| My
Official Public Comments on the "CC Grasslands Plan," also
known as the "Cimarron and Comanche National Grasslands Draft
Land Management Plan" March 27, 2006 Addressed to: Environmental Science Associates,
Inc. (ESA) 225 Bush Street San Francisco, California 94104-4207
Fax: 415-896-0332 415-896-5900 Marty Abell, vice-president of
Environmental Science Associates, Inc. (ESA) 436 14th Street, Suite 600 Oakland, California 94612 mabell@esassoc.com or
510-839-5066 and either directly addressed to by
email or “cc”ed to all the following, whose email addresses have
been checked for accuracy: ccgrassplan@caet.esassoc.com;
propertyrights@earthlink.net;
mabell@esassoc.com;
abond@fs.fed.us;
adetoy@fs.fed.us;
aedwards@fs.fed.us;
akimbell@fs.fed.us;
amaliamontoya@fs.fed.us;
amarcilla@fs.fed.us;
appeals-rocky-mountain-regional-office@fs.fed.us; aschoettle@fs.fed.us;
atchappell@fs.fed.us;
awarm@fs.fed.us;
baburkhart@fs.fed.us;
bhajny@fs.fed.us; bleaverton@fs.fed.us;
bmasinton@fs.fed.us;
bpitman@fs.fed.us; btcox@fs.fed.us;
btimock@fs.fed.us;
ccairns@fs.fed.us;
cllockman@fs.fed.us; crivera@fs.fed.us;
ckyhl@fs.fed.us;
csachenbach@fs.fed.us;
cschultz@fs.fed.us; czillich@fs.fed.us;
derhard@fs.fed.us;
dfinch@fs.fed.us;
dgarcia01@fs.fed.us; dgomez04@fs.fed.us;
dlowry@fs.fed.us;
dmcarthur@fs.fed.us;
dneary@fs.fed.us;
dritschard@fs.fed.us; dsteinke@fs.fed.us;
dsvingen@fs.fed.us;
dtomlin@fs.fed.us;
emoncrief@fs.fed.us;
fcarroll@fs.fed.us;
fguzman@fs.fed.us;
freynolds@fs.fed.us;
gbecenti@fs.fed.us; gchancey@fs.fed.us;
gckeene@fs.fed.us;
gernstulrich@fs.fed.us; gfoli@fs.fed.us;
gmarkin@fs.fed.us;
gmoravek@fs.fed.us;
gsnell@fs.fed.us; jataylor02@fs.fed.us;
jbaldwin01@fs.fed.us;
jbustos@fs.fed.us;
jchambers@fs.fed.us;
jcrooks@fs.fed.us; jdersch@fs.fed.us;
jenahickey@fs.fed.us;
jfairchild@fs.fed.us;
jhartman@fs.fed.us;
jisaacs@fs.fed.us;
jmaxwell01@fs.fed.us;
jrawinski@fs.fed.us;
jrmurphy@fs.fed.us;
jsabegglen@fs.fed.us;
jschumacher@fs.fed.us;
kabray@fs.fed.us;
kburns@fs.fed.us; kclancy@fs.fed.us;
kgarcia@fs.fed.us;
kkmurphy@fs.fed.us;
kponozzo@fs.fed.us;
kself@fs.fed.us;
lbtaylor@fs.fed.us;
lcosper@fs.fed.us;
ldobson@fs.fed.us;
lknotts@fs.fed.us;
lpfeffer@fs.fed.us; lreid@fs.fed.us;
lwaida@fs.fed.us;
machambers@fs.fed.us;
Mailroom_r2_grand_mesa_uncompahgre_gunnison@fs.fed.us;
mailroom_r2_rio_grande@fs.fed.us;
mball@fs.fed.us;
michellestevens@fs.fed.us;
nryke@fs.fed.us;
nwagoner@fs.fed.us;
nwalls@fs.fed.us;
pbarney@fs.fed.us;
petermcdonald@fs.fed.us; pirwin@fs.fed.us;
plwilson@fs.fed.us;
pminow@fs.fed.us;
rblackwell@fs.fed.us;
rcloudman@fs.fed.us;
rdalrymple@fs.fed.us;
rday@fs.fed.us;
rfletcher@fs.fed.us;
rgriebel@fs.fed.us;
rhodorff@fs.fed.us;
rjablonski@fs.fed.us;
r2_psicc_webmail@fs.fed.us;
sbrigham@fs.fed.us;
scurrey@fs.fed.us;
shall02@fs.fed.us;
ssegin@fs.fed.us;
tbyer@fs.fed.us; tgates@fs.fed.us;
tjwilliams@fs.fed.us;
tliestman@fs.fed.us;
tmalecek@fs.fed.us;
tpeters@fs.fed.us; tpost@fs.fed.us;
twhitford@fs.fed.us;
twilson02@fs.fed.us;
vle@fs.fed.us; wperry@fs.fed.us;
diann_gese@co.blm.gov;
mark_marshall@co.blm.gov;
ken_hyde@nps.gov;
meadesp@wp.state.ks.us;
