Preparing Scoping Comments

Scoping is the first formal step the Forest Service must take to meet its obligation under the National Environmental Policy Act (NEPA) to involve the public in its decision-making. Scoping is simply a process used to determine the “scope” (or range) and significance of the issues associated with a timber sale or road building project. Once you have requested to be on the mailing list for a specific timber sale, the Forest Service will send you a letter (called a scoping request), requesting comments on their proposal. Scoping is your opportunity to make sure the Forest Service is aware of your concerns and how you value the resource. These issues and areas of concern will then be analyzed in the appropriate environmental analysis, either an Environmental Assessment (EA) or an Environmental Impact Statement (EIS).

The following areas of concern should be considered when writing your scoping comments. Some of them may not be applicable depending on the actual sites planned for logging. Your familiarity with the area, and/or the maps included with the scoping request, should help you to identify what issues are most important. However, when in doubt, always include the issue in your scoping letter.

WILDLIFE: Each forest has identified “indicator species” through its forest planning process. You should request at a minimum, that the environmental analysis analyze and disclose how the proposed activities would impact these species as well as any sensitive, threatened or endangered species. You should also mention any species that are particularly important to you (song birds, mountain lions, etc.). Since most forests have specific standards and guidelines for management of wildlife (such as deer hiding cover), the analysis should discuss how each alternative adheres to those standards.

WATER QUALITY and FISHERIES: request the analysis disclose all impacts to water quality and fisheries. The analysis should include: sedimentation rates (current and projected after project completion), any increases in peak flow, channel stability, and thermal pollution (increases in water temperature). Regarding fisheries, your scoping letter should ask the following two important questions. First, what is the current condition of the fisheries? Second, how will the proposed project impact them?

REGENERATION: The National Forest Management Act (NFMA) requires logged areas to be regenerated within five years. The Forest Service must document how this will be achieved based on past experience with similar soil conditions, slope and aspect. Pay particular attention to areas proposed for logging that are on southern aspects, steep slopes and/or at high elevations.

SOILS and WATERSHEDS: Are there any areas of unstable soils which could result in mass movement (landslides)? Are any riparian areas included in the logging plans?

ROADS: The analysis should clearly specify the number of miles and location of new, temporary and/or reconstructed roads. It should disclose which roads are to closed and the method of closure. Be certain to ask that the pre-and-post sale road densities (miles of road per square mile) be disclosed, and compare these with Forest Service plan standards.

RECREATION: Recreational use, including hunting, is an existing in-place public benefit. The analysis must document how recreational use will be impacted by the proposed activities. Generally, back country hiking is in short supply and the analysis must disclose how the proposed activities will alter this already limited resource.

VISUAL QUALITY: Each Forest Plan outlines Visual Quality Objectives (VQOs) for the forest. The analysis should document compliance and/or disregard for these standards. Where will the roads and harvest units be visible from? In areas of high scenic and recreational value, you may want to suggest the project maintain those qualities.

ECONOMICS: Request that the Forest Service document a substantive accounting of all costs and benefits attributable to the project. If they propose a below-cost sale (almost all are), the project decision must adequately justify their reasoning. The analysis should also carefully examine how existing in-place benefits (such as outfitting or tourist based businesses) may be impacted by the project.

While some people discredit the value of the scoping process, it improves with participation. Many times the Forest Service has claimed it didn’t realize a particular issue was important to the public. Generally, the Forest Service is willing to consider all issues raised by the public. Collective input throughout the planning process is an opportunity to improve forest management.