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UPDATE: Allegheny NF Mortality II Project
Distributed to TAP-RESOURCES, a free Internet Distribution List
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TAXPAYER ASSETS PROJECT - NATURAL RESOURCES POLICY ADVISORY
(please distribute freely)
TAP-RESOURCES
August 21, 1996
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UPDATE - Public comment period extended for the Mortality II
timber sale project on the Allegheny National Forest
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The closure of the comment period for the Mortality II
draft Environmental Assessment (EA) has been extended to
Monday, September 2, 1996. It had been scheduled to end on
August 19. There is still time for you to write to the
project team leader, Carl Leland, and ANF Supervisor John
Palmer. The Allegheny Defense Project was very fortunate to
have successfully requested this extension. Please help ADP
make the most of it by taking some time to write comments.
Below is a sample letter. Following that is the original
TAP-Resources post of August 2, concerning the Mortality
II project.
If you need more information, please contact the Allegheny
Defense Project:
Jim Kleissler
Susan Curry
ADP
P.O. Box 245
Clarion, PA 16214
(814) 226-5224
(814) 678-2404 fax
<mortality@essential.org>
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SAMPLE LETTER
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Below is a sample letter that you can use verbatim or as a guide
for writing your own letter. Whichever option you choose, DO IT
RIGHT AWAY. The comment period closes on Monday, September 2.
Any comments the Forest Service receives that are postmarked after
Sept. 2 may be ignored completely. You can also phone in your
comments. If you cannot find the time to do any of these, please
at least send a short note saying that you "oppose the Mortality II
timber sale and demand further study of the sale in an
Environmental Impact Statement."
Following the sample letter is a short e-mail post with background
information and some other contact information. If you have not
carefully read the original TAP-Resources post on the Mortality II
project, which was titled "Allegheny Nat'l. Forest Under Attack,"
you should do so now. The SAMPLE LETTER WILL BE MUCH EASIER TO
UNDERSTAND IF YOU FIRST READ THIS "BACKGROUND INFO" SECTION.
Send your letter to:
USDA Forest Service
Attn: Carl Leland
RD #1, Box 28A
Ridgway, PA 15853
814/776-6172 voice
814/772-7387 fax
If possible, send a cc: copy of your letter to:
John Palmer
Forest Supervisor
P.O. Box 847
Warren, PA 16365
814/723-5150 voice
814/726-1465 fax
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SAMPLE LETTER
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Your name
Your address
Carl Leland
Mortality II Team Leader
RD #1, Box 28A
Ridgway, PA 15853
August ??, 1996
Dear Sir:
I am writing to comment on the proposed timber sale known
as "Mortality II." Please consider my comments in your review of
the project draft Environmental Assessment (EA), respond to them
as required by law, and include these comments and your responses
in the public record.
I find the draft EA to be inadequate and the Mortality II
project unacceptable for the following reasons:
1) This sale is to yield over 30 million board feet (MMBF) of
timber, which is more than half the volume of timber cut on the
ANF in all of Fiscal Year 1995, which was approximately 55 MMBF.
It will directly impact over 5,000 acres of the ANF. The
environmental impact of this sale will clearly be significant
and cannot be adequately addressed in an Environmental
Assessment. The sheer size and potential impact of this project
demand that it be evaluated in an Environmental Impact Statement.
2) Because of the size of this project and the amount of
important information left out of the EA (noted only as being
part of the project file), no member of the public can fully
understand and adequately comment on this project based on
the information contained in the draft EA. That being the case,
the entire purpose of public comment under NEPA, to aid in sound
decision making by the agency, is subverted.
3) The "tiering" of the draft EA to the final Mortality I EA is
illogical and unsound. The stands to be cut in the Mortality II
project were not analyzed using on-the-ground field surveys until
after the analyses for the Mortality I final EA were completed.
Therefore, the Mortality I EA cannot be used to characterize or
analyze the conditions of the stands to be cut in the Mortality II
project. This inappropriate tiering does not conform to the legal
criteria for tiering in the Code of Federal Regulations at 40 CFR
Part 1508.28. This legal definition of tiering explicitly requires
that the document to which another document is tiered be an EIS.
4) The EA shows that the ANF is deficient in old growth areas, yet
previously protected old growth stands will be subject to thinning
and clearcutting. While the successful implementation of the
landscape corridor approach to old growth management adopted in May
of 1995 might someday produce sufficient old growth to meet Forest
Plan guidlelines, much of the newly designated old growth areas are
not old growth stands at this time. Until Forest Plan guidelines for
old growth are met for all Management Areas, logging existing old
growth should not even be considered.
5) One thing that was made clear in the draft EA was the
failure of the Forest Service to respond to substantive and
relevant scoping comments submitted by James Bensman. Mr.
Bensman raised numerous important ecological considerations. As
such, the issues raised by Mr. Bensman should have been examined
and addressed within the context of this particular project. The
evaluations of and responses to his comments submitted concerning
previous proposed actions cannot possibly take into consideration
the unique, site specific circumstances of the stands to be cut in
the Mortality II sale. Responses to his comments made in the past
are neither relevant nor sufficient in resolving the issues he
raised. In light of this, I find the contention in the EA that
there are "no unresolved issues" to be patently absurd.
In conclusion, the Mortality II project is an unacceptable
project which has yet to be adequately studied and evaluated. The
Forest Service should opt for the no action alternative or, at an
absolute minimum, prepare an EIS for this project. Thank you for
your time and attention in responding to my objections.
