Wild Virginia Calls for Investigation of Forest Service on Draft Pipeline Decision

For whatever reason the focus on this blog is often westward-leaning and forest-focused. I received this press release from the folks at Wild Virginia regarding a potential pipeline through the George Washington National Forest and the Monongahela National Forest, so thought I’d post it below. – mk

Wild Virginia Files Objection and Calls for Investigation of United States Forest Service on Draft Pipeline Decision

Wild Virginia, a state-wide forest conservation group, filed a formal objection today against the United States Forest Service (USFS). This was in opposition of the draft Record of Decision (ROD) that could allow the Atlantic Coast Pipeline (ACP) to be built in the George Washington National Forest (GWNF) in Virginia and in the Monongahela National Forest (MNF) in West Virginia. Joining Wild Virginia in the objection are Heartwood, the Dominion Pipeline Monitoring Coalition and various individuals.

“By filing this formal objection to the United States Forest Service Record of Decision, Wild Virginia is doing what the Forest Service has refused to do; defend the ecological integrity of our public lands,” said Misty Boos, Wild Virginia Director.

The draft ROD proposes to allow numerous exceptions to the Land and Resource Management Plans for both national forests that could allow the ACP to cross the GWNF. The current GWNF Plan, which took 7 years to complete and had input from over 10 thousand individuals and groups, was finalized in 2014, the same year that Dominion Resources and Duke Energy rolled out plans for the ACP. Neither company participated in the planning process or offered any input to forest planners, knowing full well that their planning for the ACP, then named the “Southeast Reliability Project” were in the works.

“It is criminal that the Forest Service would bless Dominion’s proposed plans for the ACP when this should have been part of the forest planning process ten years ago,” said Ernie Reed, President of Wild Virginia and Heartwood Council member. “The Forest Service has disregarded 7 years of work and thumbed its nose at the entire forest plan to pave the way for the most damaging proposal that Virginia’s forests have ever seen.”

The ROD stands in striking opposition to virtually all the input that the USFS had submitted on environmental impacts on the forest from the proposed pipeline up to the point that the draft ROD was signed. The USFS has been perhaps the most vocal critic of the process, the content and the conclusions that Dominion has submitted to the Federal Energy Regulatory Commission as the basis for its Final Environmental Impact Statement which is a regulatory requirement for all federal projects of this nature. The Draft Record of Decision was signed July 21 by Tony Tooke, then Southern Forester in Atlanta. Virtually all of the previous submissions and comments by the USFS on the project were generated at the local level by GWNF and MNF staff.

Subsequently, one month after signing the ROD, Tooke was appointed as Chief of the United States Forest Service by Sonny Perdue, the Secretary of Agriculture.

“For whatever reason, the Forest Service has suddenly dropped its formerly responsible approach to project review and is now proposing to authorize construction of the destructive ACP across the National Forest prior to receipt of detailed and site-specific plans,” said Rick Webb of the Dominion Pipeline Monitoring Coalition. “The Forest Service has seemingly adopted the same deferred-analysis model of environmental review as the other dysfunctional federal and state agencies. It’s bad news for the remaining wild landscape in the central Appalachian mountain region.”

“The stark contrast of Forest Service filings before the draft Record of Decision demonstrates a breech in agency procedure which should be scrutinized by senate and congressional committees,” said David Sligh, Wild Virginia Conservation Director. “We are making this request for an investigation today to Virginia’s senatorial and congressional delegation.”

“It becomes the responsibility of citizens to hold the USFS accountable for its actions,” Boos asserted. “Wild Virginia is taking this action on their behalf.”

Link to Wild Virginia’s Objection to the USFS

36 thoughts on “Wild Virginia Calls for Investigation of Forest Service on Draft Pipeline Decision”

  1. There must be some kind of policy within the FS and BLM that allows pipelines. I know both agencies have signed off on the Pacific connector pipeline going to Coos Bay, Oregon. A nice 100 mile long permanent clear cut for a foreign company in areas where a citizen can’t even buy a stick of firewood without a NEPA document. (And the answer is usually no.)
    Strange too how our local environmental groups seem to have little to say about it. I guess the sky only falls when you make a product from trees.

