Healthy Forest Initiative

Submitted via e-mail to:

Healthy Forests Initiative,

USDA FS Content Analysis Team

P.O. Box 221150

Salt Lake City, Utah 84116

Comments on:

National Environmental Policy Act Documentation Needed for Fire Management Activities; Categorical Exclusions

Notice of Proposed National Environmental Policy Act Implementing Procedures

December 16, 2002, (67 FR 77038)

Submitted by:

Wayne T. Brough, Ph.D.

On behalf of:

Citizens for a Sound Economy Foundation

1900 M Street, N.W., Suite 500

Washington, D.C. 20036

January 31, 2003

Citizens for a Sound Economy Foundation (“CSE Foundation”), is a nonprofit, nonpartisan organization with approximately 280,000 members. Its mission is to educate citizens on, and to promote the adoption of, free-market policies, which it believes inure to the benefit of consumers and citizens generally. CSE Foundation welcomes the opportunity to submit comments on the Department of Agriculture and the Department of the Interior’s “National Environmental Policy Act Documentation Needed for Fire Management Activities; Categorical Exclusions,” (FR Doc. 02-31576). We strongly support the agencies’ efforts to establish two new categorical exclusions as a means of implementing the policies of the Healthy Forests Initiative.

The proposal, which would create categorical exclusions for hazardous fuels reduction activities and for rehabilitation and stabilization activities on National Forest system lands, is an important step toward reducing the catastrophic losses associated with wildfires. In response to the threat of wildfires and the declining health of the national forests, President Bush announced a new initiative to develop a common sense approach to forest management. The Healthy Forests Initiative seeks to promote healthy forests through better oversight and management practices. The plan calls for reforms to environmental laws to reduce the red tape and litigation that has restricted forest management in the past. The proposal to create new categorical exclusions is an integral component of this process.

The administration’s Healthy Forests Initiative takes a much more sensible approach to forest management, based on principles supported by science and forestry. The plan would streamline administrative processes that have paralyzed forest management in the United States. In particular, the National Environmental Policy Act (NEPA) has imposed significant paperwork burdens on both the Forest Service and Bureau of Land management while fostering litigation that can substantially delay policy implementation. Originally, NEPA was enacted to provide policy makers information about the potential impacts of a policy decision. Under NEPA, each agency is required to establish criteria to evaluate policies for three categories: (1) actions that require a policy impact statement; (2) actions that require an environmental assessment; and (3) actions that area categorically excluded from additional analysis because they “do not individually or cumulatively have a significant impact on the human environment and warrant no further analysis and documentation in an environmental assessment or environmental impact statement.”

Hazardous fuels reduction and rehabilitation and stabilization actions qualify for categorical exclusions according to analysis by the agencies involved, which released a major study of more than 3,000 hazardous fuels reduction and rehabilitation and stabilization activities. As noted in the Federal Register announcement, “The review indicates that hazardous fuels reduction activities and rehabilitation/stabilization activities, absent extraordinary circumstances, do not individually or cumulatively have significant effects on the human environment.” (FR vol. 67, no. 241, p. 77042).

It is important to emphasize that that the proposed categorical exclusions do not act to circumvent environmental regulations. When conducted, these activities are subject to existing federal, state, and tribal laws environmental requirements, such as the Clean Air Act. In addition, they are implemented under procedures that provide ample opportunities for public comment, as outlined in the 10-Year Comprehensive Strategy for managing the nation’s forests.

For the reasons outlined above, CSE Foundation strongly endorses the Department of Agriculture and the Department of Interior’s proposal for two new categorical exclusions. Forests are an important resource in our nation’s economy and 190 million acres of national forests alone are under threat to wildfire or blight. The proposed categorical exclusions would allow a more efficient and expedient management of the nation’s forests and should adopted as soon as possible.

Wayne T. Brough, Ph.D.

Chief Economist