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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 Forest3. Inconsistent Information about the Time Frame of the AnalysisThe plan does not establish clearly how long it will take to achieve the ”purpose and need” (ecological restoration) under Plans A, B, C or D. • “The project is expected to take 4 to 7 years to implement” (p. 9 FEIS). • But obviously “the project” of restoring the hardwoods will take decades. • The time frame for economic cumulative analysis is 6 years (p. 54 DSFEIS) • Table 1-2 (Anticipated Chronology of management Actions by Year) shows timber sales starting in 2007 and the last prescribed fire to happen in 2016. That is a ten year period. • “The timeframe considered for visuals is 20 years to allow for canopy Development”. (p. 51 DSFEIS) • On p. 24 of the DSFEIS one can read that: “The timeframe for cumulative effects (all alternatives) is 15 years in the future because burning would be complete within 10 years and vegetation effects would continue no more than 5 years thereafter. The Forest anticipates that native hardwoods would by that time achieve nearly complete canopy closure, albeit of young forest. Many bird species inhabiting the analysis area may use this maturing forest to meet some habitat need—breeding, nesting, or foraging.” That means that here the timeframe for the analysis is 15 years. There is no analysis of all the alternatives over the time horizon required to establish Oak-Hickory Communities. Therefore, really the FEIS did not accomplish the purpose of analyzing alternative ways of achieving the stated “purpose and need”, as it is required to do: “Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable alternatives and to briefly discuss reasons for eliminating alternatives not developed in detail (40 CFR 1502.14). Comments received in response to public involvement and scoping provided suggestions for alternative courses of action. To be studied in detail, an alternative course of action should, at least potentially, achieve the purpose and need. ”2.2 (PAGE 2-19) FEIS??? A full analysis would provide the public with information of the time frame needed for the achievement of the goal (ecological restoration) under all alternatives, and of all the costs and benefits involved over that time period for the different alternatives. This again seems to confirm our claim that the “project” is really about logging (which can be accomplished within the 4-7 years), and about burning, for which there will be money appropriated by the Federal Government, if the current trend continues (see more about this in other parts of this document). The Law:§ 219.12 (f)(3) Alternatives shall be formulated to facilitate evaluation of the effects on present net value, benefits, and costs of achieving various outputs and values that are not assigned monetary values, but that are provided at specified levels. (8) Each alternative shall represent to the extent practicable the most cost efficient combination of management prescriptions examined that can meet the objectives established in the alternative. (9) Each alternative shall state at least-- (ii) The goods and services to be produced, the timing and flow of these resource outputs together with associated costs and benefits; § 219.14 (c) During formulation and evaluation of each alternative as required in § 219.12 (f) and (g), combinations of resource management prescriptions shall be defined to meet management objectives for the various multiple uses including outdoor recreation, timber, watershed, range, wildlife and fish, and wilderness. The formulation and evaluation of each alternative shall consider the costs and benefits of alternative management intensities for timber production as identified pursuant to paragraph (b) of this section in accordance with § 219.12(f). Lands shall be tentatively identified as not appropriate for timber production to meet objectives of the alternative being considered if-- (3) The lands are not cost-efficient, over the planning horizon, in meeting forest objectives, which include timber production. § 219.12 (g) Estimated effects of alternatives. The physical, biological, economic, and social effects of implementing each alternative considered in detail shall be estimated and compared according to NEPA Procedures. These effects include those described in NEPA procedures (40 CFR 1502.14 and 1502.16) and at least the following: (3) Direct and indirect benefits and costs, analyzed in sufficient detail to estimate-- (i) the expected real-dollar costs (discounted when appropriate), including investment, administrative, and operating costs of the agency and all other public and private costs required to manage the forest up to the point where the outputs are valued and the environmental consequences are realized; § 219.12 (k) Monitoring requirements identified in the forest plan shall provide for-- (3) Documentation of costs associated with carrying out the planned management prescriptions as compared with costs estimated in the forest plan Click here for part 4. Why Are Natural Disturbances Not Enough?Protect Our Woods
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