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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 Forest29b. Deficiencies of Economic Analysis (Part 2 of 2)Council on Environmental Quality (CEQ) NEPA Regulations (40 C.F.R. § 1500-1508).o § 1508.8 (b): Consider aesthetic, cultural, economic and social factors. 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. This DEIS fails to meet these requirements. Cost of Environmental RegulationsDuring the comment period for the DEIS of the HNF LRMP, GreenFire submitted the following comment under “17. Forest Service and Environmental Regulations”HNF DEIS, p. 3-278: “The cost of management is often higher on public lands because the rules and regulations that direct their management of public lands, causing additional expenses the Forest incurs that private landowners would not incur.” Timber sales on the Hoosier National Forest are money losers (see “11. Timber Sales Program” above). Does this statement attempt to imply that the deficits from extractive programs could be the result of having to adhere to strict regulations regarding the environment? The regulations are meant to insure that externalities do not occur or are reduced. When internalizing these costs (by making the Forest Service adhere to rules and regulations that protect the environment), it may become obvious that avoiding environmental impacts is so expensive that society would be better off if the logging and other extractive operations weren’t happening. In this case, if commercial timber sales were to end, forest programs costs would decrease, and this decrease in costs would be larger than the decrease in benefits (market value of timber sales revenue), in other words, it would be a net benefit to society. Forest Service “Response to Comment” Regarding Cost of Environmental RegulationsNONSUBSTANTIVE COMMENTSHNF FEIS Appendix p. 224PC #193: If the Hoosier ended the timber sale program the decrease in social costs (including environmental costs and agency costs) would further increase the net benefit from ending the timber sale program. GreenFire Comment on Lack of “Response to Comments” Regarding Cost of Environmental Regulations:The Forest Service chose not to respond to our comment regarding the costs of environmental regulations associated with logging programs, and the resulting public benefits (=equals reduced public costs) that would result from discontinuing those programs.If the Forest Service would reveal the costs associated with having to “mitigate” the impacts of logging on soils, water, NNIS, air quality, endangered species, visual quality, it would become obvious that Alternative B has hardly any such mitigation costs, whereas the other alternatives do. The Forest Service does not reveal these costs and how they differ between alternatives. With that, again, the Forest Service keeps an important piece of information from the public. The public is not given the opportunity to weigh different costs and benefits for the different alternatives. Basically the cost differentials between the alternatives remain hidden, and the “net public benefit” determination becomes an arbitrary and capricious exercise where the Forest Service decides which costs and benefits matter and which will be ignored. The NFMA requires that the costs of mitigation measures be analyzed and included in an assessment of the § 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. Instead of repeating all the other statutes relevant to having accurate cost information as a tool for decision-making, we refer to 6) above, where we quoted in detail from: The CEQ Regulation Sec. 1502.1 , Sec. 1502.2(a) , NFMA § 219.2 (a) and (b) (13) ; § 219.12 (f) (3), (8), (9); § 219.14 (c); § 219.12 (g) (3) (i) ; § 219.12 (k) (3) GREENFIRE: These comments point to the fact that people see a conflict between industrial forestry operations and their desire for recreation. No screening or mitigation can get around the fact that the noise, dust, the devastating sight of clearcuts and burns, the loss of beloved places and big trees, are not supporting recreation, they are in conflict with it, and they do not mimic natural processes. The Forest Service does obviously not give much consideration to this conflict. The Forest Service is also avoiding the question of why natural disturbances are not enough to provide the variety in the forest landscape that visitors might actually enjoy. NFMA regulations clearly acknowledge the importance of cost information for weighing the costs and benefits of different alternatives, and the requirement that Environmental Impact Statements be tools of decision making: The CEQ Regulation Sec. 1502.1 demand that environmental impact statements are concise, clear, and to the point, and shall be supported by evidence that the agency has made the necessary environmental analyses. An environmental impact statement is more than a disclosure document. It shall be used by Federal officials in conjunction with other relevant material to plan actions and make decisions.” The cost- information presented in the FEIS is neither concise, nor clear, nor to the point. It certainly doesn’t facilitate decision-making and action. Section 1502.2 of that regulation states: “To achieve the purposes set forth in Section 1502.1 agencies shall prepare environmental impact statements in the following manner: a) Environmental impact statements shall be analytic rather than encyclopedic. With regard to costs, we understand that to mean that the cost information should be presented in such a way that it facilitates “analysis” of the plan, instead of unhelpful, scattered tidbits of information, as on pages 24 and 31/32 of the Appendix, or the cost information in Table B.18 that claims that all costs are the same for all alternatives, and has no breakdown of these costs whatsoever. For suggestions of how the costs could be broken down to facilitate decision-making we refer to the Government Performance and Results Act (GPRA): “Performance budgeting is based on the assumption that presenting performance information alongside budget amounts will improve budget decision-making by focusing funding choices on program results. The Government Performance and Results Act (GPRA) makes this a requirement by mandating that performance plans display, generally by program activity, the funding level being applied to achieve performance goals. Performance budgeting shifts the focus of attention from detailed items of expense—such as salaries and travel—to the allocation of resources based on program goals and measured results. It continues the precedent set by other financial management programs initiated since the 1960s, such as Management by Objective (MBO); Zero-Based Budgeting (ZBB); and the Planning, Programming, and Budgeting System (PPBS).” The following regulations also show the importance of cost-information for decision making: Costs are an integral part in assessing efficiency, and the maximization of net public benefits is not possible without a clear sense of the (monetary and non-monetary) benefits and costs involved in a program or action. Costs are also an integral part of monitoring compliance with the plan as the plan is carried out. NFMA § 219.2(a) The regulations in this subpart set forth a process for developing, adopting, and revising land and resource management plans for the National Forest System as required by the Forest and Rangeland Renewable Resources Planning Act of 1974, as amended (hereafter, "RPA"). These regulations prescribe how land and resource management planning is to be conducted on National Forest System lands. The resulting plans shall provide for multiple use and sustained yield of goods and services from the National Forest System in a way that maximizes long term net public benefits in an environmentally sound manner. (b) Plans guide all natural resource management activities and establish management standards and guidelines for the National Forest System. They determine resource management practices, levels of resource production and management, and the availability and suitability of lands for resource management. Regional and forest planning will be based on the following principles: (13) Management of National Forest System lands in a manner that is sensitive to economic efficiency; Click here for Part 30a. No Satisfactory Analysis of Ecosystem Services (Part 1 of 2)Protect Our Woods
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