CLFA SUBMITS SUGGESTIONS TO BOF FOR 2006 PRIORITIES: CLFA submitted official comments and suggestions for 2006 Board of Forestry priorities on December 7, 2005.
CLFA ISSUES THIRD WHITE PAPER: On Thursday, July 14, CLFA will present to the Board of Forestry the third White Paper titled "California's National Forests: Active Management a Key to Sustainable Forestry in the Golden State". The first and second (in the series) of CLFA White Papers presented to the BOF earlier this year are posted below.
CLFA RECEIVES RESOLUTIONS IN HONOR OF 25TH ANNIVERSARY: During
the CLFA Annual Conference, March 4-5, 2005, the State Legislature and the
Board of Forestry and Fire Protection presented resolutions in honor of
CLFA's 25th year. Assemblyman Rick Keene and Senator Sam Aanestad co-sponsored
the Legislature's resolution, which was presented by Assemblyman Keene during
his luncheon address to the conference on Saturday. George "YG" Gentry,
BOF Executive Officer, presented the BOF Resolution during the 25th Anniversary
Celebration portion of Friday's conference agenda.
CLFA PRESENTS SECOND WHITE PAPER TO BOF: CLFA will present this second in a series of three white papers to the Board of Forestry on January 5, 2005. The paper is entitled "Natural Resource Governance and Forest Sustainability" (see below for the first paper submitted).
CLFA SUBMITS WHITE PAPER TO BOF: At the November 2004 BOF meeting, CLFA will present a white paper entitled "Natural Resource Literacy and Public Policy: An expanded Role for the California State Board of Forestry and Fire Protection?".
CLFA'S CALIFORNIA FORESTRY 2050 - "What do we want our forests to look like, and how do we get there?"
OFFICIAL CLFA COMMENTS ON DFG 1600 FEE INCREASE PROPOSAL: On July 7, 2005, CLFA submitted official comment to the California Department of Fish & Game regarding DFG's proposed 1600 Agreement fee increases. Public comments are due by July 11 and a public hearing is scheduled for the same date.
OFFICIAL CLFA COMMENTS TO BOE ON TIMBER TAX MANUAL: On July 7, 2005, CLFA submitted official comment on the State Board of Equalization's Draft Timber Tax Manual.
CLFA OPPOSES SB 646: On June 10, 2005 CLFA submitted a letter to Senator Sheila Kuehl opposing her SB 646, as amended 6/8/05. SB 646 calls for a tax, in the form of an annual fee, for water quality waivers issued for timber operations.
CLFA OPPOSES AB 715 AND SB 744: On June 8, 2005 CLFA submitted letters in opposition to AB 715 (as amended 4/14/05) and SB 744 (as amended 5/16/05). AB 715 would give the Legislature veto power over the Governor's recommendations to the federal government with regard to the management of Inventoried Roadless Areas within California. SB 744 proposes to require applicants for Timber Harvest Plans to post them on the Internet, and then to also tax these same applicants, in the form of a fee, to cover "appropriate administrative costs" for complying with this new burden.
CLFA OPPOSES AB 715: On May 16, 2005 CLFA sent a letter to the Assembly Appropriations Committee in opposition of AB 715 (Levine). AB 715 concerns the management of inventoried roadless areas on USDA Forest Service lands in California.
OFFICIAL CLFA COMMENTS TO CVRWQCB: On April 20, 2005 CLFA submitted comments to the Central Valley Regional Water Quality Control Board (CVRWQCB) regarding the "Extension of Conditional Waiver of Waste Discharge Requirements for Discharges Related to Timber Harvest Activities".
CLFA SUPPORTS AB 1705: On April 12, 2005 CLFA wrote a letter to Assemblyman Rick Keene in support of his bill, AB 1705. AB 1705 proposes to change the definition of timberland so as to exclude all parcels less than 1 acre in size and additional parcels up to three acres in size from being regulated under the Z'Berg-Nejedly Forest Practice Act (FPA); defines timberlands exempt from regulation to include lands scheduled for a project approved under the California Environmental Quality Act; and creates a Planning Watershed Timber Harvesting Plan (THP), a state permit allowing landowners to harvest timber on lands within a watershed for up to ten years.