    • Howdy Bob,

      Do you have examples of where local environmental groups “seem to have little to say” about a “nice 100 mile long permanent clear cut for a foreign company?”

      I have a feeling that a project as you describe here certainly would’ve been on the radar screen of any local environmental and public health group. Thanks.

      • So are you asking to prove a negative? Bob, Please produce comments that weren’t made………
        Matthew you have plenty of time to surf the web, please look up Pacific Connector Pipeline or do you just consistently assign homework to everyone else? Or better yet get away from the computer, I’ll meet up with you, grab Bob and take a tour. Heck I’ll even buy you a beer after a day of looking at reality. I’ll make sure you get to see the good and bad on both sides. We can hit the pipeline route, take a look at the abuse of the Antiquities Act, see the results of the current Wilderness policies, look at the beauty resulting from the National Parks policy, all within a days drive. We could make it an exchange program, with you giving the tour next? ………… completely serious, no sarcasm.

        • Ok, so in one simple 2 second google search I found that, among others, Cascadia Wildlands has this post about the Pacific Connector Pipeline: https://www.cascwild.org/campaigns/combating-climate-change/no-pacific-connector-lng-pipeline/

          Bob made a comment that was basically claiming there are examples of where environmental groups “seem to have little to say” about a “nice 100 mile long permanent clear cut for a foreign company?”

          That claim struck me as being pretty darn false, since I see lots of environmental, social/environmental justice, indigenous rights and public heath groups all around the country having plenty to say about pipeline projects.

          So, I’m not asking Bob to prove a negative. I’m simply asking him to provide an example of where a “nice 100 mile long permanent clear cut for a foreign company” to build a pipeline was met with silence from the environmental community.

          Do you fail to understand that 353? I’m not assigning anyone homework. However, if some of you fellas (usually coming from a certain perspective) are going to be so ‘loose-lipped’ on this blog as to just toss out stuff that isn’t true…why, yes, I will hound you about it.

          P.S. I work on a computer, so yes, I do have plenty of time to…work on a computer.

          • What he said was there they have “little to say.” In all fairness if you haven’t been following the project, you’d probably have no reference, and honestly I haven’t stayed on top of this project, but here’s some background. – It sounds similar to what your post refers to.
            This route was originally designed to bring NG from the Port of Coos Bay and connect into the main “permanent” clear cut that runs down the west side of the Cascades from Washington to California. Now that the US has an abundance of NG it has changed to an export system, taking NG from the main line to a terminal at Coos Bay for export. This project has been met with heavy resistance from local residents and private landowners. Due to the terrain it will have pretty severe impacts on the management of many timber tracts that it crosses. It will also require boring under several streams and a river. The construction requires ditching on slopes of 70-110%, with equipment being tethered on the slope. It goes through across an area known as the Tyee Formation which is prone to landslides and has resulted in additional restrictions for timber harvesting, yet this permanent clear cut will be water-barred and mulched and left bare except for grass. There have been numerous public meetings during both the original plan and now the reverse plan, during these meetings (the ones I attended) there was little to – no complaints voiced by the numerous environmental groups, including the ones that you listed. They have written a few comments and opinion articles, but not much more. This compared to the amount of outcry and protests regarding timber sales. No they haven’t been silent, but they “seem to have little to say”. So nothing was tossed out that wasn’t true, but if there is stuff tossed out that isn’t true then it should definitely be pointed out and I have faith that you’ll be on top of it.

            A difference in perspective doesn’t always equate to not being true, just as opinion doesn’t always equate to fact.

            P.S. I hope you give the exchange idea some serious thought.

    • I am aware of conservation group comments and protests on the Pacific Gas Connector Pipeline spanning from 2007 to the present.

