For the action oriented on the list.
[EMAIL PROTECTED]
------- Forwarded Message Follows -------
yet another affront to sensible management of public lands...
so WRITE ANOTHER LETTER! I thought this one would be of particular interest
to people who work in conservation biology... (Remember, this game is
played on many levels. If our current congress won't listen to us, we need
to make sure the people in charge of implementing the laws hear us loud and
clear.)
On April 13, 1995, the United States Forest Service (USFS) proposed
major changes in the rules which govern the agency's management of our
public lands. These proposed changes (published in the Federal Register,
April 13 1995) would restrict public input and would exempt many projects
from environmental law. This rule change is also part of the "salvage"
logging campaign set forth in the infamous rider attatched to the
recently-signed Recissiions Bill.
It is also an attempt to dismantle one of the most effective tools
we have for appealing destructive timber sales, grazing permits, etc.
Currently, the National Forest Management Act (NFMA) requires the Forest
Service to meet "population viability standards" for sensitive, threatened,
and endangered plants and animals (under the heading of "providing for
diversity.") In its justification of the rule change, the USFS claimed
that when NFMA was enacted, "population viability" was a vague concept.
According to the USFS, the authors of the act did not anticipate that
conservation biologists would develop "population viability" analysis into
a rigorous method of establishing concrete standards for management of
threatened plants and animals. The USFS now claims that the agency should
not be bound by scientific standards for population viability, but should
be given discretion to generally manage habitats of such populations so as
to "provide for diversity" as it sees fit.
"Option I" of section 219.4 would replace population viability
standards with vague goals based on continued resource extraction. In other
words, the Forest Service wants to be able to say that as long as we can
keep getting timber, cows, or rocks from a forest, we can figure it is
diverse enough, regardless of how many creatures we drive to extinction.
PRESERVE CONCRETE, SCIENTIFIC STANDARDS, and
FIGHT THE SALVAGE HOAX EVERY STEP OF THE WAY
COMMENTS ON THE PROPOSED RULE CHANGE ARE DUE BY AUGUST 17.
Show the Forest Service that we will not be shut out of the
decisions that govern our public lands!
Letters can be as short as you like, and should address specific points.
Three of the biggest problems with the proposed rule change are:
1.) Eliminating "population viability standards" would eliminate
concrete, scientifically-based standards in favor of vague "sustainable
ecosystem"goals based on resource extraction (timber, mining, grazing, etc.).
Say NO to "Option I" of section 219.4.
2.) "Interim amendments" would exempt an unlimited number of projects
from environmental laws, public input, and standard planning processes. Say
no to any exemptions from the laws that protect our forests.
3.) "Salvage" timber sales would not be included in calculations of
"allowable sale quantity." "Salvage" logging would be above and beyond the
"sustainable cut" mandated by NFMA.
(The actual text of the proposed rule change is 45 pages long, and should
be available at any USFS office.)
**mail comments to:
Director, Ecosystem Management (1920; 3 CEN)
Forest Service
USDA
P.O. Box 96090,
Washington, D.C. 20090-6090
*Get your friends to submit comments also. Quantity does matter!*thanks all*
G.S.Bodner, Student Environmental Action Coalition-SW.(520)322-9819
[EMAIL PROTECTED]
Here's a DRAFT letter, provided as an example. Letters need not be this long!
Gitanjali Bodner
Ph.D. program
Dept. of Ecology and
Evolutionary Biology
University of Arizona
Tucson, AZ 85721
Director
Ecosystem Management (1920; 3 CEN)
Forest Service
USDA
P.O. Box 96090
Washington D.C. 20090-6090
Dear sir: July 27, 1995
I am writing in response to the USFS proposed rule change regarding
the management planning process, as published in the Federal Register of April
13, 1995. I am concerned by some of the internal contradictions within this
document. I am concerned also by the numerous examples of disposing of
concrete standards in favor of vague goals. Such abdication of a
rigorous approach to decision making is profoundly unbecoming to an
agency which professes a profesional, scientific approach to management.
