Letters to the Forest Service by Georgia ForestWatch members have improved many Forest Service projects and helped to preserve old-growth forests, keep streams clean, and protect recreation opportunities. Some people, though, may not write because they feel like they don’t know where to begin. We have copied here one ForestWatch member’s letter to the Forest Service about proposed rule changes, which threaten public involvement in public land management and would eliminate environmental review for most Forest Service projects. This letter has several strong points, including: the tone is polite, the author takes a very clear position, and that position is backed up by specific reasons. Letters don’t have to be this long or technical though. If you want step-by-step help putting together a letter about the proposed rule changes, go to OurForestOurVoice.org. A more personal letter, like the one below, will be most effective and can be submitted online. Either way comments are due August 12th. For more information on the proposed rule changes see gafw.org/neparulechange.
Dear Chief Christiansen,
Thank you for the opportunity to comment on the proposed Rulemaking and changes to how the Forest Service implements the National Environmental Policy Act (NEPA). Managing our nation’s complex forests for multiple uses is an extremely difficult task, which is only made harder by limited resources. Managing them well, however, improves our economy, protects plants and animals, provides clean drinking water, and benefits every American. I appreciate all the hard work the Forest Service does to manage our public lands.
I am writing to express and ensure that you have a record of my comments regarding the Forest Service proposed changes to its NEPA procedures. I have reviewed the June 2019 Proposed NEPA revisions and am voicing my strong objections to the Rulemaking.
For the past 15 years I have lived in NE Georgia and adjacent to Chattahoochee National Forest lands. I have taken a personal interest in the Forest because it is so important to my community’s environment, water, economy, recreation and overall quality of life. As a citizen, I have actively participated in reviewing and commenting on many Forest Service projects, and have personally investigated many proposed project areas. I consider public participation to be essential for good decisions affecting public lands, and I am invested in these lands. I understand the importance of the NEPA as the bedrock environmental law assuring environmental analysis and public feedback and participation. But, under the proposed changes, I observe that the rights and protections that have been afforded through NEPA will be gutted.
Logging in the Southern AppalachiansOf great concern is the Rule proposal that would allow commercial logging of up to 4,200 acres of National Forest without any public comment or environmental review. This loophole is so big that every single timber sale in the Southern Appalachians could go through with no public input or science-based analysis. 4,200 acres of harvest in a single Federal government decision is equivalent to nearly three years’ worth of commercial logging at current levels in our Chattahoochee National Forest.
The Southern Appalachian forests are scenically spectacular and biologically rich and Georgia’s Chattahoochee National Forest is an invaluable public resource and astonishing animal and plant habitat. Activities like major logging projects can cause severe damage by fouling streams, fragmenting the landscape, and destroying species habitat. These forests are more than merely places for wood fiber production and any logging must be done with environmental impact considered.
Forest RoadsThis proposal would allow for construction of up to 5 miles of new Forest roads and reconstruction of 10 miles of roads without environmental analysis of potential impact, and with little to no public participation.
The proposed NEPA rule would allow the Forest Service (without describing to the public) to convert a non-national forest road or unauthorized road into a Forest system road. This would result in additional roads to maintain and loss of Forest acreage to “roads.”
The proposal will cut the public out of decisions involving closing of roads used by the public to access hunting areas, streams for fishing, and trails.
The proposal will allow for bulldozing new pipeline and utility rights of way up to 20 acres (e.g. 4 miles at 40 feet across) with no public input.
Furthermore, the current rules require the Forest Service to prepare an Environmental Impact Statement if a project will impact an Inventoried Roadless Area or Potential Wilderness Area. Your proposed rule eliminates these environmental checks and protections and threatens the conservation and recreation values of our mountain Forests.
These actions are far from routine and could have severe impacts in our steep, wet, and extremely diverse mountains. Not only would these decisions be made without public input, but they would be made without environmental review and without considering less harmful ways to meet the same needs. This is contrary to the heart and intent of NEPA.
Silencing the Voice of the People – Categorical ExclusionsI was particularly shocked to read the section of the proposed Rule regarding Categorical Exclusions (CEs), the lowest level of NEPA analysis with minimal consideration of environmental impact and public participation. I note that those Forest projects that would fall under Categorical Exclusion are being greatly expanded and the public’s right to be informed and to provide comment is to be greatly reduced.
I understand the Forest Service’s desire to operate more efficiently and to cut red tape on routine work, but based on the Forest Service’s own data, if this proposal is approved, over 93% of all Forest Service decisions will lose all the advance public notice and public comment requirements. The Forest Service already has authorities to carry out routine decisions and authority to do critical work like removing hazardous fuels and improving Forest health. The loopholes afforded in the proposed Rule are not necessary to carry out such tasks.
Historically, less than 1% of USFS decisions in our Region 8 have been challenged. On the other hand, the Forest Service sometimes does propose bad ideas—like logging old growth forest, rare habitats and erosion-prone slopes. This proposal would allow the agency to do the controversial, unneeded work without being held accountable by the public.
Forest OwnershipThe national forests do not belong to the US Forest Service—they belong to us, the people of the United States. Public participation is essential for good decisions affecting public lands. When the Forest Service considers allowing logging, road-building, mining or fracking on our national forest, 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.
I urge you to consider the voice of the people and send this proposed rule back to the drawing board.Sincerely,(Signature)