dstarr@iastate.edu;
dtomsice@oznet.ksu.edu;
mfarmer@oznet.ksu.edu;
jbecker@oznet.ksu.edu;
phil@cnr.colostate.edu;
webbj@okstate.edu;
dhubbell@uark.edu;
jahorns@uark.edu From: Julie Kay Smithson Property Rights Researcher London, Ohio Corrupt from A to Z, and designed to
extinguish grazing from the entire area that is southeast Colorado and
southwest Kansas, I am also blind carbon copying (BCCing) these Official
Public Comments to a multitude of concerned citizens – from ranchers
to other facets of resource providing to anyone I can persuade to
comment. The number of those receiving my Official Public Comments in
BCC form? Let your imagination run wild! These Official Public Comments are
twelve (12) pages in length. It is my fervent
hope that many people will use all or part of my comments and submit
their own, this week, because the Public Comment Period ends on April 3,
2006. Note that I am addressing these
Official Public Comments to myself, as well, so that no part of this may
be changed or tampered with. I am also mailing a hard copy of these
Public Comments directly to Robert “Bob” Leaverton, Tom Peters and
to the Kim (Colorado) Grazing Association. The Entire Text of this email is to
be construed and accepted – by each and every federal employee
receiving it, as well as by the Conflict of Interest, for-profit entity
to which our public comments are instructed to be submitted,
Environmental Science Associates, also known by its acronym, ESA, and is
to be kept intact and not subjected to the Content Analysis Process or
any other process that separates these Public Comments in any way from
their original form and content. Each document that is herein
referred to by reference is to be included – in its full text – as
part and parcel of these Official Public Comments. Comments must be postmarked by
April 3, 2006. Under the
new planning rule, only those persons or organizations [that]
participate in the comment period may formerly object to the plan prior
to its approval. Visit http://www.fs.fed.us/r2/psicc
for the Draft Plan, EA and supporting documents. Also: http://www.fs.fed.us/r2/psicc/projects/forest_revision/
The National Forest Management Act
of 1976 requires the Forest Service to develop, periodically revise and
amend all forest and grassland plans. Last December, the agency released
its new planning rule, which established a dynamic process to account
for changing forest conditions, and emphasized science and public
involvement. How to submit public comments: Content
Analysis is also known as "Social Qualitative Analysis."
Public Comments are also known as "Public Responses." Source: http://www.fs.fed.us/emc/cat/includes/CA-products.html Please,
all those receiving this in BCC form, read the following official
definition of the “Content Analysis Process” so you can see what is
intended for your comments and why I am sending my own Official Public
Comments to so many. Content
Analysis Process
(CAP) – Public responses on the Advance Notice of Proposed Rulemaking
are documented and analyzed using a process called content analysis.
