We need more time to study this proposal.
The Bureau of Land Management and Forest Service spent $35 million and took four years to produce these 4000 page draft Environment Impact Statements (DEIS). The public was given 120 days to read, comprehend and react to them. They will affect 144 million acres, which is 225,000 square miles. That is an area only slightly smaller than the original 13 colonies.
The DEIS’s would reduce or eliminate many human activities, including many private property rights and uses such as farming, logging, mining, grazing, hunting, fishing, and other forms of recreation. We must be extremely thoughtful and cautious about how we proceed.
The US has a moral imperative to feed hungry people throughout the world. The impact should be well documented before we proceed.
Thousands will be denied the use of their land.
This ecosystem management concept by the federal government covers 144 million acres. This area is so massive, it could be our third largest state behind Alaska and Texas. It is only slightly larger than California. 75 million acres are federal lands. The remaining 69 million acres is mostly private property.
The DEIS’s admit that the boundaries of ecosystems are difficult to identify. How much land owned by private citizens will be taken to protect ecosystems and federal lands?
The DEIS’s propose to "provide a predictable, sustainable flow of economic benefits within the capability of the system. The DEIS’s do not define capability of the system and assumes that any action benefiting people could change the landscape and is not within the capability of the system.
Citizens will be denied access to recreation areas.
The DEIS’s say that road closures would hit recreational users the hardest because they account for most road use, 60% in the Upper Columbia River Basin.
The federal government’s experience in ecosystem management has been disastrous for humans.
A new set of values, not scientific findings, stand behind the DEIS’s assumption that nature produces ideal landscapes.
The federal government’s action to set aside habitat (eco-system) for the spotted owl or any other endangered species ignored human values such as jobs, stable families and college for the kids.
The DEIS’s fail to define key regulatory language, leaving too much power with federal regulators.
An ecosystem is anything regulatory agencies want it to be. With this proposal there is no way to prevent regulators from using an arbitrary approach in selecting and establishing boundaries for ecosystems.
The DEIS’s appear to use watersheds to define ecosystems, but in Yellowstone National Park it was the range of the Grizzly Bear. How would ecosystems be defined?
The single most important phrase in the DEIS’s – ecosystem integrity – is not defined in the document and they admit that "Absolute measures of integrity do not exist."
The DEIS’s state that integrity is difficult to measure because we can never know exactly what is in any particular ecosystem, it is always changing, that changes are unpredictable and the boundaries we put on ecosystems are artificial, making it hard to know when you are looking at an entire system or a part.
Scientists who have written about ecosystems over the past 60 years cannot agree what an ecosystem is.
Terms within the DEIS’s reflect the imprecision, uncertainty and confusion often associated with them in scientific literature.
- A dung pile and whale carcass are ecosystems as much as a watershed or a lake.
- - - The Ecological Society of America, 1996
- The fact that no one really knows what ecosystem management means has not diminished enthusiasm for the concept.
- - - Dave Wilcove, Environmental Defense Fund
- I promise you I can do anything you want to do by saying it is ecosystem management ... it’s incredibly nebulous.
- - - Jack Ward Thomas, former Chief US Forest Service
- Ecological systems ... have no boundaries in space or time – they are not discrete, identifiable units like organisms.
- - - Robert Rickles, University of Pennsylvania
- The goal of sustaining ecosystems "is difficult to translate into specific objectives."
- - - Jane Lubchenco, Distinguished Professor of Zoology,
Oregon State University
- Attempts to develop general criteria for evaluating, and therefore defining ecological integrity have not been successful.
- - - James Kay, University of Waterloo
University of South Florida professors K.S. Schrader-Frechette and E.D. McCoy argue that ecology does not have and cannot develop unambiguous standards regarding what constitutes a healthy or normal ecosystem.
- We protect nature by restricting or prohibiting human use of the Earth whenever and wherever possible. When human activities must be allowed, they must be consistent with the maintenance or restoration of ecosystem health and integrity. Those who champion this approach to ecosystem management deem it a moral and ethical imperative.
- - - Reed Noss, Edward LaRoe III & Michael Scott, National Biological Service Report 28, February 1995
- While "health" and "integrity" are used in policy documents as goals of protection efforts, they have never been defined well enough to make them useful in practice."
- - - Robert Costanza, Bryan Norton & Benjamin Haskell (ecosystem management advocates), Ecosystem Health: New Goals for Environmental Management
In a 1990 workshop, Robert Costanza said, "An ecological system is healthy and free from distress syndrome if it is stable and sustainable – that is, if it is active and maintains its organization and autonomy over time and is resilient to stress." What is healthy? What is distress syndrome? What does sustainable mean? How do we know if it is active? When is it stable? How does an ecosystem maintain its organization and autonomy? And, what is organization and autonomy? These definitions are left to regulatory agencies who may define it differently.
