Quincy Library Group
P.O. Box 1749 Quincy, CA 95971
March 4, 1999
Kent Connaughton
USDA Forest Service
Sierra Nevada Framework Project, Room 419
801 “I” Street
Sacramento, CA 95814
Dear Kent,
Our thanks to you and your staff for the help extended to three of our members when they reviewed the public file of scoping comments on February 10th. Having had time to study a selection of the comments and the Content Analysis Report that was posted on your web page, we want to bring two potential problems to your attention, hoping they can be corrected before any damage is done.
1. It appears that significant issues raised in the QLG comments (#1040) are not reflected in the content analysis of public comments upon the Sierra Nevada Conservation Framework EIS. Conceivably this could be because, as the Report says, "[it]...represents preliminary analysis of approximately 1,000 of the 2,400 Scoping comments...received to date...." This leaves open the possibility that either our comments were not received in time to be considered, or that only 1,000 were chosen for analysis by a process that somehow omitted QLG. The former seems unlikely, because a later comment, #1620, is listed in the analysis, and we don't see how a QLG comment would be excluded by any valid selection process, since the NOI specifically asked for comments related to the HFQLG Act. No later or more complete version of the February 5th preliminary analysis has been posted on the Internet or referred to in publicly available SNCF documents. Therefore we are concerned that the content analysis has somehow got off track.
An indication of the problem can be found in Chapter 6 of the preliminary content analysis. One comment on the HFQLG Pilot Project is cited (#16, by an individual from Long Beach), which asks that you "subordinate and fold" the QLG plan into the SNCF plan. That, of course, is one view of the issue, but it isn't at all adequate to cover the ground. A variety of opinions and ideas were expressed in the comments. QLG presented a quite different view from the one reported, that the SNCF decision should adopt the results of the HFQLG EIS as the SNCF decision for the QLG Area for the term of the HFQLG Pilot Project. This is obviously a view of the issue that is not represented in the NOI or in other cited public comment. How could that QLG comment possibly be considered not to have enough "content" to warrant analysis in a section headed "Herger-Feinstein Quincy Library Group Forest Recovery Act Pilot Project?"
2. The other problem is that some of the issue statements in bold face type, which typically start "The DEIS should..." or something similar, are not legitimate restatements of the issue that is raised in the quoted comments. Instead of hearing everything that the public actually said, it often appears that the analyst could hear only a narrow range of Forest Service frequencies the rest of us aren't tuned into. These slightly off-kilter interpretations appear in a disturbing number of the issue statements, but since we can't be sure what the other commenters intended to say, we'll illustrate with just one example based on a QLG comment. Chapter 26 of the Content Analysis Report quotes from our October pre-scoping letter, "The SNCF must assess the current socioeconomic, cultural, and demographic situation of each affected area, and state how these would change as a result of the land management actions proposed for that area." The Report says this means that QLG's comment was "The Sierra Nevada Forest Plan Amendment EIS should analyze and consider the economic impacts of road closure on local communities."
2. The other problem is that some of the issue statements in bold face type, which typically start “The DEIS should...” or something similar, are not legitimate restatements of the issue that is raised in the quoted comments. Instead of hearing everything that the public actually said, it often appears that the analyst could hear only a narrow range of Forest Service frequencies the rest of us aren't tuned into. These slightly off-kilter interpretations appear in a disturbing number of the issue statements, but since we can't be sure what the other commenters intended to say, we'll illustrate with just one example based on a QLG comment. Chapter 26 of the Content Analysis Report quotes from our October pre-scoping letter, “The SNCF must assess the current socioeconomic, cultural, and demographic situation of each affected area, and state how these would change as a result of the land management actions proposed for that area.” The Report says this means that QLG's proposal was “The Sierra Nevada Forest Plan Amendment EIS should analyze and consider the economic impacts of road closure on local communities.”
In fact the QLG comment neither said nor meant any such thing. There are three significant references to roads in the QLG letter. The first is two paragraphs before the above quote, where QLG suggests "...short-term reallocation of the landbase maps to protect large roadless and sensitive areas as well as previously designated wilderness areas, and to focus management actions on restoring healthy forest conditions to lands already roaded and logged..." The second reference to roads is more than a page later, where QLG suggests that "Each fuelbreak should contain a road (an existing road wherever possible)..." The third reference is a few pages later, where QLG says "Roads. The landbase usage specified in the QLG bill would put most roadless areas in the QLG area either off-base or deferred from road building. The 'available' landbase in the QLG area is already adequately roaded... and improved maintenance and repair of existing roads is the main problem to address."
Considering the short time-line of the SNCF EIS and the fact that this was a "preliminary" content analysis, we are concerned about whether public comment will actually be interpreted accurately and given its correct weight in the development of the EIS. What is the current status of the "final" content analysis? Will it be revised so as to be a valid reflection of public comment, and will it be complete in time to affect the Draft EIS?
Sincerely,
/s/ /s?
Linda L. Blum Edward C. Murphy
Corresponding Secretaries
Healthy Forests & Stable Communities for the Northern Sierra Nevada, California
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