- The U.S. Forest Service has extended a deadline for comments on proposed changes to their implementation of the National Environmental Policy Act
- The Ruffed Grouse Society and American Woodcock Society will submit detailed comments on the proposals
- We will make our comments available to members in advance of the new August 26 deadline
Right off the bat, I want to let you know I am not writing to ask you for anything. I won’t implore you to set aside what you’re currently doing and divert your time to a pressing call to action. I simply wish to provide you with an update regarding a topic with serious implications for forest health and wildlife management. I know our members appreciate staying informed on such issues, and on how the Ruffed Grouse Society and American Woodcock Society (RGS/AWS) are working on their behalf.
If you have not heard, the U.S. Forest Service (USFS) is concluding a process to propose changes to their regulations for implementing the National Environmental Policy Act (NEPA). A Federal Register notice on June 13, 2019 opened a public comment period on their proposed rule. The comment deadline has been extended by 14 days.Comments will now be due by August 26.
NEPA is a critical piece of environmental legislation. It establishes restrictions and requirements for federal agencies that propose any major actions with the potential for significant environmental impacts, “to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man.” The stated intent of the USFS proposed rule is primarily to improve efficiency and “do more to increase the health and productivity of our national forests.” Though there is widespread evidence that more efforts are required to increase the health of our national forests, the proposed changes to NEPA implementation have been sharply and publicly critiqued.
RGS/AWS is generally supportive of what USFS has proposed, but we are taking the responsibility to provide detailed, substantive comments very seriously. Our staff continue to weigh our input, and network with partner organizations to share different ideas and viewpoints so that our positions can be as informed as possible.
Some organizations are encouraging ALL members to provide blanket positive or negative statements regarding the proposed changes. Such general comments will have little effect on the final outcome of the decisions. In their Federal Register notice, USFS summarized comments received through an earlier Advance Notice of Proposed Rulemaking. Out of nearly 35,000 comments received, only 1,229 were unique – and most unique comments supported agency efforts to improve efficiencies. Nearly 33,000 comments were submitted through just two “form letter” campaigns that urged USFS to reject any changes that might accelerate their NEPA process. Fortunately, the notice also indicated USFS “will not regard form letters as ‘votes’ as to whether the proposed rule should go forward.” The message here is that substance is more important than volume.
The stakes here are high. We are dedicated to supporting thoughtful reform. To minimize disruption of this process and backlash following implementation, we are also encouraging as much unity as possible within the conservation community to support USFS efforts to be good managers and responsible stewards of the public lands under their care. We appreciate the support of our members and partners, and will share our final comments with you in advance of the deadline, along with information on how you may provide input if you wish to do so.