Did you miss the public open house held in Moab for planning the first revision of the Manti-La Sal National Forest plan in 32 years (Moab Sun News, “Forest service revising management plan,” Nov. 21)? Don’t worry: there is a law that will allow you to study and weigh in on distinct alternatives in 2019 for the Manti-La Sal National Forest.
Our local 1.2 million acre national forest doesn’t only rise above Moab; it hosts part of the Bears Ears National Monument in the Monticello District west of Blanding, and is being dug for coal, grazed by domestic sheep and providing a bare-bones home for year-round greater sage-grouse in the Ferron-Price and Sanpete districts up by Price.
And the law that gives you additional chances to weigh in? The National Environmental Policy Act (NEPA), which requires that Environmental Impact Statements (or EISs, such as the one that will be required for the Manti-La Sal plan revision) be public friendly.
Crucially, NEPA says the EIS must “rigorously explore and objectively evaluate all reasonable alternatives” to the proposed plan. The EIS must present the alternatives “…in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision-maker and the public.”
This is an amazing requirement. NEPA is saying that a federal agency (the U.S. Forest Service) cannot simply develop the new plan. NEPA requires the forest to publicly compare “all reasonable alternatives” in terms of their environmental impacts.
And when the forest service does analyze the alternatives, it has to use facts: “Agencies shall insure the professional integrity, including scientific integrity of the discussions and analyses in environmental impact statements.”
In addition to requiring alternatives and the use of facts to compare the potential impacts of each alternative, NEPA requires that the forest service respond to information in your comments on the alternatives, by either modifying or developing different alternatives, improving its analyses, making factual corrections, or “explain[ing] why the comments do not warrant further agency response.”
So, what about the alternatives?
Remarkably, the NEPA regulations do not require that the “reasonable alternatives” be generated only by the agency. Too often, agencies write the alternative they want, and then write some “straw-person” alternatives that have any of a number of poison pills in them to ensure that nobody else will want those alternatives.
Under NEPA, alternatives can be developed by non-agency entities, and if they are reasonable, the agency must analyze them to meet the “all reasonable alternatives” requirement.
Of course, it’s no small task to develop a comprehensive alternative for an entire forest. So many activities must be included in the alternative: recreation, grazing, wildlife, watersheds, forest-cutting, cultural sites, endangered species, fire, insects, transportation and more.
For the past year, several conservation organizations have been writing an alternative for the Manti-La Sal National Forest plan that will emphasize the long term health of the forest.
The alternative being developed is reasonable and feasible to implement (even with the current, deplorable lack of funding for non-fire forest service staffing). But it will likely be different than the one developed by the Manti-La Sal National Forest — and that’s the reason for alternatives.
For instance, the Moab Sun News’ article on the public meeting reported that forest service grazing manager Tina Marian said people won’t see a lot of grazing changes in the new plan that aren’t already being implemented on the ground. She shouldn’t predetermine that outcome. The conservation alternative will recommend changes to how grazing is implemented in the forest (which is a part of Moab’s watershed), like reducing the rate of cattle grazing.
The alternative will propose a process by which at least some allotments could become cattle-free — voluntarily by the permittee — as has happened in other national forests and public lands. The alternative will ensure that pinyon and juniper communities are not removed on thousands of acres for the purposes of growing grass for cattle and artificial populations of elk.
It will require the forest to remove the non-native mountain goats that are tearing up the rare alpine area above 11,000 feet in the Manti-La Sal Mountains. It will not allow honeybee apiaries, which would devastate native bees.
The forest plan process is a long one — likely four years from 2016 when the process began. But please hang in there, and really weigh in on how this forest should be treated for the coming 10 or 15 — hopefully not 32 — years amid rising heat, deeper droughts and more of us spending time at this national treasure.
Mary O’Brien lives in Castle Valley, is a NEPA nerd, a botanist and a lifelong devotee of public lands.
“It will require the forest to remove the non-native mountain goats that are tearing up the rare alpine area above 11,000 feet in the Manti-La Sal Mountains.”
