W.I.S.E. Objections to the RR-SNF Let It Burn Plan
In March of 2008, the Rogue River-Siskiyou National Forest issued a notice of intent to produce a Fire Use Amendment Environmental Assessment [here]. They requested scoping comments to be submitted within 30 calendar days.
The Western Institute for Study of the Environment responded in the time allotted with a 170-page discussion [here] of the pertinent issues accompanied by 450 MB of appendices containing references.
For one and a half years the RR-SNF remained silent about this process. They did not even acknowledge receipt of our comments. Then, 17 months later, the Fire Use Amendment EA [here] was distributed with a 30-day time limit (again) for submitting official objections.
While not expressly stated, the reason that a 17-member Interdisciplinary Team spent a year and a half preparing the EA was because of the size, breadth and depth of the W.I.S.E. scoping comments.
Yet at no time during that year-and a half did the RR-SNF contact us to discuss our concerns, to ask clarifying questions, to invite our expert consultation, to hold workshops, or to encourage our collaboration in any manner.
Instead, a year and a half later and unexpectedly, we were given very few days to review an EA over 100 pages long.
We have complied. Our official Objections are [here].
In the short Objection time window we were unable to address in detail the probable significant impacts of the Proposed Action on flora, fauna, historical and cultural resources, watersheds and water quality, airsheds and air quality, recreation and scenery, and other forest resources and values. But we did address the inadequacy of the RR-SNF EA and again requested that a full Environmental Impact Statement (EIS) be prepared.
If the RR-SNF had acted in a more open and welcoming manner, those issues could have been explored in greater depth over the last year and a half. Instead, the RR-SNF chose to shun our involvement.
Our motives throughout this process have been to improve the stewardship of our public forests and landscapes and to avert poor management and poor planning that will inevitably lead to more Biscuit Fires. We hope the RR-SNF shares those motivations.
by Bob Zybach
by Ned
I agree with Zybach. A great effort. I have to believe that the RR-SNF produced this EA to test the National AMR/WFU policy and how to amend existing Forest Plans. Your effort illustrates that the AMR/WFU fire policy violates NEPA and other Acts including NFMA.
If the Forest Service is so arrogant that they intend to ignore your objections, we should proceed to appeal and litigate. The cost of litigation should be covered by the Equal Access to Justice Act. I can’t believe that the Forest Service would be so foolish that they would believe they could prevail after reading your objections. Certainly they should find that a significant impact results from AMR/WFU; as they should have found in a decision with the EA. Hopefully that will be precedent setting.
HEY!! Maybe I could offer up my forestry services at $120 per hour to help collect data and evidence! I could also offer up my photographic services for $800 per picture, too!!
I’m still compiling a collection of forestry photos from my 20+ years, to send to Mike for general uses and enlightenment. I did find a program to set resolution to a group of photos. I’ll burn them on to a DVD.
Mike:
I have just finished reading the entire 66-page W.I.S.E. summary of objections to the RR-SNF “Let it Burn” Plan, and must commend you and Dr. Brenner for an excellent and well thought-out response.
Your specific and detailed descriptions of the plan’s shortcomings — and your specific objections to those failures — should be required reading for other forest and wildfire managers considering adoption of “WFU” strategies in the management of public resources.
I was particularly taken with your analysis of the apparent disregard of NEPA regulations in the development of this EA,especially as they related to public participation in the planning process and to the apparent condescending disregard of known cost-plus-loss damages attributed to large-scale wildfire events.
It is difficult to tell if the RR-SNF staff who developed this document are genuinely ignorant of public law and fire effects in these regards, or if some form of institutional arrogance is at play here. In either instance, both you and Dr. Brenner have provided a real service for the RR-SNF staff members and US taxpayers with the preparation of this document.
Congratulations! I hope your efforts are successful.