforest Alliance received no substantial support in last year's bill; in
effect it was rejected by the conservation community, 2; According to the OFA
Fiscal Note regarding State Impact of the bill; DEP has had a pre-certification
evaluation conducted under the "Smart Wood" program, at a cost of $3,000.00.
We do not know where the authority to enter into this service originated; however,
it seems from the intent of HB 5588, (authorizing the Commissioner to enter into
a certification program) one would have to conclude that the Commissioner did
not have the authority to enter into this pre-certification evaluation! Until
reading the OFA report, I was totally unaware of this service being conducted.
No one from DEP brought this up at our CAC meetings. 3; Rainforest Alliance is
an organization of international dimensions, and perspective. We hope that should
certification be deemed necessary, the service be performed by an institution
resident in North America, and whose primary focus is North American! We do not
want to see any Connecticut forestry program certification outsourced.
As regards private donations and gifts to cover the costs associated with the
certification application: This provision of the bill points out the obvious;
that certification is not generally desired or supportable. If it was; the state
would be willing to fund it. The OFA report sheds some light on this issue in
that it reports the DEP anticipates funds for the initial costs of certification
to be available from un-named, non-profit organizations. There seems to be an
invisible proponent of certification; one that has substantial influence with
the DEP, and that proponent is probably a large, non-profit environmental conservator.
It may be that this proponent has offered to fund the initial application expense
through a gift or donation. The motives of this proponent may be well intentioned;
but I do not think the advice of the overwhelming majority of conservationists
and private forestry experts should be ignored to accommodate this proposal.
I hope the committee will consider the costs involved beyond the initial application
and the advisability of crafting state laws based on invisible gifts and donations.
The sportsmen and women of the Northwest CT Sportsman's Council advocate passage
of a sound Forestry Management bill. We feel HB 5588 can be the vehicle for meaningful
legislation. We ask all of our legislators to review the facts and check all
sources mentioned above. We hope you will make the changes to HB 5588 that will
provide a sound and meaningful answer to the environmental needs of our state.
Goshen, CT 06756
Chris M. Marino
President, Northwest CT Sportsman's Council
3 Bare Hill Rd.,