Copyright 2000 Federal News Service, Inc.
Federal News Service
June 22, 2000, Thursday
SECTION: PREPARED TESTIMONY
LENGTH: 2837 words
HEADLINE:
PREPARED TESTIMONY OF H. MICHAEL ANDERSON SENIOR RESOURCE ANALYST THE WILDERNESS
SOCIETY
BEFORE THE HOUSE COMMITTEE ON RESOURCES
SUBCOMMITTEE ON FORESTS AND FOREST HEALTH
SUBJECT - THE
INTER-RELATIONSHIP OF THE FOREST SERVICE'S RULEMAKINGS AND REGIONAL PLANS
BODY:
The Wilderness Society and the Pacific
Rivers Council appreciate this opportunity to testify on the inter-relationship
of the Forest Service's rulemakings and regional plans for the National Forests.
The Wilderness Society is a national environmental organization that works to
protect America's wilderness and to develop a nationwide network of wild lands
through public education, scientific analysis, and advocacy. The Pacific Rivers
Council is a private, non-profit organization dedicated to protecting and
restoring rivers, their watersheds, and native aquatic species. Both
organizations have been significantly involved in Forest Service regulatory and
planning activities for many years.
The Forest Service is in the midst
of several important national regulatory and regional planning processes
pertaining to National Forest management. These include, at the national scale,
the Forest Service's rulemakings on roads management, roadless
area conservation, and the forest planning process; the agency's
strategic plan; and the interagency Unified Federal Policy for Ensuring a
Watershed Approach to Federal Land and Resource Management. At the regional
level, the Forest Service has proposals for the Interior Columbia Basin
Ecosystem Project, the Sierra Nevada Framework for Conservation and
Collaboration, implementation of the Quincy Library Group plan, and the Survey
and Manage Guidelines under the Northwest Forest Plan. These regulatory and
regional planning efforts stem from a variety of specific statutory mandates,
policy initiatives, and judicial decisions. For example, the Government
Performance and Results Act of 1993 requires all federal agencies to prepare a
strategic plan and to update the plan every three years. Similarly, the
Herger-Feinstein Quincy Library Group Forest Recovery Act of 1998 directed the
Forest Service to implement a pilot project on federal lands within three
National Forests in California. Some of the regulatory proposals - most notably
the roads management and roadless area conservation rulemakings
- are policy initiatives undertaken pursuant to the Forest Service's general
rulemaking authority. The revision of Survey and Manage Guidelines, on the other
hand, resulted from a court decision that the Forest Service and Bureau of Land
Management had failed to implement the species monitoring requirements of the
Northwest Forest Plan.
Overall, The Wilderness Society and Pacific
Rivers Council support the Forest Service's current regulatory and planning
efforts. As discussed below, most of these initiatives are consistent with
principles of environmental protection, sound science, economic efficiency, and
public involvement. They respond to the desires of most Americans for National
Forests that provide clean water, diverse wildlife habitats, and unspoiled
landscapes. The cumulative result of these efforts, if successfully adopted,
will set the National Forests on a path toward environmental and economic
sustainability in the 21st century.
That is not to say the Forest
Service is adequately addressing all conservation issues facing the National
Forests. For example, we are very disappointed that the agency has made
virtually no effort at the national level to control the impacts of dirt bikes,
ATVs, snowmobiles, and other off-road vehicles. The proliferation of larger,
more powerful ORVs is causing serious damage to soils and water quality,
accelerating the spread of invasive weeds, and destroying the natural quiet and
solitude of the forests. Unless strict controls on ORV use are adopted and
enforced, the negative impacts of ORVs will nullify many of the positive
environmental effects of the Forest Service's pending policy initiatives.
STATUS AND ROLE OF THE NATIONAL FORESTS
National Forests provide
much of the nation's clean drinking water, refuges for hundreds of fish and
wildlife species, irreplaceable recreational resources, and places of spiritual
solace. Unfortunately, they have been overused. Since the 1950s, logging and
roadbuilding, in concert with grazing, mining, and fire suppression, have
degraded the public values of the National Forests, forcing the Forest Service
into a series of policies that aim to protect and restore those values.
National Forests and other federal lands serve as critical ecological
anchors. The ecological importance of federal lands to the conservation of
aquatic ecosystems and imperiled aquatic species cannot be overstated. Fully 85%
of the remaining strong populations of cold-water salmonids in the Columbia
Basin spawn and rear on federal ground. Overall, about 60% of all available
spawning and rearing habitat is managed by the Forest Service or the Bureau of
Land Management. Extremely sensitive cold-water species like bull trout are now
found almost exclusively on federal lands. These ecologically significant
characteristics are typical of federal lands in other parts of the country as
well: the watersheds with the greatest known aquatic biodiversity in the
temperate world are primarily managed by the Chattahoochee and Cherokee National
Forests in the southern Appalachians.
