Certified Range Manager Requirements

In 2008 California's Deputy Attorney General (DAG) prepared an opinion on "CRM Licensing Issues" in response to questions about the requirement for the CRM license in the conduct of professional rangeland management in California. This legal analysis had been requested by Eric Huff, Executive Office, Foresters Licensing Program, Board of Forestry and Fire Protection, and the CalPac Certification Panel.

The DAG's analysis clarifies some important facts about the CRM license that affect our work as professional rangeland managers:

1. CRM LICENSE IS REQUIRED. An individual possessing the CRM license is required for rangeland management on non-federal "forested landscapes," with the exception of landowners. This term "forested landscapes" is not clearly defined in state regulations, and further definition would require legislation. "Forested landscapes" are defined on page 2 of the DAG opinion. This implies that all government agencies and private sector organizations and individual professionals conducting work on non-federal "forested landscapes"
and the related rangeland resources in California are subject to these regulations. This further implies that conducting such work without the CRM license would be in violation of the regulations in addition to professional ethics. And that projects conducted and resulting documents prepared without the CRM license would be in violation of the regulations, and subject to complaints and litigation.

2. LICENSED CRMs MAY SUPERVISE AND TAKE RESPONSIBILITY FOR UNLICENSED WORKERS IF CONDITIONS ARE MET. Unlicensed persons are restricted from engaging in professional rangeland management on non-federal "forested landscapes" and the affected rangeland resources in California unless "a [CRM] is in charge of the professional practice or work of that person and all professional work or documents are done by or under the supervision of the [CRM}." (Refer to page 5 of the DAG opinion.) This implies that an agency or company conducting the regulated professional work must employ individuals possessing the CRM license to directly work on or supervise any unlicensed workers participating in the work, including authorship of documents. This further implies that such licensed CRMs could thus be held responsible for any errors, omissions, or ethical violations related to the covered work performed by him- or herself as well as the work of the unlicensed workers under supervision. Refer to the ethical requirements and standards defined in the CalPac CRM program description (included in the links at http://www.casrm.org/ certified.html).

3. REQUIREMENTS TO BE A CRM IN GOOD STANDING. Regarding or referring to oneself as a licensed CRM requires that such person has passed the CRM exam (unless "grand-fathered" at time of program establishment), applied to and been licensed by the Foresters Licensing Program, and paid the required application and renewal fees to the CalPac SRM Section and the Foresters Licensing Program (respectively). The CRM in good standing must also participate in the SRM and document continuing education activities. This implies that anyone who has fulfilled part, but not all of these requirements, or who has not continued to fulfill these requirements is not in good standing, and may be removed from the list of licensed CRMs. (Refer to the continuing education requirements defined in the CalPac CRM program description (included in the links at http://www.casrm.org/ certified.html). Find the current "Roster of Valid CRMs" at http:// www.fire.ca.gov/CDFBOFDB/licensing/licensing_current_docs.aspx .)

4. OTHER REQUIREMENTS. Other information about the CRM program, application and licensing requirements and procedures, and forms can be found at http://www.casrm.org/certified.html .

5. CRM PROGRAM HISTORY. In addition, Eric Huff, Executive Officer, Foresters Registration, for the Board of Forestry and Fire Protection prepared a useful memo describing the CRM program’s history, which may be found with appendices at http://www.fire.ca.gov/CDFBOFDB/ licensing/licensing_current_docs.aspx .

• Deputy Attorney General's Opinion