By: Jess Riddle, Georgia ForestWatch Executive Director
Perhaps the best way to understand the magnitude and gravity of the rule changes the Forest Service is proposing is to view them in the context of areas familiar to many Georgia ForestWatch members and volunteers. We’ve talked about the Cooper Creek project many times because it is a large and problematic project. But today let’s talk about it a different way. Not as a threat to magnificent forests, outstanding recreation opportunities, and sparkling streams—which it is—but as an example of why it’s important for the government to inform the public of its plans and give people an opportunity to participate in the management of the public lands that belong to all of us.
Cooper Creek was originally proposed in 2014. The project had many problems, one of which was that it contemplated commercial logging on slopes on the north side of Duncan Ridge that were far too steep at accommodate logging equipment. Georgia ForestWatch knows the area better than anyone, and the inoperability of the stands and erosion risk were immediately apparent to us. We pointed out the problem to the Forest Service, and the agency dropped the steepest stands from the project.
Cooper Creek remains a deeply problematic project, but preventing logging on the steepest stands was still an improvement from the initial proposal. Anyone at Georgia ForestWatch that has actively participated in the back-and-forth with the Forest Service as it develops and revises projects knows that projects change from the time they are proposed to the time they are implemented. These changes benefit all forest users and the agency itself. Instead of wasting money planning a timber sale on slopes that are too steep to log, the Forest Service can revise its plans and put its funding to better use.
Unfortunately, these vitally important opportunities to provide feedback to the agency are at risk. The Forest Service is revising its regulations implementing the 1970 National Environmental Policy Act (NEPA) by proposing to cut out public involvement in timber sales under 4,200 acres. The proposed rules would allow the Forest Service to log 4,200 acres without providing a single opportunity for public comment and with only minimal public notification. The entire Cooper Creek project is less than 4,200 acres.
These proposed changes would also have allowed the worst parts of other projects to survive. Public involvement in the Brawley Mountain Project saved beautiful forests of large trees and fern-covered slopes. The new 4,200-acre loophole could have allowed that project to proceed without environmental review, and that valuable forest would have been lost to an ill-conceived attempt to create open woodlands in an area where they would never naturally occur. The same logging loophole could have led to the cutting of an old-growth stand in the Upper Warwoman Project, which Georgia ForestWatch identified with the help of details provided in the project’s environmental review.
The Upper Warwoman Project also originally included plans to reconstruct and extend a road to bypass another road. The Forest Service estimated how many tons of sediment that construction would have put into a stream, and carefully compared that plan against the option of improving and retaining the existing road. Under another part of the proposed new NEPA rules, the road could have been extended without any of that informative analysis. The proposed rule would allow the Forest Service to build up to five miles of new road and reconstruct up to 10 miles of existing road without environmental review or public input. This change is especially concerning when you consider the Forest Service does not have the resources to maintain all of their existing roads.
The proposed changes would also reinforce problems with current projects. One of the biggest issues with the Foothills Landscape Project is it describes only the kinds of places where the Forest Service would harvest timber, but not the actual locations. The proposed changes would codify that approach as “condition based management,” ostensibly to allow the Forest Service to be more responsive to on-the-ground conditions. Ironically, in practice, this approach actually does the opposite because the unique characteristics of individual locations are not considered.
Even without those specific changes, the proposed new rules would allow the worst mistakes of the past to be repeated without the public being able to see and point out the problems. The Forest Service would be able to skip environmental analysis if they deemed a project “similar” to one they had analyzed in the past.
This approach would be particularly problematic because many of the issues ForestWatch raises with projects do not revolve around the particular type of timber harvest but instead concern the location. We recognize differences that the Forest Service misses, both large and small. North Georgia is not the Ozarks and it is not the Coastal Plain. The Cooper Creek Wildlife Management Area is not the same as the Lake Russell Wildlife Management Area. Yet the Forest Service has repeatedly proposed ill-suited actions that ignore these differences. Under the proposed rules, the Forest Service could potentially repeat the Cooper Creek Project in an even more sensitive and inappropriate area without assessing the impacts.
The more you learn, the more you realize how much there still is to learn, but with these changes the Forest Service seems to be missing this lesson. The Forest Service wants to take a simpler, short-cut approach while the lands they are managing and the problems they are facing are only becoming more complex. Climate is changing, user groups are diversifying, and budgets are shrinking. And we are still learning to recognize the complexity that has always been there. Just in the past couple of decades have scientists started recognizing the “wood wide web,” the complex network of tree roots and fungi that passes nutrients and information between trees.
The Forest Service should meet this new complexity with more meaningful analysis, not less. They should describe projects with more transparency, not less. People outside the Forest Service have a wealth of varied expertise and experience with our precious public forests, and the Forest Service needs to listen to them more, not less.
Comments are due August, 12th. Your comments on these rule changes will help improve not just one project but many. Your comments will also help protect forests not only in Georgia but also across the entire country. You can submit simple comments by going to OurForestOurVoice.org, or submit more impactful personal comments by going to https://www.regulations.gov/comment?D=FS-2019-0010-0001