Sincerely,
your name
cc: John Palmer
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BACKGROUND INFO - originally posted to TAP-Resources on Aug. 2, 1996
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Distributed to TAP-RESOURCES, a free Internet Distribution List
(subscription requests to listproc@tap.org)
TAXPAYER ASSETS PROJECT - NATURAL RESOURCES POLICY ADVISORY
(please distribute freely)
TAP-RESOURCES
August 2, 1996
This post was prepared for TAP distribution by the
Environmental Resources Information Network on
behalf of Allegheny Defense Project (ADP). Thanks
to Ned Daly and the folks at ADP for their assist-
ance. -Arthur Clark, ERIN Project Coordinator
INTRODUCTION
The Allegheny National Forest is the only national forest in
Pennsylvania. As such, it is of great concern to forest advocates of
the Commonwealth. Like other national forests, its management by the
U.S. Forest Service is far from ecologically sound.
The Allegheny Defense Project (ADP) is a grassroots group of
forest defenders dedicated to fighting for the land and creatures of
the ANF. ADP is a small, low-profile operation, so few people outside
of the area around the ANF have ever heard of it. Until now, ADP has
never sent out a call for outside assistance. However, the situation
that ADP and the creatures of the ANF now face is very grave. We
urgently ask that everyone who can do so to help us study, challenge,
and defeat the monstrous timber sale proposal currently being planned
by the Forest Service for the ANF. Below is a short description of
the sale, followed by what you can do to help defend the Alleghenies
against this devastation.
The "Forest Health" Scam Comes to Pennsylvania
Under the guise of "treating" stands to counter the effects of
"forest decline," the U.S. Forest Service is planning a massive 31
million board-feet (MMBF) timber sale project in Pennsylvania's
Allegheny National Forest. The project is called "Mortality II."
It is the second phase of the ANF plan to supposedly improve
forest health by cutting both green and dying trees using
clearcutting, salvage thinning, and commercial thinning methods.
The first phase of this plan, the Mortality I project, is already
being implemented after approval in June 1995.
The Mortality II project calls for an initial 20.3 MMBF of
timber, cut from over 5,000 acres. The cutting will occur in ten
delineated "Treatment Areas" throughout the Forest. Additionally,
the project calls for over 10 MMBF of timber cutting on 2,000
acres, once regeneration is established in previously logged areas.
Many of the Mortality II Treatment Areas are adjacent to areas to
be cut under the Mortality I project. The close proximity of many
areas to be cut calls into question whether either the Mortality I
or Mortality II analysis can possibly evaluate what is essentially
one enormous project. Last year's total annual cut on the ANF was
approximately 55 MMBF, less than twice the volume of the Mortality
II project alone.
One might imagine that in planning such a massive project with
such an obviously significant level of impact, that the Forest
Service might dispense with the formality of preparing an
Environmental Assessment (EA) to determine whether an Environmental
Impact Statement (EIS) or a Finding of No Significant Impact (FONSI)
is in order. Not a chance. In fact, the Mortality II EA issued by
the ANF was only 45 pages in length, excluding maps and appendices.
A preliminary examination of the EA by the ADP revealed
extremely serious problems with the information provided and the
project itself. The following are but a small sampling of these:
* clearcutting and salvage thinning of previously protected
old growth stands
* highly suspect "tiering" of the Mortality II EA to the
inadequate Mortality I project EA
* project impacts on Pennsylvania-designated High Quality
(Tier 2) Cold Water Fishery trout streams, so designated
pursuant to the CWA
* possible NEPA violations, including exclusion of scoping
comments submitted by ADP activist Jim Kleissler and failure
to respond to comments submitted by others
* false and misleading descriptions and tables concerning
Present Conditions and Forest Plan-prescribed Desired Future
Conditions (DFCs) of the forest, used to justify the proposed
logging activities
WHAT YOU CAN DO
ADP urgently needs assistance in evaluating this project. The
COMMENT PERIOD FOR THE EA ENDS AUGUST 19. Due to the terrible
inadequacy of the information provided to the public in the
scoping letter and EA, ADP will be conducting a massive file review
of the Mortality I and Mortality II project files from August 12
through August 16. Anyone who can travel to north-western
Pennsylvania to help is urged to come. Please contact ADP as soon
as possible to make the necessary arrangements. (see "CONTACTS"
section below)
All other people willing to help should also contact ADP
immediately. We can use all the help we can get, in-person or on a
consultation basis, with all of the following and more:
* mailing or faxing letters about the sale: write/fax
and tell ANF Forest Supervisor John Palmer that an
EIS is needed to properly study and document a
project of this size and potential impact; also
tell him there should be no logging of old growth
areas, whether or not they are "officially"
protected (see "CONTACTS" section below)
* legal consultation on NEPA, FOIA, NFMA and ESA issues
* guidance on interpretation of CIR (G R IR -> B G R)
1:12,000 aerial photos
* fieldwork and consultation on locating listed or candidate
species (both plants and animals, e.g. hellbender, n.
goshawk, eastern small footed shrew, small-whorled
pogonia, etc.)
CONTACTS
To help:
Jim Kleissler
Susan Curry
ADP
P.O. Box 245
Clarion, PA 16214
(814) 226-5224
(814) 678-2404 fax
<mortality@essential.org>
(scientific, legal and policy experts please contact ERIN at
814-678-0007, 814-678-2404 fax or <aclark@essential.org> if
you are inquiring during normal business hours Mon. - Fri.)
To write letters to:
John Palmer
Forest Supervisor
Allegheny National Forest
P.O. Box 847
Warren, PA 16365
(814) 723-5150
(814) 726-1465 fax
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