CLFA SUPPORTS AB 887: On April 5, 2005 CLFA wrote a letter to Assemblyman Michael Villines in support of his bill, AB 887. AB 887 proposes to lengthen the time a THP may initially be valid from three to ten (10) years, with the additional optional one-year extensions remaining unchanged.
CLFA OPPOSES SB 646: On March 30, 2005 CLFA submitted a letter in opposition to Senator Sheila Kuehl's SB 646. SB 646 proposes to disallow the issuance of a Water Quality waiver in the event that the pertinent water body is listed as impaired pursuant to federal law. The bill will also require the payment of a fee by Timber Harvest Plan proponents, and others impacted by this legislation, to cover the costs of the waiver program.
CLFA WRITES TO GOVERNOR REGARDING LOCKYER LAWSUIT ON SIERRA NEVADA FRAMEWORK: On March 18, 2005 CLFA wrote to Governor Arnold Schwarzenegger expressing concerns about the recently filed lawsuit by Attorney General Bill Lockyer. The lawsuit aims to stop forest management activities proposed in the revised Sierra Nevada Framework.
CLFA COMMENTS ON PROPOSED BOF ELIMINATION: On 1/31/05, CLFA sent a letter to the Little Hoover Commission with official CLFA comments on the Governor's Reorganization Plan 1 (GRP1), Proposal to Eliminate the State Board of Forestry and Fire Protection. The Little Hoover Commission is charged with reviewing the Governor's proposals and submitting a report back to the Governor and the Legislature.
CLFA SUBMITS SUGGESTIONS TO BOF FOR 2005: On December 8, 2004, CLFA presented to the Board of Forestry a letter outlining CLFA's suggestions for BOF Tasks and Goals, 2005.
TMDL IMPLEMENTATION IN NORTH COAST REGION: On November 11, 2004 CLFA submitted official comment to the North Coast Regional Water Quality Control Board regarding their Order No. R1-2004-0087 (Total Maximum Daily Load Implementation for Sediment Impaired Receiving Waters in the North Coast Region).
FUEL HAZARD REDUCTION PROPOSAL: On October 18, 2004 CLFA submitted official response to the Board of Forestry rule proposal "Fuel Hazard Reduction, 2004".
CLFA'S INPUT TO BOF ON RMP: On October 4, 2004 CLFA submitted written comment on the 45-day notice for the "Road Management Plan, 2004" proposed rule package.
CLFA'S CPR RESPONSE: On September 30, 2004, CLFA submitted a letter to Governor Arnold Schwarzenegger with comments on the California Performance Review (CPR) covering: 1) the proposal to split the California Department of Forestry and Fire Protection; 2) the proposal to eliminate the Board of Forestry and Fire Protection; 3) improving the Timber Harvest Plan development and review process; 4) reorganization of the California Environmental Protection Agency; and 5) simplification of the process for interagency work authorizations.
CLFA LETTER TO STATE PARK AND RECREATION COMMISSION:On September 21, 2004, CLFA sent a letter to the State Park and Recreation Commission regarding "Fire Prevention for Parks and Private Landowners within Special Treatment Areas". The purpose of the letter is to discuss the need for an understanding of the risks posed to landowners on both sides of the property line.
OFFICIAL CLFA RESPONSE TO BOF TRANSITION SILVICULTURE, 2004 RULES: On July 9, 2004 CLFA submitted written comments in response to the 15-day notice on the Board of Forestry proposed rulemaking package (Transition Silviculture, 2004).
LISTING OF COHO SALMON: On June 23, 2004, CLFA submitted official comment to the California Fish and Game Commission on the notice of proposed changes in regulation (Listing of Coho Salmon).
FOREST PEST DETECTION REPORT: The California Forest Pest Council is sponsoring a survey of forest pests and has developed a FOREST PEST DETECTION REPORT. The Board of Forestry is particularly interested in Western Gull Rust and the prevalence of this species.
CLFA CONTINUES TO OPPOSE SB 1648:On June 1, 2004, CLFA submitted a letter to Senator Wesley Chesbro, author of SB 1648 (Jackson Demonstration State Forest), and members of the Assembly Natural Resource Committee, in continued opposition to the bill (see other CLFA correspondence regarding this bill below at "CLFA Opposes SB 1648).
OFFICIAL CLFA RESPONSE TO AB 2420: On May 28, 2004 CLFA submitted a letter to Senator Sheila Kuehl, Chairperson of the Senate Natural Resources Committee, to recommend support of AB 2420 (LaMalfa) (if amended). AB 2420 provides regulatory relief to landowners and communities who are faced with a fire threat..
