Davidson River in the Pisgah National Forest in Transylvania County. File photo/Carolina Public Press

Later this winter, the US Forest Service is expected to share a draft of the Pisgah-Nantahala National Forest land management plan, wrapping up six years of work.

With the passage of the National Forest Management Act of 1976, the Forest Service is mandated to include the public in the oversight of its multi-use land throughout the country. The Pisgah-Nantahala National Forest Management Plan is one of more than 100 plans across the country, which the Forest Service revises every 15 to 20 years.

In 2012, new planning rules required the Forest Service to expand and strengthen its level of public input, creating a management plan that represents the public interest. Because of the wide array of interests and uses in a national forest, forest planners must balance the interest of numerous groups with competing interests.

Thanks to a federal Freedom of Information Act request, Carolina Public Press has studied thousands of emails and other comments delivered to the Forest Service.  This, the second of three articles, examines the comments from individuals representing the views of advocacy organizations that have campaigned to influence the Forest Service’s management strategies. (See part one, here.)

“In public commenting, letters (and emails) tend to be more effective because rule makers have more time to catalog them and to understand their meaning,” political scientist Chris Cooper of Western Carolina University told CPP.

Emails written since 2013 may shed light on how the comments will play out in the planning process, since the law requires the Forest Service to consider the public’s views and the best available scientific information. As a result, the emails examined in this article may reveal the role of interest groups in shaping the future of the national forests.

Comments show that grassroots organizations – intentionally or not – have used similar tactics, such as emotional arguments, to influence the future management decisions of the Forest Service.

Several statewide and national organizations, such as the Wilderness Society and the National Wildlife Federation, have commented during the revision process. But many emails represent the views of local organizations and user groups – such as the Fish and Wildlife Conservation Council, the Friends of Big Ivy, and mountain bikers – who have played active and forceful roles during the forest plan revision.

Just the facts

Many of the emails present verifiable information about the condition of the national forests in Western North Carolina and how they are used. For example, environmental scientist Michael Stevens’ opposition to timber harvesting in the Big Ivy area of Buncombe County in the Pisgah National Forest identifies invasive plant species as a reason for land protection.

“Invasive exotics love disturbance (there is a direct correlation of disturbance to invasive plant establishment).  The high quality of understory plants such as blue and black cohosh, ginseng, etc… will be irreparably harmed.   There are … other reasons to not disturb such prime habitat, but of primary concern to me is the … invasives issue that is not under control,” Stevens wrote.

In contrast, in a position letter to the Forest Service, David Whitmore, chair of the Fish and Wildlife Conservation Council, used ecological knowledge about the age of trees to argue for more flexibility in forest management:

“Given the documented lack of early successional habitat (ESH) on Pisgah-Nantahala, the fact that additional designations could impact our ability to establish ESH is one of our great concerns,” Whitmire wrote. “Many wildlife species requiring this type of habitat have already declined over the past 15 years due to a lack of active forestry management.”

Craig Harper, a wildlife specialist at the University of Tennessee, wrote: “I do not believe designating additional acreage as wilderness would be in the best interest of our natural resources or public use. I believe allowing more proactive management as determined by USDA-Forest Service biologists as well as biologists with the NC Wildlife Resources Commission is most needed for the greatest number of species and ecosystem management.”

Economic and personal arguments

While the science underlying their positions matter, political scientists and economists suggest that regulatory decisions are likely to be reinforced if science and ecological knowledge are supported by economic considerations, which many of those submitting comments did.

For instance, Kevin Thompson, a guide for Navitat Canopy Adventures at the time of his email, said: “(The) Big Ivy area constitutes the vast majority of the view-shed enjoyed by over 20,000 Navitat visitors each year when they are zip-lining and looking out at the spectacular vista below the Craggies.”

Ed Taylor, a retired engineer from Brevard said, “I am concerned over any proposal to increase the percentage of forest land managed as wilderness…. The economic impact of restricting more federal lands from timber harvest could impact local economies which are already depressed.”

The emails demonstrate that local organizations not only submit detailed technical comments and form letters, their platforms are supported by personalized emails that portray more subjective cultural views of the forest.

Kim Maney Ray, whose “great-great grandparents settled in the Dillingham section of Big Ivy” wrote, “Please do not cut Big Ivy. Please help maintain this area as a preserved area. You have a chance to make a big difference in this world – and a way of life that is subject to being lost forever in this area of the Southern Appalachians.”

