White Mountain National Forest
ENVIRONMENTAL ANALYSIS PROCESS
Producing a timber sale on the White Mountain National Forest is a complicated and
time-consuming process. Federal law requires the Forest Service to follow the National
Environmental Policy Act. It is easier to understand this law if we review some history.
Up to the 1960s, the government produced many large and controversial, projects like
dams, and highways. These projects often had extensive effects on local or regional
communities. Some were unpopular with large groups of people. These groups began to
sue the government, often exposing poor planning or questionable reasons for doing the
project. Congress responded with legislation that required government agencies to
involve the public in the planning process and disclose the effects of the project. If
people participated in the analysis and still disagreed with the decision they could appeal
and have a higher authority review the work. The higher authority could reverse the
decision or require the agency to do additional analysis.
In the early days this was a fairly simple process. Projects that were well thought out
with a reasonable purpose, moved through the process with very little attention from the
public. Over time, some groups who oppose activities like logging learned that they
could slow the process and create a great deal of extra work for government agencies by
commenting adversely, and routinely appealing all projects. On a few occasions they
won appeals where the Forest Service analysis was poorly done. They also won a few
court rulings where judges disagreed with Forest Service decisions. Today there are so
many complicating factors - endangered species, new scientific information, public
misconceptions about the effects of timber harvesting - that it becomes more and more
difficult to produce a flawless document in a reasonable amount of time.
The White Mountain National Forest recently completed a revision of their Forest Plan.
A lot of good people, with different interests, participated, compromised, and agreed to
the final alternative selected. It provides something for everyone and carefully combines
the interests of all the users of the White Mountain National Forest. This plan provides
overall direction for all future projects on the forest. It includes managing timber
resources on about 46 percent of the Forest with an annual harvest of 24 million board
feet of forest products. It supports local economies, produces a mix of wildlife activities,
and helps meet the demand for forest products, nationally.
The timber sale process starts after the Forest Service has conducted an inventory of the
resources in the project area and develops a list of desirable management activities
covered under the management plan. These often include activities in addition to timber
management such as recreation needs or wildlife habitat improvement. A notice is put in
the Manchester Union and a letter or an e-mail is sent to people who have asked to be
involved that outlines the project. The purpose, quantity, and type of work proposed is
included with a project map. People have 30 days to send in their comments concerning
the proposed activities. To be effective the comments need to be specific to the project.
General comments or opinions don’t count. This process is called Scoping.
When the Scoping period is over, Forest Service personnel read all the comments and
decide if the project needs to be modified or if more information is needed. They may
also decide to develop alternative methods of accomplishing the project objectives based
on the public comments about the proposed activities.
For example, a project might include a cutting unit next to a hiking trail, several
commentors object to the visual effects to hikers. An alternative could be developed,
creating a buffer area where only hazard trees would be removed and an informational
sign would be posted to describe what was being done in the adjacent area and why..
After Forest Service personnel have digested all the comments, they develop an
environmental analysis. This document explains the effects of the activities proposed in
all the alternatives developed to accomplish the project. It must include a no action
alternative that does nothing more than continue ongoing projects and serves as a
baseline for comparison of the effects of the other alternatives. The analysis estimates
the effects of doing each of the alternatives - economic, recreation, water quality, wildlife
habitat, etc. When the analysis is completed and a tentative, preferred alternative is
selected, a copy is sent to all those who commented and a notice is put in the Manchester
Union. Another 30 days is provided for the public to comment on the analysis. These
comments help the Forest Service determine if the analysis is complete or needs more
work and provides input from the public on which alternative they think should be
selected. Following this comment period the District Ranger makes a decision on what
alternative the Forest Service should implement.
Once made, a copy of the decision is sent to all those who participated in Scoping or
commented on the analysis and alternatives. The decision is also published in the
Manchester Union. If any of those who participated in the decision making process
disagrees with the decision, they can appeal. Forty-five days are provided for the public
to submit an appeal. If there is an appeal, first there is an attempt to negotiate the
differences with the appellant. If that fails, the document, supporting information, and
the appeal are sent to the next higher Forest Service office where the document and
decision are reviewed. Another 45 days are provided for this step. Those who
participated earlier have established standing and have the right observe any subsequent
negotiations and provide information to the Forest Service. The decision may be
reversed, upheld, or upheld with stipulations. This process was designed to reduce the
number of law suits government agencies had to deal with. Today it is often just a
required step prior to the law suit.
If you assume there will be an appeal and do the math, you can see that there is 5 months
of time associated with just waiting for public input or higher headquarter review. This
doesn’t include the time it takes to inventory, prescribe, and layout a sale, plus all the
writing time.
If a decision is contested in court, it can often take years to get a legal decision. Often,
during the review of the project and appeal record, the judges read the comments portion
to gauge public sentiment for the project. If all they see are negative comments it can
effect their perception of the project and enter into their ultimate decision. Positive
comments also help as a support to Forest Service personnel who have to fight this up hill
battle. It helps them to know that there are citizens out there who support their work and
effort.
These timber sales are important to our industry and the NH economy. The potential 24
MMBF represents 740 jobs and $75 million in revenue in our economy. It also means
approximately $1.3 million to local towns in timber tax receipts and “25% fund”
payments. A significant portion of recreational activities in the White Mountain area is
hunting, fishing and bird watching. Practicing good forest management is also valuable
to wildlife habitat. Income form these forms of recreation are also important to our local
economies.
In review, we have an opportunity to support White Mountain National Forest timber
sales, by commenting at the start of a project, called scoping, and after the Environmental
Analysis is released. Doing this is relatively easy if you have access to a computer. All
you do is click on the e-mail address for the project and type out your comment and send
it. If you want to do it on paper, just write out your comment and send it to the mailing
address provided. It doesn’t have to be a formal letter. As long as you identify the
project and make comment that is specific to it and the project area.
Examples: Wrong – “I support this project because clear cuts are important to wildlife.”
Right – “I support this project and the clear cuts proposed because they are
needed in this area for wildlife.”
Wrong – “I support timber cutting because it is good for our economy.”
Right – “I support this project because the harvest of timber will provide
income to my town and will create jobs in our region.
Thanks for taking the time to read this. Please send comments for the next project, every
comment counts!
Steve Wingate
NHTOA Program Director