In the six years since the Pisgah-Nantahala National Forest land management plan revision began, the U.S. Forest Service has collected thousands of comments. The public record includes remarks from individuals, special interest groups and collaborative groups.
The comments submitted to the federal government also include many from state and local government entities.
This, the third of three articles on the results of a Carolina Public Press Freedom of Information Act request for the more than 6,000 comments, focuses on these governmental emails.
Government comments taken seriously
Sharon Friedman, who moderates Smokey Wire, a blog about national forest policy, is a retired Forest Service bureaucrat who participated in the development of current national forest planning rules and regulations.
New forest plans, such as the Pisgah-Nantahala are treading into “uncharted territory,” Friedman said. “It’s an enormously complicated process that everyone — the Forest Service, the public, stakeholders, elected officials — is trying to navigate for the first time.”
The last forest plan to oversee the more than a million acres of national forest in Western North Carolina was completed in 1994. The current revision process began in 2012. Later this winter, the Forest Service is expected to release a draft management plan and draft environmental impact statement.
“The Forest Service is going down this path among all of these competing groups that want different things for the same piece of land,” Friedman said. “It’s a lot for one process to carry.”
Nevertheless, she said, “There’s plenty of reason to believe that the trove of comments can lead to a better plan. The beauty of a forest plan is that it’s a community having a discussion about the future.”
“Governments’ and tribes’ points of view count,” said Friedman, who served as the planning director for the Forest Service’s Rocky Mountain region.
“It’s part of the regulation that the Forest Service has to cooperate with states and take them seriously.”
Providing feds with information
State agencies have often provided the Forest Service with expertise, science and other information to inform federal forest planners.
A key state agency in the revision has been the N.C. Wildlife Resources Commission, which is mandated by the N.C. General Assembly to “conserve and sustain the state’s fish and wildlife resources through research, scientific management, wise use and public input.” North Carolina legislation designates wildlife — both game and nongame species — as a public trust resource and under the stewardship of the NCWRC regardless of the land ownership.
In practice, the state agency has had a long history of advising and working with public land managers, including the Forest Service.
Many of the comments from the NCWRC are technical. For example, an October 2016 cover letter and document details recommendations for placement of management areas in the national forests as part of the revision process. The document includes a detailed table that outlines “characteristics” of each management area.
Other state agencies have provided similar input and feedback.
The N.C. Natural Heritage Program, a state agency, consolidates information about rare species and natural communities and protects areas with significant species diversity or natural features — some within national forest boundaries. In 2015, Director Misty Buchanan wrote: “The Natural Heritage Program recognizes the complexity of developing a management proposal for such a diverse landscape. … We anticipate that updated mapping may improve the outcome of the management plan revision and help ensure that protection of the existing and proposed Registered Heritage Areas.”
According to the Forest Service, state, local and tribal governments should be prepared to clearly describe how their public mission or responsibilities are affected by the management of national forests.
An example in this spirit is a letter from Steve Troxler, commissioner of the N.C. Department of Agriculture and Consumer Services who wrote in a Feb. 21, 2013, letter that the Forest Service should “continue to allow year-round hunting and other taking opportunities for feral swine” to prevent potential damage to crops and cropland.
“Any significant restriction on control measure for feral swine would provide these invasive species with a haven supporting significant population growth, which would result in considerable negative impacts on both public and private land in North Carolina,” Troxler wrote.
Local government, local representatives and federal land
Forest Service records show that local governments and elected officials have participated in the use and management of federal lands. A common theme that emerged were concerns over their ability to manage land within their borders.
The McDowell County Soil and Water Conservation District board of supervisors wrote in a letter from 2014 to the Forest Service that “the economic vitality of the rural communities will be enhanced by logging receipts, tourist and recreational users of the forest, and increase of sportsmen utilizing the forest to pursue game and fish. All of the aforementioned revenue sources are economically sound and beneficial to the rural communities we live in that are surrounded by USFS land.”
The McDowell Soil and Water Conservation District includes both elected and appointed positions. In all, McDowell County has over 73,000 acres of national forest land.
State Rep. Chris Whitmire, R-Transylvania, wrote in a letter on April 26, 2014, that because Transylvania County “has a tremendous percentage of their land masses classified as federal forest and not available for economic development further restricting these areas as wilderness and road-less is troubling.”
U.S. Rep. Mark Meadows, R-Sapphire, represents the 11th U.S. Congressional District, which includes a large share of the Pisgah and Nantahala national forest acres. In an April 15, 2014, letter he wrote: “The Pisgah and Nantahala National Forests are an important part of Western North Carolina’s heritage and key drivers of economic growth in the region.
