Get Forestry-Involved
Participate in NEPA
The Forest Service has a problem with their ‘process’ - they can’t perform their intended role as public lands stewards and professional resource managers while they’re straight-jacketed in red tape. The BHFRA believes that any progress toward reducing redundant, unnecessary, or unreasonable analysis requirements for certain types of Forest Service projects is a step in the right direction. However, we also believe that in order to form a long-term solution to public forest management issues, a complete overhaul of the way the Forest Service administers the National Environmental Policy Act is necessary. We believe that the fundamental tenets and intent of NEPA were honorable, necessary, and laudable. However, the maze of precedent, administrative procedure, and rulemakings the Forest Service has either created for itself, or been forced into instituting as a result of appeals and litigation, must be thrown out the window in favor of a clean sheet.
Participating in NEPA is the easiest and most fundamental
way to let the Forest Service know that you support the practice of forestry in
the Black Hills.
Each time the Forest Service (and all other Federal
Agencies) proposes to do something - whether it’s performing a timber sale or
putting up a toll booth -- the National Environmental Policy Act requires them
to analyze potential environmental effects, disclose them, and seek public
input. The public input phase is
done in several steps, and represents your opportunity to influence what an
agency does or does not do.
First among the public involvement steps for a Forest
Service project is the “scoping” phase.
Here, the Forest Service lays out a description of what sort of project
they propose to do, its location, and some preliminary information about the
desired outcome of their proposal - what their objectives are for the condition
of the land, and what outputs, such as timber, will be produced in the process.
“Scoping”, as the name implies, establishes the scope of the project
and the decision that is to be made upon either proceeding with the proposed
action or with an alternative thereto.
After scoping is completed, the Forest Service considers
the comments it has received on the proposed action, and proceeds to draft a
more detailed Environmental Assessment (or simply, ‘EA’).
Once the Draft EA is complete, it is sent out to all the people who
responded to scoping for another round of comments.
After these second comments are received and analyzed, a decision on the
project is issued, and an appeal period begins before implementation can
proceed.
Under NEPA’s requirements, you have two separate chances
to tell the Forest Service what you want them to do, and as they say, “the
world is run by those who show up.”
So you’re thinking, “how do I find out what projects
are open for comment?” There are
three things you can do:
§
Most projects
are generated at the level of local District Offices; in the Black Hills, these
are located in Custer, Rapid City, Spearfish, and Sundance.
You may simply call or write any or all of the Districts and request to
be added to their mailing list for future projects.
Here are the phone numbers and addresses:
Hell
Canyon Ranger District
Mystic Ranger District
330
Mt. Rushmore Rd.
803 Soo San Dr.
Custer,
SD 57730
Rapid City, SD 57702
Ph:
(605) 673-4853
Ph: (605) 343-1567
FAX:
(605) 673-5461
FAX: (605) 343-7134
Northern
Hills Ranger District
Bearlodge Ranger District
2014
North Main St.
US 14 East, Box 680
Spearfish,
SD 57783
Sundance, WY 82729
Ph:
(605) 642-4622
Ph: (307) 283-1361
FAX:
(605) 642-4156
FAX: (307) 283-3727
§
The second
option is to receive the Black Hills NF’s
‘Schedule of Proposed Actions’.
This is a document produced quarterly at the Supervisor’s Office in
Custer, and it details all projects (not just forestry ones) that are either
proposed or in-process, in a list that’s broken down by individual Districts.
This is a good way to track the progress of a project, or to just find
out what the Forest Service is up to. The
Schedule also provides information as to which Forest Service employee is
heading-up a given project, so that you can contact them directly. To receive this publication, just call or write the
Supervisor’s Office and say you’d like to get on the mailing list for the
Schedule of Proposed Actions:
Black
Hills National Forest
Supervisor's
Office
25041
North Highway 16
Custer,
SD 57730
§
Yet a third
means by which to involve yourself in the NEPA process is to go poke around on
the Black Hills NF web site. New or
ongoing projects are routinely posted and updated in electronic format, along
with other news and info about the goings-on with the Black Hills.
The Black Hills NF home page is
here,
and the page devoted to NEPA projects is
here.