This is a systematic process of compiling and categorizing all public
viewpoints and concerns submitted on a plan or project. Content analysis
is intended to help decision makers clarify or adjust the next phase of
the project. Information from public meetings, letters, emails, faxes,
and other sources are all included in this analysis. In the content
analysis process, each response is assigned a unique number. This number
allows analysts to link specific comments to original responses. All
respondents’ names and addresses are entered into a project-specific
database program, enabling creation of a complete list of all
respondents. Analysts read and code responses using the coding
structure. Each comment is coded by subject and verified by a second
analyst for accuracy and consistency. Then all coded comments are
entered verbatim into a comment database. Database reports track all
input and allow analysts to identify public concerns and to analyze the
relationships among them. The final analysis document includes an
executive summary, which discusses respondents’ main areas of concern,
and a formal list of public concern statements. Each public concern
statement is accompanied by one or more sample excerpts from original
responses. This process and the resulting document do not replace
responses in their original form. Rather, they provide a map to the
responses and other input on file at the office of the Content Analysis
Team (CAT) … Interested parties are encouraged to read public comment
firsthand. It is important to recognize that the consideration of public
comment is not a vote-counting process in which the outcome is
determined by the majority opinion. Relative depth of feeling and
interest among the public can serve to provide a general context for
decisionmaking. However, it is the appropriateness (sic), specificity,
and factual accuracy of comment content that serves to provide the basis
for modifications to planning documents and decisions. Further, because
respondents are self-selected, they do not constitute a random or
representative public sample. The National Environmental Policy Act (NEPA)
encourages all interested parties to submit comment as often as they
wish regardless of age, citizenship, or eligibility to vote. Respondents
may therefore include businesses, people from other countries, children,
and people who submit multiple responses. Therefore, caution should be
used when interpreting comparative terms in the summary document. Every
substantive comment and suggestion has value, whether expressed by one
respondent or many. All input is read and evaluated and the analysis
team attempts to capture all relevant public concerns in the analysis
process. Source: http://roadless.fs.fed.us/documents/xcsumm/Appendices053102.pdf Directing public comments to
Environmental Science Associates is akin asking a person to use the
services of a maximum-security prison to order products by phone using
their credit card and other personal information. Those least deserving
-- and least trustworthy -- of having our personal information, are
telling the public to "trust us." I think not! Marty Abell's
company is pro-"green" and anti-rancher, anti-resource use,
anti-livestock grazing -- yet a federal agency (the USDA Forest Service)
directs people to make their public comments to this private,
for-profit, information-gathering company? Is this not a Major Conflict
of Interest? It is clear that the intent is to install a
"Environmental Management System" and remove "public
lands grazing" from the 20 percent of lands "you own" --
paid for with our taxpayer dollars. For Your Information: We are not
planning for federal actions – and/or those of the “public-private
partnerships” – to relegate American resource providing to a single
apologetic page in a future history book. "Potential Forest Service Lands
For Sale:" http://www.fs.fed.us/land/staff/spd.html You clearly mention and list at this
URL: http://www.fs.fed.us/emc/nfma/includes/public_participation_05Rule.pdf
Seven "Topics of Interest:" 1.) Fragmentation of land
ownership; 2.) Use of fire and livestock grazing to manage Mountain
plover and lesser prairie chicken; 3.) Tamarisk infestation; 4.) Threat
of new invasive species; 5.) Sustainable elk populations; 6.)
Recreation, tourism: potential for increased resource damage and 7.)