      FERC twice rejected this pipeline because there was not any proven market for the gas and thus no public benefit to outweigh the impacts to private property rights. The application resubmitted a modified project, but it has not been approved. I assume this pipeline through BLM and Forest Service lands will have to go through NEPA again.

      • And I worked on the Bull Mountain Pipeline, which was litigated by Earthjustice and I believe is currently constructed. Do others know more about the later history?

      • I believe that Pacific Connector was also approved once by FERC – the original proposal was to use the port facility in Coos Bay as an import facility and then use the pipeline to transport the LNG to a major north-south pipeline. But then, with all of the gas production in the US, they decided to make it an export facility and to use the pipeline to export the gas. I always thought the idea of importing the gas was kind of odd…I am not sure where the NEPA is at on this one. The NEPA was done initially, then it was determined that the FERC NEPA did not do the needed Forest Plan Amendments, so there was a separate NEPA for that, but I don’t know if that was ever completed or not. The effects of the pipeline won’t change, regardless of whether the port/pipeline is used to export or to import gas.

        • The problem was that California would never approve a LNG facility in a port. So they decided to ram-rod it down the throats of Oregonians. It’s crazy to think they could build a pipeline through all that country, without running into protected areas, difficult spots, and sensitive areas. Chances are, it was exports that the energy folks wanted, all along.

  2. “multiple use vs. ecological integrity” = rock & hard place. Energy development is a legitimate use of public lands…so is conserving the natural resources that we all enjoy. This is one project that has much national implications as local, so where do we draw line?

    There is no absolute answer and I submit that Wild Virginia’s opinion should not carry the majority of the conversation. Public lands cannot be “protect at all costs”. That is contrary to the multiple statutes that decree public use of their land. Whether this pipeline should have been discussed during the planning process is irrelevant – the EIS process run by FERC has been a public one. So, all perspectives have had the opportunity to be heard and now, are taking the opportunity to voice their perspectives through the pre-decision objections process. All the information will be before the decision maker, who has to consider all perspectives on this project. So, what information should be considered to tip the scale?

    We do not live in a “no effect” world.

    • Thanks for helping to focus discussion here on a key moral responsibility ignored by the captured agencies, their cheerleaders and apologists on NCFP:

      “We do not live in a ‘no effect’ world.”

      There are massive and compounding nonlinear effects being driven by USFS public policy decisions. They are being imposed on both the America public and entire planet.

      These are known in civil society as “social costs” and “externalities” and in the daily news as multi-billion dollar climate disruption disasters on daily display in Houston, Bangladesh, the American West, Alaska, and elsewhere across the biosphere.

      Unfortunately, the moral and cognitive disconnect on NCFP gets confined to treating the effects, (“Why we disagree about Fuel Treatments …”, rather than why we disagree about the moral consequences and cognitive dissonance perpetuating the causes of climate forcings.

      Until the discussion here focuses on causation (climate forcings driven by pipelines on public lands, and so many more policy decisions), thinning forests as a mean of addressing wildfires and other routinized climate disasters only adds to the hot air enveloping our planet.

      • Indeed, every decision is a compromise, even including ‘non-decisions’. Impacts (especially upon humans) continue, despite ‘protections’. We can sequester carbon, or we can let it burn. We can use other more damaging building materials, while forests die, rot and burn, adding more carbon to our upper atmosphere. We can mitigate human impacts…. or complain about them.

        It isn’t the Forest Service’s job make American weather more palatable. However, it is their job to keep forests healthy and productive. They are neither of those when they are dying, rotting and burning. I’m not in favor of preserving forests that have become carbon sources, instead of carbon sinks. I don’t think the general public is in favor of that, either.

        • The USFS and its parent agency the USDA, is morally obligated to measure the consequences of its agricultural management. Agriculture industry contributions represent 30 % of total US carbon emissions. Think about that Larry.

