Collaborative Learning on EA vs. EIS for Vegetation Projects

This is a test. If this works everyone could enter a project or two from his or her own area and then we could compare what happens across the country, and then ask questions.

So the first step is this: Take a look at this spreadsheet in google docs. Check and see if you can edit it and if you think the columns are the right ones to ask the questions that we might want to ask.

17 thoughts on “Collaborative Learning on EA vs. EIS for Vegetation Projects”

  1. Interesting Sharon…but maybe you should also include “how many pages.” And whether any ESA species are present. When I compare EIS’s on “litigated vs. Non-litigated” forests, I don’t include the appendices…Sometimes, “response to comments” are in the appecndice’s. I’ve seen “response to comments” that go on for 150 pages…usually in Montana. You might also want to include how many MBF is harvested. Another good tidbit would be to post “date of initial public scoping”…and the date of decision. I’ve seen many Montana EIS’s and EA’s that linger on for 3-5 years. I’ve seen EIS’s in MOnt. that have the FEIS completed two years ago…with no decision yet! WTH. In “non-litigated” forests like Colorado, I’ve seen EIS’s that only take a year from “scoping to decision.” Yes, the USFS can be very effecient on Non-litigated.

    • Thanks, Bob and Derek, those are good suggestions. I think there are probably only a couple above 10K, maybe 4FRI and the Black Hills project? But maybe not.. it would be good to hear fro others…

      Forest Service folks- this information may be already be available in some combination of PALS and FFACTS. and NFPORS if so let me know.

      • There are almost always a lot of wildfires in excess of 10,000 acres most years, and there certainly should be a lot more restoration projects of that size, too: you would think they should be at least the size of large-scale wildfires that can transfigure a beautiful landscape of growing timber, thriving wildlife populations, and desired habitat into something else entirely in a matter of minutes and days. Don’t those require recovery plans? EAs or EISs?

    • Derek, Could it be, perhaps, that in a place like Montana you have a lot more issues to deal with than with compared with the Front Range of Colorado, which seems to be your favorite place to compare Montana do. How many ESA species do they deal with in Colorado compared with Montana? Do they have griz? Or bull trout?

      Also, Derek, when you write: “I’ve seen many Montana EIS’s and EA’s that linger on for 3-5 years. I’ve seen EIS’s in MOnt. that have the FEIS completed two years ago…with no decision yet!”

      You should know some of the actual reasons for this, instead of just hypothesize. You seem very willing to blame all this on enviros, but have you ever stopped to consider that perhaps it’s the USFWS who isn’t happy with some of these large-scale proposed timber sales in Montana? Perhaps contact the Forest Service or the USFWS and see about that large timber sale on the Lolo NF in the St. Regis and Superior areas of Montana. I know we’ve debated that Cedar-Thom logging sale before. Hint: Ask about the USFWS consultation and bull trout and USFWS’ unwillingness to give the green light to the USFS.

      Or how about the Marshall-Woods project on the Lolo NF? Technically, my first involvement with that project was back around 2004. Still nothing’s been done with that project. Why? It’s not because the enviros are forcing the Forest Service to chase their tails around or produce another piece of paper. Nope, turns out the Lolo NF has infested much of their staff time, resources and money into the portion of the Lolo NF that covers that Southwestern Crown CFLRP project. The Forest Service figured out real fast that they could get extra money by turning their attention to the CFLRP-portion of the Lolo NF and you know what? That’s exactly what they have done. Meanwhile projects on other parts of the Lolo (outside the CFLRP-portion) just sit there in some sort of limbo. We warned that CFLRP had a chance of causing balkanization throughout the entire USFS system, as it basically rewards a few portions of a few national forests at the expense of the rest….and that’s exactly what’s happening on the Lolo NF. Don’t take my word for it, contact any members of the Lolo NF’s westside collaborative working group and here it directly from them.

      • Hello Mathew. The two timber sales I like to use in my “litigated VS. Non-litigated” apples to apples comparison of EA’s, is the “Fleecer Mountains EA on the Beaverhead Deerlodge in Montana and the “Lower Blue EA” on the White River forest in Colorado. I’m just quoting all these numbers from memory, cause I don’t want to dig through a pile of papers right now, so forgive me. The Lower Blue is not on the “Front RAnge”…it’s five miles from Breckenridge Colorado in the heart of MPB killed lodgepole country. So is The Fleecer Mountains project. The Fleecer Mountain project will log 1700 acres and the EA ran to 228 pages, while the Lower blue project will log 4000 acres and the EA ran to 57 pages! I picked the Fleecer Mountain project because there isn’t an endangered grizzly bear within what, 150 miles. They both have endangered lynx to deal with, but Colorado doesn’t have an activist judge who demands the USFS do a supplementary “cummulative analysis” on lynx.