OFFICIAL CLFA RESPONSE TO NCRWQCB ORDER NO. 41-2004-0016: On May 28, 2004 CLFA submitted written comments to the North Coast Regional Water Quality Control Board concerning the "Categorical Waiver and Waste Discharge Requirements for Discharges Related to Timber Harvest Activities on Non-Federal Lands in the North Coast Region"
OFFICIAL CLFA RESPONSE TO BOF TRANSITION SILVICULTURE METHOD RULE PACKAGE: CLFA has submitted written comments to the Board of Forestry & Fire Protection on the Transition Silviculture Method 2004 rule package.
OFFICIAL CLFA RESPONSE TO NCRWQCB: CLFA provided testimony and written response (dated 511/04) to the north Coast Regional Water Quality Control Board Order No. R1-2004-0016, Categorical Waiver and Waste Discharge Requirements for Discharges Related to Timber Harvest Activities on Non-Federal Lands in the North Coast Region.
CLFA OPPOSES SB 1648: On April 1, 2004 CLFA submitted a letter in opposition to SB 1648 (Chesbro) to the Senate Appropriations Committee. SB 1648, among other things, changes the purpose of the state demonstration forests as well as constraining management flexibility at Jackson Demonstration State Forest.
CLFA SUBMITS SUGGESTIONS TO BOF ON CLASSIFICATION OF WATERCOURSES: After discussion at the Board of Forestry Forest Practice Committee in January concerning confusion surrounding the classification of watercourses under the Forest Practice Rules, the committee asked for suggestions specifically regarding the classification of Class II and Class III watercourses. CLFA submitted a letter to the Committee with several suggestions and clarifications.
OFFICIAL CLFA RESPONSE TO CALIFORNIA PERFORMANCE REVIEW: CLFA has submitted two letters to The California Performance Review (CPR) set up by Governor Schwarzenegger to allow input on ideas for changes to the state government. The letters provide ideas on changes in FOREST MANAGEMENT and FOREST FUEL REDUCTION.
OFFICIAL CLFA RESPONSE TO SB 1648: CLFA has written a letter to Senator Wesley Chesbro opposing his SB 1648 legislation. This bill would, among other things, remove 12,000 acres from management in the Jackson Demonstration State Forest and restrict even-age management.
CLFA RESPONSE - PROPOSED NAPA COUNTY RULES: On February 27, 2004, CLFA submitted to the Board of Forestry an official response to the "Proposed Napa County Rules 2004". Napa County is proposing special Forest Practices Rules, which will require approval by the Board of Forestry.
CLFA SUBMITS LETTER TO BOF REGARDING STREAMLINING THE PROCESS: CLFA has developed a list of proposed issues/ideas for streamlining red tape while maintaining strong standards of environmental and recognizing the regulatory burden being placed on forest landowners and the impact on the ability of those landowners to keep their lands in timber production. This has been submitted (February 20, 2004) to the BOF Ad Hoc Roads and Watershed Management Committee. CLFA will continue to review other sections of the Forest Practice Rules for additional suggestions to submit to the BOF.
CLFA ISSUES PRESS RELEASE REGARDING STATE NURSERIES: On February 19, 2004, CLFA issued a media press released entitled "Budget Woes at CDF Tree Nurseries Harming State's Environment, Biodiversity".
CLFA REQUESTS OAL TO RE-INSTATE PETITION PROCESS: On December 10, 2003 CLFA requested the Office of Administrative Law (OAL) to re-instate the petition process which has recently been suspended due to budget constraints.
CLFA SUBMITS SUGGESTIONS FOR BOF 2004 PRIORITY LIST: At the December 2003 Board of Forestry meeting, the board will be putting together their list of priorities for 2004. CLFA submitted a letter on December 4 to the BOF with several suggestions for the board to consider.
CLFA LETTER TO FIRE SAFE COUNCIL: CLFA has written a letter to the Chair of the California Fire Safe Council providing information as to when the various Fire Safe Councils throughout the state need to use the expertise of a Registered Professional Forester in their projects.
SAF/USDA MOU - CERTIFIED FORESTERS: Official CLFA RESPONSE (8/2/03) to SAF/USDA MOU calling to SAF's attention licensing requirements in California. (See additional CLFA comments on SAF's Certified Forester Program below.