Plant species diversity: many plant communities near monocultures; areas
lack native bunchgrass. The Public Comment Period must be
extended by a minimum of ninety (90) days to give impacted ranchers,
landowners, homeowners, businesses, and others time to review the
paperwork for this "CC Grassland Plan." Forest Service
employee Tom Peters has been discouraging people in the impacted area
from either acquiring or reading hard copies of the Plan. The Forest
Service has not had enough public meetings -- with sufficient
public notice -- so the above-mentioned entities may attend and learn
more. By providing notice of meetings and invitation to only a select
few, knowledge of the Plan is limited, so the ability to make
intelligent, informed public comment is limited. The Public Comment
Period must be extended to July 3, 2006. The current structure for submitting
and analyzing public comments involves sending personal information --
rather than to the Forest Service itself -- to a non-federal
corporation, Environmental Science Associates, Inc. (ESA), based
in San Francisco, California. This corporation contracts with
the USDA Forest Service to produce a product that enhances the Forest
Service's ability to implement plans on public and private land. The
vice-president of this corporation is Marty Abell, an environmental
consultant. This is a blatant conflict of interest and goes against
ranchers and others that are responsible utilizers of natural resources
in these lands that are covered by the "Cimarron and Comanche
National Grasslands Draft Land Management Plan." It is, therefore,
a Conflict of Interest to require those submitting public comments to
submit them to such a for-profit, private sector corporation. USDA Forest Service -
National Content Analysis Contract:
Resource Dimensions Teams with ESA in San
Francisco to Win Largest Contract Award in its History -
Resource Dimensions, a Gig Harbor, Washington based, woman-owned
environmental economics, land use and resource policy consulting firm
learned in late October 2004 that it -- together with the lead firm Environmental
Science Associates (ESA), based in San Francisco, California,
and two other firms, Timberline Resources, in Billings, Montana, and The
Environmental Company’s Boise, Idaho, office -- had been awarded the
largest consulting contract in the firm's history. The contract awards
were announced by the USDA Forest Service after over 14 months of
meetings, preparation and proposal review by the USFS Content Analysis
Team based in Salt Lake City, Utah and Missoula, Montana. The
5-year, $25-million national contract, will support Content Analysis
Services on a variety of federal projects and was issued on an
Indefinite Delivery/Indefinite Quantity (ID/IQ) basis, which allows for
awards up to $5 million for each of the five years. Social
qualitative analysis (a/k/a content analysis) related to land use and
resource management issues and environmental policies is
one of Resource Dimensions’ unique areas of specialty. The
work will include the compilation, recording, coding, examination, and
qualitative analysis of public comments related to a diversity of
proposed projects and/or policy changes that may affect or impact the
environment and management of natural resources across the country.
The broad range of projects on which Resource Dimensions and its project
partners will be involved in will include those required to follow the
National Environmental Policy Act (NEPA). Passed in 1969 and
subsequently revised, NEPA mandates specified periods for public
comment within the decision-making phase of projects that use
federal funds or are undertaken by federal government agencies (e.g.
National Park Service, U.S. Forest Service, Bureau of
Land Management, U.S. Army Corps of Engineers, Federal Highway
Administration, Department of Energy, Environmental Protection Agency,
etc.). For more information please contact Resource Dimensions' Nan
Gostyn nan@ecologicalecon.com Source:
http://www.ecologicalecon.com/pages/22/page22.html?refresh=1128433201930 FBO
(FedBizOpps) Daily Issue of October 21, 2004 FBO #1060. Content Analysis
Services of Public Responses on Environmental Documentation. Date:
October 19, 2004. Awardee: Environmental Science Associates, 225 BUSH ST
SUITE 1700, SAN FRANCISCO CA 94104-4248. Award Amount: maximum IDIQ
amount of $25,000,000.00. Source:
http://www.fbodaily.com/archive/2004/10-October/21-Oct-2004/FBO-00696336.htm Also
located here: http://www.cbd-net.com/index.php/search/show/707400/print (Note:
FBO, or FedBizOpps, was formerly the Commerce Business Daily, or CBD.) Pages 25 and 26 of the
"Cimarron and Comanche National Grasslands Draft Land Management
Plan" state: "With 80% of the Grasslands' watersheds in
private ownership, the potential for National Grassland management to
affect change at the watershed scale (and associated perennial streams)
is very limited. The fragmented land ownership pattern also compromises
the Grasslands' recreational potential by interfering with the sustained
solitude sought by many recreationists. The time and costs of management
and law enforcement are also increased." Here are reasons why private land is
proven to be far better 'habitat' than the 20 percent you currently hold
hostage: "Seventy-five percent of U.S.