With that in mind, I respectfully urge you to consider a balanced land management plan that incorporates the needs of all relevant stakeholders, including the timber industry and hunting and fishing groups.”
The record of comments also included nine county resolutions and three city resolutions that were in favor of fewer restrictions on how federal forest land is managed. For example, the following is a sample from a resolution passed by the Caldwell County Commission in October 2016 and submitted as a public comment to the Forest Service.
“Whereas, the National Forest lands within Caldwell County significantly enhance the County’s economy and the Caldwell County Board of Commissioners believes that further expansion of wilderness area would negatively impact the County; and Whereas, inclusion of additional land into the Federal Wilderness Protection System will result in greater regulations and restrictions on recreation, hunting, timber management, etc.; and, …”
Peter Bates, a natural resource conservation and management faculty at Western Carolina University, told CPP that resource management issues are often driven by local economic factors. “If we want to practice sustainable management, we have to think about the social stuff. (Local communities) have to buy into what the Forest Service is doing, so I don’t see anything wrong with local governments stating their position.”
But exactly how the Forest Service uses those resolutions and concerns is complicated. For example, elected bodies from the most populous county in Western North Carolina, Buncombe County, and the largest city, Asheville, are in favor of more significant land protection.
The following is a segment of the resolution passed by the Asheville City Council in August 2017:
“WHEREAS, Craggy/Big Ivy offers some of the best opportunities for primitive recreation and solitude in Buncombe County and throughout the Pisgah National Forest with rugged, remote peaks and ridges that are surrounded by 100,000 acres of contiguous wildlands, making Big Ivy an ideal location for wilderness; and BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF ASHEVILLE THAT: 1. That the expanded Craggy Mountains Wilderness Study Area be recommended for designation as a wilderness area by the U.S. Forest Service and designated by the U.S. Congress.”
While the anti-wilderness resolutions outnumber pro-wilderness resolutions, since there are counties on both sides of the issue, Friedman said it “gives planners leeway to find a path through the middle. But even if the counties all lined up on one side, they wouldn’t dictate what the Forest Service would do. They are going to do their best to take all voices into account.”
Sam Evans, an attorney with the Southern Environmental Law Center in Asheville, wrote in an email to CPP that the Forest Service is required by law to listen to local government input but is prohibited from simply adopting a local government’s preferences.
“The Forest Service is required to balance many needs, so blanket opposition to any one of those needs, whether timber or wilderness, isn’t helpful whether it comes from a local government or anyone else,” Evans said.
“But local government input can be very useful when it explains the community’s plans for the future, such as needs for future water supplies or facilities needed to draw tourists.”
State agency and special interest groups
Comments show that state agencies, particularly the NCWRC, have provided both counties and special interest groups with expertise behind some of their comments.
In 2017, CPP reported on a controversy in April 2014 that followed a PowerPoint presentation shared with the Fish and Wildlife Conservation Council, a volunteer sportsmen’s group with statements that opposed wilderness.
A May 14, 2014, letter from the NCWRC to the Forest Service demonstrates that position in response to a Forest Service designation and scenery workshop help in 2014. “NCWRC is opposed to additional wilderness areas at this time,” wrote Doug Besler, the mountain region fishery supervisor. “The economic impacts of removing any area from the suitable timber base should be weighed, including the impacts to counties dependent on payments for schools.”
Several letters and comments from others reflect a similar logic.
For example, Rep. Whitmire wrote: “According to the NCWRC more (than) 70 percent of public forest lands have some type of restrictive use designation.” Later in the letter he concluded, “The desired goal with the Nantahala and Pisgah Forests should be conservation and sustainability, and the way to achieve that is through a working and well-managed forest.”
Similar text appears in other letters to the Forest Service, suggesting a similar source. Such as this letter from Manly West, the president of the N.C. Association of Soil and Water Conservation Districts. The organization represents local soil and water conservation districts. He wrote: “According to the NCWRC more than 70 percent of public forest lands have some type of restrictive use designation” and “the desired goal with the Nantahala and Pisgah Forests should be conservation and sustainability and the way to achieve that is through a working and well-managed forest.”
Since 2014, however, the NCWRC has moderated its position on wilderness. Evidence is a 2016 comment letter that focused on geographical areas and avoids any position on wilderness.
CPP also reported that the NCWRC formed a “forest plan workgroup” in 2015 to develop a clear process for providing input from the agency to the forest plan.
“The main reason to form the workgroup was to have a single voice that brought input from different voices on the commission working with different facets of wildlife – game and nongame, terrestrial and aquatic,” NCWRC biologist Andrea Leslie told CPP in 2017.
