For the action oriented on the list. [EMAIL PROTECTED] ------- Forwarded Message Follows ------- yet another affront to sensible management of public lands... so WRITE ANOTHER LETTER! I thought this one would be of particular interest to people who work in conservation biology... (Remember, this game is played on many levels. If our current congress won't listen to us, we need to make sure the people in charge of implementing the laws hear us loud and clear.) On April 13, 1995, the United States Forest Service (USFS) proposed major changes in the rules which govern the agency's management of our public lands. These proposed changes (published in the Federal Register, April 13 1995) would restrict public input and would exempt many projects from environmental law. This rule change is also part of the "salvage" logging campaign set forth in the infamous rider attatched to the recently-signed Recissiions Bill. It is also an attempt to dismantle one of the most effective tools we have for appealing destructive timber sales, grazing permits, etc. Currently, the National Forest Management Act (NFMA) requires the Forest Service to meet "population viability standards" for sensitive, threatened, and endangered plants and animals (under the heading of "providing for diversity.") In its justification of the rule change, the USFS claimed that when NFMA was enacted, "population viability" was a vague concept. According to the USFS, the authors of the act did not anticipate that conservation biologists would develop "population viability" analysis into a rigorous method of establishing concrete standards for management of threatened plants and animals. The USFS now claims that the agency should not be bound by scientific standards for population viability, but should be given discretion to generally manage habitats of such populations so as to "provide for diversity" as it sees fit. "Option I" of section 219.4 would replace population viability standards with vague goals based on continued resource extraction. In other words, the Forest Service wants to be able to say that as long as we can keep getting timber, cows, or rocks from a forest, we can figure it is diverse enough, regardless of how many creatures we drive to extinction. PRESERVE CONCRETE, SCIENTIFIC STANDARDS, and FIGHT THE SALVAGE HOAX EVERY STEP OF THE WAY COMMENTS ON THE PROPOSED RULE CHANGE ARE DUE BY AUGUST 17. Show the Forest Service that we will not be shut out of the decisions that govern our public lands! Letters can be as short as you like, and should address specific points. Three of the biggest problems with the proposed rule change are: 1.) Eliminating "population viability standards" would eliminate concrete, scientifically-based standards in favor of vague "sustainable ecosystem"goals based on resource extraction (timber, mining, grazing, etc.). Say NO to "Option I" of section 219.4. 2.) "Interim amendments" would exempt an unlimited number of projects from environmental laws, public input, and standard planning processes. Say no to any exemptions from the laws that protect our forests. 3.) "Salvage" timber sales would not be included in calculations of "allowable sale quantity." "Salvage" logging would be above and beyond the "sustainable cut" mandated by NFMA. (The actual text of the proposed rule change is 45 pages long, and should be available at any USFS office.) **mail comments to: Director, Ecosystem Management (1920; 3 CEN) Forest Service USDA P.O. Box 96090, Washington, D.C. 20090-6090 *Get your friends to submit comments also. Quantity does matter!*thanks all* G.S.Bodner, Student Environmental Action Coalition-SW.(520)322-9819 [EMAIL PROTECTED] Here's a DRAFT letter, provided as an example. Letters need not be this long! Gitanjali Bodner Ph.D. program Dept. of Ecology and Evolutionary Biology University of Arizona Tucson, AZ 85721 Director Ecosystem Management (1920; 3 CEN) Forest Service USDA P.O. Box 96090 Washington D.C. 20090-6090 Dear sir: July 27, 1995 I am writing in response to the USFS proposed rule change regarding the management planning process, as published in the Federal Register of April 13, 1995. I am concerned by some of the internal contradictions within this document. I am concerned also by the numerous examples of disposing of concrete standards in favor of vague goals. Such abdication of a rigorous approach to decision making is profoundly unbecoming to an agency which professes a profesional, scientific approach to management. 219.4: "Sustainability of ecosystems" In the Federal Register, 4/13/95, the USFS complains that "insuring viable populations... envisions an outcome that is not guaranteable by any agency" You can think of viable populations as being impossible to guarantee, and hence give up even trying, or you can take it as a concrete, explicit goal, and try to do the best of your ability. Furthermore, maintaining such a concrete goal provides a ruler by which to evaluate your progress. No court would fault an agency for failing save a species from a threat over which the agency had no control (such as disease), so long as the agency proves that it truly has done everything in its power to preserve habitat necessary to support viable populations, and provided that habitat necessities have been established on the basis of sound, rigorous, quantitative science. "Options for Providing Diversity:" "Option I" is unacceptable for the following reasons: 1.) As you note on p. 18895, much scientific progress has been made regarding "species viability." If the USFS is truly concerned about the survival of endangered, threatened, and sensitive species, the agency ought to applaud these scientific advances and use them to their fullest potential. Instead, it appears that the agency is bellyaching about having to actually collect field data and perform basic analyses before making management decisions. Wildlife biologists, conservation biologists, population biologists, ecologists, and geneticists have teemed up to develop rigorous, quantitative procedures for analyzing viability of populations (and habitat required for maintenance of viable populations). They have done so because they recognize that such procedures provide information that is ABSOLUTELY ESSENTIAL for informed land management planning that "provides for diversity." 