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Pine Creek Lake. Photo by Walker Stole
Nov 25 2019

Protecting the public’s right to input in the Bitterroot

There’s less than one week left to weigh in on the Bitterroot Front Project

Proposed by the U.S. Forest Service, the Bitterroot Front Project is a wide-ranging land-management endeavor that would span 150,000 acres in the western Bitterroot. According to the agency, the project would seek to increase landscape resiliency, increase public and firefighter safety, reduce fire risk to communities, improve wildlife habitat, and add forest-based jobs and recreation opportunities. 

While we agree that reducing wildfire risk to our communities is critical, we are worried that the plan could jeopardize the future of our wild places, particularly recommended wilderness areas and inventoried roadless areas in the Bitterroot. We also have concerns about how this project will be implemented and the reduced opportunities for public involvement.

The good news is that the project is in the early stages of planning (pre-scoping), and there is still significant opportunity for the public to steer it in a positive direction.

Please take a few minutes to write a comment explaining why public input and the protection of our wild places are so critical to the success of the Bitterroot Front Project.

Submit your comment to the Forest Service today

The Forest Service has indicated they’d like to authorize this project using “condition-based NEPA analysis.” By doing so, it would be sidestep a considerable part of the thorough review required by the National Environmental Policy Act (NEPA), one of our country’s bedrock environmental laws.

Condition-based NEPA analysis comes directly from the current administration’s draft rules, which plan to limit the environmental review required under NEPA. The intent is to reduce the analysis required in advance of a wide variety of management actions including logging, non-commercial thinning, prescribed burning, and road construction, over many years and across thousands of acres. 

In the case of the Bitterroot Front Project, condition-based NEPA analysis means Forest Service staff will determine the precise location, specific management treatments, and associated design criteria after the final authorization of the project, without performing a site-specific analysis. 

Condition-based NEPA analysis might allow the Forest Service to execute management across a large landscape more quickly, but it does so by undermining NEPA’s original intent of ensuring federal agencies look at management alternatives, listen to the public, and take a hard look at what they propose to do.  

At the public meetings for the Bitterroot Front Project, Forest Service staff shared that there will be one single landscape-level environmental analysis (EA) for the project’s 150,000 acres. The public will have the opportunity to weigh in during that time, but we will not know where or how specific projects will occur on this landscape throughout the 10 to 15 year life of the project. As a result, the public will not know how management actions will affect wildlife habitat, water quality, fisheries, or to what degree it may benefit homeowners, which is one of the main purposes of the project.

For example, the agency talked about “reduced fire risk,” but it is unclear how the project will measure that benefit.

The concerns that we have about the Bitterroot Front Project are not isolated. There are real and significant concerns about how public comment processes and input are being limited and ignored across land-management agencies, and condition-based NEPA analysis has the potential to further limit critical public engagement.

Now is the time for you to weigh in and speak up for public input and thorough, detailed land management. The comment period ends on November 30, so write your comment today. 

Write your comment now

We encourage you to use the following information in your comments to the Bitterroot National Forest: 

  • Authorize the Bitterroot Front Project using traditional NEPA standards, not condition-based NEPA analysis. 
  • This project warrants completion of a full Environmental Impact Statement (EIS) and not an Environmental Assessment (EA). 
  • This project should exclude research natural areas (RNAs) and recommended wilderness, and protect wild land values in all Inventoried Roadless Areas (IRAs). 
  • The Forest should exclude areas that have burned in the last 25 years or design the project to only allow for lighter treatments in these areas, such as hand thinning and no new or temporary roads.
  • Timber harvest alone will not achieve the stated project purpose. Restoration, prescribed fire, recreation and wildlife habitat improvements should be implemented in conjunction with harvest. 
  • This project must be backed by funding that will equally support restoration components, ongoing maintenance, recreation surveys and planning, as well as timber harvest activities. 
  • Emphasize the need to cooperate and partner with county government, private landowners, and community entities to provide for public and firefighter safety and reduce fire risk to communities. 

While we support reducing the fire risk to communities in the Bitterroot and increasing the safety of our wildland firefighters, we want to ensure the Bitterroot National Forest upholds critical standards for public input, couples timber harvest with ecological restoration, and maintains and manages vital wild areas appropriately.

Please tell the Bitterroot National Forest that the Bitterroot Front Project will benefit strongly from a transparent process that maximizes opportunities for public input, as well as refinements to the project area.

- Erin Clark, western Montana field director

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