Six forestry spray projects.
4,226.08 acres.

October spraying · June 2025 disclosure

Six October applications. Work orders handed over in June 2025.

All six work orders document October applications: two in October 2023 and four in October 2024. They cover 4,226.08 completed application acres across Lassen and Plumas counties.

The cover emails show Paul Washburn of Western Helicopter Services sending the work orders to the Lassen County Agricultural Department on June 10, 2025. The email titled “2023 Spray Reports” was sent at 9:21 a.m.; “2024 Application” was sent at 9:04 a.m. The packets contain the two 2023 work orders and four 2024 work orders respectively.

CWMP reports that these applications had not been reported to the appropriate county agricultural departments as required before Western Helicopter handed over the work orders in June 2025. The emails document that handover; the account of the missing earlier reports is CWMP’s finding.

2023 cover email: page 1 · 2024 cover email: page 4. Work orders appear on pages 2–3 and 5–8. The original page images and redactions are unchanged.

The six completed work orders

4,226.08 application acres across two counties.

The complete packet contains two October 2023 work orders, four October 2024 work orders and both June 10, 2025 cover emails. Every one names WM Beaty as customer and Western Helicopter as applicator. The completed-acreage totals are 3,717.22 for Lassen County and 508.86 for Plumas County.

Calculation: 2,160.22 + 392.86 + 197.00 + 470.00 + 890.00 + 116.00 = 4,226.08 acres. Each work order is counted once, regardless of the number of products. HogSheepDixie’s two half-rate passes are counted as the recorded 116.00 acres, not doubled. This is a sum of application acreage across 2023–2024, not a surveyed total of unique land; treatment areas may overlap between projects or years.

Three work orders include 2,4-D.

Dixie West (197.00 acres), Dixie North (890.00 acres) and HogSheepDixie (116.00 acres) list Low Vol 6 Ester, EPA registration 34704-125, containing 2,4-D 2-ethylhexyl ester. These three work orders total 1,203.00 completed application acres.

California designates 2,4-D as a restricted material, with formulation and package-size exceptions. The EPA product label for Low Vol 6 Ester lists 88.8% 2,4-D ester (58.9% acid equivalent) in a 2½-gallon container. That labeled formulation and package fall under California’s restricted-material designation in 3 CCR §6400(e).

How missing reports shape the monitoring plan

Follow the reported spring treatment. Investigate the missing autumn application.

In the non-reporting cases CWMP has uncovered, the earlier applications are reported: crews use backpack sprayers on foot in spring or early summer, often around late June, applying glyphosate and imazapyr. CWMP reports that it is the later October helicopter applications of hexazinone, indaziflam and/or 2,4-D at the same sites that are missing from the reporting record.

This is why obtaining pesticide-use reports remains central to our work. The earlier PUR can identify a treated forestry site even when a later application has not been reported. We will check the site’s records across the season, investigate a missing autumn PUR through notices, work orders and other evidence, and plan laboratory testing for the suspected autumn chemicals regardless of whether that later report has been filed.

A missing October report does not establish that no spraying occurred. It is a reason to investigate. Our testing plan will identify which chemicals are documented, which are suspected and what evidence supports the selection of hexazinone, indaziflam or 2,4-D for analysis.

Read the monitoring and follow-up plan.

Company leadership & public oversight

Ryan Hilburn and Shane Compton.

Ryan Hilburn

W.M. Beaty’s current company biography identifies Hilburn as General Manager, responsible for directing forest-management activities for the firm’s clients. It lists his professional forester registration as RPF #2782.

Hilburn also serves on the California Board of Forestry and Fire Protection as a Forest Products Industry Representative. His appointment was announced on December 3, 2024, after the applications documented here. The appointment announcement and Board biography describe his earlier role as Chief Forester. He is also the Board’s co-chair of the Effectiveness Monitoring Committee (EMC).

Photo: California Board of Forestry and Fire Protection.

Shane Compton

W.M. Beaty’s staff page identifies Compton as Reforestation Forester. He is the forester named on the Motor Sheep permit, with listed credentials QAL #139592 and RPF #2903.

Photo: W.M. Beaty & Associates staff page.

What the Board is responsible for

The Board’s statutory responsibilities include setting California’s forest policy, establishing guidance policies for CAL FIRE, adopting Forest Practice Rules and overseeing professional-forester licensing. The Board also developed the California Vegetation Treatment Program, which includes herbicide application among its vegetation-treatment methods.

CAL FIRE administers Forest Health grants and other forestry funding programs. Pesticide-use reporting and enforcement involve DPR and county agricultural commissioners.

The same committee that left the herbicide study unfunded.

Ryan Hilburn now serves as the Board’s co-chair of the Effectiveness Monitoring Committee (EMC). The Board created the EMC to assess whether California’s forestry rules protect public resources. W.M. Beaty’s General Manager therefore also holds a leadership position in the committee that helps select research used to evaluate those safeguards.

This is the same EMC that considered EMC-2022-001, the proposed study of herbicide discharges and water quality after post-fire reforestation. The November 18, 2022 meeting record shows that members discussed the proposal before lunch, but the funding motion after lunch covered EMC-2022-003, EMC-2022-004 and EMC-2022-005, leaving the herbicide-water study out. That decision preceded Hilburn’s December 2024 appointment to the Board.

CWMP sees this overlap between industry management and monitoring leadership as a serious accountability concern: the committee that left the herbicide study unfunded is now co-chaired by the General Manager of a firm involved in the applications CWMP identifies as unreported. How will the Board and EMC ensure independent herbicide monitoring, transparent research decisions and public accountability?

Who CWMP says knew about the missing reports

CWMP reports that Ryan Hilburn, Shane Compton, Western Helicopter Services and the Lassen County Agricultural Department knew the two Plumas applications had not been reported to Plumas County. According to CWMP, they did not bring the missing reports to Plumas officials’ attention or ensure the required reports were filed, even after becoming aware of the omissions. This allegation concerns their knowledge and subsequent actions; the work orders alone do not establish who knew what or when.

Unreported applications · Investigation & enforcement

What CWMP reports about the agency response.

CWMP reports that Motor Sheep’s hexazinone and indaziflam applications were not reported to the Lassen County Agricultural Commissioner as required by law. CWMP identifies Motor Sheep and the five other projects above, involving W.M. Beaty & Associates, Shane Compton and Western Helicopter Services, as applications that were not reported to the appropriate county agricultural department within the required deadlines.

DPR and Director Karen Morrison

CWMP reports that the California Department of Pesticide Regulation has been informed about all six unreported applications but has declined to intervene. CWMP also reports that communications to DPR Director Karen Morrison about this matter remain unanswered.

Agency-status account provided by CWMP as of October 9, 2026. The source packets published here contain application work orders and June 10, 2025 transmission emails. They do not contain the citation, investigation correspondence or CPRA transfer records; the account of enforcement and communications above is attributed to CWMP.

Reporting is a legal requirement.

For applications to produce an agricultural commodity, 3 CCR §6626(b) requires an agricultural pest control business to report pesticide use to the agricultural commissioner in the county where the application occurred within seven days of completion. Section 6626(a) addresses the property operator’s reporting duty when the business has not reported. Section 6627 provides monthly reporting deadlines for uses outside §6626.

The June 10, 2025 cover emails and all six October work orders are published together so readers can examine the application dates and the later transmission to Lassen County.