          Just because we have an amoral, climate denying president in the White House and self serving elected representatives dependent upon corporate campaign contributors; and just because #45 is bent on appointing a non scientist as chief scientist of the agency, doesn’t mean we have to stick our heads in the sand too.

          • According to the EPA, actually it’s about 24% of which 20% is offset by carbon sequestration globally. 12% of the total greenhouse gas output in the US is offset by agriculture, including forestry……..

      • While I am not a “Climate Change Denier”, I have serious doubts on the human impact on climate change. I also paid enough attention in science to know that methane (which is a much more serious green house gas) is produced during the decay of organic material, as well as the release of carbon. I also know that the increased rate of warming correlates directly with the use of instruments to measure temperature vs. using composition of ancient air samples, sediment, etc. which adds skepticism to the accuracy of data and the effects of humanity on climate change.
        All that being said I’m at a complete loss how addressing the release of billions of tons of carbon and methane, through organic litter build up and subsequently larger fires, is not addressing causation. How is it a moral disconnect to address the destruction of ancient forests by wildfire, due to lack of fuels treatment?
        The “climate forcings” you list are part of sustaining humanity. Every time we further restrict our economy, by restricting the production of natural resources, we only transfer that production to some other country that usually has a greater impact on the “causes of climate forcings”. It would seem to me that not addressing the effects of these routinized climate disasters, and instead thinking that you will affect the billion dollar climate disruption disasters, because you are civilized, is both arrogant and nescient.

        • Thank you for the opportunity to learn the meaning of “nescient.” That’s a great word, the definition of which I was previously nescient.

          Regarding your opener, ” While I am not a “Climate Change Denier”, I have serious doubts on the human impact on climate change.”

          Here’s the definition of the term from Wiki:

          “involves denial, dismissal, unwarranted doubt or contrarian views contradicting the scientific opinion on climate change, including the extent to which it is caused by humans…”

          The international climate science consensus, of course, on Anthropogenic origins of Climate Disruption is overwhelming — and overwhelmingly at odds with your opinion, which you are entitled.

          USDA/USFS policy however, again, represents 30% of GHG emissions in the US. These include substantial quantities of methane, and CO2, the latter of which has a far longer presence in the atmosphere, and therefore is regarded as far more dangerous to future generations than much the shorter-lived CH4. I do agree CH4 is particularly serious as northern latitudes are experiencing massive permafrost thawing.

          These facts are not merely my opinion but the product of scientific international consensus. The labels you apply to the representation of these facts are themselves demonstrably arrogant and nescient.

          Many countries are surpassing the US in reducing these emissions from agricultural practices including forest management. Many countries are already surpassing the US in replacing fossil fuels (including pipeline construction) with non-combustion renewable energy (wind, geothermal, solar, tidal, etc.)

          Regarding, “every time we further restrict our economy by restricting production of natural resources…” are precisely the claims which mirror the singular metric of financial losses to the recidivist environmental corporate criminals driving US policies, such as the multinational oil giants, and the fossil fuel-dependent industries.

          These alternatives to fossil fuels are already proving to be far cheaper sources of energy than the heavily subsidized fossil fuel industries and heavily subsidized fossil fuel dependent agricultural industries.

        • Methane is mostly produced through anaerobic decomposition which does not happen that much in a natural forest. However, lots of wood products end up in landfills and then break down anaerobically and produce a lot of methane. Point is, natural decay of logs in the forest is better than landfill decay.

          • How many billions of board feet are now decaying in the forest vs. landfills? By the USFS own estimates the rate of mortality is almost equal to the annual growth. Now I admit I haven’t done a landfill study, but I do know that most landfills put wood products into compost and mulch which would greatly decrease the anaerobic breakdown and mimic the natural decomp that you prefer.
            At the end of the day the amount of CO2 and CH4 is greater due to the lack of management on federal lands and the mismanagement of wildfires, but I’m guessing that your ok with it, as long as we don’t harvest.
            The protest of the pipeline is good, the use of electric cars is good and the use of fossil fuel is bad, right?