The BHFRA tracks, engages Forest Service personnel, and
submits formal substantive comment letters upon each and every significant
forest management project the Black Hills NF proposes. If you have any questions about what something in a project
proposal means (EA’s tend to contain overly technical lingo), or would like to
know what issues might be important to bring up in a project comment letter,
feel free to contact
us, using the project’s name in the email subject line.
We’ll say it again: “the
world is run by those who show up.”
Participating in NEPA is the best way to begin engaging the Forest
Service about your views on continuing active forest management in the Black
Hills. You don’t have to be a
forest policy expert, or know all the regulations to make a contribution to how
your forest is managed.
Here are some general tips on writing comment letters to
the Forest Service:
1. Tell them what you want, and then tell them why you want it. There’s no need to cite some obscure legal precedent, or
recount the letter of Standards and Guidelines from the Forest Plan, but you
should be sure to let the Forest Service know the reasoning behind your beliefs.
Simply making a statement about your wishes regarding different aspects
forest management doesn’t really give them anything they can respond to
favorably. What is the reason for
your concern about the health of the forest, or wildfire risk, or road closures,
or water quality, or wildlife habitat? Do
you live near the project area? Do
you have a special use permit for an activity in the area?
Does your economic livelihood depend on your use of the area? Do you hunt, fish, or otherwise recreate in the project area?
Do you belong to an organization whose interests are affected by the
proposal? What expertise can you
share with those who are planning the project?
These are just examples of things to ask yourself, but always have the
“why” in mind.
2. Be constructive. When
opposing a certain aspect of a project, it’s useful to provide an alternative
practice or strategy for the Forest Service to consider.
This way, they can at least evaluate how such a proposal would fit into
the regulations they’re obligated to conform with.
Overridingly, though, it’s important to remember that there are real
people on the other end reading your letter who have likely been working on the
project for a number of months or even years.
No one really likes to be told that they might be off-base.
Your chances of a favorable response increase if you can present your
arguments in a constructive fashion.
3. Ask questions. One
of the key tenets of NEPA is full disclosure of effects, so if you’re
wondering about something and would like the answer to your question aired
publicly, just ask the Forest Service to disclose that information in their
analysis. For instance, if the
Forest Service proposes to refrain from treatment in certain areas (usually this
is for wildlife reasons), you might ask that they reasonably disclose how much
acreage is being deferred and on what basis.
Alternatively, if road closures or other access restrictions are proposed
as part of the project, you might ask the Forest Service to disclose the
estimated increase in fire suppression response time or decreased recreational
opportunities that accompany such closures.
Another example would be asking the Forest Service to disclose the
environmentally beneficial effects of the proposed forest management, such as
habitat for different wildlife species, and the reduction in the risk of
wildfire or mountain pine beetle infestations.
Too often, environmental documents like these are framed in the context
of what “bad” things “might” happen if the project is implemented.
Ignored are the “bad” things that are imminent, should nothing
happen, as well as the “good” things that come from doing something.
4. Confine your comments to the project itself.
There is a hierarchy in the world of Forest Service projects.
First, the Forest completes a long-term Land and Resource Management Plan
- this is a big, programmatic document that lays out the framework for how the
forest is to be managed over the long-term.
Each project that is proposed on a national forest must comply with the
goals, objectives, standards, and guidelines of the Forest Plan - this concept
is known as “tiering” (the project is “tiered” to the Forest Plan).
If the Forest Service cites a Forest Plan standard, for example, as their
reasoning behind a particular aspect of a project proposal, they cannot be
expected to deviate from this standard (even if it doesn’t make sense).
Generally, projects can’t change the Forest Plan, so telling the Forest
Service that their standards don’t make sense, while it might be true,
doesn’t get you very far. Instead,
try focusing on the way the standard has been interpreted
in the project, or on other resource management concerns that might out-weigh a
particular standard’s direction. These
interpretive and priority-setting issues are the kinds of things that can be
addressed at the project decision-making level. If you’d like to get more familiar with what the Land and
resource Management Plan says, contact the forest Supervisor’s Office at the
address above and request a copy (be warned, it’s big!).
Please, take the
time to write!