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Discussion Starter · #1 ·
I posted this on the LandUse alert page, bur felt it was important enough to put here too. If you care at all about how our forests are going to be managed for years to come, please send your comments to the USFs ref their proposed management plan, the deadline is Feb. 3. I have attached an article I wrote with my views on the issue, please read it, there is also info on where to send comments and how to get the document. This is going to be FEDERAL LAW, folks.

Brad (from the 4 Wheeling center of the universe, 4 corners USA)
 

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Discussion Starter · #2 ·
Re: USFS Proposed Mgmt Plan-2 days till deadline

For those that don't have word, here's the text of my comments.
The U.S. Forest Service Land and Resource Management Planning
Proposed Rule

The United States Department of Agriculture-Forest Service is in the midst of a possible dramatic change in its management planning procedures. In the October 5, 1999 Federal Register the proposed changes to 36 CFR 219 and the removal of part 217 were published as the "National Forest System Land and Resource Management Planning; Proposed Rule." This 40 page document consists of an explanation of the proposed changes and then the text of the actual rule as proposed. The original public comment period for the proposed changes was to end on January 4, 2000, but it was extended to February 3. So, If you want to take the time to read through the document, you still have the opportunity to submit your comments.

A while back I downloaded the complete copy of the Federal Register from the USFS web site. It sat around for a while, looking intimidating, incomprehensible, and very legal. Recently I finally found the time to sit down and wade through the entire thing, and it turned out to be a worthwhile couple of evenings. After spending several hours highlighting and trying to make sense of what I read, I figured maybe I could save others a little time by pointing out what I perceived to be some of the highlights and possible dangers and pitfalls of the proposed rule. All of our National Forests' Management Plans are up for revision in the next couple of years, so the new rule will set the tone for the way the forests are managed for the next 10 to 15 years.

Generally being skeptical of anything that comes out of the current administration, I wasn't surprised to find many potential dangers to multiple use and motorized recreation in the proposed rule. On the one hand, it is repeated constantly that the goal of the new plan is to get the public more involved, but on the other hand there are many ways that the proposed rule leaves avenues for the bureaucrats and GAGS to manipulate the process. What it comes down to is, sure, the public will have all the input it wants, then the administration will do what it perceives to be the best thing.

One of the most dangerous parts of the proposed plan is the power given to the "responsible official", either the district or regional supervisor depending on the nature and scope of the issue. Basically, it gives the power solely to District Rangers to decide what site specific projects are important, and if the site specific decision is then inconsistent with the current plan he may have the power to amend the plan to permit the proposal. The responsible official also has the power to make the decision up front what topics of general interest or concern are appropriate for further consideration. He then has the discretion to choose how information will be collected and how much of it to collect. Over all, the power given to District and Regional Supervisors has the potential to be abused power, and if the future administrations have the same point of view as the current one the abuse of power could very well be in a direction contrary to multiple use interests.

The really scary parts of the proposed plan come in the middle, Sections 219.19 and 219.20 are where ecological sustainability are discussed. Section 219.19 begins with the statement that the overall goal of management of our forests is ecological, social and economic sustainability. Great, a balance of all three, I can live with that. BUT, then you get to Section 219.20, Ecological sustainability. This section has the potential, if forest supervisors see fit, to completely close the forests to motorized recreation and other types of multiple use. This section talks very seriously about returning the forests to PRE-EUROPEAN status, that is, BEFORE WE ALL GOT HERE. The kicker falls in Section 219.20(b)(3)(ii), "Where current ecological conditions fall outside the historical range of variability, decisions must not shift those conditions further from the historical range of variability, and should provide for restoration towards likely states within that range." In other words, they pretty much can do what they want to do to return the forest to the way it was 450 years ago. This assumption is given even more ammunition later in the same section where it states that the Forest Service can do whatever it takes to avoid having to list a species as endangered.

But, the proposed plan also contains much that could be used to the advantage of anyone, multiple use or otherwise. Section 219.2(d)(1) states "The national forests and grasslands belong to the American people." (And just when I was beginning to wonder.) There is much about getting the public involved in the sections concerned with the goals and principle of the planning process. Just a little bit further along in Section 219.2 it is stated "Effective planning should restore and maintain the trust of the American people in the management of the national forests and grasslands." And just a couple sentences later trust and respect are again mentioned! Do we perhaps perceive a government that thinks maybe these things haven't existed lately?