      • David, Your view of what is moral and others’ may well be different. Morality is a complex subject and not entirely unrelated to one’s metaphysical views. Like “what are moral consequences?” “by whom to whom?”.
        Climate as a narrative of capitalist-driven end of the world is one narrative, but not the only narrative that can be used to explain the facts as we know them.

    • Thanks, Tony. Plus there is no such thing as “ecological integrity”.

      This reminds me of a succinct statement from Judge Jackson on an ongoing coal case (more on that later):

      “Prior to granting consent, the Forest Service is authorized to impose conditions to protect
      forest resources. Id. To be sure, conservation is not the Forest Service’s sole mission. The
      Lands Council v. McNair, 537 F.3d 981, 990 (9th Cir. 2008) (“Congress has consistently
      acknowledged that the Forest Service must balance competing demands in managing National
      Forest System lands. Indeed, since Congress’ early regulation of the national forests, it has never
      been the case that the national forests were … to be set aside for non-use.”) (citing United States
      v. New Mexico, 438 U.S. 696, 716 n. 23 (1978)) (internal quotation marks omitted).”


      • ” Like “what are moral consequences?” “by whom to whom?”.

        First Sharon:
        I am referring to the moral consequences of national forest (mis)management policies which are determined within the national illusions of an extant constitutional republic. (Along with that, the shared, and inescapable moral consequences of the electorate of that republic, facing policy choices they have no meaningful say in, which determine the fates of succeeding generations of humans to say nothing of the present unprecedented Sixth Mass Extinction Event you are on record being unaware of.)

        ( In short, “We the people,” “get the democracy we deserve” { author[s] unknown}. )

        As a long term NCFP commenter, you and I are well aware of the stark contradictions and flagrant hypocrisies of our world views– unsurprisingly your hypocrisies being more clearly evident for me to perceive, than mine for you .

        And there exists no hypocrisy more clear than the issues of morality, ethics, and the plain language and intuitive understanding of the meaning of “ecological integrity.” (Denial — as a clear intent to dissemble, based upon your ‘legal’ citation you use — does not reverse the fundamental truths such practice of Denial targets.)

        For that, I will always be grateful for this NCFP forum. On the one hand, to illuminate the spectacle of Denial. On the other hand, I will be ever personally regretful for exposing the quid pro quo circumstances entangling your co-founder of NCFP. I really should have kept those financial entanglements to myself in order that I fully understand your co-founder and compatriot’s worldview.

        Having had the opportunity to hear Martin firsthand, debating (and subsequently demurring to his academic British Columbian contemporary’s prevailing thesis) in Southeast Alaska on the occasion of the first and last symposium in which we were treated with the presence of the (then), “Chief Scientist of The Nature Conservancy,” as keynote speaker rehashing his already-tired national spectacle, stridently ridiculing Thoreau, while extolling the virtues of collaboration with Dow Chemical Inc..)

        I’ve been left wanting more to work with.

        (Frankly, I was expecting worse from Martin, but was utterly gobsmacked by the magnitude of the then, TNC’s Chief Scientist’s pompous, narscisstitic audacity, to lower his keynote address to the quintessential nadir of cheap shots of defenseless and deceased environmental icons. Cheap shots, juxtaposed with Peter’s self evident religiously financial fervor and whoredom to recidivist environmental criminals such as Dow Chemical. Such inconvenient allegiances, no doubt assured his brief tenure with TNC.)

        In some respects I’ll miss TNC’s perfect pick of a prick, Dr. Peter Kareiva.

        But I digress…. on “ecological integrity.”

        Integrity in this context is, “the state of being whole and undivided”;
        Integrity is, “the state of being unified and unimpaired.”
        Lastly, integrity is defined (in relation to the agencies whose mission is to fulfill legal and ethical obligations to the social contract they were once charged with compliance to):
        “The quality of being honest and of strong moral principles”
        (Quoth the Raven, “Nevermore.”)

