Objections to a Project on the Chattahoochee-Oconee National Forests in Georgia

How about a break from looking at Western US issues? A News article here has links to several documents….


The plan’s stated goal is to: “Create, restore and maintain ecosystems that are more resilient to natural disturbances.”

In the final draft of the plan, released Oct. 26, forest supervisor Edward Hunter Jr. wrote, “The reality facing our forests is that without active management on the ground to increase the resiliency of these ecosystems and difficult decisions for the sustainability of our recreation program, these public lands and all their inhabitants are at severe risk.” 

But Georgia ForestWatch, the Chattooga Conservancy, Georgia Chapter of the Sierra Club, and the Wilderness Society filed a joint 25-page objection to the plan on Dec. 13. The objection states the plan lacks sufficient opportunities for public participation, circumvents future National Environmental Protection Agency review and lacks clarity on how the plan will be implemented in specific areas. The plan does not properly account for carbon emissions and carbon storage, the objection states, and the plan would lead to an increase in carbon emissions in the near term. 

The final environmental assessment, “unlawfully fails to identify the actions that will receive additional review and the actions that will not,” wrote J.D. McCrary executive director of ForestWatch in a statement to The Times. 

“(The final assessment) does not quantify the project’s likely impact on greenhouse gas emissions. Given the threat posed by climate change and the need to reduce emissions in the near term, it is important for the Forest Service to understand the impact of its actions on carbon emissions and sequestration.”

4 thoughts on “Objections to a Project on the Chattahoochee-Oconee National Forests in Georgia”

  1. Without looking at it, it sounds like a condition-based management project. Which seems to me, if true, it’s all about how the public will be involved in the site-specific proposals.

    FWIW, after the controversy about the similar approach on the LAVA project on the Med-Bow, I haven’t seen any specific complaints about the implementation.

  2. With regard to LaVA, I don’t think there’s been any implementation. Here’s an update from September, after the Mullen Fire: https://www.wyomingnews.com/laramieboomerang/news/mullen-fire-didnt-burn-through-usfs-long-term-plans/article_b48c870f-48b3-5938-8870-09fdc96c12be.html

    Here is the post-fire “Supplemental Information Report: “https://www.fs.usda.gov/nfs/11558/www/nepa/106251_FSPLT3_5660013.pdf

    According to the article, here is what is happening AFTER the “SIR” said “there will be no significant effects that were not previously considered resulting from the implementation of the LaVA Project.”

    “Locations called “Linx Security Areas” for the Canada Lynx, federally listed as a threatened species, were affected by the fire. Because of that, new timber treatments proposed in LaVA that create additional unsuitable habitat “will be unacceptable in the Douglas and French Creek Lynx Analysis Units because the Mullen Fire created greater than 30% unsuitable habitat” for those animals.

    Before treatments that remove live trees occur in the Snowy Range Lynx Linkage Area, evaluations of the vegetation must take place to determine if it is needed for connectivity or opportunistic foraging consistent with protecting Canada lynx, the report says.

    The fire also caused localized change in conditions for timber resources within the fire perimeter, burned more than a third of nine watersheds in the area and affected soil conditions within the LaVA project area.

    The new report guides the Forest Service to prioritize treatments within the Mullen Fire footprint by overlaying the needs for watersheds, wildlife and other resources.”

    After they figure out exactly what they are going to do, I assume they will have to prepare another new “SIR” to address all the new information, but expect they will again conclude no new NEPA process is needed to look at or disclose the effects of the alternatives they considered (meaning there would be no appeal rights, and any challenge would have to go directly to court). At that point we could talk about how happy everyone is with the implementation.

  3. The Foothills Landscape Project is a massive forest management plan proposed by the U.S. Forest Service in the Chattahoochee National Forest and is the single most important Forest Service proposal in Georgia in the last 15 years. Stretching over 157,000 acres (almost double the size of the city of Atlanta), the project proposes the use of logging, herbicides, and prescribed fire to manage forests while also altering trails and roads. It is still unclear how and when input on specific actions will be considered by organizations like Georgia ForestWatch (GAFW) and concerned citizens.

    Public input by organizations like GAFW, and that of concerned citizens, is crucial to both our mission and the appropriate management of our national forests.

    Review of Timeline:
    October 2017 – Forest Service initial proposal of the Foothills Landscape Project released
    December 2017 – Public comments due on the initial project plan (Scoping notice)
    December 2019 – First Programmatic EA released
    January 2020 – Public comments due on first Programmatic EA
    July 2021 – Revised Programmatic Environmental Assessment released
    August 2021 – Public comments due on the Revised Programmatic EA
    October 2021 – Draft Decision Notice released
    December 13, 2021 – Objections due on the Draft Decision Notice

    Georgia ForestWatch is committed to thoughtful consideration of this immense project and its lasting impacts, yet concerns remain that the Foothills Landscape Project is still too vague to appropriately address when and where there will be opportunity for public input. GAFW, and many partner organizations, overwhelmingly believe that each distinct action must receive the proper analysis and input by the community mandated by the National Environmental Policy Act (NEPA).

    This is why Georgia ForestWatch and partners: Southern Environmental Law Center, Georgia Chapter of the Sierra Club, Chattooga Conservancy, and The Wilderness Society filed a formal objection to the Foothills Decision Notice. Our concerns, previously raised at every step in the process, are threefold.

    The Final Programmatic Environmental Assessment (EA) unlawfully fails to identify the actions that will receive additional review and the actions that will not. The Forest Service’s Final Environmental Assessment seeks to use a programmatic review for the project, in which an entire suite of actions is broadly reviewed now and, in the future, the agency commits to conduct further environmental reviews of individual actions. However, the Final EA does not specify which actions have been fully evaluated and will not receive additional review under this programmatic approach.

    The Final EA improperly defers key decisions to the collaborative to be made without NEPA review. The Final EA defers key decisions into the future, to be made based on input from a collaborative group made up of forest stakeholders. We agree that getting input from stakeholders is important, but the environmental effects of the collaborative group’s recommendations also need to be evaluated. These decisions should not be made after the environmental review is completed.

    The Final EA fails to properly consider the climate impacts of the Foothills Landscape Project. The Final EA does not quantify the project’s likely impact on greenhouse gas emissions. Given the threat posed by climate change and the need to reduce emissions in the near term, it is important for the Forest Service to understand the impact of its actions on carbon emissions and sequestration.

    J.D. McCrary
    GAFW Executive Director


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