Press release from USFS
The Best Responses to Complex Comments Takes Time
In December 2016 we introduced you to the comment review team that is analyzing the public comments the Forest Service received on the draft environmental impact statement (EIS) and draft forest plans for the Inyo, Sequoia and Sierra National Forests. It’s time for an update on their progress.
First, here are two key terms associated with our comment analysis:
Substantive comment – provides supporting facts or information, and pertains to the proposed action (draft forest plans). Comments may present new information relevant to our analysis, present reasonable alternatives we didn’t consider in our analysis, or challenge the accuracy of our information, methodology or analysis.
Issue statement – restatement of a public comment or concern in a concise, cause-and-effect relationship that links environmental effects to actions.
While reading all the comments we received, the review team determined if the comments were substantive. If so, we then coded them to identify key themes and concerns raised in each comment. This coding resulted in 70 topic areas, including grazing, recreation, tree mortality, partnerships, wilderness, and motorized trails – just to name a few.
During coding we determined that about 7,000 substantive, unique comments (not counting repeated comments or form letters) were submitted. The coded comments resulted in about 1,700 issue statements. When listed one after the other, the issue statements would average about 6 issues per page, for a total of 324 pages of data.
We are using the 70 topic areas to develop strategies for responding to comments. How we respond to comments will ultimately shape the final EIS and forest plans. In other words the selected alternative we present in the final EIS will be a combination of adaptive management techniques developed in response to the issues raised by the public comments.
Now let’s dig into the content of those comments and how it’s guiding our next steps.
The majority of public comments requested more information about our analysis. For instance people asked for more descriptive plan components associated with sustainable recreation, winter specific recreation opportunities, special recreation management areas, and management prescriptions for wilderness areas. We also received requests for more complete wild and scenic rivers inventories, as well as clearer analysis and consideration of critical aquatic refuges, and greater explanations of land allocations.
In developing responses to comments, we are assessing what changes are necessary to the draft environmental impact statement and plans. This is a complex task: there is no simple formula for determining how being responsive to comments will affect our analysis.
For instance, meeting a request to supply a lot of information in one topic area may not be a substantial alteration to the overall final document (EIS or forest plan); however, meeting a request to improve or provide a small amount of data across many portions of the draft document could result in an entirely new document that doesn’t resemble what the public reviewed last summer.
The good news is that there are several potential options for addressing issues and concerns raised by the public, such as: making modifications to the current alternatives; developing or evaluating alternatives not previously considered; producing a supplemental EIS and draft plans; improving or modifying the current analysis, and making factual corrections based on public comments.
Any of these approaches may be acceptable and will lead us to another round of considerations: does the result of any of these approaches lead to a completely new document that the public wouldn’t recognize? If so, is that okay because we are truly being responsive to the input we received?
The complexity of these deliberations doesn’t end here with responding to public comments. There’s more for us to consider.
We’re now beginning to verify if any significant new circumstance or information related to the proposed action exists, and if so, how it affects our analysis. This determination will be grounded in similar cumulative reasoning to what we’ve outlined above.
Recently, we’ve heard questions about if we’ll be completing a supplemental EIS or issuing a final EIS. The answer is – we’re still working. It’s not clear yet whether the cumulative changes in our analysis or preferred action are substantial enough to warrant issuing a revised draft EIS. We’re in the midst of a multifaceted endeavor to balance transparency and responsiveness while completing our work. It’s not until we’ve considered and made all the required adjustments that we can truly assess what our next steps will look like.
So stay tuned. We’ll continue to update you on our progress. Thanks for the interest and information you’ve provided to date – we hear it and appreciate it.