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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 Forest29a. Deficiencies of Economic Analysis (Part 1 of 2)We think it is imperative that the Forest Service provide, in a transparent way, the information that is necessary for the public to see clearly the different monetary and non-monetary costs and benefits of all plan alternatives.It is not enough to either say there will be no impacts on the different “resources” from burning and logging, or list some of the impacts. The important piece of information is how much these impacts differ from one alternative to another. As the Plan contains information about how many acres would be cut with the different alternatives, rather than just giving vague, statement of “more” or “less”, so also should the plan have some clearly displayed, comprehensive information about the different environmental impacts, including the impacts of burning, of the 4 alternatives, and the costs of mitigation measures. That is important information to have on the project level, because it is at this level that the we can begin to calculate how much more air pollution, sedimentation, CO2 etc. will be the result of the respective alternatives, and understand how much the German Ridge project will contribute to the total Hoosier National Forest Plan contributions. The Forest Service is failing to consider important use- and non–use demands and values related to the Forest by not conducting a concise, transparent, simultaneous evaluation of all price and non-price benefits, costs, and effects. • In addition, the Forest Service has not proven that the alternative that they have chosen provides a value to the public that could not have been achieved with the no-action alternative. This is required by law: Council on Environmental Quality (CEQ) NEPA Regulations (40 C.F.R. § 1500-1508).§ 1502.14 (a): Fairly assess the “no action” alternative. • The FEIS and DSFEIS indicates numerous negative effects of this project. (for more info see Section 28. Soil Analysis) These include potentially serious soil erosion from logging on steep slopes, decrease in water quality, and loss of Indiana bat habitat. Other negative effects not listed that could result from this project include loss of particular hunting and other spots that have become important to people from the use of this area over years. The DEIS needs to include all of the costs of these losses, either qualitatively or quantitatively. Without a full accounting of these costs, the Forest cannot make a clear decision of whether or not the true benefits of this project outweigh the costs. • The EIS’s state that the slope in a large part of the proposed logging areas ranges from 8 to 50 percent and some of the soils are eroded or severely eroded.”3.7.1 (FEIS page 3-72). What are the costs of erosion control measures over a time frame beyond 4-7 years? • If the soil erosion cannot be completely controlled, how does it affect water quality? What is the cost of a lower water quality and higher flow rates? Will water that people drink in the surrounding areas have to be filtered due to increased sedimentation? What about the cost of flooding? • There is higher risk of non-native invasive species invading areas that have been logged, according to the FEIS/DFEIS, and the prescribed burning may not keep all of them under control (FEIS 3.3.1. and 4.2.3.) What about costs (hand pulling, herbicides, burning) of controlling invasive species after the 4-7 year period? • In Section FEIS 3.3.8, there is a list of Regional Forester Sensitive Species, including rare and sensitive plants. There is also a section of very unconvincing and contradictory conclusions about whether or not these plants exist in the pine plantations, and how they are going to be protected once logging commences. No scientific evidence is given about whether these plants can actually survive the prescribed burns. Finally, the FEIS does not include the cost of the loss of habitat of these rare and sensitive plants. This does not include an assessment of whether these plants are important for medicinal uses, and whether they are valued by local visitors to the Forest. All of these potential benefits need to be described either qualitatively or quantitatively • The project area includes the following subwatersheds and their aquatic resources: Bear Creek, Big Poison Creek, Fanny Creek, Millstone Creek, Deer Creek Headwaters, Middle Deer Creek, East Deer Creek, and Deer Creek. These watersheds include a system of ephemeral, intermittent, and perennial streams. In addition, the project area includes steep slopes. It has been shown that logging on steep slopes causes erosion and this erosion has an effect on water quality and quantity. However the FEIS/DSEIS fails to adequately show the full costs of this effect on water quality and quantity. (See also Section 28. Soil Analysis) • In section 4.10.2, the FEIS states that “Alternative B would not contribute to the economic picture and thus would not contribute to cumulative effects to economics.” In other words, no economic benefit is assigned to Alternative B. This statement discounts all the positive effects that standing forests contribute to the local and regional economy, including water purification, erosion control, and sensitive plants with possible medicinal value (as shown in the listing of RFSS plants in the DEIS). It does not fairly evaluate the no-action alternative, which is a NEPA requirement. Council on Environmental Quality (CEQ) NEPA Regulations (40 C.F.R. § 1500-1508). § 1502.14 (a): Fairly assess the “no action” alternative. • In addition, contingent valuation studies from this and other regions of the country clearly show that endangered species have extremely high existence, option and bequest values. We understand that the Forest Service may not have the resources to undertake original research on the value of the Indiana bat to populations across the country. However, the FEIS/DSEIS does not even make the slightest attempt to qualitatively describe the importance of this species to the public. This is astonishing in light of how often the public has appealed this Forest’s logging projects over the years because of the threat to the Indiana Bat’s habitat. Also, the Forest could have attempted to use benefit-transfer analysis to try to estimate the value of the bats. Benefit-transfer analysis is a tool that is widely utilized by Forest Service and other government, university and privately employed economists. • The FEIS states in 3.13: “Several environmental values and amenities are in the Project Area, including visual, recreational, and wildlife resources (non-priced commodities). It is outside the scope of this FEIS to assign monetary values to these amenities or to include them in the financial analysis.” However, by law, the Forest Service must manage national forests for the highest and best use. Forest Service programs must maximize the net social and economic contributions of national forests to the American people. Forest Service Planning Regulations (36 C.F.R. § 219). § 219.1 (a): Maximize net public benefits of national forest programs. § 219.4 (a): Develop systems of analysis to insure public benefit maximization. § 219.4 (b) 1 (ii): Consider the relative value of market and non-market outputs. • The FEIS/DSFEIS fails to assure the public that the Forest is willing to protect the habitat of the Indiana bat. (For more info see Section 20. Indiana Bat) The Forest Service can point to the USFWS’s Biological Opinion all it wants. In the end, the BO is merely a death warrant for Indiana bats, and a rubber stamp from the USDI to the USDA. There are no guarantees given in the BO that the Forest Service will protect the Indiana bat’s habitat. The public has already spoken on this issue. Why is the Forest using precious resources and money to recycle a project that does not stand on its merits? Click here for Part 29b. Deficiencies of Economic Analysis (Part 2 of 2)Protect Our Woods
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