CLFA CORRESPONDENCE TO LA COUNTY FIRE DEPARTMENT: CLFA has sent a letter to the Los Angeles County Fire Department in response to their announcement for "Assistant Chief, Forestry" position which no longer requires the applicant to hold an RPF license. This position will be responsible for supervision of the Forestry Division's Vegetation Management Program. The activities of this program take place on forested and oak woodlands located in the service area of the Los Angeles County Fire Department.
OFFICIAL CLFA RESPONSE TO "KUEHL REPORT": CLFA has responded to the Senate Natural Resources Committee Report (see below), also known as the Kuehl Report.
CLFA CORRESPONDENCE TO SAF: CLFA has sent a letter to the national SAF headquarters to inform them of the license requirements for practicing forestry in the state of California and that the "Certified Forester" issued by SAF does not allow someone to provide services on non-federal lands unless they also hold a valid RPF license. SAF is granting the Certified Forester designation and publicly acknowledges those that have met SAF's professional forestry education and experience requirements. A national Certified Forester Directory on SAF's website provides the public with a prominent listing of those professionals who have earned the Certified Forester distinction, and for those who hold an RPF license, the information should be listed on the SAF website along with an explanation that the RPF license is required if one is to provide professional forestry services in California.
OFFICIAL CLFA RESPONSES TO BOARD OF FORESTRY RULE PACKAGES: On October 3, 2003, CLFA submitted official response letters to 15-day notices regarding the following proposed BOF rule packages: VARIABLE RETENTION - 2003, HARDWOOD RETENTION - 2003, and ROAD MANAGEMENT PLAN - 2003. At the October BOF meeting, the Board approved the VR package and the HR and RMP packages were sent back to committee.
CLFA REQUESTS VETO OF SB 810: On September 17, 2003 CLFA sent a letter to Governor Gray Davis asking him to veto SB 810 (Burton). SB 810 grants regional water boards additional authority in THP review. Governor Davis has until October 12 to sign or veto legislation sent to him by the legislature.
OFFICAL CLFA RESPONSE TO SACRAMENTO BEE EDITORIAL: On September 2, CLFA submitted a "Letter to the Editor" to the Sacramento Bee in response to a Bee editorial, 8/29/03, regarding the imminent closing of the Wetsel-Oviatt Lumber Mill. To read the Sacramento Bee editorial go to: http://sacbee.com/content/opinion/editorials/story/7315746p-8260133c.html.
OFFICIAL CLFA RESPONSES TO BOARD OF FORESTRY RULE PACKAGES: On August 29, 2003, CLFA submitted official response letters to the Board of Forestry regarding the following proposed rule packages: HARDWOOD RETENTION - 2003; VARIABLE RETENTION - 2003; and ROAD MANAGEMENT PLAN - 2003.
WATERSHED PROTECTION EXTENSION, 2003: Official CLFA Official CLFA RESPONSE to 45-day Notice of proposed Board of Forestry "Watershed Protection Extension, 2003" for the BOF hearing at their August meeting.
CLFA RESPONDS TO SB 18: Official CLFA response to Senator John Burton, author of Senate Bill 18, which mandates additional protection for certain Native American cultural sites.
CLFA RESPONDS TO LEGISLATION: Official CLFA responses June 19, 2003 to SB 923 (Sher) and SB 754 (Heritage Tree Preservation Act).
OAK RETENTION & WATERCOURSE CLASSIFICATION: Official CLFA Comments submitted April 2003 to the Board of Forestry & Fire Protection on OAK RETENTION STANDARDS and WATERCOURSE CLASSIFICATION.
CLFA RESPONDS TO ASSEMBLY AND SENATE BILLS: Official CLFA response to: AJR 11, AB 47, AB 344, AB 561, AB 1168, and SB 810. For more information on these bills and others CLFA is tracking, go to www.clfa.org/tracked_leg.htm
CLFA FILES BRIEF IN SUPPORT OF SUIT: CLFA has filed an Amicus Curiae Brief (Friends of the Court) in support of a suit filed by Donald H. Weburg, Petitioner, v. the State Board of Forestry for the State of California and Does 1-20, Respondents, in the Superior Court of the State of California in and for the County of Sacramento. This case presents the question to the court as to whether an applicant for a timber harvest plan under the Z'Berg-Nejedly Forest Practice Act can be compelled to submit a survey for certain plant species as a condition of approval. CDF and the BOF both denied approval of a THP submitted by Weburg because petitioner refused to agree to submit a survey of the proposed harvest area for the purpose of determining the presence or absence of certain plants species. Weburg based his refusal on the provisions of Fish and Game Code section 1913, which sets forth in statute the method by which rare, threatened and endangered plants are to be preserved, protected and enhanced in the course of commercial timber operations. The Court has accepted CLFA's brief as part of the case.