Or this one, by Marc Bischof of Franklin who wrote: “As a lifelong hunter and outdoorsmen, now at the age of 62, I appreciate the biorhythm of wildlife and I can tell you ours is in dire need of our attention and commitment. Practices that were employed by our native predecessors, whose heart beat in synchrony with the land and its wild inhabitants, need to be revived.”

‘Baptists and bootleggers’

“Public choice” economists who study how public rules and regulation evolve have developed theories to explain the influence of special-interest groups. One theory, known as the “bootlegger and Baptist” theory of regulation, may provide a useful lens to interpret the commenting in the forest plan revision.

Former Clemson University economist Bruce Yandle wrote that his theory comes from the effort to regulate alcohol by banning Sunday sales at legal outlets. “Baptists,” he wrote, “endorsed such actions on moral ground.” However, “bootleggers” also supported the ban on alcohol since it eliminated their competition and allowed them to sell more.

Groups represented by “Baptists” tend to be organized around moral and emotional arguments to influence regulation, while “bootlegger” groups may be organized around financial interests. In spite of different motivations and political strengths, “bootlegger” and “Baptist” groups benefit by formally or informally joining forces. The theory explains that special-interest groups that don’t necessarily meet or coordinate, but who desire the same outcome, will adopt similar arguments and strategies to achieve their goal.

The theory may provide a framework to explain how forest planners may be influenced by the political engagement and interaction of individuals and groups who have participated in the forest plan revision. This concept may also untangle the array of intentional or unintentional strategies that pro-wilderness and anti-wilderness groups have used to support their agendas.

The degree of land protection, that includes federal wilderness designation, has an impact on how sections of the forest may be used.

“Some of these access issues are good examples of where you get strange bedfellows,” said Cooper. “It can be really effective if you get multiple interest groups together.”

For example, while mountain bikers, hunters, wildlife experts, the timber products industry, and local governments may not be formally aligned, they share concerns over additional federal wilderness designation. Current rules prohibit mountain bikes and some hunters view wilderness designation as an access barrier, among other concerns.

Jim Gray, a leader of the Fish and Wildlife Conservation Council, which advocates for sportsmen, represents the interests of grouse hunters in the revision process. In an email he advocates for more habitat management and access for sportsmen.

Gray wrote: “The Forest Service is damaging wildlife populations by allowing more and more forest to transition to mature growth forest.  I am very opposed to the designation of additional areas that are excluded to management of timber, by whatever means – special designation, designation as “scenery”, etc.”

In the same email, Gray attempts to strengthen his argument by presenting a “bootlegger” argument, too:

“The National Forests should function as a reserve of timber to meet the nation’s needs for forest products. By these actions the Forest Service is directly eliminating many jobs for timber products workers in Western North Carolina. The timber products industry is an important part of the culture of Western North Carolina and the Forest Service is involved in destroying this culture,” he wrote.

Among the comments delivered to the Forest Service were resolutions by several western NC county governments that included this statement to justify their opposition to additional wilderness designation for economics reasons:

“WHEREAS, the Cherokee County Board of Commissioners hereby express a desire to maintain and support our ever decreasing timber industry, and to retain its economical input into county revenue and school revenue streams for Graham County and Cherokee County….”

Michael Despeaux, a mountain biker from Jackson County, values land protection, but is opposed to its current set of rules that prohibit mountain biking.

He wrote: “The interpretation of mechanized equipment to include human-powered bicycles by the Wilderness Act is very unfortunate and creates an unsupportable, irrational, and unfair double standard. Please represent our (the cycling community) interests equally. We may not have the most powerful lobby, but we constitute a very large, supportive, responsible, visible, and committing user group that leads young people into the wilderness and leaves minimal trace while maximizing enjoyment and access to natural areas.”

Rhetoric Matters

Yandle’s theory predicts that “rhetoric matters” in how rules are determined in a political process where special interest groups can participate. Since “Baptist” groups typically believe “fervently in their cause,” Yandle said, they may rely on emotion to reinforce their positions.

While most emails that CPP reviewed were polite, an emotional strategy may explain why portions of the Pisgah-Nantahala revision process has seen testy attacks on opponents and have inflamed and engaged their cadre of supporters in the planning process. For example, this email from Gina Tines in response to her concerns over timber harvesting:

“Please listen to the many cries of the people I am sure you are receiving,” Tines wrote.

“It is unwise to upset so many people who live in this area as their home. Please, rethink these selfish and cold proposed actions. I pray that you make the right choice and cancel this proposal. Shine your enviromental consciousness to the world by saying NO to this forest degradation. You are the National Forest Service!! You are here to protect our forest not destroy them!! This is not the type of reputation that you want to have.”

