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May 23, 2019

Review of the Draft USFS Forest Plan: Providing Substantive Comment


On May 21 the Mountainair Ranger District Collaborative announced the public rollout of the latest draft Cibola Forest Plan will be posted on the USFS website on either July 19 or July 26 for public review. Public meetings for comment will follow in August and the draft plan available for written public comment until October.

A presentation was given by Mark Werkmeister of the New Mexico Off Highway Vehicle Alliance (NMOHVA) on how to provide Substantive Comment when submitting comments on the draft plan. Often public comments received contain opinions based in generalities and are rejected according to rules established in the Council of Environmental Quality regulations (CEQ). Under these rules comment must address the basis of the decisions made, not the decisions themselves. This type of comment is regarded as Substantive Comment and is acceptable by the Forest Service if the basis of the comment is found to be reasonable.

Under the National Environmental Policy Act (NEPA) the plan must contain an Environmental Impact Statement (EIS) which is compiled by various specialists within the Forest Service. The statements contained in the EIS are the basis of the planning decisions made by the Forest Service and are the key to developing reasonable alternatives, identifying errors, and determining if the EIS has adequately addressed the actual conditions of the forest. Resources available to aide in writing good comments include CEQ Title 40 Parts 1500-1508, the Code of Federal Regulations (CFR) Title 36 Part 15 (Forest Service Regulations), CFR Title 40 Part 1503.4, and the Forest Service Handbook chapter 1909.15.

Learn the rules governing the agency, what rights you have, and when you can apply them. There are three times during the planning process the public can submit comment:

The Scoping Period when the agency is determining specific points of their proposal, the planning process, and proposed actions.

When the draft EIS is available for comment.

When filing an objection to the Forest Service on a decision.

The object of substantive comment is to ensure the EIS is compliant with the CEQ regulations for a complete, honest, and accurate document or show the document is flawed in a way that would affect the decisions made for the plan. Substantive comment identifies errors in the decision making process and offers reasonable alternatives for consideration. Be specific with remarks and support comments with pertinent facts and references to any regulations or portions of the EIS. In conclusion: The EIS is often a large document with repetitive information under the various sections and may seem overwhelming. In reality it is arranged in a specific order and referring to the table of contents to find those portions of the EIS which are relevant to your concerns is quite simple.

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