I said here: “NEPA documents have started saying that cutting down trees is beneficial for the environment because it produces funding to replace culverts and the like. That may not be a defensible effects analysis.”
Sharon asked: “I don’t see why people need to say that at all in NEPA docs. Do you have examples?”
I do. I’ll provide two here that I have encountered with forest plan revisions.
The Flathead revision FEIS provided very little useful information about aquatic effects, but it revealed this as part of their logic (p. 131, but their point seems to be that it doesn’t matter):
Although alternative D proposes more timber harvest and the potential to generate more Knutsen-Vandenberg revenue for restoration actions such as best management practices, road decommissioning, and culvert replacements that would benefit aquatics, it is anticipated that money would still be available from partnerships and appropriated watershed dollars to implement restoration projects regardless of how much money is generated from timber sales.
The Helena-Lewis and Clark was more to the point that it DOES matter in their revision DEIS (p. 71):
Alternative E would result in the highest volume of timber production and therefore have the potential to generate more money from timber receipts for restoration projects for watershed and fisheries. If more money is available from alternative E then there would be more short-term impacts from restoration projects but there would be more long-term gains
I think I have seen other better examples for projects that have stated that the proposed action is better for the environment than no action because the timber sale revenues will be used for restoration activities. Maybe I’ll run across more examples, but I wanted to post this now so that others could contribute examples they are aware of.
So no, I don’t think they should include this in NEPA documents. The problem is that effects disclosed in an EIS must be reasonably foreseeable. If the funding process works in a way that makes money available but does not commit it to a specific use, then any effects are not reasonably foreseeable. This is more obvious in the forest planning context because restoration is only a “potential” (to quote both examples above). The result of including this kind of poorly substantiated assumption in an effects analysis is to distort the comparison of alternatives and to provide less meaningful information for the decision-maker and the public. This tends to subvert the core purpose of NEPA.