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ALERT - December 4, 2006: Protect Our Woods joins allies to submit a response to the Draft Supplement to the Final Environmental Impact Statement (FEIS) for the German Ridge Restoration Project in Hoosier National Forest12. Deficiencies of Cash Flow Analysis• Table 4.20 in the DSFEIS (cash flow analysis) is presented to the reader without an indicationof the time period over which the costs and revenues are realized. This makes the table 4-20 virtually useless. The DSDEIS/FEIS text itself is confusing with regard to the time period underlying the analysis, ranging from from 4 to 15 years (See above point 3.Time Frame for Plan) • Any analysis conducted over a long period of time (such as the decades needed to restore the Oak – Hickory Communities) should include a Net Present Value Analysis, which has not been attempted in the FEIS. • It doesn’t matter what reason or excuse the Forest Service determines is the cause for a negative NPV or cash flow. It is obvious that the negative cash value is not addressed at either the Plan or project level. Both the HNF Plan and the German Ridge Plan openly defy the regulations saying the “Forest Service must avoid programs with negative net present values.” • While the costs of road construction, reconstruction and obliteration are now included Table 4.20 (they were not in Table 4.19 of the DEIS), the total amount is questionable. • No distinction has been made in this table between the barrens restoration and the Pine removal. Obviously these two projects could be conducted separately, and the reader of the DEIS has no indication of the respective costs/benefits of these projects. • Burning costs have been removed from the table (they were still present in Table 4.20 of the FEIS) on the grounds that burning is paid for by appropriations. “The net cash flow does not reflect the total cost of burning (ranging from approximately $184,500 for Alternative A to approximately $264,500 for Alternative C). Appropriated funds, rather than timber sale dollars, would pay these and some other costs. (p. 57 DSFEIS). This is hard to understand. Can the Forest Service pick randomly what they consider costs depending on whether or not they have to come up with the money? Assuming that the cash flow analysis is a tool for the Forest Service and for the public to identify cash costs and revenues associated with a government action, in order to be able to assess correctly how much society is paying for a project, and whether a project pays for itself or not, this random inclusion or exclusion of project–related costs in inexcusable. Actually, “random” is maybe not the right word to use here, since the purpose of inclusion or exclusion could be to make logging/burning look more attractive to the tax payer. • The cash flow analysis has no entries for mitigation measures. This skews the analysis towards the alternatives that propose logging and burning, since it does not disclose their full costs. The NFMA requires that the costs of mitigation measures be analyzed and included in an assessment. § 219.14 (b) Forest lands other than those that have been identified as not suited for timber production in paragraph (a) of this section shall be further reviewed and assessed prior to formulation of alternatives to determine the costs and benefits for a range of management intensities for timber production. For the purpose of analysis, the planning area shall be stratified into categories of land with similar management costs and returns. The stratification should consider appropriate factors that influence the costs and returns such as physical and biological conditions of the site and transportation requirements. This analysis shall identify the management intensity for timber production for each category of land which results in the largest excess of discounted benefits less discounted costs and shall compare the direct costs of growing and harvesting trees, including capital expenditures required for timber production, to the anticipated receipts to the government, in accordance with § 219.12 and paragraphs (b)(1) through (b)(3) of this section. (2)Direct costs include the anticipated investments, maintenance, operating, management, and planning costs attributable to timber production activities, including mitigation measures necessitated by the impacts of timber production. • The cash flow analysis has no entries for costs associated with regeneration of timber stands such as, planting, hand-pulling or burning of invasive species, herbicide treatment for roads and/or invasive species, thinning, and timber stand improvement. If the Forest Service is saying in the EIS that they might have to plant hardwood trees after the pine trees are cut, then the cost of this planting effort must be included in the Cash Flow Analysis. We understand that these are the costs that usually push the Forest Service timber sales way below cost. Yet they were not included. • Other costs that are also very high that are missing are overhead costs for the Tell City Ranger District, Hoosier National Forest Bedford Office, the Regional Office in Wisconsin, and the Washington Offices. We are also unsure from this analysis where the costs for planning were included in these costs. What about the cost of the appeal? Was that included in EA costs? Leaving out these costs, again, makes timbering alternatives look more attractive. It also violates applicable laws and regulations. The Forest and Rangeland Renewable Resources