wildlife live on private land, as do half of all endangered
species." Source: http://www.perc.org/pdf/guide_wild.pdf (Page
5 of 14) Since endangered species, according
to this Environmental Protection Agency (EPA) document, are found
"...almost entirely on private land," the push is on to
designate such private lands as "critical habitat" and take
over the ability to use these private lands. If private lands are
clearly the places where endangered species prefer to reside, it is only
good sense that the private landowner is better at species care than the
federal government agencies that lust to control. Source: http://www.epa.gov/fedrgstr/EPA-IMPACT/2003/January/Day-09/i130.htm "9.9 Habitat Conservation Plans
[HCPs]: 2. ...If critical habitat for an endangered species is found on
private land covered by an HCP, the federal government will have to buy
the land if it wants to save the
habitat and the species." Source:
http://wfcb.ucdavis.edu/www/Faculty/Peter/petermoyle/publications/chapter9.pdf If eighty percent of the area in
private ownership, and most of the species -- endangered and otherwise
-- inhabiting and apparently surviving better on private than 'public'
land, why don't you sell the remaining 20 percent to the private
landowners and stop trying to manage/control what the private landowners
are already doing a far better job of than you? Put in writing a ROFR
(Right Of First Refusal) Purchase Option, at current use appraised value
and not assignable, for the 20 percent of lands in the area
that are currently federally owned and which are covered by the
"CC Grasslands Plan." Private landowners can also deal with
what recreationists want, and it is very likely more than the
"sustained solitude" to which you allude. A buyout of the
'public' land also keeps "the time and costs of management and law
enforcement" down, so you won't have to worry about that, either.
After, private landowner Ted Turner is acclaimed as an
"environmental steward," and he has huge, Electrified Fences
to keep his wildlife IN, so he can demand astronomical fees so the
moneyed and powerful can come and hunt -- and Mister Turner also keeps
captive herds of buffalo that wind up slaughtered and on the menu at his
chain of 'Montana Grill' upscale restaurants -- so why not afford the
rest of us private landowners the same chance to provide habitat on our
lands by buying out all of your holdings? This is a 'win-win' situation
for the American taxpayer, the species, et al! Readers of this "Plan" are
never told that their public comments are being submitted to
Environmental Science Associates, Inc. (ESA). The reader thinks that
he/she is commenting to the USDA Forest Service, when in reality, public
comments and personal information are being fed directly to a for-profit
"environmental" corporation with a multimillion-dollar
contract with the USDA Forest Service to "analyze" the
comments and spit out a "report." This method completely
Obliterates the public's ability to actually comment directly to the
Forest Service and removes the content and context of the comments by
using "content analysis." How many private landowners,
homeowners, etc., trust such a "process" to a private,
information-gathering firm located in a distant state? This is not what
"public comment" to federal agency plans is supposed to be. It
is an utter Abomination that said federal agencies have stooped so low
that they are spending taxpayer dollars to disenfranchise the public
from its own dignity and identity. It spits on both the NEPA (The
National Environmental Policy Act of 1969 http://ceq.eh.doe.gov/nepa/regs/nepa/nepaeqia.htm) "process"
and FLPMA (The Federal Land Policy and Management Act of 1976
http://www.blm.gov/flpma/) and does so in a most arrogant and
arbitrary manner, by "awarding" multimillion-dollar contracts
to such anti-private property corporations as this "ESA"
apparently is. These Official Public Comments
are being submitted to every federal employee of the USDA Forest Service
that is involved in the Cimarron and Comanche National Grasslands and
related, federally owned and/or “managed” lands and/or waters and
other resources, as well as to the USDA Forest Service at the
Washington, D.C., level, understanding full well that submitting public
comments to the "ESA" (Environmental Science Associates, Inc.)
is the equivalent of submitting our public comments directly to a paper
shredder, knowing the destruction of commenters’ identities that will
occur, as well as the structure and integrity of the comments in their
original, unmolested form. Public Comments on the "CC
Grasslands Plan," also known as the "Cimarron and Comanche
National Grasslands Draft Land Management
Plan," are directed (in the "Users
Guide") to be submitted/postmarked by April 3, 2006, to
an entity called "ESA," whose website, http://www.esassoc.com,
describes itself thusly: "ESA is where solutions and service meet.
