Audubon Official Position On Quincy Library Group Bill

Originally posted in IGC member conference:

Date: September 20, 1997

Posted by:

/* Written 6:20 PM Sep 20, 1997 by in */

/* ---------- "Audubon position on S. 1028" ---------- */

This is the official position of the National Audubon Society and an undetermined number of our chapters on S. 1028, the Quincy Library Group bill. A condensed version of this letter may be available soon. If you have questions and/or comments, contact:

Mike Leahy
Forest Campaign Coordinator
National Audubon Society
1901 Pennsylvania Ave, NW
Washington, DC 20006
202/861-2242x3019 fax 861-4290


September 17, 1997

Subject: S. 1028, The Quincy Library Group bill

Dear Senator:

The National Audubon Society and many of our chapters encourage you to oppose S. 1028, which would legislate the Quincy Library Group's plan for management of the Plumas, Lassen, and Sierraville Ranger District of the Tahoe National Forests. As you develop a position on S. 1028, please consider the reasoning which led us to oppose the bill. The popular appeal of "community consensus" forest management has led many Members to marginalize important and legitimate concerns about S.1028 and its House counterpart H.R. 858, and has prevented these concerns from receiving the serious consideration by Congress they deserve.

S. 1028 and H.R. 858 raise issues which have been hard for the environmental community to wrestle with. Nonetheless, with few exceptions, grassroots and national environmental/conservation groups across the country all strongly oppose the QLG's bills.

These issues have been particularly hard for National Audubon Society to deal with because one of our respected chapters, Plumas Audubon Society in Quincy, CA, is participating in and actively supporting the QLG's legislative strategy. National Audubon is a chapter based organization which supports and promotes local involvement in both local and national environmental issues. Indeed, activism on local and national environmental issues is our greatest strength. Many of our chapters participate in local community forums with conflicting interest groups, and we have not opposed their efforts.

At the same time, the actions of our chapters must pass certain screens before we can support them. The arrangement with our 518 independent chapters is that we agree to the right to disagree. S. 1028 differs from the many other community efforts we have not opposed in a number of respects. Because S. 1028 does not pass our screens for public participation, adherence to environmental laws and regulations, and impacts on the forest, National Audubon and many of our chapters oppose these bills despite the objections of the Plumas Audubon Society in Quincy, CA.

Why such vigorous opposition from environmentalists to a proposal with popular appeal and support from some of the local environmentalists? It has nothing to do with the fundraising goals of national environmental groups, as has been suggested by some. In fact, the opposition to these bills has been led largely by small grassroots groups around the country. These groups often have opportunities to participate in community coalitions on local environmental issues, and are in the best position to understand the potential dangers inherent in them. Even groups participating in their own community coalitions widely panned the QLG's bills. We have received requests to oppose this legislation from our other chapters in northern California, and from chapters as far away as Iowa.

Opposition to the QLG's bills can be broken into three categories. First, the bills minimize important environmental laws and regulations and public participation opportunities. Second, they set bad precedents for inconsistent and unreliable public participation in public resource management , and for legislating individual forest plans around the country. Finally, the logging aspects of the plan are untested and costly and will not likely reduce the chance of fire but will damage resources. QLG bills short circuit environmental laws and public participation

Environmental laws are often all that exist between a resource and its exploitation. Last year's Lawless Logging Rider showed us how important environmental laws and public participation are to public forest management, and what happens when they are removed: illegal abuse, such as clearcutting under the guise of salvaging the forest. Environmental groups are understandably upset when these laws, through which we can protect a small subset of our resources, are tampered with.

S. 1028 is not the Lawless Logging Rider, but it truncates law in a manner that could have worse long-term implications for public forest management. QLG-like bills would allow a relatively small group of citizens to dictate public forest management, rather than agency officials receiving input from the public at large. Forest Service employees often make poor decisions and may not process the public input in a manner we approve of, but they are more likely on the whole to act in the public's best interest than local management coalitions, which don't have the national scientific backing of an agency, and which include people whose personal interests may not be the best interests of the public forest.

Here, Sierra Pacific Industries, a regional logging company, initiated the QLG, while many environmentalists, including many who are active on the forests in question, report being unable to participate in or influence the creation of the QLG's plan. The QLG claims that people who want to participate had ample opportunity, but without the stable, established procedures provided by our existing laws and regulations it is impossible to be sure. The QLG might not have provided the same level of opportunity the Forest Service would have. Further, people who would have otherwise participated in a management plan for three national forests might not have joined the QLG group, perhaps because they did not understand or were not familiar with the QLG-designed participation procedures; they did not think QLG would be treated as official; they did not think the QLG was legitimate; or for other reasons. It is unfair for Congress to punish these would-be participants by telling them after-the-fact that QLG's product was, indeed, the one Congress would endorse as official public policy.