“We’re not opposing or supporting any specific wilderness, we’re here to address our interests, which is wildlife conservation.”
Which comments matter most?
Will Harlan, an organizer of the Friends of Big Ivy and editor-in-chief of Blue Ridge Outdoors magazine, said that an analysis of more than 22,000 comments conducted by the magazine, faculty at UNC Asheville and the organization I Heart Pisgah, showed that 92 percent of the comments analyzed were in favor of “more, stronger and permanent protection for the Pisgah National Forest; while 8 percent were against protected areas or wanted more logging.”
“Analyzing comments is much more of an art than a science,” Friedman said. “There’s really no objective way to analyze the content.”
However, she said, planners will likely consider the expertise of the commenter, the rationale for their comment, and its specificity.
“What is useful to planners is (for commenters) to say, ‘I want X activity in Y places for Z reasons.’ That’s so much more helpful than saying, ‘I want (more or less) protection’ since the meaning of ‘protection’ may not always be clear,” she said.
The most useful comments, Friedman said, often come from stakeholders groups. A reliance on stakeholder groups is “enshrined” in the 2012 planning rule. In fact, the Forest Service often relies on groups of stakeholders on major projects, such as the Grandfather Restoration Project in the Pisgah National Forest that is a decade-long effort to restore 40,000 acres of forest.
In all, two stakeholders groups have been active in the forest plan revision and have submitted detailed comments that seek balance among various interests and users.
For example, the introduction to a 43-page document from October 2017 submitted as public comment explains the approach of the Nantahala-Pisgah Forest Partnership:
“We, the ‘Partnership,’ are a collaborative of over 30 organizations representing a diverse cross section of public lands interests, including recreation, forest products, cultural heritage, conservation, wildlife, hunting, angling as well as other forest user groups. … Our approach strives to reach community-supported, science-based methods for forest management, interpretation and investment. … Beyond the forest plan, we are committed to creating a lasting voice for innovative management and public investment in the public forests of North Carolina’s mountains for the future.”
“Comments from individuals sometimes don’t include their rationale for a position or may bend the facts in their favor,” Friedman said. “Stakeholders groups hold each other accountable, and the conversation is able to go to a much deeper level.”
Another benefit, said Evans of the SELC, is that collaborative comments can help the Forest Service understand “a broader zone of consent” around divisive topics, such as wilderness designation and timber harvesting.
While special interest groups, for instance, can provide valuable information to the Forest Service, “they often state a position in order to negotiate,” Friedman said. “So it’s hard to know where they stand.” For instance, a group may be satisfied with 10,000 acres of land to accommodate its use, but it may ask for 20,000 acres.
Evans said, “Collaborative comments take the form of statements and positions that acknowledge that the Forest Service can promote many different values simultaneously. Collaborative comments often take the form of ‘I can support use X, if my needs are met too.’ Most public comments take the form of zero-sum statements that consist of two parts: a fear or hope plus a ‘do’ or a ‘do not.’ For example, ‘I support logging, so I’m opposed to wilderness.’ Or, ‘I support managing for wilderness character, so I don’t want logging.’”
Mostly absent from the collaborative groups are elected officials. While elected officials represent residents, Friedman said, they are seldom effective members of stakeholders groups that strive for collaborative solutions.
“They may not share the level of passion and knowledge of individuals, experts and special interest groups that participate in stakeholders groups,” she said.
“Forest planning is only one of many things counties have on their plates, and so their comments tend to be very big-picture. And that’s absolutely appropriate. At the same time, there are infinite possibilities in where you can do both …’keep timber in the pipeline’ and ‘be protective,’ or ‘make everything recommended wilderness’ and ‘make nothing recommended wilderness.’ Ultimately, that’s the balance the Forest Service and collaborative groups explore in detail.”
Some previous CPP reporting on national forests
- Interest group emails compete to influence NC national forests’ future, Jan. 7, 2019, link
- Emails show depth of public concern about future of NC national forests, Dec. 20, 2018, link
- Massive volume of comments delays draft forest plan’s release, Sept. 28, 2018, link
- Wilderness protection for coveted trails divides cyclists, conservationists, May 21, 2018, link
- Long process of revising plans for national forests reaches crucial point, March 2, 2018, link
- Thousands of years of expertise: Cherokees contribute to National Forest management plan, Dec. 21, 2017, link
- Angry signs in the NC wilderness, April 15, 2016, link
- Illegal shooters trashing Eastern North Carolina public lands, Aug. 6, 2018, link
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