        That said, I don’t think the Northern Region’s problems can all be attributed to enviros. There’s something amiss there. I’ve seen “project scoping” listed on the “projects web page”…that languish for a couple years before the DEIS comes out. I have a theory, purely speculative and probably not true, and meaning no disparage to USFS employees, that all the foresters go somewhere else, and all the “ologists” go to Montana. It does beg my next question…what is the ratio of “foresters to ologists” in the USFS today?(not trashing ologists here). Somethins wrong.

        It would be nice if this blog was granted “journalist powers” so we could ask the Northern Region and not be blown off, “why is it that it takes so long for projects to go from scoping to DN.” And perhaps more importantly, and this absolves you Matt,”Why does it take so long from scoping to DEIS?” Manpower? Budget? I don’t think I’m exagerating when I say the EIS’s I read in Colorado take maybe a year from scoping to DN.Of course, they got $40 million dollars a couple years ago also.

        That all said, I have no doubt that enviro litigation, or the threat of, soaks up a lot of NEPA budget dollars in Montana. The NR could crank out twice the EIS’s, and thus cut twice the timber, if their NEPA costs were the same as Colorado. Sharon, can’t you pull some strings and get the GAO to investigate this? (just kidding). Enquiring minds want to know.

        • I’m gonna reply to my reply. Something I’ve pondered many a time,is “how much of the decline in timber harvest since the 80’s was attributable to the Enviros, and how much is attributable to the USFS. If unfettered by spotted the spotted owl or ANY enviro litigation…how much of a “reduction” in timber harvest would Jack Ward Thomas have liked to have seen? 30%? 50%? I doubt 80%.

          The ONLY thing I want to know, is “how much does it cost to do an EIS in Colorado VS. Montana.” It’s another one of the invisible truths that haunts us.Litigated vs. non-litigated.Colorado and Montana is the perfect laboratory. Dollars per board feet, dollars per acre…it doesn’t matter.Without, transparency is just another cheap party slogan.

        • Derek wrote: “I picked the Fleecer Mountain project because there isn’t an endangered grizzly bear within what, 150 miles.”

          That’s just entirely not true. Not only are there plenty of grizzly within 150 miles of Fleecer Mountain, the Butte newspaper reported that a grizzly bear was killed near Elk Park in 2010 and in 2005 a hunter killed a grizzly bear within the Mount Haggin Wildlife Management Area, which adjoins the Fleecer timber sale and is within the wildlife security analysis area for the project.

          So to make some claim that grizzly bears aren’t within 150 miles of that area is just non-sense. Sorry to say it, but it’s true, Derek.

          I agree with you that perhaps something is amiss in the northern Region, however, I’m not sure it’s because of a lack of “foresters” vs. the “ologist.” Maybe that “amiss-ness” is why the northern Region produces all the Chiefs lately, eh?

          I’m not sure how it works in other regions, but I do know what you are saying about projects languishing. We’ve seen the same things on some good projects, as I’ve pointed out. I think budgets have something to do with it. I also know that when things like space shuttles blow up, or a hurricane levels the gulf coast that USFS employees in rural ranger districts in Montana get called out for duty for two weeks or so. And of course fire season – thanks to hottier and drier conditions across much of the west – is now longer and that pulls Montana employees away from Montana during spring, if there is a bad fire season in TX, NM, AZ, etc. And it pulls them away again in the summer and fall throughout the northern Rockies. Fire season is followed pretty closely by bow and rifle hunting seasons, and I know many Forest Service employees save up much of their vacation time and take off for a few weeks every fall. And then let’s not forgot that Congress really doesn’t produce a budget anymore, so the FS and everyone else is just operating without knowing what their budget will be, if it will be sequestered or fall off the ‘cliff.” You over-lap all this stuff and pretty soon your actual effective work year gets cut, what, in half? I don’t mean to talk bad about FS employees at all, but I’m just sharing what I’ve heard many current FS employees speak about.

          • Once again, let’s highlight Derek’s statement: “I picked the Fleecer Mountain project because there isn’t an endangered grizzly bear within what, 150 miles.”

            And compare that statement about “no grizzly bears within 150 miles of the Fleecer Mountain project” with the following ‘statement of facts’ from the actual lawsuit:

            26. In 2005, a dead grizzly bear was found within the Mount Haggin Wildlife Management Area. AR A-02: 101; AR X-05. The Mount Haggin Wildlife Management Area is adjacent to the Project area. AR A-02: 18. It is also within the Big Hole Landscape, AR H-01: 72, which is within the wildlife security analysis area for the Project.6

            27. The Forest Service admits that there have been recent grizzly sightings on the north end of the Forest. AR A-02: 99.

            28. The Forest Service admits that grizzly bears “could disperse through” the Project area. AR A-02: 319.

            29. The Forest Service admits that “[a]s a result [of its connectivity with the Anaconda-Pintler Wilderness], the project area could receive incidental use [by grizzly bears].” AR A-03: 107.

            30. The Forest Service admits that there could be “transitory [grizzly] bears that might move across the project area or mountain range.” AR A-01: 23.