DFG 1606 PROCESS: The Department of Fish and Game (DFG) has developed a process for implementation of DFG Code Section 1606. The pilot program that will implement this process starts November 1, 2002 and will be applicable in the following six northern counties: Shasta, Siskiyou, Trinity, Tehama, Lassen and Modoc. The process joins the development of 1603 agreements within CDF's public comment period for harvesting plans and relies on specified information provided in the plan to substitute for the current 1603 notification process. Notification under this process and development of the 1603 agreement during review of the plan will allow DFG to issue the final 1603 agreement soon after plan approval. For more detailed information, please download or view the following document "Notification Standards for Implementation of Fish and Came Code Section 1606", or contact DFG staff Bruce Webb @ 530.225.3714, Mary Ann Quarisa @ 530.225.2367, or Curt Babcock @ 530.225.2740.
CDF NATIVE AMERICAN CONTACT LIST: CLFA has written a letter to the Native American Heritage Commission (NAHC) requesting answers to questions CLFA has concerning the expanded list of contacts on the CDF Native American Contact list (December 10, 2001).
STREAMBED ALTERATION AGREEMENT PROCESS: CLFA has written to the Department of Fish & Game requesting they consider a policy that will utilize the THP functional equivalence to secure performance of Streambed Alteration Agreements.
BOTANICAL SURVEYS: On February 18, Bill Apger submitted a letter to Andrea Tuttle, California Department of Forestry & Fire Protection Director, and Robert Hight, Department of Fish and Game Director, requesting that CDF discontinue the practice of requiring botanical surveys as a condition of approval for harvesting plans. The letter also requests that DFG discontinue its practice of requiring botanical surveys as a condition of approval of plans in its recommendations to plans. The letter was submitted on behalf of several RPFs and other resource professionals.
MEADOW VISTA PTEIR NOW AVAILABLE ON WEBSITE: The Meadow Vista Program Timberland Environmental Impact Report (PTEIR) was prepared by the Placer County Resource Conservation District, with assistance from CDF, to make it easier for landowners in the Meadow Vista Community to conduct fuels reduction treatments that also yield some revenue from commercial timber harvest. A programmatic timber harvesting plan (PTHP) must be prepared for each individual fuel treatment project, and each PTHP must be consistent with the PTEIR. According to FRAP (Fire & Resource Assessment Program), the PTEIR provides a potentially useful model for other efforts to use a programmatic EIR approach to facilitating timber management across multiple small forestland ownerships. http://frap.cdf.ca.gov/projects/Meadow_Vista_PTEIR/PTEIRframes.html.
BOTANICAL ISSUES: Copy of letter from Niel Fischer to Robert Floerke, Regional Manager, Central Coast Region, Department of Fish & Game (DFG), regarding botanical issues related to timber harvesting and request for current written DFG policy.
Raptor Survey Requirements for THP Applicants: Letter to William Apger, dated 10/10/01, from Department of Fish & Game concerning Raptor Survey Requirements for Timber Harvesting Plan Applicants.
RAPTOR SURVEYS: The Department of Fish & Game (DMG) has issued two memos regarding currently policy for Raptor Surveys on THPs for the North Coast Region and the Central Coast Region.
BILL OF RIGHTS FOR THP SUBMITTERS: CLFA member, Jere Melo, has submitted a Petition for Rule Making to the Board of Forestry requesting they adopt a Bill of Rights for Timber Harvest Plan Submitters. CLFA is supporting the petition and has submitted official response to the BOF.
OFFICIAL CLFA RESPONSES TO BOF RULES PACKAGES AT SEPTEMBER, 2002 HEARING:
STOCKING STANDARDS - 2002: CLFA has officially responded to the California Department of Forestry & Fire Protection re: Stocking Standards - 2002.