We are a multi-disciplinary consulting firm committed to effective
problem-solving and helping our clients confront today's challenges in
project planning and environmental compliance. Our skilled managers,
scientists, planners and engineers provide the kind of critical
thinking, objectivity, dedication and responsiveness that is essential
to good environmental stewardship and to successful project completion
in an increasingly sophisticated regulatory and community interest
context." At the About Us button: "Our Work: ESA
specializes in all aspects of project planning, environmental analysis
and assessment, natural resource management and regulatory compliance.
With diverse practice groups and multiple offices nationwide, the firm
is able to pull together nimble, multidisciplinary teams with
project-specific expertise at the local level." http://www.esassoc.com/?p=Our+Work&s=3 History:
ESA was founded in California in 1969, shortly before enactment of the
National Environmental Policy Act (NEPA) and the California
Environmental Quality Act (CEQA) landmark laws that have greatly
influenced environmental planning and analysis. Over the years ESA has
grown into a broad-based environmental consulting company with a
nationwide presence and wide range of planning, management,
documentation and analytical services. The firm's seasoned staff helps
clients define environmental and planning parameters, identify
opportunities and constraints, and save resources, time and money. http://www.esassoc.com/index.php?p=History&s=11 Key
Staff: At heart, ESA professionals are problem solvers. Client
challenges come in all forms, from resolving complex public issues to
meeting demanding deadlines and regulatory requirements. Each requires a
solution that is effective and unique. ESA's professionals are a mix of
minds and capabilities. We are experts who are deeply steeped in their
respective fields and creative enough to arrive at solutions that are
daring and new. http://www.esassoc.com/index.php?p=Key+Staff&s=12 At
"Practice Groups: Land Management:" Land Management Practice
Groups: Large areas of land invite competition for its resources among
farmers, wildlife managers, outdoor enthusiasts and other users. If the
area contains an important water source or timber supply, competition
can quickly become contention. ESA's staff helps balance interests with
management plans grounded in scientific and regulatory expertise. By
meeting deadlines, distilling the complex and developing clear
communication tools, ESA provides invaluable service to tribes,
government agencies and the nation's largest parks. http://www.esassoc.com/index.php?p=Land+Management&s=27 Contact
Us: http://www.esassoc.com/index.php?p=Contact+Us&s=121 415-896-5900
The "Cimarron and Comanche
National Grasslands Draft Land Management Plan," also known as the
"CC Grasslands Plan," must come to a Screeching Halt until and
unless the honorable "public comment" that involves submission
of public comments Directly to the USDA Forest Service is Reinstated. The "Cimarron and Comanche
National Grasslands Draft Land Management Plan," also known as the
"CC Grasslands Plan," must come to a Screeching Halt until and
unless the USDA Forest Service reconvenes Public Meetings and this time
gives proper public notice for All the Public to attend. The "Cimarron and Comanche
National Grasslands Draft Land Management Plan," also known as the
"CC Grasslands Plan," must come to a Screeching Halt until and
unless USDA Forest Service employees stop discouraging the public from
learning about or possessing the hard copy contents of the
"Plan." While the following paragraph may
not be specific to the area currently under “Public Comment” period,
it is of vital interest, for it shows the intent that is directed toward
users of these lands and the very likely future “planning” that will
overspread the grasslands like a February blizzard: Under Chapter II. Alternatives,
Including the Proposed Action, E. No Action Alternative, excerpt: Pike
and San Isabel National Forest, Cimarron and Comanche National
Grasslands, Forest Order (Order No. 91-07) and the BLM RMP (Resource
Management Plan) decisions allow direct motor vehicle travel to a
suitable parking site within 300 feet of a road or trail if travel does
not damage the land or streams. The existing network of roads and trails
are not in compliance (not all are authorized for use) with the Forest
Plan or the RMP. It would continue to be illegal to operate motorized
transportation off authorized routes. Source: Cimarron and Comanche
National Grasslands Environmental Assessment http://www.fs.fed.us/r2/psicc/publications/fourmile/ea_3_13.htm “ESA” is Environmental Science
Associates, Inc., a for-profit entity that writes environmental impact
reports (EIRs); a phone call to them, posing the question, "Do
you do Content Analysis?" received the reply, "No, we do not
do Content Analysis." See here: http://www.fs.fed.us/emc/cat/includes/idiq_contractors.html to
prove this is a lie. Quote: "Environmental Science
Associates, Inc. - Environmental Science Associates (ESA) is a national
environmental consulting firm specializing in land use and resource
planning, environmental technical studies and investigations,
environmental impact assessment and documentation, and environmental
compliance. NEPA documentation for these projects range from focused
Environmental Assessments (EA) to complex Environmental Impact
Statements (EIS). ESA has been assisting federal clients for over three
decades. The ESA Team brings extensive experience working with
content analysis, most notably the National Park Service's
Merced Wild and Scenic River Management Plan and EIS. The ESA Team is
complemented by technical specialties offered by three subcontractors.