Even though the natural value of
these lands is great, they have suffered extreme degradation. For example, close
to half the federally managed waterbodies in eastern Oregon do not meet water
quality standards. Habitat impacts are believed to be responsible for a 70-90%
reduction in the numbers of salmon from historical levels that migrated through
the Columbia River system. Yet these lands still hold the greatest hope for
imperiled salmon and trout.
Fish and wildlife are not the only
beneficiaries of the water produced by our federal lands. As Forest Service
Chief Dombeck has recognized, our National Forests are literally "the headwaters
of the nation." Although forested lands comprise only about one-third of the
nation's land area, they supply about two-thirds of the country's total runoff,
making National Forest lands the largest single source of water in the
continental United States. Nationally, over 3,400 communities rely on National
Forest lands in 33 states for their drinking water, serving over 60 million
people. Similarly, in Oregon, federal lands are the direct or indirect source of
drinking water for most Oregonians, including those in the three major
metropolitan areas of Portland, Eugene, and Salem.
Degradation of the
National Forests has been severe enough that today only ecosystem-level
protection and restoration are legally and ecologically appropriate directions.
For example, only dramatic reductions in old growth logging and substantial
commitment to restoration allowed the President's Northwest Forest Plan to pass
legal muster. The spotted owl forests are not unique -a thorough reworking of
public land management in the Columbia Basin and the Sierra Nevada is required
to bring those lands into compliance with the law, and to begin to truly protect
and recover public values.
GENERAL COMMENTS ON FOREST SERVICE
INITIATIVES In the rising tide of listed species, degraded streams, and public
demand for the protection of environmental values on the National Forests, the
government has embarked on a whole series of policy initiatives to address the
problems.
We would like to make three points regarding the mutual
characteristics of these policies:
(1) ecosystem restoration is the
appropriate theme for federal lands management in the foreseeable future;
(2) better information for decisions is needed to accomplish this goal;
and
(3) each of these policies responds to a mandatory duty to act under
existing law.
Ecosystem Restoration is the Appropriate Common Theme
Taken together, the thrust of these policies is to guide federal
agencies to manage the lands entrusted to their care by the American people in
accordance with the spirit and the letter of our environmental protection laws.
Because for too many years we have asked more of these lands than can be given
without destroying their natural productivity, today our guiding principle must
be ecosystem restoration. Although there is much legitimate controversy over the
form that ecosystem restoration should take in a given circumstance, the
conclusion that our goal must be restoration of federal lands is inescapable.
As the empirical evidence linking the survival of both humans and wild
creatures to the health of federal lands grows, the economics are catching up.
Increasingly, the value of federal wildlands for their ecosystem goods and
services is being recognized as the source of amenities that generate a "second
paycheck" for those who live near enough to federal lands to benefit directly
from the quality of life they provide. According to federal economists, in 2000
the value of the unroaded areas on federal lands in the Interior Columbia Basin
is about four times greater than the value of their timber and forage combined -
on a par with the value of recreation. The Forest Service recently assessed the
value of water on National Forest lands to be more than $3.7
billion per year.
The Policies Recognize that Managing for Sustainable
Ecosystems Requires Informed Decisionmaking
Many of the policies under
discussion focus on ensuring that management decisions are grounded in the best
available information about the conditions of our land, air, and water.
Investment in regional ecosystem assessments, watershed assessments, road
inventories, and other related activities gives decisionmakers a solid basis for
their decisions, builds public confidence in federal land managers, and provides
citizens with better means of holding managers accountable for the stewardship
of public lands.
The Policies Represent Attempts to Take Necessary and
Appropriate Actions to Meet the Requirements of Existing Law
Each of the
policies discussed here is not only within the authority of the federal agencies
to promulgate and implement, but each is spurred by the agencies' correct
identification of a need to act in order to meet existing mandatory duties under
federal law. As examples, the roads policy addresses conservation and recovery
duties assigned to the Forest Service under National Forest Management Act, the
Endangered Species Act, and the Clean Water Act, as do the regional planning
processes. The policies attempt to reduce the likelihood that illegal forest
plans will be promulgated, exposing the government and federal land users to
legal challenge and disruptive injunctions. Similarly, the Environmental
Protection Agency's proposed water quality and planning regulations recognize
that states are not meeting the letter or spirit of the Clean Water Act, whose
objective is to restore and maintain the chemical, physical, and biological
integrity of our nation's waters. The EPA regulations attempt to provide better
guidance regarding the Act's requirements and to expand the tools available to
states. Similar statements can be made for the intent of each of these policies.