        That there no longer exists a defensible moral principle in agency directions at this late hour of the planet — that there no longer exists certainly in the previous, but indubitably, in the present administrations, moral, much less ecological integrity as a benchmark — there is little to conclude other than illustrating the most naked present state of amorality in government.

        This state of amorality exemplified through appointments of the most unqualified and antithetical personages in charge of, and/or inhabiting, the regulatory and management agencies manning its obligations to the social contract. How else would the EPA be presently conned by the steady hand of an attorney formerly commissioned to object to the moral principles of the public trust doctrine guiding agency direction?

        “We the People,” must now reckon with precisely the corporate coup d’ etat I described years ago here, and met with your denial. Regardless, we are now confronting the aftermath of Harvey savaging Houston, Irma barreling across the Caribbean towards Miami, and two nascent hurricanes queuing for their turns at precisely the climate carnage .precicted by international consensus, and you as outlier, vociferously denied.

        Again, “Denial, is more than just a river in Egypt.” (Author also unknown.”)

        That you claim moral fiber while renouncing ecological integrity seems a moral contradiction itself, while the American West is aflame.

        ‘Like “what are moral consequences?” “by whom to whom?’

        The moral consequences of human and ecological tragedies knowingly engineered, covered up, and unleashed by the corporate criminals of the USA are already self evident Sharon. Rest assured your denial will help condemn the planet and its myriad life forms to a living Hell long after we are dead and gone.

        • And this is why those of us who actually work in the field (the ones smarter than myself) avoid these blogs and avoid people who envision themselves sitting in a pipe smoke filled room, in their cushy leather seats, spouting dissertations, using ten dollar words for their two cents worth, that the rest of us wouldn’t give a penny for.

            • Except the characterization of me in “pipe smoke filled rooms” sitting on cushy leather seats. Also let the record show I never considered pricing words, nor whales, nor carbon, etc. etc. I am however guilty of familiarity with and citing peer reviewed research pertaining to the ecological, social, and economic impacts of the timber industry in Southeast Alaska, PNW and elsewhere.

              For the last three decades I’ve been standing at the wheel as owner/operator of a small boat (46 ft.) commercial fishing in Southeast Alaska (USFS Region 10) participating in several different fisheries for about half of the year. I’ve been holding limited entry permits in dungeness crab, halibut, diving for abalone and sea cucumbers, and both Northern and Southern herring roe on kelp pound fisheries.) I’ve done this ever since 1983 when I first realized I could be an independent small business owner in paradise.

              Since my livelihood is totally dependent upon sustainably harvesting the “fat of the land” (and sea) and that which can only be reliably provided by stable, thriving, and resilient marine, estuarine, riparian, and terrestrial ecosystems; and since my livelihood (along with that of the rest of the planet) is directly threatened by energy policies accelerating global warming, ocean acidification, ocean warming, ocean stratification, eutrophication, sea level rise, climate disruption, invasive species, algal blooms, toxic pollution, deregulated industrial extraction industries, political corruption and predatory neoliberal economic policies — i spend the other half of the year as an environmental advocate in defense of the ecological integrity (sorry Sharon) of the last of what remains at this late hour of the planet.

              As a subsistence-dependent, rural resident of the Alexander Archipelago (almost wholly designated as the Tongass National Forest), I live on an island in a town of 3000 and rely upon access to local deer, salmon, and other wild foods. We are surrounded by other islands subjected to the relentless USFS “intensive timber management” of the last 50 years, and the biological toll on the ecological integrity of our island ecosystems has been devastating.

              Recently, the Public Employees for Environmental Responsibility (PEER) issued a press release pointing out their findings of fact in a year old Washington Office investigation of two large timber sales conducted on two Ranger Districts here.