Combined, these four firms have over 30 years of comment response
experience." A Google search: Results 1 - 10 of about 26 for "content
analysis" "Environmental
Science
Associates" This for-profit corporation has
three decades of self-proclaimed “comment response experience.” This
bodes ill for ranchers and other responsible landowners and users of
natural resources in the area covered by the Cimarron and Comanche
National Grasslands “Plan.” The comments of those whose custom and
culture depend utterly upon the ability to utilize the resources in this
land area are now offered up to the altar of an “environmental
science” corporation – at the express direction of the USDA Forest
Service! The very people whose taxpayer dollars pay the salaries of
Forest Service employees are now being betrayed by the actions of this
federal agency, with malice aforethought. The intent is to stop all
grazing by “livestock” on American soil. The intent is also to
“restore” and “preserve” – under the guise of “management”
– every iota of America’s natural resources, including Human
resources. This “plan” is nothing more than one more nail in the
coffin of American Resource Providing and Generational Resource
Stewards, also known as Property Rights and Freedom. This commenter isn’t buying the
ploy any more than she’d fall for the sideshow barker telling her how
wonderful his “prizes” are and how easy it is to win them – all
the while intent upon separating her from her money. It is the same with
the announcement that this area of Colorado and Kansas would be the
“first unit” to “use” the “new planning rule” – as though
it were a prize for the ranchers and resource users to win! It is the
same with the Cimarron and Comanche “National Grasslands” “Draft
Plan.” Those responsible resource users – ranchers, landowners, etc.
– are being told that their ways are no longer “acceptable” or
“in compliance.” Hogwash and Balderdash! Here’s a newly coined and accurate
way to spell and use “eco system:” Eco-System – Economic System.
America runs best on an economic system that guarantees economic
prosperity to all who are able to work and strive, to own private
property and responsibly utilize that property. Everyone benefits from
this “eco system” – including, but not limited to, the
“endangered” species that federal agencies, including the USDA
Forest Service, say inhabit privately owned land. The other term that
“Environmental Science Associates, Inc.,” and other “Wildlands
Project” proponents and implementers are wont to worship is
“ecosystem,” which is just as all-encompassing as “landscape
scale,” “watershed,” and so many other words and phrases that
employ Language Deception. The complete release is pasted
here for all to read: USDA FOREST SERVICE RELEASES DRAFT
CIMARRON AND COMANCHE NATIONAL GRASSLANDS’ NEW LAND MANAGEMENT PLAN -
First unit to use new planning rule, including an auditing system
USDA Forest Service Rocky Mountain Region Pike, San Isabel National Forests
and Cimarron, Comanche National Grasslands 2840 Kachina Drive Pueblo, Colorado 81008 http://www.fs.fed.us/r2/psicc/
Contacts: Cass Cairns, ccairns@fs.fed.us or
719-553-1428 Robert J. Leaverton, Forest
Supervisor bleaverton@fs.fed.us or
719-553-1400
“The Draft Grasslands Plan is the
first land management plan produced under the 2005 Planning Rule,”
said Bob Leaverton, Forest Supervisor for the Pike and San Isabel
National Forests, Cimarron and Comanche National Grasslands. “It is a
long-term strategic document that will guide land management decisions
over the next decade.” For the first time as part of the
new planning rule, auditing will be required through an Environmental
Management System (EMS). An EMS aims to improve performance and
accountability, and also includes monitoring efforts on those
environmental issues of greatest concern. The draft plan contains: existing
conditions and trend evaluations; social, economic and ecological
sustainability evaluations; proposed species-of-concern and
species-of-interest evaluations; roads analysis process reports; and
applicable maps. An environmental assessment (EA) was
completed on the Draft Grasslands Plan. No significant impacts on the
environment were found since the plan is strategic in nature and does
not make specific project management decisions with environmental
effects. Public comments can be sent by mail
to: CC Grasslands Plan, 225 Bush St., Suite 1700, San Francisco, CA
94104-4207. Comments by e-mail should be sent to: ccgrassplan@caet.esassoc.com.
