NRDC Planning Rule Comment Form

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Ask the Forest Service to protect our national forests
Consisting of more than 193 million acres, our national forests are the crown jewel of America’s natural heritage. They provide critical wildlife habitat for endangered and threatened species, as well as clean drinking water and recreational opportunities for millions of Americans. The U.S. Forest Service is now drafting new rules for their management. Please urge Agriculture Secretary Tom Vilsack to give our national forests the strongest possible protection.

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Tom Vilsack, Secretary of Agriculture

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Adopt strong rules for our national forests

I am writing to ask that you adopt strong, conservation-oriented and science-based rules for our national forests. I appreciate your commitment to preserving and restoring this key piece of America’s natural heritage, and applaud the spirit in which the proposed management rules have been drafted.

The final rules must deliver and improve upon the intent of the draft version. A core function of these rules must be to produce good outcomes for national forests and to help ensure that local managers don’t make the kinds of mistakes that have degraded too much of our public forest estate already. That will require much stronger guidance in several key areas.

First and foremost, it is critical that these rules fully protect the species that depend on national forests for their survival. The final rules must ensure that management choices don’t contribute to wildlife and other species disappearing from parts of their ranges. Local extirpations of plants and animals strip national forests of some of their most cherished elements and weaken ecosystems, increasing vulnerability to climate change and putting added pressure on surrounding lands.

Second, the rules must include numeric standards to protect streams, wetlands, and other water bodies. Please make sure that the rules specify a minimum buffer zone around all national forest waters of at least 100 feet, where all management has to promote aquatic health.

Third, consistent with President Obama’s commitment to scientific integrity across the federal government, the Forest Service needs to be guided by the best available science. I’m concerned that as drafted, the rules only direct the agency to “take account” of the science. The final rules need to require that it rely on the best available science, not just consider and then ignore it.

And finally, I am quite concerned that the public have a fully meaningful opportunity to raise concerns about management decisions with top officials in the agency. Under the rules that now apply, citizens have 90 days to appeal local planning decisions to supervisors. It’s crucial that we have at least that much time for decisions that have been years in the works, fill multiple volumes, and rely on thousands of documents.

Thank you very much for considering my concerns. I share your interest in the welfare of these wonderful forestlands and in passing them on, unimpaired, to future generations. I look forward to management rules that will ensure that outcome.

I’m particularly interested in the “science” paragraph:

Third, consistent with President Obama’s commitment to scientific integrity across the federal government, the Forest Service needs to be guided by the best available science. I’m concerned that as drafted, the rules only direct the agency to “take account” of the science. The final rules need to require that it rely on the best available science, not just consider and then ignore it.

According to my count, that’s Science/Scientists as drivers of land management:
NY Times 1
Wilderness Society 1
Graduate student in ecology 1
NRDC 1

I found the comments to be very interesting as well

Noted, but not resident of US, so could not sign.
If something isn’t done to save what we have it would be a travesty!
“They took all the trees and put’em in a tree museum, and charged a dollar and a half just to see ’em” Joni Mitchell 1970
Forty one years ago they were singing songs about the environment, why has it taken so long? Why did it get to be a worse problem??

What do you think? How should the FS consider comments from people who click buttons based on info they read online?

5 thoughts on “NRDC Planning Rule Comment Form”

  1. “What do you think? How should the FS consider comments from people who click buttons based on info they read online?”

    What do you think about this?

    How should state election officials consider votes from people who pull levers based on info they read online, or get from a political TV commercial?

    Honestly, that’s how I view the logical conclusion here. I’ve always been amazed that while we have a public process in place for managing our public lands, if the public’s comments don’t match up with what the agency wants to do, then it must be because the public really doesn’t understand these issues and they were just tricked into “clicking and sending.”

    However, you can bet if people or a group organized form comments to support an agency position that the agency wouldn’t make a big deal about it.

    Reply
  2. “Second, the rules must include numeric standards to protect streams, wetlands, and other water bodies. Please make sure that the rules specify a minimum buffer zone around all national forest waters of at least 100 feet, where all management has to promote aquatic health.”

    Ummmmm, we ALREADY have all those watershed protections, even including protections for dry gulches.

    Also, “best science” is always open to interpretation. What is good for one species might not be good for other species. Preservationism on degraded public lands surely doesn’t “protect” wildlife from destructive wildfires. When ESA habitat burns to a crisp, it will be gone for a long, long time, losing its “protections”, along with those species.

    Reply
  3. I’m trying to understand and give your line of questioning the benefit of the doubt, but I just keep returning to the first impression:

    Really Sharon, are you serious? Or is this turning into a personal game of baiting the readers to see who will rise to your cast rhetorical dry fly?

    Are you really going to focus on the “click” associated with the public’s choice in response to information (which may not be a primary source at all, but which may well resonate with personal experience, knowledge, or point of view) as some sort of excuse for the agency to disenfranchise the choice of the taxpayer/owner of public lands?

    Where are you going with this line of questioning? Perhaps the Forest Service could outsource this enforcement function to a Xe (Blackwater Inc.) truth squad? Or impose a quota of clicks per year?

    Is this what you get paid to do? Or do you muse upon the absurd on your own time based upon what you get paid to do? Have you any idea what logically follows from your own questions? It is hard not to conclude jaded/ biased careerist stereotypes occur within the agency because they routinely make themselves obvious to the public.

    Reply
    • Since the Forest Service rarely defends its position in public, maybe Sharon is attempting to provide information not volunteered in the press. If the Forest Service had to address all the untruthful and misleading anti-forestry statements, would they actually get more done, on the ground?

      Reply
  4. Foto- I think there are people out there who are concerned about getting all their news from biased sources (who may be telling one side of the story). It is getting more and more difficult to find articles that are explanatory and relatively unbiased (even ones that simply get the facts straight!) due to changes in the journalism industry. That’s why I try to honor those here on the blog, when I know the facts on a certain topic.

    David- I spent the last couple of weeks (other things) talking to county commissioners and others of the public on a non-planning rule topic; I honor their knowledge and the discussions and mutual learning that we had. I know this may be controversial in some circles, but I think dialogue is much more productive than button-clicking (or even button-clicking on various aspects of a dialogue). What concerns me is that one groups says “X” and people punch buttons without hearing the other side. Of course, that’s true in politics as well but much of our country is concerned that we don’t have enough civil dialogue and have become hyper-partisanized.

    Perhaps I am channeling Dave I. ;), (I seem to remember him saying this on another thread recently) but my recent experience suggests that some form of public dialogue would be better than comment and analysis of comments. Especially with today’s technology, we could imagine discussion fora of all shapes and sizes. I think some of my peers might be concerned about the time and effort it would take, but Gifford Pinchot said in his maxims (1-7)

    A public official is there to serve the public and not to run them.

    Public support of acts affecting public rights is absolutely required.

    It is more trouble to consult the public than to ignore them, but that is what you are hired for.

    Find out in advance what the public will stand for. If it is right and they won’t stand for it, postpone action and educate them.

    Use the press first, last, and all the time if you want to reach the public. Get rid of the attitude of personal arrogance or pride of attainment or superior knowledge.

    Don’t try any sly or foxy politics, because a forester is not a politician.

    Learn tact simply by being absolutely honest and sincere, and by learning to recognize the point of view of the other man and meet him with arguments he will understand.

    I think discussion is the most palatable form of education on controversial subjects.

    Reply

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