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Jul 25, 2019

Submit a Comment: Help us Keep the Public Involved in Public Land Management

The Trump Administration’s Forest Service has proposed a sweeping new rule to strip environmental review on proposed Forest Service activities on our national forests. Estimates are that as many as 90% of Forest Service decisions could now be fast-tracked and not subject to meaningful environmental review.

The proposed changes to the Forest Service’s implementation of the National Environmental Policy Act (NEPA) would also drastically weaken public involvement on projects on the Green Mountain National Forest in Vermont and national forests throughout the country. In short, the proposed rules would take the public out of public land management.

Your help is needed to stop this brazen move regarding our public lands. Please submit comments by August 12. See below for into on how to submit comments.

Overview of the Proposed Rule (click here to read the rule):

The proposed rule would reduce environmental review for projects including timber harvesting, mining, and road construction on national forests. The proposed rule would greatly expand the types and size of projects that qualify as “categorical exclusions”. These are projects which, at the agency’s discretion, do not undergo an environmental assessment or impact analysis, and they typically include negligible activities, but the Trump Administration’s Forest Service wants to expand categorical exclusions to much larger, and more impactful projects. The proposed changes would allow up to five miles of road-building, timber harvesting on thousands of acres, special use permits on up to 20 acres, and even the approval of illegally created roads into the Forest Service system to occur without any substantive review of environmental impacts. Furthermore, the proposed rule removes the need to conduct an environmental impact statement for mining projects up to a square mile in size, and for actions that would alter the undeveloped character of inventoried roadless areas and potential wilderness areas.

The public could be largely cut out of the decision-making process. Aside from reducing the environmental safeguards for such projects, the proposed changes would also remove public involvement, as projects classified as categorical exclusions are exempt from the typical channels of public input and review. Furthermore, the rule provides the authority to limit scoping as well, which would remove the public’s ability to raise concerns at the beginning of a project. Transparency and public engagement have been bedrock principles to public land management. NEPA is the most important federal law granting access to the environmental decision-making, and weakening this provision risks leaving the public with little involvement on the management of our public lands and the Green Mountain National Forest.

The proposed changes would grant new deference to the Forest Service to limit public awareness of site-specific impacts. The Forest Service proposes to codify “condition-based analysis” as a permissible practice for new projects. This would allow the Forest Service to define broad project targets at the beginning while waiting to identify the location and size and scope of activities, such as new roads or timber harvests, and the site -specific impacts of these activities, until later in the process after public involvement.

Strains on Forest Service resources are caused by shrinking budgets, not by environmental review processes. The main reason offered for these changes is to streamline the environmental review process for Forest Service projects, so as to reduce the backlog of projects still needing review.  However, shortchanging environmental review is the wrong way to address shrinking agency budgets. The Forest Service should have the full resources necessary to complete environmental reviews in a manner which safeguards these important public resources and wholly involves the public. We should not be cutting corners on vital environmental safeguards for the sake of efficiency.

How to Comment on the Proposed Rule:

Submit comments by August 26 through one of the following channels. Please make your comments specific and unique to your concerns and relate your comments to a particular national forest, like the Green Mountain National Forest.

The Forest Service will lump together comments that have similar talking points and count them as one comment, so please make your comments unique to be counted.