            31. The draft EIS for the Revised Forest Plan found that grizzly bears may be present in the West Big Hole inventoried roadless areas: “Black bear, mountain goats and transient populations of grizzly bear are particularly numerous in the Sheep Mountain portion of this area but are found throughout.” AR A1-24: 304 (emphasis added).

            I’m all for a comparison, but I’d put forth that none of us know enough information to make a true apples to apples comparison. The simple fact that Derek claimed, for certain, that there were no grizzly bears within 150 of this project and your compare that with the info I’ve been able to quickly dig up helps prove my point. And I’m not trying to pick on Derek, just trying to point out that this little exercise is might almost be like comparing costs to heat the average home in Missoula, Montana compared with an average home in Miami, Florida.

        • Derek: That is an excellent point and provides the type of ready access to public information we’ve all been in agreement on: why can’t a blog have standard journalistic access (“SJA”), or whatever it is called, to such information? Sharon is in the process of obtaining a 501 c(3) for her public outreach organization(s), which includes — I think — this blog. Would something like that just create more work for someone (possibly a volunteer or two), or would it provide this blog with an important new communications tool?

          More investigative journalism and focused research on nationally-important issues takes place here in a week than seems to occur in a month of Sunday papers from whatever source. Why not simply describe this blog as a medium for sharing, investigating, and discussing current issues of importance to study and management of the nation’s resources. Maybe not even that elaborate; e.g., “federal lands issues news journal” as a descriptor.

          Or am I off on some tangent here? There has been a core of at least 10 or 20 individuals that have regularly contributed to this blog over the past few years, and there now seems a daily readership of about 200 people a day (100/day on weekends). That is a fair amount of talent and interest, and certainly seems to cover the entire spectrum of ideas and opinions on these emerging topics and issues — but we all like the actual facts and figures that these issues are based on.

  2. Sharon: I think this is a good start. I’d suggest adding “BLM” to Forests and “Threatened” to Endangered — and maybe a couple of Treatment columns for planting, seeding, salvage logging, precommercial thinning, thinning, clearcutting, chemical uses, trapping, etc. Maybe even a ROS Map. Also, this is a limited scale. Howabout: 100-1000 acres; 1000 to 10,000 acres; and 10,000+ acres? Or align the acreages with various government regulations. Just no hectares.

  3. Sharon, I would also add columns for:

    -approx NEPA costs for the decision (gathered from indvidual forests)

    -appealed, Y/N (and by whom).
    -approx appeal costs (gathered from readily available (albeit coarse) data from RO NALS wonkshops).
    -net gain/loss of project acres as a result of appeal/appeal resolution. (gathered from individual forests)

    In the litigation section I’d add:

    -number of claims won by plantiff(s)
    -net gain/loss of project acres as a result of litigation (for those that go forward to implementation))
    -EAJA fees requested
    -EAJA fees awarded

    Some of that will likely be heavily depentent on FOIA requests (Thanks Sharon! Good thing your “retired”), but I think the picture that would eventually be painted (or has been painted if you’re really ambitious and willing to do a retro-look) would be very informative…and something Congress might be interested in taking a look at.

    All part of CREATE I hope?

    • Yes, all part of CREATE, and I promise I won’t FOIA if people will provide the information directly. Maybe some of my fellow retirees would be interested in helping? Or graduate students?
      And I think all regular contributors should be willing to put at least 2 projects from their local areas onto the spreadsheet. Derek probably has more.

    • JZ….I gots to ask. You said above “approx NEPA costs for the decision.” Is it possible the individual USFS forest’s keep track of the cost to do an “individual project” EA or EIS? How do we get a hold of that gem. The only place I’ve gotten clues about EIS NEPA costs…is the very rare cases where the USFS has “contracted” that…and that is very course data.

  4. One more thing that should be on your “people’s data base”(I always picture chairman Mao when I hear that)…somewhere… “cost.” Cost to do RX burning, PCT, road obliteration per mile,and of course, my favorite, “slashing small diameter trees.” Every USFS website should list that…it’s readily available in “the project file.” And “budget.” I’ve noticed that on “old forest monitoring reports,” they frequently listed FY budget. That went away in the 90’s. It’s that whole silly “transparency” thing. Of course, you probably wouldn’t want to include it in what you want to do above…but I just got to keep hammering on it.

  5. Wow, you guys are great! Derek, I haven’t seen costs reported but I can leave some columns in case they are. Also stewardship contracts make that more complicated. Maybe we could ask for a standard report on projects from the FS with that information?

    • I’ve only seen costs reported on a few EIS’s, in the “economic” section of chapter 3. By no means do all EIS’s or EA’s have them. Sometimes they refer to the “project file” for costs…so I spose a person could get that. They know what it costs, from past histories, to do these treatments. Of course with all things “bid”…there are site specific variables.

  6. Many of our projects now include “miles of road decommissioned”. We don’t build permanent roads anymore, we are removing them.


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