The proposed rule would amend the agency’s procedures for implementing the National Environmental Policy Act, commonly known as “NEPA.” The proposed changes fundamentally undermine NEPA’s bedrock principles of government transparency, accountability, public participation, and science-based decision-making.
In more technical terms, the Forest Service’s proposal would allow most land management activities to take place under a “Categorical Exclusion” or “CE,” whereby the Forest Service can approve projects without first conducting an Environmental Assessment (EA) or Environmental Impact Statement (EIS). Traditionally, CEs have been used for minor, non-controversial activities like removing hazard trees from campgrounds and roadsides. The proposal also does away with requirements that the Forest Service notify the public and allow for public comment on projects before a decision is made, whether carried out under a CE or with a full Environmental Assessment or Environmental Impact Statement.
- Logging (including clearcutting) on up to 4,200 acres at a time (over 6 square miles) for nearly any purpose
- Building up to 5 miles of new system roads through the forest (and reconstructing old roads up to 10 miles), even though the agency can’t maintain its current road system
- Bulldozing up to 4 miles of pipeline and utility right-of-ways through the forest
- Closing roads and trails used for recreational access
- Adding illegally created roads and trails (especially those created by off-roading) to the official Forest Service road and trail system
In effect, every single logging project, and nearly all utility and road building projects on the Daniel Boone National Forest and at Land Between the Lakes National Recreation Area could be proposed in secret, with no environmental review and no public input. Adding to the audacity and absurdity of the Forest Service’s proposal, the 4,200 acre logging exemption was created by averaging project sizes from across the country, with the 170,000 acre Land Between the Lakes National Recreation Area treated the same as the 17,000,000 acre Tongass National Forest in Alaska.
And these aren’t the only destructive provisions in the proposal.
But NEPA isn’t the problem. The main reason that the Forest Service has trouble getting work done – whether it’s maintaining campsites and trails or selling timber – is that they are severely underfunded by Congress and woefully under-staffed which shockingly high turnover. Over the last 10 years, the Daniel Boone National Forest has had four Forest Supervisors and eleven District Rangers in charge of the four Ranger Districts. Forestry and wildlife personnel – the people that actually plan most land management projects – are often temporary fixtures, coming and going from other national forests and agencies from all over the country. It’s become rare to have consistent Forest Service personnel throughout the development of even a single project on the Daniel Boone National Forest.
Public lands belong to the public, and the Forest Service can make some really bad decisions. Whether you care about hiking trails or rare plants, old-growth or clear streams, your voice matters.
Without the currently mandated system of public participation and environmental analysis we never would have identified and saved the forest above Climax Spring and old-growth in Little Egypt from logging in the Crooked Creek project, or stopped thousands of acres of deeply unpopular logging in Land Between the Lakes in the Pisgah Bay project, or saved old-growth “Core Areas” in Land Between the Lakes from getting logged in the Birmingham Ferry Salvage project, gotten hundreds of acres of logging dropped in the Greenwood project (saving the trailhead to the Beaver Creek Wilderness and Three Forks of Beaver Creek Overlook), stopped road building in the Beaver Creek project near Cave Run Lake, or identified old-growth that the Forest Service wants to log in the South Redbird project…the list goes on.
Send in your comments!
The Forest Service is accepting comments on their proposal through August 12th, 2019. Although you can submit comments directly through the Forest Service’s website here, we recommend using the web portal set up by our friends at the Southern Environmental Law Center at OurForestsOurVoice.org. This web portal will assist you in submitting unique comments, and help us track the number of comments getting submitted. There have been indications that the federal government has been “losing” comments submitted through federal portals and we want to make sure your voice is heard.
Spread the word!
We need help getting the word out. Our social media feeds and inboxes are all packed these days, and we’re not seeing much about this from many of the big national organizations that have a big reach. By helping to amplify this message you can make a real difference.
Call your members of Congress!
While this proposal is coming from the Trump administration and U.S. Forest Service, make sure your members of Congress know that you strongly oppose the Forest Service taking away public participation and oversight of national forest management. Public opposition has stopped similar proposals in the U.S. House and Senate in recent years.
For more details and a great explainer on why this matters so much, head on over to our friends at Tennessee Heartwood. They’ve done a fantastic job going deep on why NEPA and public participation are critical for protecting our public lands.
Official documents for the Forest Service’s proposal can be found on the Forest Service website here.
And if you find this useful, please consider supporting our work by donating or joining Kentucky Heartwood here.
To comment, we recommend using the web portal set up by our friends at the Southern Environmental Law Center at OurForestsOurVoice.org.
This web portal will assist you in submitting unique comments, and help us track the number of comments getting submitted. There have been indications that the federal government has been “losing” comments submitted through federal portals and we want to make sure your voice is heard.