              Both Districts were in violation of serious breaches of timber sale management, administration, failures to provide basic documentation, and other measures to prevent timber theft and enforce contractual obligations in public interest. The WO concluded revenue losses (Rural Schools Act proceeds, and IRTC funding to accomplish “stewardship and restoration “) to local communities to be likely in excess of $4 million dollars. (Those losses occur in the midst of a $4 billion statewide fiscal budget crisis.)

              This PEER report featuring a local timber sale with nominal losses to the local community of $1.7 million was not covered in the local weekly newspaper nor local public radio.

              (Your absence in the recent discussion on NCFP of the PEER report, along with Sharon’s, and several others was duly noted.)

              In addition, Southeast Alaska residents are subjected to the unsustainable intensive timber management regimes of ANCSA’s corporatized Native Tribal entities. In addition, we are subjected to the unsustainable intensive timber management of State of Alaska’s Division of Forestry, the Alaska Mental Health Trust timber program, and the University of Alaska timberlands management on top of what has already been previously “harvested” from all those islands.

              Currently the “timber industry” of Southeast Alaska represents less than 1% of the regional economy.

              So I know more than just my way around the woods here. I am immersed in coastal temperate rainforest ecology, natural resources management and the associated political machinations bent on “bringing home the bacon” of US Taxpayer funded timber subsidies. The indirect subsidies known as externalities and unaccounted costs are routinely unreported, uncalculated, and ultimately incalculable.

              I also track agency actions and act when it is clear these agencies are not following S&Gs, FSH, NEPA, APA, CWA, ESA, etc. I know a captured agency when I see one, and gladly help force state and federal agencies to abide by constitutional mandates, laws enacted by Congress and upheld by the courts.

              I and others groundtruth and document the carnage across the archipelago.

              I research historical databases of what we lost, and compare these losses with the false claims of state, federal, Native Corporate, Mental Health Trust, and University claims of their “sustainable” ancient old growth timber extraction.

              Research clearly demonstrates even age management of coastal temperate rainforest destroys old growth structure, function, and composition, essential to an array of old growth dependent species. Research is clear: it will take 2 to 3 centuries (if ever) to fully recover from the effects of road building and clearcutting.

              “Restoration” here is an open fairy tale and a well known greenwashing tactic. “Stewardship” is nothing more than rebranding standard silviculture thinning treatments which often never occur due to lack of funding.

              • My apologies for missing the opportunity to comment on the discussion of the PEER review, sincerely. I have a very low tolerance for timber theft and non-compliance on sales, both public and private. I would’ve said “unethical practices”, but I’m afraid another can of worms would have been spilt. Regardless, I intend to go back and at least read the discussion.
                But since it was duly noted, it should also be noted that I unfortunately lose the ability to be on here for sometimes weeks at a time. I’d apologize for that except I do choose the woods over the desk whenever possible.
                The rest of your reply has me torn. While I appreciated learning your back ground and found it interesting, much of your rhetoric often shuts out the validity of what may also be included. But I’ll walk away with the positive of learning more about you. Thanks

        • David, I think one of our differences is that you are from the wet west and I am from the dry Interior. I used to see that when timber was king (now almost 40 years ago) and all the scientists were on the west side of Regions 5 and 6. You are from an area in which “leaving something alone” is a possibility.

          On the east dry sides, there was logging in the past for railroad ties, or charcoal or wood for building communities.I’m not making moral judgments about the miners of the past. Native Americans burned the forests and the prairies.
          Unlike Alaska, we inherited a managed landscape and a landscape that reflects past actions by humans. If you flew over my home state, you would see a pattern of dams that provide water for people. They were designed and built in the past, serve people today, and I suppose make the “ecosystem” have less “integrity.” I live in a place where the actions of people are everywhere (e.g.,jets over the Weminuche Wilderness). I live in a place where whether we do something, or don’t do something, the land won’t be the same as it was (if that’s what “integrity” is).

          I live in a place that produces and uses coal, natural gas, solar and wind energy. I live in a place full of military people and so I believe the most moral thing is to be energy independent. It’s about the environment, but it’s not all about the environment. Even Germany is opening new coal mines- are they also dominated by evil US corporations? .In the energy transition, which is happening, there are trade-offs.

