OAL Reference Attorney
300 Capitol Mall, Suite 1250
Sacramento, California 95814
California Board of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 944244-2460
Re: New Sections to 14 CCR Chapter 13 Section 1665 (Benefit Fee)
The Sustainable Forest Action Coalition (SFAC) wishes to comment on the proposed State Responsibility Area Fire Prevention Fees stated above. The Sustainable Forest Action Coalition (SFAC) represents 19 rural counties in Central and Northern California. Our members are representatives include individual Supervisors, Chambers of Commerce, Fire Safe Councils, Farm Bureaus, Agricultural Commissions, Forest Products Industry, Bio-energy Industry, Education, individual businesses with a mix of public and private agencies and associations. SFAC is opposed to this indiscriminate $150 fee for the following reasons:
1. In many cases, our structures within our non-public lands are covered by mutual aid agreements with the U.S. Forest Service and local fire districts.
2. In these mutual aid locations, our property owners already pay to support our local fire districts through bond measures voted on at the local level.
3. The State Legislature and Board of Forestry and Fire Protection should evaluate their compensation pay structure for Cal Fire employees before stating that lay offs would result if this “Emergency Rule” is not implemented. Consider the following before a decision is made to again impact local citizens with the cry of increased fires and loss as a result of lay-offs.
a. Cal Fire crews and supervisory or support staff are paid portal to portal on any fire assignment. This means that once they leave their duty station, they are on the payroll until the return to that same duty station.
b. In most cases, this same staff requires motel rooms during this same duty tour rather than remaining in fire camp.
c. In most cases, this same staff eats their meals in restaurants instead of the contracted food service offered at fire camps and are provided per diem for this expense.
4. Federal and local fire fighting crews are only paid for the time they are on duty and are off the clock when in fire camp. These same non-Cal Fire crews and workers stay in fire camps and are not housed in expensive motels and eat the contracted meals in the fire camp.
5. The State Legislature and Board of Forestry and Fire Prevention should set a standard of reasonableness and meet the same pay, meals and accommodations like all other fire crews and workers.
SFAC does not support this so called Emergency action and calls upon our Legislatures and Board members to evaluate the dollars that would be saved by implementing and changing the Cal Fire pay, meals and accommodation requirements and funding. This change could easily cover the estimated $7.5 million impact and stated lay-offs. In addition, the State of California would be a reasonable partner is reducing the state and federal budget impacts associated with fighting fires on mutual aid and public lands.
This proposed Emergency fee is nothing more than another effort to put the burden on local citizens for the lack of financial reason and responsibility to bring Cal Fire in line with their exorbitant pay and compensation. These same employees are allowed to retire at a very young age while drawing the same salary or more in retirement.