The Bush administration if trying to change the 36 CFR Part 219, National
Forest System Land and Resource Management Planning, Proposed rule, published
Dec 6, 2002.
Below are the comments submitted by Cherokee Forest Voices If you wish
you may use these comments as a base for your own. Here is a link to the Federal
Register containing the proposed rule change in [PDF]
and [TEXT]
formats.
The email address for comments is planning_rule@fs.fed.us and the
fax number is 404-329-3556. The deadline for comments is March 6 2003. Background
factsheet information obtained from Steve Holmer American Lands Alliance
http://www.americanlands.org/bush_regulations.htm,
and Mike Anderson of Wilderness Society http://www.wilderness.org/ and other
national groups.
USDA FS Planning Rule
Content Analysis Team
P.O. Box 8359
Missoula, Mt. 59807
March 1, 2003
Dear Chief Bosworth,
Re: 36 CFR Part 219, National Forest System Land and Resource Management
Planning, Proposed rule, published Dec 6, 2002
Sir:
Please accept these comments on behalf of Cherokee Forest Voices (CFV).
Cherokee Forest Voices is a not-for-profit educational association of conservation
groups and volunteers whose mission is to encourage increased emphasis on
the ecological values of the Cherokee National Forest. Included in this mission
is the restoration and preservation of biodiversity, improved protection
of fish, wildlife, plants, soil and water resources, and increased availability
of nature oriented recreation and the protection of scenic values.
CFV wants to register our strong objection to the newly released proposal
that seriously weakens protections for wildlife and the environment under
the National Forest Management Act. The current administration argues
that the proposed regulations are too complex to be implemented but the regulations
are complex because the issues are complex.
Under the proposed regulations:
The proposed regulations render the forest management plans meaningless:
Individual projects will not have to be consistent with the forest plan due
to provisions for easy exemption from the standards set out within the plan.Interim
amendments to the plan may be issued by a regional forester without any public
review and can remain in effect for four years.
Forest Management Plans will not have to undergo analysis under NEPA:
It is explicitly stated that forest management plans do not make an irreversible
or irretrievable commitment of resources that may have a significant effect
on the environment and thus categorical exclusions can be used to exempt
the plans from any formal environmental analysis or impact statements.The
categorical exclusion of plans means that different alternatives of the plans
will not have to be offered or considered for review the provision for evaluating
the merits of alternatives is the heart of NEPA. Analysis of the environmental
impact of the plan is significantly reduced.
Species protection is revoked:
The proposed regulations restrict the need for consideration of species viability
to vertebrates and vascular plants, eliminating any protection for fungus
and insects. It bases species protection on habitat capacity, a concept that
has already been rejected as an effective protection of species viability.
The large scale population dynamics of species would be ignored, possibly
creating isolated and unsustainable populations. Provisions are established
that allow the sacrifice of short term viability for long term goals.
Science is eliminated from the planning process:
This is the first time that significant changes would be made to the forest
management regulations without independent scientific review. Extensive requirements
for scientific review and consultation with independent scientists in the
development of forest plans would be eliminated and replaced with optional
provisions for including scientists in the process. Monitoring requirements
for measuring how effective the plans are at promoting sustainability are
significantly reduced, giving regional foresters the discretion to determine
the level of monitoring needed and eliminating requirements for scientific
review.
Logging is given priority:
Provisions for salvage logging, hazardous fuels reduction, or habitat improvements
mean that logging is not restricted anywhere on Forest Service lands unless
explicitly stated in law. Other provisions would allow the maximum sustainable
yield of timber harvest to be exceeded without limit.
Public participation is greatly restricted:
Only comments that cite exactly how the forest plans are inconsistent with
law, regulations, or other official policy will be considered, other substantive
comments on the direction or goals of the plans will be dismissed. The bypassing
of NEPA review eliminates important opportunities for public participation.
Only original comments will be considered meaning the typical methods that
citizen s groups use to weigh in on decisions will be ignored. This would
eliminate consideration of public comments by postcard, email, and mass or
form mailing.
There is no opportunity to appeal decisions on the plan.
Mandatory rules to keep native species on National Forests are needed, especially
since these forests are heavily used for logging, mining and oil and gas
drilling. Maintaining our native plants and wildlife must be required by
law, and not be voluntary or subordinate to logging and other extractive
interests. Mandatory environmental impact statements, scientific review,
public participation, monitoring and evaluation are also needed.
It is the Forest Service's obligation to maintain species that depend on
healthy forest habitats, and to prevent them from becoming endangered by
excessive logging, clear-cutting, road-building and other extractive industrial
processes.
The revised regulations should be withdrawn by the Bush Administration.
Respectfully Submitted,
Catherine Murray
Cherokee Forest Voices
1101 Antioch Road
Johnson City, Tennessee 37604