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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 Forest30b. No Satisfactory Analysis of Ecosystem Services (Part 2 of 2)The question we have for the Forest Service is this: If these institutions can and do use economics to value ecosystem services in order to prioritize projects and contrast costs and benefits, why then, can’t the Forest Service do the same? Instead of coy statements about how impossible it is to do, the Forest Service needs to enter the 21st Century and utilize these tools. Indeed, NFMA regulations absolutely demand this of federal agencies, as well as the Forest Service Handbook:FSH § 1909.15.12.1: Use appropriate expertise in economic and social analysisNFMA directs the Forest Service to maximize net public benefit, to respond to changes in public demands on the forest regarding services that the forest has to offer, and to take into account resource trade-offs and opportunity costs. Trade-offs and opportunity costs refer to benefits and uses that are forgone by pursuing an alternative, in the case of logging, the economic benefits of watershed protection regarding water purification and flood control for communities in the watershed. Both NFMA and MUSYA acknowledge the fact that demand and supply conditions (relative values) can change and can therefore trigger a re-evaluation of the use of the National Forests depending on and what goods and services are the most important for the American people.The statutes encourage the Forest Service to take these ecosystem services into consideration, especially since they are now moving from the status of “non-quantifiable” to the status of “quantifiable in Dollars”. No one can deny that forest “attributes” such as flood control, water purification, etc. are becoming more scarce as more and more forest land is developed, and therefore are becoming so much more critical to the health, safety and security of the American people. To NOT analyze these changing circumstances and attitudes, and instead trying to convince the public that they need more fragmented national forests is therefore, not only against the law, but highly irresponsible. NFMA: § 219.1 Purpose and principles. (14) Responsiveness to changing conditions of land and other resources and to changing social and economic demands of the American people. § 219.11 Forest plan content. The forest plan shall contain the following: (a) A brief summary of the analysis of the management situation, including demand and supply conditions for resource commodities and services, production potentials, and use and development opportunities; § 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: (1) The expected outputs for the planning periods, including appropriate marketable goods and services, as well as nonmarket items, such as recreation and wilderness use, wildlife and fish, protection and enhancement of soil, water, and air, and preservation of aesthetic and cultural resource values; (2) The relationship of expected outputs to the RPA Program tentative resource objectives for the forest displayed in the current regional guide; (3) Direct and indirect benefits and costs, analyzed in sufficient detail to estimate-- (ii) the expected real-dollar value (discounted when appropriate) of all outputs attributable to each alternative to the extent that monetary values can be assigned to nonmarket goods and services, using quantitative and qualitative criteria when monetary values may not reasonably be assigned; (iii) the economic effects of alternatives, including impacts on present net value, total receipts to the Federal Government, direct benefits to users that are not measured in receipts to the Federal Government, receipt shares to State and local governments, income, and employment in affected areas; and (iv) the monetary opportunity costs (changes in present net value) associated with those management standards and resource outputs in each alternative that were not assigned monetary values but were provided at specified levels, compared with the maximum present net value benchmarks developed in § 219.12(e)(1)(iii). (4) The significant resource tradeoffs and opportunity costs associated with achieving alternative resource objectives. (h) Evaluation of alternatives: Using planning criteria, the interdisciplinary team shall evaluate the significant physical, biological, economic, and social effects of each management alternative that is considered in detail. The evaluation shall include a comparative analysis of the aggregate effects of the management alternatives and shall compare present net value, social and economic impacts, outputs of goods and services, and overall protection and enhancement of environmental resources. Multiple Use-Sustained Yield Act (MUSYA): Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That ø16 U.S.C. 528¿ it is the policy of the Congress that the national forests are established and shall be administered for outdoor recreation, range, timber, watershed, and wildlife and fish purposes. In the administration of the national forests due consideration shall be given to the relative values of the various resources in particular areas. ‘‘Multiple use’’ means: The management of all the various renewable surface resources of the national forests so that they are utilized in the combination that will best meet the needs of the American people. NEPA Sec. 102 [42 USC § 4332]. The Congress authorizes and directs that, to the fullest extent possible: (1) the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act, and (2) all agencies of the Federal Government shall -- (A) utilize a systematic, interdisciplinary approach which will insure the integrated use of the natural and social sciences and the environmental design arts in planning and in decisionmaking which may have an impact on man's environment; (B) identify and develop methods and procedures, in consultation with the Council on Environmental Quality established by title II of this Act, which will insure that presently unquantified environmental amenities and values may be given appropriate consideration in decisionmaking along with economic and technical considerations; GreenFire: It is irrelevant that the Forest Service wants to convince the public that logging is a means to an end (wildlife habitat). Again, we restate the fact that Forest Service rules and regulations state the agency’s actions must make economic and financial sense, regardless of the motives. Further, we have no way of knowing if the programs make economic sense if we are not given an economic analysis (cost information) of timber and other programs on the EIS. It is important to reveal the full $-costs and $-returns of the timber program before any determination can be made whether the potential losses of that timber program can be justified by any other benefits that may be achieved with that program. Only if the dollar-losses incurred by the timber program are known can the next steps be taken, which are: • To ascertain whether a certain non-monetary benefits of that timber program will offset that loss. Just because there is some non-monetary benefit, that does not mean that this non-monetary benefit actually outweighs the timber losses. • To analyze opportunity costs, which are the benefits forgone by pursuing certain programs. Those benefits forgone could be monetary or non-monetary, quantifiable or not quantifiable. Even if we assume that a $-loss from logging will be offset by a certain non-monetary benefit, that does not mean that this course of action should be chosen, since the opportunity costs of this action (forgone benefits), could be higher than the non-monetary benefits under consideration. This comparison of benefits and costs, and of opportunity costs, whether monetary or non-monetary, is integral to forest planning. The Forest Service did not respond to our comment that in fact, economics is an important aspect of the planning process that the Forest Service must pay attention to in developing the Forest Plan. In fact, it is laid out very clearly in the FSM: Forest Service Manual and Handbook • FSM § 2403.4: Design a timber sale program where benefits equal or exceed costs. • FSM 2402.5: To plan and conduct cost-effective timber sales and other timber management activities. Instead of repeating all the other relevant statutes here, 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) Click here for Part 31. Hoosier National Forest Plan Management AreasProtect Our Woods
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