Comments may also be faxed to: 415-896-0332. Comments must be postmarked by
April 3, 2006. Under the
new planning rule, only those persons or organizations [that]
participate in the comment period may formerly object to the plan prior
to its approval. Visit http://www.fs.fed.us/r2/psicc
for the Draft Plan, EA and supporting documents. Also: http://www.fs.fed.us/r2/psicc/projects/forest_revision/
The National Forest Management Act
of 1976 requires the Forest Service to develop, periodically revise and
amend all forest and grassland plans. Last December, the agency released
its new planning rule, which established a dynamic process to account
for changing forest conditions, and emphasized science and public
involvement. How to submit public comments: http://www.fs.fed.us/r2/psicc/news/2005/nr_so_122105.shtml
Related reading, including the
Federal Register notice, which is dated December 30, 2005: http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/200
5/05-24645.htm http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/200
5/pdf/05-24645.pdf http://www.fs.fed.us/r2/psicc/news/2005/nr_so_122105.shtml http://www.fs.fed.us/emc/cat/contentanalysis_page.htm http://www.fs.fed.us/emc/cat/includes/idiq_contracts.html Under Chapter II. Alternatives,
Including the Proposed Action, E. No Action Alternative, excerpt: Pike
and San Isabel National Forest, Cimarron and Comanche National
Grasslands, Forest Order (Order No. 91-07) and the BLM RMP (Resource
Management Plan) decisions allow direct motor vehicle travel to a
suitable parking site within 300 feet of a road or trail if travel does
not damage the land or streams. The existing network of roads and trails
are not in compliance (not all are authorized for use) with the Forest
Plan or the RMP. It would continue to be illegal to operate motorized
transportation off authorized routes. Source: Cimarron and Comanche
National Grasslands Environmental Assessment http://www.fs.fed.us/r2/psicc/publications/fourmile/ea_3_13.htm http://www.fs.fed.us/business/standards/Agreements_Desk_Guide.doc http://www.fs.fed.us/projects/documents/Omi_pollet_2002_thinning_effects.htm http://www.fs.fed.us/r2/riogrande/projects/sopa/documents/sopaoct2004.pdf http://www.fs.fed.us/r2/riogrande/projects/sopa/documents/sopajan2005.pdf http://www.fs.fed.us/r2/riogrande/projects/sopa/documents/sopaapril2005.pdf http://www.fs.fed.us/r2/riogrande/projects/sopa/documents/sopajan2006.pdf http://www.fs.fed.us/r2/psicc/hayres/travel/roadsEA/DN/South%20Platte%20Wildcat%
20DN_FONSI.pdf http://www.fs.fed.us/r2/psicc/hayres/travel/roadsEA/DN/Complete_Package.pdf http://ncrs.fs.fed.us/pubs/gtr/gtr_nc244.pdf
(9.62 MB) Felix Ponder, Jr. Illinois University and jgarvey@siu.edu Harris Park Fuels Management
Project, March 2005 http://www.fs.fed.us/r2/psicc/spl/harris_park_ea_final_web.pdf
(156 pages) Rocky Messenger-Howard Fuels
Management Project August 2005 Forest Service Region 2
Directory: http://www.fs.fed.us/intro/directory/rg-2.htm Signed, Julie Kay Smithson Property Rights Researcher London, Ohio 4,448 words. |