Planning Act and the NFMA Amendments (16 U.SC. § 1600-1614). - § 1604 (l): Evaluate long term program costs and benefits. • The new Table 4:20 (different from the DEIS Table 4.19) has another surprise. Now Alternative B includes an entry for “Environmental Analysis”. It is not clear to us why this entry for no-action Alternative B is of the same magnitude as for Alternatives A and C, which are the alternatives that include logging and burning, and why the costs of an environmental analysis would also not be lower for D, which includes only burning, and minimal logging. We ask the Forest Service to specify exactly what is included in an environmental analysis, and why an environmental analysis for Alternative B would cost the same as an analysis for alternatives with heavy logging and burning. For ultimately, the public would not have to incur the cost of an environmental analysis and all the other unidentified costs having to do with planning, appeals, lawsuits, etc., if the Forest Service simply did not plan timber sales and burning projects that do not make environmental or economic sense. • Table 4-20 gives no indication of how the losses incurred are covered, in other words, where the money is coming from to cover the losses that are biggest for the logging alternatives A and C. • The Economic Analysis under 4.10 of the DEIS/FEIS addresses the fact that, as shown in Table 4-20, there is a negative cash flow for all alternatives. The DSFEIS (p. 53) states: The objective for managing vegetation on the Hoosier is not economic. This is especially true for conversion of stands of nonnative pines to native hardwood forest. • However, according to Forest Service regulations, the timber sale program must make financial and economic sense. The FEIS/DSFEIS fails to show that this project makes financial and economic sense. It does not matter for an economic analysis that timber sales bring in some cash to offset other costs. DSFEIS p. 54: “The stumpage value of pine is low. Even so, the timber receipts would help reduce the total cost of the ecosystem restoration—that is, the removal of nonnative pine trees along with application of prescribed fire to restore native hardwood forest and restore the barrens.” While some costs may be offset by timber sales, the overall problem remains: Alternatives A, C and D are much larger cash drains than Alternative B. In other words, the logging plus the burning will cost the tax payers hundreds of thousands of dollars over the seven years of the project. And the public is still not convinced that this is “worth it.” At the same time, the Inspector General’s report chastises the Forest Service for spending millions of dollars on burning projects that have no proven benefit. The German Ridge Project and the HNF Plan - to which the German Ridge Project is tiered - show negative Cash Flow for logging and burning alternatives and justify that with the restoration of Oak Hickory and the supposed need to create early successional habitat. -From HNF FEIS Appendix p. 160/161: …. The economic analysis provided in the EIS is adequate for the programmatic level of decision making. Additional NEPA compliance with public involvement is undertaken at the site-specific level of decision making. The key to understanding the economic analysis is to recognize that the revised plan is focused upon providing a healthy, sustainable forest. The condition of the resources --what is left on the land after proposed management--is of paramount concern, not commodity production.” - HNF Appendices for FEIS, p. 184 ….The EIS discloses both the effects of passive management and the effects from logging. Timber harvesting will be used when it is determined to be the most effective method to achieve desired results. ….Timber sales, when needed, provide a net benefit to the public and the ecosystems. Because a timber sale is a tool used to attain our desired condition, the economics and results are described as part of a project analysis. -HNF Appendices for FEIS p. 223 Public Comment #278: The USDA Forest Service FY 1999 budget exploratory notes for the committee on appropriations found that taxpayers lost over one billion dollars on the Federal logging program each year. In the last timber sale program report available to the public, taxpayers lost $462,000 on the HNF timber sale program in one year alone. Note by Forest Service: Congress has directed the Forest Service to manage for timber, among other resources and uses. The primary purposes the Hoosier proposes timber sales are not financial, but rather to maintain or create wildlife habitat and meet other ecosystem needs. It is therefore no surprise that the German Ridge project uses the same justifications. However, these arguments justifying large negative cash flows by referring to “ecosystem management” are not convincing: We have already: • Questioned above the purpose and need of Oak Hickory Restoration, and of creating early successional habitat on the forest. (See Section 7.Questionable Need of Restoring Oak Hickory) • We have also questioned whether logging and burning are the right tools for achieving the stated purpose and need. (See Section 8. Logging and Burning as Tools) • And we have pointed out alternatives that could be used to achieve the purpose and need without “treatments”. (See Sections 6.and 9.) • The inspector general is not convinced of the benefits of the program. Click here for Part 13. Roadless AreasProtect Our Woods
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