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I know this belongs in another section but IMO it's to important. Time is very short.
RE: Forest Service’s proposed Land Management Planning Rule.
Below is a copy and paste of e mail notification I received today. Click link below to submit comment. The draft under consideration places higher import on "invertebrates" than recreation on public land. The draft being considered does not "define" any of the ridiculous terms included, thus leaving the door WIDE OPEN to litigation.
IMO, They are attempting to shift the direction of Forest Service management away from Multiple Use, toward Conservation. Because this draft will govern massive amounts of public land, this would equate to a HUGE victory for the enviro's if passed as currently written. It will give them a basis to legally challenge ORV use in most currently open areas.
What I did: Copy orange text below then clicked / opened link. Click "submit comment" and paste orange text in box. Personalize and send.
http://www.govcomments.com/ProjectInformation.aspx?a=25&b=20800.
As a recreationist I am concerned that the proposed Land Management Planning Rule will be burdensome, costly and leave too many key terms and phrases undefined. The rule, if finalized as drafted, would invite litigation and do little to end the decades-long effort to craft a planning rule that will stand the test of time – and courts. Further, while the Forest Service responded to requests from the recreation community to include recreation in the draft rule, the proposed rule clearly provides that preservation trumps social and economic factors, including recreation, contradicting the Multiple Use Sustained Yield Act, the statute that authorizes many Forest activities.
I am also concerned that expanding the “viable populations” provisions to include invertebrates will prove impossible to implement and ultimately lead to further restrictions to access. The “viable populations” provisions of the 1982 rule have proven difficult to implement and a magnet for litigation. Please remove these provisions before finalizing the rule.
The issues listed above, among others, leave me concerned that recreation will be limited as a result of the rule, both because of specific rule provisions, and because resultant litigation will be brought by anti-access organizations who will use the courts to interpret the many ambiguities in the draft.
Anyone who recreates on our National Forests has a vested interest in the implementation of a successful planning rule. I am concerned that proposed rule would limit recreation and become mired in legal challenges and as a result I encourage you to vastly rework the draft before finalizing the rule. I also join with Subcommittee on Conservation, Energy, and Forestry Chairman Glenn Thompson in encouraging you to reconsider your decision not to extend the comment period for an additional 90 days. This is too important and the issues too complex for the public not to have ample time to thoughtfully consider, and comment on, the proposed sweeping changes.
Thank you.
RE: Forest Service’s proposed Land Management Planning Rule.
Below is a copy and paste of e mail notification I received today. Click link below to submit comment. The draft under consideration places higher import on "invertebrates" than recreation on public land. The draft being considered does not "define" any of the ridiculous terms included, thus leaving the door WIDE OPEN to litigation.
IMO, They are attempting to shift the direction of Forest Service management away from Multiple Use, toward Conservation. Because this draft will govern massive amounts of public land, this would equate to a HUGE victory for the enviro's if passed as currently written. It will give them a basis to legally challenge ORV use in most currently open areas.
What I did: Copy orange text below then clicked / opened link. Click "submit comment" and paste orange text in box. Personalize and send.
http://www.govcomments.com/ProjectInformation.aspx?a=25&b=20800.
As a recreationist I am concerned that the proposed Land Management Planning Rule will be burdensome, costly and leave too many key terms and phrases undefined. The rule, if finalized as drafted, would invite litigation and do little to end the decades-long effort to craft a planning rule that will stand the test of time – and courts. Further, while the Forest Service responded to requests from the recreation community to include recreation in the draft rule, the proposed rule clearly provides that preservation trumps social and economic factors, including recreation, contradicting the Multiple Use Sustained Yield Act, the statute that authorizes many Forest activities.
I am also concerned that expanding the “viable populations” provisions to include invertebrates will prove impossible to implement and ultimately lead to further restrictions to access. The “viable populations” provisions of the 1982 rule have proven difficult to implement and a magnet for litigation. Please remove these provisions before finalizing the rule.
The issues listed above, among others, leave me concerned that recreation will be limited as a result of the rule, both because of specific rule provisions, and because resultant litigation will be brought by anti-access organizations who will use the courts to interpret the many ambiguities in the draft.
Anyone who recreates on our National Forests has a vested interest in the implementation of a successful planning rule. I am concerned that proposed rule would limit recreation and become mired in legal challenges and as a result I encourage you to vastly rework the draft before finalizing the rule. I also join with Subcommittee on Conservation, Energy, and Forestry Chairman Glenn Thompson in encouraging you to reconsider your decision not to extend the comment period for an additional 90 days. This is too important and the issues too complex for the public not to have ample time to thoughtfully consider, and comment on, the proposed sweeping changes.
Thank you.