Private Citizens will face bureaucracy, uncertainty, lawsuits and delays in decision-making.
The DEIS’s admit as much for all resource providers in stating that Alternatives 3-7 "would introduce uncertainty compared to continuation of current practices." They state that the same alternatives "would make short-term projections of timber supply more uncertain ... it would be difficult to achieve predictable supplies of timber from federal lands" and that "changing the way (grazing) permittees use and invest in their allotments would entail substantial planning, negotiation and administration by the agencies, potentially reducing the predictability of outcomes in the short term."
"Timber, livestock and mining jobs, although a small part of the total regional employment, make up a larger portion of total employment in some communities and counties. Changes in outputs from Forest Service- and BLM-administered lands can have substantial economic and social effects in these areas."
There is no legal authority for ecosystem management.
- Currently there is no government-side legal requirement to maintain or restore ecosystems as such ... [and that no] acts or implementing regulations define or delineate ecosystems or specifically require federal agencies to act to maintain or restore the health of ecosystems.
- - - US General Accounting Office (GAO)
- No single federal statute contains an explicit overreaching national mandate to take an ecosystem approach to management and Congress has never authorized that a particular federal agency has the ecosystem approach as its sole, or even primary, mission.
- - - The White House Interagency Ecosystem Management Task Force
The DEIS’s cite the President’s 1993 directive to the Forest Service to "develop a scientifically sound and ecosystem-based strategy for management of Eastside forests." But it does not offer any statutes requiring or justifying broad-based ecosystem management.
The Senate has refused to ratify the United Nations Convention on Biological Diversity which requires protection of ecosystems.
The Senate took no action on S.93, the "Ecosystem Management Act of 1995" which would have authorized the concept of ecosystem management.
The DEIS’s redefine the meaning of "sustainability."
Sustainability was defined by the Multiple Use and Sustained Yield Act of 1960 to mean a "regular or sustained supply of timber volume in perpetuity." The DEIS’s attempt to circumvent this lawful definition and reinvent the term to include all parts of the ecosystem and to account for disturbance in shaping how the ecosystem changes over time.
Using 1850 as a base, the DEIS’s seek to change the land to what it would be today if European settlers had never arrived.
Why do we need to go back to 1850? The very concept presented within the DEIS’s – nature knows best – runs against the history and nature of humans. We grow crops, build roads, domesticate livestock, develop cures for diseases, build homes and hospitals, and take vacations to get away. Why should we seek to eliminate mankind from the balance? Why should we put the well-being of nature before the well-being of people?
Can’t we have both – protect the environment and allow for humans at the same time?
- The debate over ecosystem management is really about whose values will determine resource management practices in both the public and private sectors.
- - - Ron Johnson, Economist, Montana State University
- The goal of ecosystem integrity places the protection of ecosystem patterns and processes before satisfaction of human needs.
- - - Ed Grumbine, The Sierra Institute
The DEIS’s do not explain which 1850 vegetation map was used by the researchers or why.
They do not explain how they overcome the inherent uncertainty and inaccuracy that are part and parcel of trying to recreate past landscapes in order to produce a viable standard to guide present public policy decisions.
If the 1850 map is inaccurate – and how can they verify its accuracy – how can we possibly know what the landscape should look like 100 years from now?
The DEIS’s attempt the impossible by projecting 100 years into the future.
The Department of Energy refused to make projections beyond 2030 for the National Energy Strategy because they deemed such estimates would be valueless owing to the inability to make meaningful appraisals about all the factors that influence energy production and consumption.
The DEIS’s projections do not account for obvious factors like societal change; new laws and policies; living and non-living components; technological change; shifting perceptions and preferences; how the outdoors is viewed; what is considered ideal homesites; and, cultural changes, etc.
The DEIS’s create a new term – landscape health.
Landscape health is not a scientific term. It has never been defined or used in any other document.
Show us the maps.
The DEIS’s contain more than 100 maps, but not a single one shows the ecosystem(s) the Federal Government propose to regulate.
Since the DEIS’s admit that the boundaries we put on ecosystems are artificial, doesn’t it make sense for the federal government to show us what it proposes to regulate?
US Fish and Wildlife has a map of the US that shows 42 ecosystems. The Forest Service has a US map that shows 57 ecosystems. The US Environmental Protection Agency’s US map shows 103 ecosystems.
Most of this material was produced by the Washington State Farm Bureau. Copies of the 40-page DEIS analysis from which these talking points were developed are available at ALRA.