Many of the emails show that wilderness advocates and anti-wilderness advocates – in addition to using arguments based on science, economics and local knowledge – have adopted moral perspectives to form compelling argument.

For example, Gray suggests that environmental groups and the Forest Service are colluding. He argues this to elevate his interest as more noble and establish a superior moral perspective:

“I also believe that the Forest Service is siding with, colluding with and favoring environmentalist groups that are pressing for the elimination of timber cutting,” Gray writes. “I close by imploring you to resist the efforts of the environmentalist groups, to resist the efforts of protectionists within the Forest Service and to manage the national forests as they have been historically managed – for the benefit of jobs, culture, wildlife, watersheds, species preservation and recreational interests that benefit from a broad mix of multiple age forests.”

Will Harlan, a co-founder of the Friends of Big Ivy, blends ecological rationale in an email to protect “one of the most special places in the Pisgah National Forest, (which) deserves protections for its old-growth forests that provide crucial habitat for native brook trout and many other rare and endangered species.”

Harlan also delivers an economic and moral argument for protection:

“I am dismayed to see that the Forest Service’s draft management plan for Big Ivy seems to undermine both our local tourism-based economy and the past progress made in protecting remote and ecologically sensitive areas of our forests. This is a big step backward, when past plans have made headway to concentrate logging and other extractive uses in places where it makes sense. Thank you for doing the right thing and protecting Big Ivy from large commercial timber operations.”

Nicholas (last name not given) of Wiesenberg, Ohio, combines an economic argument and moral perspective to support access for mountain biking:

“The area has some of the very best big adventure mountain bike riding that can be found in the east,” he wrote. “The area attracts a type of individual who loves nature and has a desire for a true backcountry riding experience. We not only come to ride but we also spend money in local establishments, hotels, etc. … quite a lot of money in many cases.”

Eleanor Dye, however, singles out mountain bikers for criticism in her emotional email:

“I write to you to express my OPPOSITION to the National Forest Service for a new Pisgah and Nantahala National Forests Plan that provides both more bicycle wheels as recreational opportunities.  We should be conserving Western North Carolina’s backcountry and wild places.

NEVER has the bicycling group stopped at an acreage grab. They will want more.” she wrote.

Plan Alternatives

This winter, the Forest Service will release a draft plan that will include several possible management alternatives that balance the public’s demands for management of the forests.

For their part, Forest Service employees are well aware of the emotion among forest users and advocates, but have said the public comments have helped them “understand how different people use, depend on and appreciate the Nantahala and Pisgah National Forests and provide the planning team with information that we may not have,” according to Forest Service planner Michelle Aldridge.

She said the planning team hopes to create a plan that is not polarizing and that won’t “set people back to corners” and encourage diverse interests to collaborate.

Nevertheless, Cooper said that whether there is more or less protection, forest planners could be swayed by the organizations that are more effective in conveying their message.

“I think it is a healthy debate whether (forest planning) is democracy at its best, or if this is another avenue for special interest influence,” he said.

“I do believe the Forest Service listens to public opinion, but is it singing louder for some groups than for others?”

Selected previous reporting on the National Forest management plan revision process

  • Emails show depth of public concern for future of NC national forests, Dec. 20, 2018: link
  • Massive volume of comments delays draft forest plan’s release, Sept. 28, 2018: link
  • Graham County, where the national forest drives the economy, June 25, 2018: link
  • Wilderness protection for coveted trails divides cyclists, conservationists, May 21, 2018: link
  • Long process of revising plan for national forests nears crucial point, March 2, 2018: link
  • Thousands of years of expertise: Cherokees contribute to national forest management plan, Dec. 21, 2017: link
  • Big Ivy support bucks trend of local government opposition to wilderness, Oct. 3, 2017: link
  • Wildlife at center of disagreements in revising national forests plan, June 5, 2017: link
  • Long process of national forests plan revision continues, May 15, 2017: link
  • Wilderness recommendations face challenging political path, Sept. 6, 2016: link
  • Wilderness alternatives could expand acreage or stand pat, July 26, 2016: link
  • Changing times in Franklin, changing attitudes on national forests, June 9, 2016: link
  • Forest service in home stretch on draft forest plan, May 12, 2016: link
  • Angry signs in the NC wilderness, April 25, 2016: link
  • Forest process could protect more Western North Carolina rivers, Jan. 26, 2016: link
  • Behind-the-scenes effort seeks harmony on forests plan, Oct. 21, 2015: link

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