In Wheeler v. State Bd. of Forestry (1983) 144 Cal. App. 3d 522, a registered professional forester was disciplined for "gross incompetence." The court noted that competence has to do with ability, qualifications and fitness to perform a prescribed duty. The record, however, contained no statute, rule, regulation, or implied standard by which to measure competence. Under those circumstances, the court found no ascertainable standard of conduct, and held that the board could not rely upon "gross incompetence" as a basis for discipline. ( Id. at pp. 527-528.)