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Bush to Gut Northwest Forest Plan: Send in your comments by November 20th

As the first step in the Bush Administration's plan to gut the Northwest Forest Plan, the Administration is proposing to dispense of requirements to survey for and protect rare and sensitive species before logging.
The Survey and Manage Requirements are the bare bones of minimal protection afforded species under the Northwest Forest Plan.
Bush to Gut Northwest Forest Plan: Send in your comments by November 20th
After being sued by environmentalist for neglecting to implement the surveys, the Forest Service has already drastically revised the plan twice, severerly limiting the number of species to be surveyed and protected. Now the Bush Administration thinks it's a good idea to get rid of the requirment all together.
Until November 20th, the Forest Service and Bureau of Land Management (BLM) are accepting "scoping" comments to help define "issues and alternatives" for their proposal. The Survey and Manage protections are there as a safety net to keep species at risk for extinction from reaching the point where they would need to be offically listed as "Endangered." Furthermore, these are species endemic to mature and old growth forests. Already, 90% of the public lands logging is targetting mature and old growth forests. Do we really need to increase the amount and speed at which our last remaining native forests are logged?
The protections that we currently have are barely being implemented. After being sued by environmentalists for neglecting to implement the required surveys, the Forest Service has already drastically revised the plan twice, limiting severly the number of species to be surveyed for and protected. Despite these inadequacies, our last native forests have benefited from Survey and Manage protections. The majority of the old growth being targeted in the Clark Timber Sale in the Willamette National Forest was dropped after tree-sitters in the area discovered several red tree vole nests. At the Solo timber sale, which will clear-cut 216 acres of old growth in the Mt. Hood National Forest, a buffer was placed around the old growth specklebelly lichen that activists found. It is one of the rarest lichens in the US, and if the Bush administration's plan goes through the small buffer it is receiving at Solo will be removed all together. Native forest logging and habitat fragmentation on public lands in Oregon, Washington and Northern California will increase if these protections are removed. We need to respond to this threat by loudly and clearly demanding an increase in protection for mature and old growth forests. We must remember that the removal of these protections are only one step in the Bush Administration's larger plan to streamline the decmination of the Northwest's native forests.

The Bush Administration's plan to remove these protections are very suspect. Mark Rey, Bush's Under Secretary of Natural Resources and the Environment who helped craft the proposal is a former logging industry lobbyist. The proposed removal is the result of a closed-door deal between the Bush administration and logging corporations involving a meritless lawsuit challenging certain wildlife protections required by the Northwest Forest Plan. The "Survey and Manage" procedures are only needed because the Forest Service and Bureau of Land Management insist on continuing to log the last of our native forests.

This is only the one step of the Bush Administration's plan to gut the Northwest Forest Plan. Please comment to oppose the removal of these species protections, and demand the inclusion of an alternative that would permanently protect the last mature and old growth forests of the Pacific Northwest. Let the Bush administration know that the time has come to end the commercial logging of our public lands.



Include a Citizen's Alterative in the range of alternatives that would permanently protect all mature and old growth forests from commercial harvest on public lands governed by the Northwest Forest Plan and instead focus funds and resources on ecologically-based scientific restoration to protect and restore forest ecosystems, including obliterating unnecessary roads.
Address the biological impact to species of increased targeting of old growth forest stands for public lands logging. In September 2001, the Northwest Ecosystem Office received a letter from several prominent scientists clearly stating the need to end logging of all mature and old growth forests on public lands now. The reasons for this included the need to provide habitat for species with small home ranges (precisely the type of species inadequately protected by the current Survey and Manage regulations). Removing the few protections we have for these types of species flies in the face of current science. How will removing the protections for the Survey and Manage species impact the viability of these species? How will it impact the viability for other species which rely on the Survey and Manage protections as "indicator species" to provide their own protection?
Address the economic cost of increased targeting of mature and old growth forest stands for public lands logging. In 1996, the Forest Service issued a report that predicts that by 2000, recreation, hunting and fishing on National Forests will contribute more than 30 times more to the national economy than the timber sale program. Increased logging of mature and old growth forests will harm the peoples and communities that depend on healthy forest ecosystems for their livelihoods while studies have shown that increased logging levels do not affect timber employment. Repeatedly we have seen that while timber harvest levels increase, timber jobs are lost do to mechanization. The majority of the Northwest's drinking water supply comes from sources that originate in our National Forests. Increased harvesting of mature and old growth forests will harm our drinking water supplies. Please include the monetary value of clean drinking water when evaluating the economic cost of removing the Survey and Manage procedures and when you evaluate the economic benefit of a Citizen's Alternative protecting mature and old growth forests. Increased logging of mature and old growth forests, as removing the Survey and Manage protocols would lead to, will increase the amount of money our national forests lose. A recent report by Tax Payers for Common Sense found that the top money loosing national forests are the same forests we know to be doing the most logging of mature and old growth forests. The only National Forest in the country making money is the Siuslaw National Forest which does not log mature and old growth forests, concentrating on restoration and plantation harvests.
How can the Northwest Forest Plan be "scientifically credible and legally defensible" if the key Survey and Manage protections, already twice reduced, are removed all together? The Survey and Manage protections are there as a safety net to keep species at risk for extinction from reaching the point where they would need to be officially listed as "Endangered." How will these species be adequately protected without these requirements? For of these species we still lack adequate knowledge about how few remain and what their precise habitat means are. How will we gather this information? What interim protections will be provided until this knowledge is found?