The proposed plan also speaks of several types of advisory boards, including ones consisting of interested citizens, experts and scientists. The supervisors are supposed to seek the advice of anyone who is interested or affected, this, in the past, has been those who speak loudest, the so called environmental organizations. But, the vehicle is there for we who are involved in motorized recreation to speak up and be heard, but it will take gaining the ear of District and Regional Supervisors by asking to be on advisory boards. Another way that any interested citizen can be heard is by appealing any proposed amendment or revision. The law says your appeal must be considered by the responsible official when making the final decision. Section 219.16(a) states "[The responsible official must:] Ensure that appropriate information is made available and that no one, including persons with diverse opinions and values, is deliberately excluded or denied participation in land and resource management planning." We have the power if we so choose to make the bureaucrats hold to this promise.

The last 2 sections of the proposed plan that I will discuss I also perceive as promises to the American people. Section 219.14, Involvement of state and local governments, is just that. The Forest Service must get input from local governments in the planning process. The plan recognizes that these entities are the ones with much at stake, especially economically. It is even stated further on in the proposal: "Resiliency and community capacity should be considered in a risk and vulnerability analysis." And in Section 219.21(b) it is stated: "Social and economic analyses are important in gaining understanding of the relationships among ecological, social, and economic sustainability. Social analyses address human lifestyles, attitudes, beliefs, values, demographic characteristics, and landuse patterns [Does this widen the door for the use of RS2477? Time will tell. (my note!)] of human communities and their capacity to adapt to changing conditions." My only concern here is, after they do all these "make the public feel good" analyses, will they really care what they say?

Finally, Section 219.17, Interaction with private landowners, states "Consideration of the pattern and distribution of land ownership in assessment and plan areas is critical." In making management decisions, the needs and rights of landowners adjacent to or within national forest boundaries must be considered. If this section of the law is retained and the bureaucrats follow through, the potential is there to restore much of what private land owners have lost in the past several years.

I could go on and on about what I perceive as good and bad in the proposed plan. Like I said, the document is 40 pages long, and the plan itself covers 16 pages. But, the purpose of this article is not to bore you with my view of every section of the plan. Instead, do what I did, sit down, read it, make notes, highlight things, go back and read them, and then after all that send your comments to: CAET-USDA, Att. Planning Rule, Forest Service, USDA, 200 East Broadway, Room 103, PO Box 7669, Missoula, Montana 59807; or you can e-mail them at planreg/[email protected] Remember, the deadline is February 3, 2000. The proposed plan gives us the opportunity to be heard, the time to start being heard is BEFORE February 3.

(As a final note, in the very last section of the proposed plan are definitions. According to the plan an Unroaded area is: Any area without the presence of a classified road (a road at least 50 inches wide and constructed or maintained for vehicle use). Yes, they are still planning on taking away our Jeep, ATV and dirtbike trails!)

Brad Ullrich
[email protected]

Brad (from the 4 Wheeling center of the universe, 4 corners USA)
 
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Discussion Starter · #3 ·
Come on guys, one more day till no more input and the feds will do what they and the GAGS want. Read the proposed law, if you don't have time or don't want to read my post (I wrote it in the form of an article, my letter is slightly different) and feel free to use anything in it you want, the original post has a downloadable version in MS Word. Read it, I hope it makes you angry and will scare the sh!t out of you at the same time.

Brad (from the 4 Wheeling center of the universe, 4 corners USA)
 
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Discussion Starter · #4 ·
Here's the text of my letter to the USFS, plase feel free to use it or any part of it. Heck, if you don't have much time, just copy it and send it.

CAET-USDA
Attn. Planning Rule
Forest Service, USDA
200 East Broadway, Room 103
PO Box 7669
Missoula, Montana 59807

February 2, 2000

Dear Forest Supervisors:

I would like to take this opportunity to comment on the National Forest System Land and Resource Management Planning; Proposed Rule (36 CFR Parts 217 and 219).

One of the most dangerous parts of the proposed plan is the power given to the "responsible official", either the district or regional supervisor depending on the nature and scope of the issue (Secs. 219.3(5)(b) and 219.4(b)). Basically, it gives the power solely to District Rangers to decide what site specific projects are important, and if the site specific decision is then inconsistent with the current plan he may have the power to amend the plan to permit the proposal. The responsible official also has the power to make the decision up front what topics of general interest or concern are appropriate for further consideration. He then has the discretion to choose how information will be collected and how much of it to collect. Over all, the power given to District and Regional Supervisors has the potential to be abused power, and if the future administrations have the same point of view as the current one the abuse of power could very well be in a direction contrary to multiple use interests.

