By Hugh Rogers
Last month, representatives from the Highlands Conservancy, Sierra Club, Trout Unlimited, Friends of Blackwater, and Rivers Coalition met with Clyde Thompson, Monongahela National Forest Supervisor, and some of his staff at a “roundtable” in Elkins. Our organizations have been concerned about a recent push to streamline the process that examines environmental impacts of forest use.
Meetings were taking place across the country. After video conferencing brought us national and regional perspectives, we had a lively, local discussion.
The Forest Service’s Washington office put the issue in the context of four priorities:
(1) safer working area (i.e., free from harassment)
(2) reduce costs and risks of fire suppression
(3) environmental analysis and decision-making
Proposed rule-making on #3 had drawn 35,000 comments. Most were said to describe the current process as cumbersome, time-consuming, and expensive. That, of course, would have been the opinion that prompted the rule-making to begin with.
Recall that the National Environmental Policy Act (NEPA) calls for three levels of scrutiny of government action: full Environmental Impact Statement (EIS); simpler Environmental Assessment (EA); and Categorical Exclusion (CE), for actions that do not, “individually or cumulatively, have a significant effect on the human environment.”
Environmental Assessments, declared the national speaker, should be 15-20 pages; in practice, they are running to 100-150 pages. The process has gone from “strategic” to “encyclopedic.” A graph displayed the steady rise in average days-to-decision: now, for a full Environmental Impact Statement, 3-4 years; for Environmental Assessments, 2-3 years; for Categorial Exclusions, 6 months. Other agencies, it was said, spend only weeks on an Environmental Assessment. (The federal agency with the most similar mission, the Bureau of Land Management, is notorious for giving short shrift to environmental concerns.)
It’s undisputable that many other jobs aren’t getting done. Maintenance and restoration of everything from roads to campgrounds to watersheds. Special use permitting. Dealing with risks of fire . . .
Fire! That was the elephant in the room.
Tucked into the power point presentation, “Improving Environmental Analysis and Decision Making,” was a peek at the overwhelming impact of fire. We know that the agency’s budget has been flat for more than ten years. It has somewhat fewer employees now than it did in 1998. The big difference is the shift in those employees’ roles. In 1998, over 18,000 of them worked on the core mission of land management, while just over 5,000 were dedicated to fire-fighting. By 2015, barely more than 10,000 were working on the core mission; close to 12,000 were directly involved with fire. Each year has topped the last as the “worst fire season.” The share of the budget dedicated to fire has risen from 20% to 60%. Call it the U.S. Fire Service.
Are we surprised that 10,000 people take longer to do as much as 18,000 used to do?
Briefly, we turned to Priority #2: the Forest Service has asked Congress to change how fire-fighting is funded. If fires were treated as disasters, the expense would not eat up the regular budget. We’ll see how that goes.
The Forest Service has always been a decentralized organization; the way EIS’s, EA’s, and CE’s are written differs somewhat from forest to forest. The Washington office is encouraging the regions and individual forests to improve efficiency. One way and another, through training, technology, and new templates for analysis, it intends to decrease the cost overall by 20% by 2019, the 50th anniversary of NEPA.
On the Monongahela, some changes underway include:
(1) templates to encourage consistency in documentation
(2) “small project NEPA day” – interdisciplinary team meetings to review small-scale, routine, non-controversial projects eligible for CE’s
(3) improvements in GIS mapping – and better public access to the data, so we can be involved in collaboratively defining projects and determining the level of NEPA analysis
On that, Sierra’s Mary Wimmer, whose experience goes back to the Mon’s 1986 Land Management Plan, said, “That’s the way we used to do it.” Dustin Wichterman shared a more recent example, Trout Unlimited’s role in the Big Mountain project.
Mary asked how recreation will fit into this emphasis on efficiency. Clyde Thompson said the Forest wants to integrate its efforts with surrounding communities, a holistic approach to the recreation economy. They hope to add a couple of staff for recreation. Meanwhile, they are planning to hire local contractors to work on trails.
Matt Kearns, West Virginians for Public Lands Coordinator, was worried about national rules to encourage CE’s that would lump together the big forests out west and our smaller acreage in the east. He suggested that proposals should be reconciled with their areas’ Management Plan (MP) prescriptions; if they’re consistent, an EA should not be a complicated matter.
A cautionary note from Beth Little: the 2009 extension of the Cranberry Wilderness included former 3.0 MP’s (would have allowed logging) on Rough Run and Little Fork. MP’s shouldn’t always control. As the Supervisor put it, “The Plan develops projects, but we can use projects to review the Plan.”
Toward the end of a wide-ranging discussion, Kent Karriker, recently retired from the Mon, brought us back to a crucial question: “What is it that we’re notgoing to do?” If we continue the same workload and same number of people to do it, “efficiency” can only nibble at the edges. The question was left hanging in the air.
I’ll conclude with a comment on the distortion of NEPA’s original purpose. In spite of the title of this national exercise, “Improving Environmental Analysis andDecision Making,” the latter subject was not addressed at any level, national, regional, or local. NEPA was supposed to bring environmental factors into decision making. A “hard look” at impacts would lead to better decisions. But politics turns the process on its head: the decision comes first, then a nearly-pointless look at its impacts.
This is not so much the case when the local administration is allowed to carry out its mission, but it has always been the case for large-scale “special” uses, projects not begun in-house but dumped on the Forest to deal with as well as it can. Highways and pipelines, for example.
Saving a certain percentage of time on small projects seems almost trivial when compared to those abuses.