| July 22, 2019 NEPA Rule Change And What It Means For OUR FORESTS National forests belong to all of us, and public participation in their management has been crucial in making sure future generations will be able to enjoy our national forests just as much as we do. Science-based environmental review of Forest Service projects helps ensure they are well-designed, appropriate for the land, and protect animals, plants, and streams. Georgia ForestWatch relies on the public’s right to comment and information in environmental reviews of projects to improve projects and preserve, protect, and restore the Chattahoochee-Oconee National Forests. Now the Forest Service is proposing to take that away. For their projects they are proposing rule changes that would eliminate almost all public participation and environmental review. The good news is the Forest Service must take public comments on the proposed changes. Speaking now will help preserve our rights to know about what the Forest Service is planning and have a say in how our public lands are managed. Comments are due August 12. Problems with the proposed changes: Most of the proposed changes focus on how the Forest Service would implement the National Environmental Policy Act (NEPA), a bedrock environmental law that ensures public review when government projects may have a significant environmental impact. Public participation is essential for good decisions affecting public lands. When the Forest Service considers allowing logging, road-building, or mining on our national forests, it must balance those uses with impacts to wildlife, clean water, backcountry areas, recreation on rivers and trails, and other social and economic impacts. That balancing act is impossible without listening to the people who would be affected by its decisions. This proposal would remove public commenting on projects involving, among other things:Building up to 5 miles of new roads at a time;Bulldozing new pipeline or utility rights of way up to 20 acres (e.g. 4 miles at 40’ wide);Commercially logging up to 4,200 acres (over three times the size of Forest Service ownership on Mount Yonah) at a time No chance for the public to comment on commercial logging up to 4,200 acres (over three times the size of Forest Service ownership on Mount Yonah) at a timeThe road building loophole would have allowed the Forest Service to slice off part of the Rabun Bald roadless area, which was proposed by in the Upper Warwoman Project and turned back through the involvement of Georgia ForestWatch, Southern Environmental Law Center, and public commenters. Georgia ForestWatch fought the construction of the powerline over Glassy Mountain, in part because it would cut through unusual and sensitive habitats. Under the proposed changes, we wouldn’t even have known the powerline would cross through those areas. The logging loophole is so big that that it would cover all the timber harvest in the Cooper Creek project—meaning no public input or science-based analysis on the worst Forest Service project of recent years. In fact, 4,200 acres of harvest is almost three years’ worth of commercial logging at current levels on the Chattahoochee National Forest. The proposed changes would codify and encourage one of the biggest problems with the Foothills Landscape Project. Foothills describes the kind of places where timber harvests would occur but not the specific locations. Without knowing the location, you don’t know if the Forest Service is planning to harvest a stand that nurtures rare species, is the last mature stand in an area of old clear-cuts, or has unique features. The Forest Service hides this problematic approach behind the bland jargon “condition based management”. The proposed changes would allow the Forest Service to skip environmental review when they have completed a “similar” project that did not cause significant impacts. History suggests many projects that they consider “similar” will not look similar to us. Georgia ForestWatch’s issues with Forest Service projects often come down to us recognizing differences between areas that the Forest Service misses, differences that lead to a mismatch between the proposed treatment and the particular location. Additionally, as science advances our understanding of ecosystems and climate changes, we may see impacts in types of projects where previously there were none. In bureaucratic language, this process of checking for similar environmental reviews is “determination of NEPA adequacy”. Not only would project decisions be made without public input, they would also be made without environmental review and without considering whether there are less harmful ways to meet the same needs. Protect your right-to-participate and our national forests: NEPA functions well now. Public comments and environmental review have a long track record of improving Forest Service projects. Please tell the Forest Service what you think about changes that would allow up to 4,200 acres of commercial logging, 20 acres of right-of-way construction, or 5 miles of new road construction without public comment or environmental review. Tell them about the problems with condition based management and determination of NEPA adequacy. Tell them how you feel about the public having a voice in national forest management and science-based environmental review. Please comment by August 12th How to Comment on the Proposed Rule Public Participation Portal (preferred) Mail: NEPA Services Group, c/o Amy Barker, USDA Forest Service, 125 South State Street, Suite 1705, Salt Lake City, UT 84138 Email: nepa-procedures-revision@fs.fed.us NOTE: This helpful message is posted on the Public Participation Portal: Regulations.gov will undergo scheduled maintenance and will be unavailable from July 27th, 6 am (ET), to July 28th, 6 pm (ET). We regret any inconvenience that this maintenance may cause. |
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