USFS will allow public comments!

Larry Harrell lhfotoware at
Tue Dec 23 11:34:07 EST 2003

December 22, 2003  Greenwire

Agency will allow mass e-mails, form letters as public comment 

by Dan Berman

The Forest Service has dropped a controversial plan to ignore chain
e-mails and other forms of mass mailings as legitimate public comment
on agency forest management plans, amendments or revisions.

The proposal, which was tucked into the Bush administration's November
2002 draft changes to planning rules under the National Forest
Management Act, was widely criticized by environmentalists and public
advocacy groups. However, it will not be included when the final
planning rules are released early next year, Forest Service
spokeswoman Heidi Valetkevitch said.

Under the proposal, the Forest Service said it would consider only
"original substantive comments" submitted by citizens or groups. "Form
letters, check-off lists, pre-printed postcards or similar duplicative
materials will not be accepted as objections," the proposal stated.

Earlier this year, Forest Service Chief Dale Bosworth noted the
collection of public comments is often portrayed as a public vote on
agency proposals, even though that is not the intent.

"My view is that we're not counting votes anyway," Bosworth said. "But
it always ends up becoming an issue. People say, 'If you have 1.6
million comments on an issue and 95 percent of them went one way, then
how can you possibly do something different?' It just distorts the

More recently, a Heritage Forests Campaign analysis of the 250,000
public comments submitted on the Forest Service's plan to eliminate
Clinton-era rules limiting development for Alaska's Tongass and
Chugach national forests found that about 99 percent of comments
opposed the proposal. However, the vast majority of comments were
submitted as form letters.

Cindy Cohn, legal director of the Electronic Frontier Foundation,
which opposed the proposal, praised the Forest Service's decision to
abandon the comment rule. "The Forest Service is right to ... allow
the public to continue to make its voice heard," Cohn said. "Allowing
ordinary people to influence the rules that affect their lives through
Web site action centers is one of the best benefits of the technology

Even so, Valetkevitch said the Forest Service still prefers
"substantiative comments rather than form letters," especially before
a final decision on forest plans is made. "During that critical time
we have a deciding official who really wants to deal with the issues
that people have with the forest plan, and form letters often don't
deal with much detail," Valetkevitch said. "The planning process takes
so long now, we wanted to save time where we could."

NMFA, roadless rule changes due early next year 

Meanwhile, the Forest Service plans to publish its final changes to
planning rules under the National Forest Management Act as well as its
replacement of the Roadless Area Conservation Rule early next year,
Valetkevitch said.

According to an Aug. 28 final draft of the planning rule changes, the
Bush administration is planning to bar individual forest managers from
conducting environmental reviews when they update forest management
plans. Under NMFA, the Forest Service is required to develop land and
resource management plans every 15 years for all of the nation's 192
million acres of national forest. The plans dictate activities such as
timber harvesting, recreation and wildlife management, and
environmentalists fear any changes could open the door to logging or
other disruptive activity.

For the roadless rule, the Forest Service has been working for months
on a new policy to replace the Clinton-era rule for 43 million acres
of forest in the lower 48 states. A federal judge struck down the
3-year-old rule in July, calling it a de facto attempt to create
federal wilderness areas.

For the two Alaska forests, the Forest Service could publish its final
decision dropping the roadless rule by the end of the month,
Valetkevitch said.

Comment from poster: I see this as a way to still accept the public's
input, no matter how ineffective many of those forms and cards may be.
The REAL challenge for the "preservationists" will be to "produce"
opinions that the Forest Service won't ignore, based on science.
"Preservationists" are just being lazy and ignorant if they use these
"tools", IMHO.

The way I see it (I've looked at "officially accepted" public
responses before), we cannot cut the public out of their right to
express their opinion. It's part of our Democratic system but, the
Forest Service can and will exericise their option to disregard
opinions that have no basis in reality and science.

Regarding the Roadless Rule, which "preservationists" often falsely
call an "initiative", they claimed X million "votes" for their cause.
I want to know how many "voted" multiple times. I want to know how
many non-citizens "voted", as well. I want to know how many "votes"
were disregarded because those forms and cards did not have a valid
point. In short, we need a comprehensive report on such gatherings of
public opinion. BTW, I'm all for no more roads, especially in
Designated Roadless areas.

If "preservationists" want to "vote", I'm thinking that we need a
registration and reporting system, similar to elections. One person,
one "vote", one officially registered name or social security number.
(I can already hear the calls of "Big Brother") No one with a name
like "Bluebird" or "Terra Verde" can be accepted <G>. I'm also
thinking that the USFS needs to address the issues brought up by
popular forms and e-mail cards. It is EXTREMELY important that the
agency explains to the public why their opinion is wrong OR explain
how they're going to mitigate their concerns OR why they're going to
change their project to accomodate good science and good forestry, as
the public may rightfully point out.

The excuse that people are too busy to write individual and unique
responses is bullpucky! If it's important enough to you, then you'd
better FIND the time to write a sincere and science-based letter with
your concerns over specific projects. However, I truly wonder if,
collectively, today's "preservationists" have enough education to
write an elegant and educated letter that the USFS can't ignore.

Larry,    "voting" for science-based ecosystem management

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