219.4: "Sustainability of ecosystems"
In the Federal Register, 4/13/95, the USFS complains that "insuring
viable populations... envisions an outcome that is not guaranteable by any
agency" You can think of viable populations as being impossible to
guarantee, and hence give up even trying, or you can take it as a concrete,
explicit goal, and try to do the best of your ability. Furthermore,
maintaining such a concrete goal provides a ruler by which to evaluate your
progress. No court would fault an agency for failing save a species from a
threat over which the agency had no control (such as disease), so long as
the agency proves that it truly has done everything in its power to
preserve habitat necessary to support viable populations, and provided
that habitat necessities have been established on the basis of sound,
rigorous, quantitative science.
"Options for Providing Diversity:"
"Option I" is unacceptable for the following reasons:
1.) As you note on p. 18895, much scientific progress has been made
regarding "species viability." If the USFS is truly concerned about the
survival of endangered, threatened, and sensitive species, the agency ought
to applaud these scientific advances and use them to their fullest
potential. Instead, it appears that the agency is bellyaching about
having to actually collect field data and perform basic analyses before
making management decisions. Wildlife biologists, conservation
biologists, population biologists, ecologists, and geneticists have teemed
up to develop rigorous, quantitative procedures for analyzing viability of
populations (and habitat required for maintenance of viable populations).
They have done so because they recognize that such procedures provide
information that is ABSOLUTELY ESSENTIAL for informed land management
planning that "provides for diversity."
2.) A "focus on habitat capability" rather than actual populations of
species of concern (P. 18894) is undeniably inappropriate for most species.
Any competent biologist - agency or otherwise - would agree that we simply
have not done enough research on the vast majority of sensitive species to
have any real understanding of what that species' specific habitat needs
are. The only way we can learn about the habitat requirements of such a
species is to study population dynamics in habitats with differing
characteristics. How can you advocate making decisions on the basis of
factors we do not understand and cannot measure, while ignoring the factors
we CAN measure and can study directly???
Furthermore, "analyses involving population demographics and
prediction of population trends...would likely only be needed when a
continuing downward trend in habitat capability is predicted to be leading
to the listing or extirpation of the species." How can you expect to see
such downward trends if you refuse to study population dynamics or make
informed predictions of population trends???
One case in which Option I appears to be superior to Option II is in
the case of expanding consideration to include also "invertebrates,
vascular plants, bryophytes, fungi, and lichens." However, even token
consideration of these other important groups would require hiring hundreds
of new biologists who specialize on these groups. In the previous
paragraphs, the USFS complained that the agency lacks resources to conduct
thorough analyses of the vertebrates they are already required to
consider. Thorough analysis of a few species (in this case vertebrates, who
usually require enough habitat that they function as "umbrella species"
confer some protection to other components of their ecosystems) is far
preferable to less-than-half-assed consideration of many, many, many, many
species.
Abdicating range-wide consideration of species is a recipe for
endangered species listing, and for extinction itself. It also conflicts
with the USFS stated mandate to cooperate with other agencies and
professionals. In dealing with species which have limited or threatened
populations in one management area but appear to be widespread in other
areas, we must pay attention to the CUMULATIVE impacts of land uses across
the species range. If we do not coordinate planning on a range-wide basis,
we risk losing species by one population at a time.
Abandoning the study of indicator species:
No, there is not "diminishing scientific support for ... [using)
individual species as indicators of the welfare of a group of associated
species." On the contrary! Use of indicator species continues to be widely
acclaimed as one of the most effective ways of monitoring welfare of
associated species and hence general ecosystem health. The fault
biologists most often find with the use of indicator species is that we
need to monitor more species than we do now in order to better understand
ecosystem health and diversity.
Furthermore, The USFS has spent many years and millions of dollars
monitoring certain indicator species, and has accumulated an extremely
valuable pool of scientific and management-related information. It is this
information which can provide us with the long-term data essential to
observing patterns and predicting trends in ecosystem health and
sustainability and in populations dynamics of protected species. To
abandon monitoring of indicator species now would mean giving up a
multi-million dollar experiment just as it is beginning to show
significant results! Both the tax-paying public and the scientific
community would be outraged by such an irresponsible, wasteful action!