2.) A "focus on habitat capability" rather than actual populations of species of concern (P. 18894) is undeniably inappropriate for most species. Any competent biologist - agency or otherwise - would agree that we simply have not done enough research on the vast majority of sensitive species to have any real understanding of what that species' specific habitat needs are. The only way we can learn about the habitat requirements of such a species is to study population dynamics in habitats with differing characteristics. How can you advocate making decisions on the basis of factors we do not understand and cannot measure, while ignoring the factors we CAN measure and can study directly??? Furthermore, "analyses involving population demographics and prediction of population trends...would likely only be needed when a continuing downward trend in habitat capability is predicted to be leading to the listing or extirpation of the species." How can you expect to see such downward trends if you refuse to study population dynamics or make informed predictions of population trends??? One case in which Option I appears to be superior to Option II is in the case of expanding consideration to include also "invertebrates, vascular plants, bryophytes, fungi, and lichens." However, even token consideration of these other important groups would require hiring hundreds of new biologists who specialize on these groups. In the previous paragraphs, the USFS complained that the agency lacks resources to conduct thorough analyses of the vertebrates they are already required to consider. Thorough analysis of a few species (in this case vertebrates, who usually require enough habitat that they function as "umbrella species" confer some protection to other components of their ecosystems) is far preferable to less-than-half-assed consideration of many, many, many, many species. Abdicating range-wide consideration of species is a recipe for endangered species listing, and for extinction itself. It also conflicts with the USFS stated mandate to cooperate with other agencies and professionals. In dealing with species which have limited or threatened populations in one management area but appear to be widespread in other areas, we must pay attention to the CUMULATIVE impacts of land uses across the species range. If we do not coordinate planning on a range-wide basis, we risk losing species by one population at a time. Abandoning the study of indicator species: No, there is not "diminishing scientific support for ... [using) individual species as indicators of the welfare of a group of associated species." On the contrary! Use of indicator species continues to be widely acclaimed as one of the most effective ways of monitoring welfare of associated species and hence general ecosystem health. The fault biologists most often find with the use of indicator species is that we need to monitor more species than we do now in order to better understand ecosystem health and diversity. Furthermore, The USFS has spent many years and millions of dollars monitoring certain indicator species, and has accumulated an extremely valuable pool of scientific and management-related information. It is this information which can provide us with the long-term data essential to observing patterns and predicting trends in ecosystem health and sustainability and in populations dynamics of protected species. To abandon monitoring of indicator species now would mean giving up a multi-million dollar experiment just as it is beginning to show significant results! Both the tax-paying public and the scientific community would be outraged by such an irresponsible, wasteful action! In short, "Option I" is in direct conflict with NFMA intentions. A vague goal of "sustainable ecosystems" (based on continued production products for human use) IS NOT sufficient to meet NFMA provisions to "provide for diversity of plant and animal communities." "Option I" is also in direct conflict with the USFS stated goal of preventing the decline of species to the point where they merit listing as threatened or endangered, and with the desire of the public to have our public land managed for maintenance of biological diversity and natural heritage. Section 219.8: Paragraph (a): Interdisciplinary Teams: In order to truly use "the best information [and expertise] available," interdisciplinary teams ought to be allowed to include external scientists and other agency or university collaborators. Section 219.9: Forest Plan Amendment; Paragraph (d)(1), "Interim amendments:" "Interim amendments" would function to allow and encourage the USFS to operate behind closed doors, without answering to the public, complying with environmental laws, or following standard procedures for changing management plans. This same strategy of exempting agency activities from law and public review is behind the salvage rider now being debated in the U.S. Senate. The concerned public will not tolerate such a power-grab at the level of a USFS rule change. "Interim amendments" as defined in this section are unacceptable for the following specific reasons: 1.) Interim amendments are billed as limited in scope and duration, but paragraph (d) (7) indicates that they begin with a duration of two years and are subject to being renewed indefinitely. A lot of damage can be done in two years of an over-hasty plan that was not subjected to standard scientific assessment, public review, and legal supervision. To allow such a plan to continue indefinitely would be reckless and unprofessional. 2.) Official USFS policy (legally mandated by NEPA and NFMA and often stated by agency directives) is to encourage public participation in public land management decisions. Paragraph (d)(9) would reduce the public input process to a token after-the-fact suggestion-box. Precluding public comment on plans until after implementation has already begun and exempting plans from administrative appeals IS NOT a good-faith effort to get public input in management of public land. An after-the-fact comment period which begins at the same time as the project in question IS NOT an "effective way for the public and other government entities to communicate with the responsible official about any potential concerns (Fed. Reg. 4/13/95, p. 18907)" (emphasis added). We refuse to be shut out of this planning process. 3.) We do not need such broad exemptions from environmental laws and standard amendment procedures. The USFS already has emergency exemption provisions for safety and liability concerns. Vague exceptions for "catastrophic events" and "resource protection" would be subject to much more misuse than are the current safety and liability restrictions. Exempting interim amendments from public notice requirements and from compliance with NEPA regulations (including preparation of Environmental Impact Statements) is underhanded and dishonest. We cannot give up thoughtful and thorough management planning for the sake of expediency. If the USFS is managing our lands to the best of its ability, it will have no need to exempt itself from the law. Section 219.7: Salvage Logging and timber quotas: I do not aprove of the proposed change which would exclude "salvaged" timber from Allowable Sale Quantity calculations. ASQ calculations are designed to ensure that timber on public lands is harvested in a sustainable manner. The agency is currently engaged in an agressive "salvage" program, as typified by the recent rider on the Recisions Bill, which mandates cutting BILLIONS of board-feet under "salvage" programs. Excluding "salvage" cuts of this volume from calculations of ASQ will inevitably result in huge discrepancies between calculations of "sustainable cuts" and truly sustainable forestry practices. This is tantamount to claiming that adding bagfulls of slightly-damaged cookies to a carefully-calculated maintainance diet does not violate the intent of the diet because the cookies are broken. Excluding "salvaged" timber from ASQ would give greedy timber industry executives even more "discretion" to shortchange their employees, whose job security depends on sustainable harvesting, and would violate the intent of NFMA. I hope the USFS proves to be a professional enough organization to take these criticisms seriously and act accordingly. Sincerely, Gitanjali S. Bodner