AG'S OPINION ON FLORA SURVEYS: California Attorney General's (AG) opinion No. 95-902 concludes that as a condition of issuing a timber harvesting permit, the Department of Forestry and Fire Protection may not require a property owner to submit a comprehensive flora and fauna survey of the property.
CLFA REQUESTS RESPONSE FROM CDF & DFG: In a letter dated March 18, 2002, to CDF Director Andrea Tuttle and DFG Director Robert Hight, CLFA has requested that they respond to Bill Apger's letter to them regarding botanical policies.
RPFS PETITION FISH & GAME RE: RAPTOR/OWL CONSERVATION: A group of RPFs have signed a petition which was submitted along with a letter, under Bill Apger's letterhead, requesting the California Department of Fish & Game reconsider DFG's approach to the conservation of raptor and owl species within the context of THP, NTMP and PTHP review. The letter was sent to Donald B. Koch, Regional Manager, North Coast Region and Robert W. Floerke, Regional Manager, Central Coast Region. The letter was sent April 11. To date, no reply has been received. The letter submitted was not a CLFA letter but CLFA received a copy of the correspondence. At the June 2 CLFA Board meeting, the board decided that CLFA would write a letter to the two DFG officials inquiring as to the status of their reply.
NEW ARCHAEOLOGY RULES PACKAGE TO BE PRESENTED TO BOF: Dan Foster, CDF Archaeologist, met with the CLFA Board on March 23 to discuss a proposed archaeology rule revision package the Department plans to present to the Board of Forestry this year. At that meeting he also discussed the Native American Contact List (NACL). After the meeting, Dan prepared a memo to CLFA outlining some of the reasons the Department has prepared the rules package (Summary Report), and included the latest copy of the proposed rule revisions (Rule Revisions). Dan also included a revised NACL Cover Page and NACL Revised Contact List (revised 3/18/02). CLFA has not taken an official position as yet regarding the proposed rule revisions. However, CLFA has sent to Dan Foster some preliminary CLFA Comments about the package. Update: CLFA has just received a Revised Version (April 8) of the proposed rules package which we understand is the version that will be submitted to the Board of Forestry.
WATERSHED PROTECTION EXTENSION 2001: CLFA letter to Office of Administrative Law (OAL) requesting that OAL return this rule extension to the BOF because of deficiencies in procedure.
Large Old Trees Rule Package: Official CLFA comment to the Office of Administrative Law (OAL) regarding the Large Old Trees Rule Package approved by the BOF.
OFFICIAL CLFA RESPONSES TO BOARD OF FORESTRY RULE PACKAGES:
Administrative
Hearings
Infractions
Watershed
Protection Extension 2001
Interim Watershed Mitigation 2002
(IWMA)
REQUESTS TO GOVERNOR FOR SUPPORT/VETO OF LEGISLATION: Letters to Governor
Davis from OMI Government Relations, on behalf of CLFA, regarding the following
legislation on his desk awaiting signature (deadline for signature or veto
is October 14):
AB62 (Migden) - Sudden Oak Death - Request
for Support
SB540 (Sher) - County Appeal of THPs - Request
for Veto
PROPOSED REGULATION FOR PERMANENT LARGE OLD TREES: Official CLFA response to the BOF proposed Regulation for Permanent Large Old Trees. Go to: www.fire.ca.gov/BOF/board/board_proposed_rule_packages.html to view the proposed rule package and 45-day notice.
REVIEW TEAM RECOMMENDATIONS, 2001: Official CLFA response (3/30/01) to the State Board of Forestry & Fire Protection to rule package "Review Team Recommendations, 2001" which was developed after a petition was filed with the Board of Forestry by Charles Ciancio.
OFFICIAL CLFA RESPONSE to "Coho Considerations, 1999" Rule Package at August BOF meeting.
Official CLFA Response to "Plan Submitter, RPF and LTO Responsibilities, 2000" Rule Package at July Board of Forestry Meeting.
CLFA'S OFFICIAL RESPONSE TO THE BOARD OF FORESTRY'S "Protection for Threatened & Impaired Watersheds, 2000" Rule Package, noticed January 28, 2000
MANDATORY CONTINUING EDUCATION: The issue of voluntary versus mandatory continuing education has once again come up for discussion. Review CLFAs 1998 response to the PFEC on this matter.