The parts of the proposed plan that are wide open for abuse by anti-multiple use interests come in the middle, Sections 219.19 and 219.20 are where ecological sustainability are discussed. Section 219.19 begins with the statement that the overall goal of management of our forests is ecological, social and economic sustainability. Great, a balance of all three, I can live with that. BUT, then you get to Section 219.20, Ecological sustainability. This section has the potential, if forest supervisors see fit, to completely close the forests to motorized recreation and other types of multiple use. This section talks very seriously about returning the forests to PRE-EUROPEAN status, that is, BEFORE WE ALL GOT HERE. The kicker falls in Section 219.20(b)(3)(ii), "Where current ecological conditions fall outside the historical range of variability, decisions must not shift those conditions further from the historical range of variability, and should provide for restoration towards likely states within that range." In other words, they pretty much can do what they want to do to return the forest to the way it was 450 years ago. This assumption is given even more ammunition later in the same section where it states that the Forest Service can do whatever it takes to avoid having to list a species as endangered (Sec. 219.20(b)(10)).

But, the proposed plan also contains much that could be used to the advantage of anyone, multiple use or otherwise. Section 219.2(d)(1) states "The national forests and grasslands belong to the American people." (And just when I was beginning to wonder.) There is much about getting the public involved in the sections concerned with the goals and principle of the planning process. Just a little bit further along in Section 219.2 it is stated "Effective planning should restore and maintain the trust of the American people in the management of the national forests and grasslands." And just a couple sentences later trust and respect are again mentioned! Do we perhaps perceive a government that thinks maybe these things haven't existed lately?

The proposed plan also speaks of several types of advisory boards and interested party participation, including ones consisting of interested citizens, experts and scientists (Secs. 219.3(a)(2), 219.5(a)(3), 219.11(b), 219.12(a) and 219.18(b), . The supervisors are supposed to seek the advice of anyone who is interested or affected, this, in the past, has been those who speak loudest, the so called environmental organizations. But, the vehicle is there for those who are involved in motorized recreation to speak up and be heard, but it will take gaining the ear of District and Regional Supervisors by asking to be on advisory boards. Another way that any interested citizen can be heard is by appealing any proposed amendment or revision, this is the only fair way to make amendments and revisions, hopefully these sections will be retained as written (Secs. 219.8(3)(b), 219.9(f). The law says your appeal must be considered by the responsible official when making the final decision. Section 219.16(a) states "[The responsible official must:] Ensure that appropriate information is made available and that no one, including persons with diverse opinions and values, is deliberately excluded or denied participation in land and resource management planning." I like this section of the proposed plan, if the bureaucrats hold to this promise.

The last 2 sections of the proposed plan that I will discuss I also perceive as promises to the American people. Section 219.14, Involvement of state and local governments, is just that. The Forest Service must get input from local governments in the planning process. The plan recognizes that these entities are the ones with much at stake, especially economically. It is even stated further on in the proposal: "Resiliency and community capacity should be considered in a risk and vulnerability analysis." And in Section 219.21(b) it is stated: "Social and economic analyses are important in gaining understanding of the relationships among ecological, social, and economic sustainability. Social analyses address human lifestyles, attitudes, beliefs, values, demographic characteristics, and landuse patterns of human communities and their capacity to adapt to changing conditions." My only concern here is, after they do all these "make the public feel good" analyses, will they really care what they say?

Finally, Section 219.17, Interaction with private landowners, states "Consideration of the pattern and distribution of land ownership in assessment and plan areas is critical." In making management decisions, the needs and rights of landowners adjacent to or within national forest boundaries must be considered. If this section of the law is retained and the bureaucrats follow through, the potential is there to restore much of what private land owners have lost in the past several years.

I could go on and on about what I perceive as good and bad in the proposed plan. But, as a final note, in the very last section of the proposed plan are definitions. According to the plan an Unroaded area is: Any area without the presence of a classified road (a road at least 50 inches wide and constructed or maintained for vehicle use). This absurd definition of a road will close many roads and trails that are currently in use by a variety of OHV users.

Sincerely,

Brad (from the 4 Wheeling center of the universe, 4 corners USA)
 
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