Not the end of NEPA analysis

  While I know you need to take a little literary license to keep the controversy alive and sell papers, you went way over the edge and into fiction with your article “The end of ‘analysis paralysis’?” You state five times in this article that under the new planning regulations “Forest plans would no longer be required to go through NEPA analysis.” This is patently false.

Under the new planning regulations, revised forest plans don’t have to have an Environmental Impact Statement (EIS) and review numerous alternatives, but they still go through NEPA analysis. Revised forest plans would be categorically excluded from analysis in either an Environmental Assessment or EIS, but they still have to have a Decision Memo, which is NEPA analysis. The current NEPA for revised forest plans includes extensive collaboration and public involvement to develop the proposed plan, an ecological sustainability analysis, an evaluation of Inventoried Roadless Areas for wilderness potential, a timber suitability analysis, and a timber economics analysis, to name a few.

Remember, the agencies don’t make this stuff up or go to work every day and say, “I wonder what I’m going to do today?” They do what the people you and all your readers elect to office tell them to do.

Andy Kulla
Florence, Montana
Mar 30, 2007 04:03 PM

Sorry Andy, a Categorical Exclusion is not a NEPA document nor a NEPA analysis.  A Categorical Exclusion means that the action is excluded from NEPA, therefore NEPA is not performed and no NEPA document is prepared.  A Decision Memo is not a NEPA document nor NEPA analysis either.  The only two NEPA documents are an Environmental Assessment (EA) and an Environmental Impact Statement (EIS).  A "NEPA analysis" means the effects or impacts from proposed actions are analyzed. There is no analysis in a CX or a Documentation of NEPA Adequacy (DNA), therefore they are not true NEPA documents.  HCN was partly correct—Forest Plans would not undergo a NEPA analysis.  However, all subsequent actions the Forest Service takes would be still be subject to NEPA, so HCN is partly wrong.  That being said, I happen to agree with Andy 100% that HCN's "the sky is falling" sensationalism is way over the top.  If what FS is doing is illegal, the courts will tell us so.  Until then, quit your wining.