          Finally, there are different schools of thought on the hurricanes and climate change, and especially on current ones, e.g.

          It is premature to conclude that human activities–and particularly greenhouse gas emissions that cause global warming–have already had a detectable impact on Atlantic hurricane or global tropical cyclone activity. That said, human activities may have already caused changes that are not yet detectable due to the small magnitude of the changes or observational limitations, or are not yet confidently modeled (e.g., aerosol effects on regional climate)..


          As to “ecological integrity” here are the words of NEPA

          To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation;

          If “integrity” is “do nothing” then we have a recipe for infinite dissatisfaction (tending toward despair) as populations increase and spread. If we have a goal of “productive and enjoyable harmony” then we enter together on a discussion, as fellow humans, of the pros and cons of different courses of action.

          As to my morality, that’s between me and God, spirit guides, etc. Many religious teachings (Jesus, Hillel, Buddha) say that judging others’ morality in that sense is not a good idea. So is it immoral for you to judge my morality? Moral judgments tend to get into an eddy of recriminations, which tends not to be productive dialogue, in my experience.

  3. Having worked on a gas pipeline project for the Forest Service awhile back, I think it was the Energy Policy Act of 2005 that instituted some requirements for federal agencies when it comes to electricity transmission lines and energy pipelines if FERC approves the project. A lot of folks on the ranger districts were stunned that we had to allow that pipeline project, especially given the proposed location in places where we would have had a lot of difficulty proposing a timber sale, for example. We were able to work with the pipeline company to reroute the pipeline around some particularly sensitive areas (even though it would cost them significantly more money), and the company was very generous in providing funds for mitigation measures to do restoration work beyond the pipeline corridor and they wanted the Forest Service to start that mitigation work as soon as construction started. To me, the worst part is that the pipelines only have a useful life of about 30 years and then they are usually abandoned and it is very rare for there to be a requirement for the pipeline to be removed. The pipes eventually rust through and can cause problems with water drainage, etc. To go through all of that effort and all of that construction to build something that will only last 30 years doesn’t seem to be a very good “investment” as far as I am concerned, and the environmental effects of the pipe deteriorating and causing other problems make some of post-construction mitigation activities kind of useless.

  4. Interesting (to me) planning issues. It’s a rule of thumb (if not a requirement of NEPA) that an alternative should be considered that doesn’t require amending the forest plan. This would probably look a lot like the “not on national forest land” alternative they refused to consider in detail (which also seems necessary under special use requirements). Together those could be a NEPA problem.

    They also treat it as a “project-specific” forest plan amendment, but it in effect permanently changes the management of this corridor. Instead of creating “exceptions” to 14 individual “forest-wide” standards it creates a new management area. That may require more analysis. In particular in relation to ESA-listed species, a standard preventing adverse effects would no longer apply. The FS claims the 2012 planning rule requirements for listed species are not “directly related” to this amendment (if they were, that would require additional analysis). Dropping this standard could also trigger new consultation at the forest plan level. While it looks like Fish and Wildlife Service project consultation is occurring with FERC on the project, but there is no consultation with the Forest Service on the plan amendments.

    As far as the decision goes, it is interesting to compare it to one where the FS denied a proposal to build a ski area because that was inconsistent with forest plan standards. Maybe there are some other laws that apply to energy, but the only specific executive orders cited focus on speeding up the process, not weighting the scale towards development. Another difference might just be who got elected and what political power the proponent has (but that wasn’t mentioned in the Record of Decision).

  5. I just took these (and related) plaintiff’s statements at face value: “Virtually all of the previous submissions and comments by the USFS on the project were generated at the local level by GWNF and MNF staff… For whatever reason, the Forest Service has suddenly dropped its formerly responsible approach to project review…” It’s a familiar pattern from the old days (like when timber ASQ was a top-down decision).


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