SEIS for Survey and Manage
P.O. Box 2965
Portland, Oregon 97208
Or email:  Dick_Prather@blm.gov

It is also important to cc this information to your Senators and Representatives.

I am writing to submit official scoping comments on the proposed changes to the Survey and Manage Requirements under the Northwest Forest Plan. PLEASE INCLUDE A CITIZEN'S ALTERNATIVE THAT WOULD PERMANENTLY PROTECT ALL MATURE AND OLD GROWTH FORESTS on public lands covered in the Northwest Forest Plan. If all mature and old growth forests are not permanently protected, please expand the survey and manage requirements (instead of removing them) to adequately protect for species viability, especially on those species about whom we know little.


homepage: homepage: http://www.tree-sit.org/article.php?sid=163&mode=flat&order=0&thold=-1
address: address: SEIS for Survey and Manage ,P.O. Box 2965,Portland, Oregon 97208

gifford pinchot task force sample comment 17.Nov.2002 16:35


Another sample comment can be found at:  http://gptaskforce.org/article.php?id=114

Forgive me, but... 17.Nov.2002 17:52

What exactly is the point?

Consider this, from today's New York Times:


Flooded With Comments, Officials Plug Their Ears


OVER the last several years, the Interior Department has proposed a number of controversial ideas, like reintroducing wolves in Yellowstone, that have generated lots of mail during a public comment period. But few proposals have flooded the department with more mail paper and electronic than the one by the Bush administration to keep snowmobiles in Yellowstone and Grand Teton National Parks.

Last week, Interior Department officials said they had received 360,000 comments on the matter, the most ever on any question related to the national parks. The verdict? Ban the machines. Fully 80 percent of the writers wanted snowmobiles barred from the parks, just as the Clinton administration had proposed.

Yet even as officials of the National Park Service acknowledged the results of the comment period, they proposed to do just the opposite. They not only would allow the use of snowmobiles to continue in Yellowstone and Grand Teton and on a part of the John D. Rockefeller Jr. Memorial Parkway that connects them, but they would also allow for a 35 percent increase in the numbers, up to 1,100 a day from an average of 840 a day.

How did such overwhelming opposition to snowmobiles result in such a snowmobile-friendly decision? Officials said that there would be more snowmobiles, but that they would be newer, cleaner and quieter and that therefore any environmental damage would be reduced.

Beyond that, officials say the sheer volume of public comment is not a determining factor. "It was not a vote," said Steve Iobst, assistant superintendent of Grand Teton. The point of the comment period, he said, is to yield substantive, informed letters that alert park officials to something they might have missed in reaching their conclusion.

In fact, the public comment period has become a widely discredited measure of public sentiment because it has been susceptible to what critics call AstroTurf campaigns, the opposite of real grass-roots efforts, in which advocacy groups encourage their members to sign their names on form letters.

This is especially true since the emergence of e-mail. Mr. Iobst said that over the three-day Memorial Day weekend alone, the Park Service received 45,000 e-mail messages on snowmobiles. He said the agency considered those comments in its decision, "but not at face value."

A court decision in 1987 gave officials clearance to ignore mass mailings. The United States Court of Appeals for the District of Columbia, in a ruling written by then Judge Kenneth W. Starr, said that a determination of a clean-water issue should not be based on the number of comments, most urging the Environmental Protection Agency to allow them to discharge pollutants into the water.

"The substantial-evidence standard has never been taken to mean that an agency rule-making is a democratic process by which the majority of commenters prevail by sheer weight of numbers," Judge Starr wrote.

Has a comment period ever truly influenced a decision? Chris Wood, a senior adviser to the Forest Service chief in the Clinton administration, said that typical agency behavior is to "develop the plan you want, announce a public comment period and then do what you want to do."

But, he said, the Forest Service actually relied on public comment when it developed its "roadless rule," intended to protect 58 million acres of undeveloped national forest from most commercial logging and road building. It drew 1.6 million comments, the most ever in the history of federal rule-making. Almost all the comments 95 percent supported the protections but wanted the plan to go even further, which it eventually did.

But the Bush administration delayed putting the rule into effect and sought more comments, receiving 726,000. Of those, it said that only 52,000, or 7 percent, were "original," meaning that the administration discounted 93 percent of the comments. The rule is now being challenged in court.