Comments will still be allowed on the QLG's forest management plan, but both S. 1028 and H.R. 858 undermine the purpose of environmental law and public participation by pre-determining the NEPA process. They tell the Forest Service to go through the motions of public participation, but mandate that the final result must be the QLG's plan. Alternative plans, the cornerstone of the NEPA's public involvement, are not allowed. Thus, opportunities for true public participation are eliminated. QLG bills lead to inconsistent public participation and needless legislation

The precedent set by the bills enacting QLG's management plan is one of unreliable and inconsistent public participation. It allows any group of individuals to gather and set the process through which other members of the public can participate in public resource management. Difficulties are inherent in all public participation, difficulties as mundane as when and where to hold meetings, or how to contact people. The Forest Service at least provides consistency and predictability in their procedure. A local group could intentionally or unintentionally exclude a number of willing participants, them claim to have created a well-reviewed consensus proposal.

Whether or not these consensus groups are legitimately acting in the public's best interest is only relevant locally. Nationally, illegitimate groups are inevitable. It is fine and may be desirable for local interests to meet and come up with ideas, but they should not be able to dictate public participation or forest management on their terms. The legitimacy of their plan should be tested through a rigorous and reliable public review process, as provided by our laws and regulations. If the plan is a good one, it will pass the test, if not it will be scrapped. This test is impossible if public participation is disabled because Congress gives out the final grade—the QLG plan in this instance--before the exam.

The QLG bills also start a trend of legislating forest plans. The amount of work involved in legislating individual management plans for every national forest, or even every 2 and * national forests, will be overwhelming for both Congress and environmental groups. As fellow watchdogs for the public interest in public forests, we will both be put in the position of continually trying to verify local management proposals and groups all over the country. We already have a process for public forest management which, while far from perfect, is far superior to this alternative. We should put it to work.

The QLG chose to legislate their plan because they felt the existing framework was not working for them, but that points to the need for Forest Service reform, not for individual and costly exceptions to the framework. Further, many feasible alternatives not requiring legislation were advanced by both the USDA and other environmental groups but were turned down by the QLG because they did not guarantee that the QLG plan would be adopted in a timely manner. The QLG's impatience and frustration with the Forest Service and environmental laws and regulations does not justify altering national policy.

Since the QLG is legislating their forest plan, we are obligated to comment on the legitimacy of the group and their plan. We believe the environmentalists who are participating in the QLG are legit and have the best of intentions. Many would-be participants interested in these forests are, however, totally unsatisfied with the opportunities for participation allowed by the QLG, and with the plan itself. This leads us to conclude that, on the whole, the QLG is illegitimate as a true community consensus management group. QLG plan mandates questionable logging activity

The litmus test for a forest management plan is its impact on the forest. In addition to the negative impact S.1028 could have on forest management elsewhere in the country, it fails the test of local impact as well. QLG's plan does temporarily set certain roadless areas and endangered species habitats off limits to logging, but it offers no long term protection for these habitats. After the plan expires in five years, the important habitat areas may once again be vulnerable to exploitation. During the period these specific areas are off-limits, intensive logging is required elsewhere.

The most questionable requirement is the mandate to cut "fuel breaks" in the forest. Up to 70,000 acres per year could be subjected to varying levels of logging on the theory that logging these swaths will reduce the threat of fire. However, logging off all or part of the forest's canopy stimulates the growth of smaller trees and other vegetation by allowing them more sunlight, water, space, and food. These young, dense forests which will grow in the "fuel break" are likely to be as prone, or more prone, to fire than the forest they replace. Additionally, people and logging equipment used to create the fire breaks are the number one cause of forest fires themselves. Therefore, these fuel breaks are likely to increase the threat of fire.

The Forest Service could perpetually clear the 350,000 acres of fuel breaks which can be cut under S. 1028, but this would require tremendous amounts of money and effort. Even if the money were clearly available for this upkeep, the fire potential might not go down, especially if the cut brush is allowed to pile up in the breaks. Prescribed burning to maintain these fuel breaks would also be costly and risky, and is unproven. In short, S. 1028 allows Sierra Pacific Industries to conduct a large-scale, taxpayer funded, 350,000 acre experiment, which requires intensive logging, when their hypothesis is untested and many experts agree that it will probably have an effect opposite of the one intended.

Other impacts of the plan include the more familiar impacts of logging. The watershed will be disturbed by soil compaction and soil run-off from logging equipment and from the miles of roads this project will require. Fish, bird and wildlife habitat will, of course, be destroyed.

The QLG's bills raise the debate about a perceived paradigm shift from national management of national forests to local management. Local involvement in public resources is important, but cannot exclude the national interest. Like it or not, national forests belong to all of us. Polls and visitor data indicate national forests are very popular, and the public is not likely to give them up any time soon. The QLG bills hand an unacceptable level of control of public resources to one local group. Not only is this unfair and undemocratic, it is short-sighted. Local forest users can tell us a lot about their forest, like which areas are used by which species or which are most valuable for wood. They are not necessarily equipped to view the bigger picture of, for example, species declines, cumulative impacts, or policy trends, because of their local focus and a possible dependence on the forest for a livelihood or otherwise.

Considering the big picture is the job of Congress, and of watchdog groups like the National Audubon Society. The trend which is surfacing around the world as the most logical one for forward-looking resource management is regional ecosystem-level management with local input. We should not begin a countertrend of short-sighted local management with little or no regional oversight, no matter how well-intentioned.

Please oppose S.1028, the Quincy Library Group Act.

Thank you,

Daniel P. Beard
Senior Vice President