TO: Michael Dombeck, Chief, U.S. Forest Service

FROM: State Representative Lorraine M. Seratti

SUBJECT: New regulations for the National Forest Management Act and the President’s “Roadless Areas” Initiative

I appreciate the opportunity to provide written comments relative to new regulations for the National Forest Management Act and the President’s “Roadless Areas” Initiative. As an elected official, I fully realize that you must consider a very broad spectrum of issues in relation to the establishment of plans for our national forests.

Over the last several months, hundreds of letters and postcards have been flowing into my office from constituents frustrated by the proposed management changes and the process in general. Changing the process now, in midstream, to incorporate 1) the Chequamegon–Nicolet Ten-Year Management Plan 2) the Clinton/Gore Administration’s “Roadless Areas Initiative,” and 3) new forest management planning regulations, is confusing, arbitrary, and unfair to citizens. A format in which United States Forest Service (USFS) facilitators lead citizen dialogue is not representative of true public input.

The first topic I wish to address is the Weeks Act of 1911, which authorized the Agriculture Secretary to purchase lands within the watersheds of navigable streams to enhance stream-flow, and the expanded authority granted by Act June, 7, 1924 to include in its scope, “lands necessary for the production of timber.” While I realize that other acts of Congress have altered the management directives of the department, I want to emphasize the original intent of these acts. I believe it is important that officials charged with the responsibility of rewriting these management plans not lose sight of the significance of the original intent of these acts.

Over the last ten years (from 1987 to 1997) timber cut volume on the Nicolet has been reduced to less than half. As a result, counties and school districts dependent on these timber harvest revenues have experienced significant decreases in payments from timber sales forcing the state to increase local government and local school aids to avoid higher property taxes for landowners in affected counties. In Florence County timber employment income generated by fiscal year 1997 USFS timber harvests amounted to $5,285,049 resulting in $60,883 in 25% fund and PILT payments to local governments. For Forest County, timber employment income generated by fiscal year 1997 USFS timber harvests amounted to $21,383,601 resulting in $205,775 in 25% fund and PILT payments to local governments.

Wood resources are used in every sector of our economy, creating hundreds of thousands of jobs in Wisconsin. The national forests in our state alone provide approximately 30% of our states raw wood resources. For example, in 1997, the Forest Service timber sale program generated over $100,059,999.00 of direct, indirect, and induced timber employment in Wisconsin.

Citizens are also very concerned about the lack of professional expertise of qualified foresters as a result of the recent personnel “buyouts” by the agency. To implement sound timber management policy, there needs to be accurate data to ensure the proper harvesting levels and management techniques are being applied. Trees are a crop that must be harvested and utilized for the benefit of all at the proper time. Many new concepts have been incorporated into these new proposed rules and initiatives, all of which appear to circumvent current law. Is this representative of “we the people?”

Also included are statements of intent to manage for “ecological sustainability” rather than multiple-use, sustained yield. The standard by which the forest service will determine whether or not an area is ecologically sustainable will be measured by a standard, which will compare current ecosystem integrity with the estimated integrity of pre-European settlement. To promote polices that encourage “old growth” pre-settlement conditions is unrealistic.

Planning rules also call for “environmental justice” for all citizens. What does this mean?

Additionally, there appears to be more emphasis on the concept of “ecosystem management” and use of a variety of “ologists” with very little emphasis on the socio-economic benefits that recreation and timber production bring to the communities surrounding our national forests. Proposed changes also attempt to mandate Congressional funding two to three years out to complete required monitoring and evaluation. One Congress cannot obligate funds for a future Congress.

Access is also a prime concern of residents throughout the national forest system. Many citizens are troubled with the closure of national forest roads and the high standards you require in the development and maintenance of road systems within the forest. The proposed initiative also creates a new classification of “un-roaded areas.” The term “un-roaded areas” first appeared in the interim roadless area moratorium. Congress has never legally recognized such a term. Is this representative government? Designating new non-motorized and semi-primitive areas and increasing wilderness set-aside will only negatively impact the economic and recreational benefits the forests currently provide to the citizens of Wisconsin.

Also, as you develop your management plans, please take into consideration the number of elderly citizens who reside in the communities adjoining our forest lands. I hear very frequently from senior citizens that areas they recreated in for years are no longer accessible as roads and trails continue to be bermed off and closed.

Timber production and recreation can be incorporated into a management plan that will enhance economic output, protect the natural resources and provide the proper habitat for a variety of plants and animals. Ecosystem management and biological diversity should not preclude other positive aspects of forest use, such as recreation by hikers, bikers, ATV enthusiasts, snowmobilers, hunters and other sportsmen. These resources belong to the people of the United States of America and they were intended to be used – not locked up or blocked off from the general public.

The emphasis placed on landscape planning should not diminish the property rights of individual landowners adjoining or interspersed between national forest lands. Private woodland owners adjoining or interspersed between national forest land should not have the health of their woodlands negatively impacted from insects and disease infestations caused from improper management of national forest lands. Improper management and decreased timber production will not only harm wildlife habitat, but additionally will lead to increased pressure on private woodlands which may not have professional foresters supervising timber harvests. Management plans should recognize the fundamental rights granted to citizens under the Fifth Amendment to our Constitution.

In conclusion, common sense and sound science should prevail in the decisions made involving timber management, wildlife habitat, road and trail development, and recreation policies. I strongly encourage your agency to resist the pressures applied through appeals and litigation brought on by extremist preservation groups, and instead work towards a multiple-use management plan that provides adequate access, maintains forest health and economic productivity and diversity, while generating funds for managing the resources well into the future.

If the USFS cannot accomplish these very important goals, then the citizens of Wisconsin should implore their Congressional delegation to begin the process of returning these public lands back to the people of Wisconsin.