Bush administration officials still say they value public opinion. In a speech in July, John Graham, head of the office of regulatory affairs in the Office of Management and Budget, said he was actively seeking public comment on various regulations and making an electronic comment form available.

Although the snowmobilers won their battle, the groups representing them say that the public comment period should be abolished. "What this outcome shows is that these huge hate-mail campaigns are not effective now and won't be in the future," said Clark Collins, executive director of the Blue Ribbon Coalition, an industry-backed lobbying group based in Idaho.

If the public comment periods ceased, he said, both sides could save a lot of time.



In sum, why bother? All of your beautiful heartfelt courage will be washed down the drain, courtesy of the neo-Star Court.

"Take care," wrote de Gasparin in answer, "the representatives of the exact sciences are on their way to become . . . the Inquisitors of our days. . . . Facts are stronger than Academies. Rejected, denied, mocked, they nevertheless are facts, and do exist."

My point being, know what is right, but also know how the Academe is structured. (For insight on THAT, consider also, from today's Times.


Debate Club's `Secret Handshakes' Turn Into Public Grins

ASHINGTON, Nov. 16 In the early days of the Bush administration, allegiance to the conservative debate club known as the Federalist Society was declared almost in a whisper.

A nominee for a top Justice Department post, questioned by a Democratic senator last year about his membership in the society, professed that he had no idea what its politics were.

Judicial nominees, meanwhile, scrambled to disavow positions they had taken before the society. As critics attacked its influence in the White House, members complained of McCarthyite smear tactics.

But if membership in the Federalist Society was once a source of controversy, this week it became cause for a party, as several thousand members at the group's 20th anniversary conference reveled in its growing influence in the Bush administration in the wake of the Republican-swept elections.

A three-day conference that concluded today at the Mayflower Hotel in Washington looked at times less like a private law conference than a Justice Department retreat.

No fewer than 12 senior Justice Department officials including John Ashcroft himself and half of his 10 top-ranking assistant attorneys general gave speeches and attended seminars.

Law professors, lawyers, lobbyists and society members from around the country shared coffee and White House-shaped cakes with cabinet members, and talked legal shop with conservative icons like Justice Antonin Scalia; Kenneth W. Starr, the Whitewater prosecutor; and former Judge Robert Bork.

Despite a budget of $3.2 million and nearly 30,000 members, the Federalist Society does not stake out official positions or endorse candidates. It does not bring lawsuits or file legal briefs. What it does, organizers say, is promote dialogue about constitutional principles and the law. Along the way, it has attracted conservative admirers throughout the Bush administration and the federal judiciary.

That is what has the society's critics so worried, particularly with the prospect of several openings on the Supreme Court soon.

Nadine Strossen, president of the American Civil Liberties Union, sparred with Assistant Attorney General Michael Chertoff and other conservative lawyers at a Federalist Society debate on Friday on the impact of the war on terrorism on American civil liberties. Ms. Strossen, invited as a contrarian liberal voice, was in the clear minority.

"The society has done a lot to advance public debate," she said. "But it's very dispiriting to me as a civil libertarian that the very conservative, pro-government wing has really taken over not just the group but, in a way, our justice system."

Federalist Society members, once ticklish about such attacks, seemed to delight in them at this week's conference, as Mr. Ashcroft, Solicitor General Theodore B. Olson and others lampooned the liberal voices who dread the group's influence.

"There are some who would paint the Federalist Society as a nefarious underground cabal with secret handshakes and blood oaths," Mr. Ashcroft deadpanned. Then, as his audience cackled, he added, "I called you all here because I want to know who squealed."

Another theme at the conference was a sense of wonderment over how far the group had come.

The Federalist Society started 20 years ago as a loosely cobbled network of conservative groups rebelling against what were seen as ultraliberal student and faculty bodies at places like Yale Law School, recalled Mr. Bork, a former law professor.

Today, the society has 140 law school chapters and 60 lawyers' chapters, and membership has grown by 5,000 people in the last year, said the society's president, Eugene Meyer.

"Who would have thought 20 years ago," Justice Scalia said at the society's black-tie gala on Thursday, "that that little organization of students at a couple of law schools would have evolved today to a power of such proportions" that mere membership could endanger a judicial nomination?

Pausing, he said, "It could have been a grand flop."



So, what to do?

This is an oligrachy pure and simple.

Why did America ever think we could form a more perfect union than has ever happened before? Such sweet deluded souls.

Again, what to do?

let them eat cake 18.Nov.2002 19:53


they are overreaching. the dog will have his day.

tough times tough measures 21.Nov.2002 00:51


the corporate monster you are up against, will gut that entire area as long as it profits from it. It will not hurt the great beauties and if random and done right no one is hurt. Fair warning and stand fast.
70% of this countrys great forest was felled with axes, before the chain saw. only Mindless greed would destroy something that would take 1,000 years to replace.