Bureaucracy !

by Leonard B. Nelzorg

Against such a background, NEPA came as a total shock. NEPA suddenly forced the Forest Service decision-maker to go through a prescribed analytical process. More, it forced him to detail his analytical process for the express purpose of subjecting it to public criticism. No longer could the agency fend off the outsider with the incantation that its decision was, by its own reckoning, in the public interest. NEPA opened a new world. The Forest Service has had an understandablv hard time entering it.

Story at a Glance

A fierce criticism of the Forest Service for their ineptitude in managing our nation's forests at a time when we desperately need all the wood products we can get.

Let's take a look at that new world. NEPA says that before making a decision on a major action significantly affecting the human environment, the decisionmaker must study, analyze and expose the reasonable alternatives to his proposed action. NEPA says it twice. The Council of Environmental Quality (COql reiterates the concept and spells out its requirements. The federal courts in, I suppose, hundreds of cases have pounded it home. Summarizing the judicial construction of NEPA's requirement, a proposed Forest Service manual revision says that all reasonable alternatives and their environmental impacts should be discussed, including those not within the authority of the Forest Service. Each such alternative must be subjected in the NEPA statement to a rigorous exploration and objective evaluation. The analysis must be sufficiently detailed and rigorous to permit independent and comparative evaluation of the benefits, costs and environmental risks of the proposed action and each alternative.

Let's see how these general propositions have been honored in a couple of concrete situations. I choose these two because one situation is simple, the other relatively complex. But simple or complex, they are in large measure representative of the kind of NEPA product that is only too often being cranked out by the Forest Service.

First, the simple case. In the Blue Mountains of Oregon the Forest Service enlarged an elk herd from about 14,000 head in 1930 to 47,000 head in 1970. Notwithstanding hunting pressures, this was largely accomplished by planning timber sales so as to produce a vast number of small clear-cuts at all elevations visited by the elk.

But recently in North ldaho, the Forest Service decided that to generate winter browse for elk it would, at the rate of 20,000 to 30,000 acres per year, burn 200,000 to 300,000 acres of 4O-year old conif'ers. The draft NEPA statement never even alluded to, much less rigorously explored and objectively evaluated, the clear-cut alternative of generating both timber and elk. When this omission was called to the attention of the decision-maker, he implicitly conceded in the final NEPA statement that he had not thought of this alternative but would analyze and report on it in three yearsafter burning 60,000 to 90,000 acres of timber. The ultimate confrontation was temporarily averted when it was agreed that the program would operate on slow bell pending a new NEPA statement.

Now there is a new NEPA draft statement issued. It alludes to, and in three or four lines rejects, the small clear-cut alternatives.