In short, "Option I" is in direct conflict with NFMA intentions. A
vague goal of "sustainable ecosystems" (based on continued production
products for human use) IS NOT sufficient to meet NFMA provisions to
"provide for diversity of plant and animal communities." "Option I" is
also in direct conflict with the USFS stated goal of preventing the
decline of species to the point where they merit listing as threatened or
endangered, and with the desire of the public to have our public land
managed for maintenance of biological diversity and natural heritage.
Section 219.8: Paragraph (a): Interdisciplinary Teams:
In order to truly use "the best information [and expertise]
available," interdisciplinary teams ought to be allowed to include external
scientists and other agency or university collaborators.
Section 219.9: Forest Plan Amendment; Paragraph (d)(1), "Interim
amendments:"
"Interim amendments" would function to allow and encourage the USFS to
operate behind closed doors, without answering to the public, complying
with environmental laws, or following standard procedures for changing
management plans. This same strategy of exempting agency activities from
law and public review is behind the salvage rider now being debated in the
U.S. Senate. The concerned public will not tolerate such a power-grab at
the level of a USFS rule change.
"Interim amendments" as defined in this section are unacceptable for
the following specific reasons:
1.) Interim amendments are billed as limited in scope and duration,
but paragraph (d) (7) indicates that they begin with a duration of two
years and are subject to being renewed indefinitely. A lot of damage can
be done in two years of an over-hasty plan that was not subjected to
standard scientific assessment, public review, and legal supervision. To
allow such a plan to continue indefinitely would be reckless and
unprofessional.
2.) Official USFS policy (legally mandated by NEPA and NFMA and often
stated by agency directives) is to encourage public participation in public
land management decisions. Paragraph (d)(9) would reduce the public input
process to a token after-the-fact suggestion-box. Precluding public comment
on plans until after implementation has already begun and exempting plans
from administrative appeals IS NOT a good-faith effort to get public input
in management of public land. An after-the-fact comment period which
begins at the same time as the project in question IS NOT an "effective
way for the public and other government entities to communicate with the
responsible official about any potential concerns (Fed. Reg. 4/13/95, p.
18907)" (emphasis added). We refuse to be shut out of this planning
process.
3.) We do not need such broad exemptions from environmental laws and
standard amendment procedures. The USFS already has emergency exemption
provisions for safety and liability concerns. Vague exceptions for
"catastrophic events" and "resource protection" would be subject to much
more misuse than are the current safety and liability restrictions.
Exempting interim amendments from public notice requirements and
from compliance with NEPA regulations (including preparation of
Environmental Impact Statements) is underhanded and dishonest. We cannot
give up thoughtful and thorough management planning for the sake of
expediency. If the USFS is managing our lands to the best of its ability,
it will have no need to exempt itself from the law.
Section 219.7: Salvage Logging and timber quotas:
I do not aprove of the proposed change which would exclude
"salvaged" timber from Allowable Sale Quantity calculations. ASQ
calculations are designed to ensure that timber on public lands is
harvested in a sustainable manner. The agency is currently engaged in an
agressive "salvage" program, as typified by the recent rider on the
Recisions Bill, which mandates cutting BILLIONS of board-feet under
"salvage" programs. Excluding "salvage" cuts of this volume from
calculations of ASQ will inevitably result in huge discrepancies between
calculations of "sustainable cuts" and truly sustainable forestry
practices. This is tantamount to claiming that adding bagfulls of
slightly-damaged cookies to a carefully-calculated maintainance diet does
not violate the intent of the diet because the cookies are broken.
Excluding "salvaged" timber from ASQ would give greedy timber industry
executives even more "discretion" to shortchange their employees, whose job
security depends on sustainable harvesting, and would violate the intent of
NFMA.
I hope the USFS proves to be a professional enough organization to
take these criticisms seriously and act accordingly.
Sincerely,
Gitanjali S. Bodner