BRIEF COMMENTS ON SPECIFIC POLICY INITIATIVES
Roads Management
and Roadless Area Policies
The Forest Service's
decision to promulgate national Roads Management and Roadless
Area Conservation policies is supported by common sense, because it
simply seeks to avoid recreating the wheel in each forest plan. Building on
lessons learned in regional planning efforts in spotted owl and salmon country,
the policies recognize the substantial body of scientific findings which
demonstrate not only that roads are a leading environmental problem for both
aquatic and terrestrial species, but that roadless and lightly roaded areas
usually correspond to critical aquatic habitats. The fact that the Forest
Service only receives 20 percent of the funding necessary to maintain the
existing road system demonstrates that additional construction of logging access
roads is economically imprudent.
Forest Planning Regulations
These regulations attempt to establish a scientifically credible and
therefore legally defensible approach to National Forest planning. The rules
appropriately address subjects such as the scale of scientific assessments,
factors important to maintenance of species viability, the achievement of
ecosystem integrity, the role of science advisors, the framework within which
collaborative planning should operate, and the mechanisms for public
participation and redress of grievances.
Interior Columbia Basin
Ecosystem Management Project
This regional planning effort seeks to
fulfill legal requirements for federal land use plans and to replace the current
interim direction with a long-term management strategy that will provide the
baseline direction for ecosystem management. It also builds on the legacy of the
Northwest Forest Plan by creating a management framework which clearly
recognizes that legal obligations cannot be met unless management impacts on
federal lands are limited to those compatible with the maintenance and
restoration of ecosystem processes and functions.
Sierra Nevada
Framework
Like the Columbia Basin project, the Sierra Nevada Framework
is a legitimate effort to incorporate sound science and economics into Forest
Service plans. The congressionally-mandated scientific evaluation of the Sierra
Nevada clearly pointed to the need for a regional ecosystem management approach
for the Sierra. For example, the assessment found that water was the most
valuable commodity resource of the region's National Forests, but that aquatic
resources were also the most impaired habitats of the Sierra. The Forest
Service's draft EIS incorporates many of the scientists' findings and
recommendations and challenges the public to view the National Forests from a
regional perspective.
Survey and Manage Requirements
The
Northwest Forest Plan required the Forest Service and BLM to locate and
appropriately protect species that were not addressed by the forest reserve
system in the regional plan. The requirement was necessary to allow some logging
of old-growth forests to continue without violating federal environmental and
wildlife conservation laws. The inability of the agencies to comply with the
Survey and Manage standards calls into question whether the Forest Service would
do better simply to protect the remaining old-growth forests.
Unified
Federal Watershed Policy
Consistent with the Clean Water Act and the
original statutory purposes of the National Forests, Chief Dombeck has made
watershed health a top priority for the Forest Service. Public opinion also
strongly favors watershed protection: according to a 1995 University of Idaho
poll, residents of the Interior Columbia River Basin consider watershed
protection to be the most important use of the National Forests. Water, as
Dombeck has said, is the most valuable and least appreciated resource of the
National Forests. The Unified Federal Policy is an important first step toward a
comprehensive watershed protection and restoration in the National Forests.
While still weak on implementation strategies, the broad policy direction and
goals of the draft policy provide the basis for an effective watershed
management strategy.
CONCLUSION
The Forest Service has often
been criticized in recent years for a lack of direction and a failure to
establish clear management priorities under the agency's broad multiple-use
mandate. However, under the conservation leadership of Chief Mike Dombeck, that
criticism is waning. The Natural Resource Agenda presented by Dombeck in 1998
provided the basic policy direction and priorities so sorely needed to move the
Forest Service from its commodity production past to its ecosystem management
future. The regulatory and regional planning initiatives currently underway are
important next steps in the implementation of that policy shift. Fortunately,
the public is engaged in National Forest issues as never before, as indicated by
the record half-million comments on the roadless area scoping
notice this winter.
A growing body of economic evidence indicates that
National Forests make their largest contribution to the economy when they are in
the best shape ecologically - that is, when they provide abundant clean water,
plentiful fish and wildlife habitat, moderation of floods, refuges for
endangered species, irreplaceable recreation, and spiritual solace. As noted
above, National Forest watershed protects the drinking water for millions of
people in many western cities and rural communities. But the value of naturally
functioning forest ecosystems goes far beyond water. The National Forests form a
prominent element in the quality of western economic life as a whole, urban and
rural. The cumulative effect of the policies discussed herein will be to enhance
the contribution National Forests make to the larger economy, as increasingly
healthy and restored forests provide greater benefits for everyone. They will
also help to fulfill our ethical responsibility to care for the forests and pass
them on unimpaired for the benefit of future generations.
END
LOAD-DATE: June 24, 2000 
