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Scoping Comments Introductory Remarks

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Scoping Comments Introductory Remarks August 16, 2017 Dear Supervisor Jaeger, Scoping Comments Introductory Remarks My scoping comments on the proposed LaVa timber sale are shown below. Each comment is clearly labeled. There are 5 comments. Please prepare 5 meaningful (emphasis added) responses to my comments in the pending draft NEPA document. They are indented and numbered using the word Comment # that’s bold, purple, 11- pitch font, and underlined. Your forest has had many acres of Mtn. Pine Beetle activity in the LPP. The dead trees are not visually attractive. Your proposal to log these trees will create clearcuts that are worse from a visual standpoint. I retired from the USFS in 2003 after 31 years with the agency. I saw it all. I worked with intelligent, caring resource specialists and I worked with so-called specialists who would knowingly trash and even destroy important natural resources in their witless quest to assure their Ranger or Supervisor would get their precious volume. Comment #1 I spent 9 years as a forest planner on the Nez Perce NF. I have experience working with LPP stands affected by Mtn Pine Beetle. I can assure you we didn’t respond to this natural disturbance event by logging the dead trees. This is why the aquatic resources on the Nez Perce NF are functioning properly. Understand that a reasonable response is to wait it out. Ask the public if they would rather see massive clearcuts or grey trees. Comment #2 A USFS employee developed the most effective method to reduce or eliminate the danger of wildfire damage and/or human deaths in the WUI. Dr. Cohen’s methods are used throughout the world yet the USFS refuses to acknowledge they exist. Opposing Views Attachment #11 explains his methods in more detail. Please assure the DEIS discloses the WUI areas will be treated ti remove fine fuels. Comment #3 Your scoping package at page 6 indicates you will take action to control noxious weed but it doesn’t say how this will be done. If you propose to apply herbicide please assure the NEPA document bases the herbicide toxicity and safety disclosures on best science supported by a variety of research conclusions. There are hundreds of research conclusions from research conducted by independent scientists that all show glyphosate is a highly-toxic carcinogen. The USDA approved glyphosate toxicity research comes from a single study at a single lab -- Syracuse Environmental Research Associates, Inc. (SERA). Of the hundreds of glyphosate toxicity studies, the one done by SERA is the only one to conclude glyphosate is non-toxic. If you don’t believe this then search on the 2 words “glyphosate” and “cancer.” Please see the Glyphosate 1 attachment. Comment #4 It would be impossible to accurately predict the environmental effects of logging 406 square miles and constructing 600 miles of temporary road. This EIS should be programmatic. This means the individual timber sale decisions will be made in separate, site specific NEPA documents. The July 2017 amended Medicine Bow Landscape Vegetation Analysis Scoping Document does not say this. I am expecting the DEIS to include this important discussion. Comment #5 When beetles kill a lodgepole pine tree, the needles fall off and decompose on the forest floor relatively quickly. When those needles die, the flammable oils break down. As a result, depending on the weather conditions, dead needles less likely to catch and sustain a fire than live needles. With an ignition source nearby live LPP trees are a greater fire hazard than dead LPP trees. Too many USFS line-officers won’t explain this to the public so they can use the insect activity as an excuse to accumulate volume. Please see Opposing Views Attachment #17 to learn more. Despite what the USFS teaches you, you must know allowing skidders and tractors weighing 35,000 pounds with spinning wheels and tracks will tear up and destroy the countless natural resources in a fragile forest. I am giving you and your IDT members the opportunity to become familiar with the natural resource research conclusions of independent scientists not associated with the USFS in the Opposing Views Attachments #1 and #4. They are numbered and presented in bold, red, underlined font. The research describes the many natural resources that cease to function properly when subjected to logging and roading. These attachments will make you all uncomfortable because they contain a wealth of independent science conclusions that are inconsistent (many times in total conflict) with what the USFS wants you to do. --------------------------------------- Please alert me when the DEIS is posted online and you are accepting comments. Sincerely, Dick Artley (retired forest planner, forest NEPA and litigation coordinator and NEPA document legal compliance reviewer --- Nez Perce National Forest, Idaho) Grangeville, Idaho 83530 [email protected] CC: selected specialists The Truth about USFS Timber Sale Planning that Most Agency Specialists know and Embrace to Maintain their Promotion Potential The bulleted items below describe a few of the NEPA process tricks that the agency teaches its employees. I’ll bet you thought you were correctly complying with NEPA didn’t you? Ask yourself what motivates the USFS to twist the process. • The Purpose & Need statements are written to deceive the public into thinking logging and roading-up the forest are ecosystem friendly. • The NEPA document text is populated with the following two undefined, sugar- coated terms: “restore” and “forest health.” • The IDT specialists know they are expected to write untrue No Action effects in Chapter 3 that ALWAYS (emphasis added) describes the highly unlikely resource damage of maintaining the status quo and doing nothing. Even interested lay members of the public understand this makes no sense. This is clearly tragic, unprofessional public deception. • The IDT specialists write untrue effects of implementing the Proposed Action in Chapter 3 that depict it in a positive way … in spite of the compelling independent science that shows logging activities destroy amenity resources so loved by the public. A minority of IDT members describe the true effects but justify the damage by telling the public it will be “short-term.” • The IDT members know there are multiple ways to achieve most timber sale P&N goals that don’t involve logging or roading. They know that including the P&N goal to “supply volume for local community economic stability” to render these other “reasonable” alternatives not responsive to the P&N. Why else is there only 1 action alternative (logging) presented to the public in 99% of timber sale EAs and EISs? Indeed, the Responsible Official selects the alternative that will be implemented prior to scoping and then runs it through the NEPA process to make it appear legal. 1 The system is rigged against the public. Ask yourself why USFS Objection Deciding Officers rule against the public in favor of the Responsible Official in the vast majority of cases regardless of the Issues. They use form responses for common objection items. Now ask yourself why the USFS looses in court most of the time when the Objection Deciding Officer’s decision is litigated. What does this tell you? In the late 1990s there was a push to change the appeals process to allow a small unbiased team of natural resource experts not associated with the USFS to decide the final appeal ruling. Of course the USFS stopped it. They wanted complete control. If you were being tried in a court of law would you want the plaintiff’s attorney to decide the case? This is exactly what occurs when a USFS Objection Deciding Officer determines the final outcome of the objection. Please consider really serving the public rather than obediently taking orders … and mindlessly doing what you are told. The USFS isn’t the military. You can still think for yourself outside the agency-approved box. You will be glad you did. The public expects resource specialists to weigh the impacts of the logging actions against the amenity resource damage that logging will inflict without bias to favor the Proposed Action. Disclosing the real tradeoffs will serve future generations of kids more than any other action you will take as a USFS employee. I know this is frightening to specialists who know as IDT members they must pave the way for all timber sale proposals. NEPA requires interdisciplinary input for a reason. It also requires Responsible Officials to seriously consider the effects of implementation before approving the Proposed Action. A professional resource specialist will have the courage to say “NO” when you know they expect you to cut legal corners and lie to assure them their precious volume. NEPA was never intended to be a hoop you must jump through to justify a decision that has already been made. Attaining timber volume to assure corporate profit opportunities should never be a reason to justify other resource damage. When and if you point this out to the Responsible Official, he/she will surely remind you of the many P&N goals that will be achieved by logging and roading-up the sale area. Courageous other resource specialists know most EA and EIS P&N statements are untrue. You know 1) some P&N goals are not needed, and 2) that legitimate P&N goals are not satisfied by logging and road construction. Have any of you ever wondered why most well-respected, independent scientists describe tragic short-term and long-term natural resource effects from logging and roading, and the USFS tells the public these same natural resources will benefit and be “restored” from “mechanical treatments” (a.k.a. logging). Have any of you ever wondered why the agency invented euphemisms and sugar-coated language when 2 describing logging in NEPA documents (i.e.
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