Property Rights Foundation of America®

P. O. Box 75, Stony Creek, NY 12878
(518) 696-5748

January 30, 2003

Healthy Forests Initiative
USDA FS Content Analysis Team
Office of the Secretary of Agriculture
P. O. Box 221150
Salt Lake City, Utah 84116

Comment Re: NEPA Categorical Exclusions
Fire Management Activities

Dear Secretary of Agriculture:

This letter is in support of the President's proposed changes to the Forest Management System. Specifically, this letter is to support categorical exclusions to NEPA for the purpose of fire management activities. This statement is in support of salvage logging and brush removal to substantially reduce fuel buildup and removal of fire-damaged timber, for governmental, environmental, fire control, and commercial purposes. This letter is to also express support for ongoing programs to maintain fuel levels at a greatly reduced level and to utilize the timber resources of the National Forests for commercial production for the benefit of people in practical ways.

The Property Rights Foundation of America, based in upstate New York, has active participants throughout the United States, including ranchers and foresters who are users of Forest Service lands. In addition, property owners adjacent to Forest Service lands are among our active participants. These land users and property owners consistently have grave concerns about the fire safety of the lands owned by the United States Government.

In addition, we in the east have grave concerns about the protection of the assets that belong to the People of the United States of America and about the environmental destruction that has resulted from mismanagement allowing the buildup of extreme fuel levels.

When I study reports of the hazardous conditions and the catastrophic fire events, I marvel that the situation has been allowed to reach this situation of extreme neglect and wrongheaded management, spurred on by people who are ironically named "environmentalists," but who are really consumed by hate for human activity all across rural America and have no particular regard for environmental protection. In fact, they will gladly sell out the preservation of wildlife for any victory against productive human interaction with the land.

It is time for reversal of the policies of "management" of the National Forests that have caused fires of temperatures often as high as 1000 to 2000 degrees with millions of acres of wildlife destroyed and the environment gravely damaged, the soil sterilized; left lakes, rivers and reservoirs contaminated with ash-like soil runoff; caused the loss of billions of board-feet of timber that will otherwise have to be harvested, perhaps from abroad, because of the undiminished demand for lumber; resulted in the deaths of many firefighters; and denied our national commerce and local communities of the fruits of the productive forests on the lands that the People have set aside for the purpose of timber production.

In addition, lack of removal of diseased trees causes the spread of disease and the loss of assets on government and private land, as well as the corollary damage to wildlife and the environment.

At the Fifth Annual New York State Conference on Private Property Rights, sponsored by the Property Rights Foundation of America in 2000, Robert H. Nelson, Ph.D., Professor of Environmental Policy, School of Public Affairs, University of Maryland, presented the closing address on the topic, "Burning Issues — The Dangers of Government Forest Management."

Professor Nelson described the many years during which official reports by the Forest Service, the Secretaries of Interior and Agriculture, and the General Accounting Office warning of the dangerous conditions of the National Forests were disregarded and during which the management of the National Forests continued to decline.

He discussed the Los Alamos fire that was on everyone's mind in the fall of 2000:

"If the Santa Fe National Forest had not been a tinderbox, the error made by the Bandelier superintendent would have been a much less significant error. Now most of the forests in the Southwest, 85 percent according to the Forest Service's own figures, are in this kind of fire-prone condition. You know, there are different degrees but all of them have significant, virtually 100 percent have significant fire hazards relative to their historic norms." (Proceedings of the Fifth Annual New York State Conference on Private Property Rights, PRFA, 2000, p. 55)

The hazardous condition of our National Forests continued. Finally, with a change of Administration, the President has proposed relief that we have so long advocated.

Too many issues relate to the management of the National Forests to discuss all of them in a letter of this nature. Some issues are ironic. Although the so-called "environmentalists" oppose improved management of the National Forests, reduction of fuel buildup in the National Forests would be constructive with respect to the issues of air pollution and global warming, as was pointed out by Professor Nelson in his speech:

"Another thing that I point out to environmentalists is that there was probably, certainly, the largest unplanned emission of carbon dioxide of the year 2000. So if you are concerned about global warming, you ought to be concerned about not having the forest of the nation burn down on a regular basis." (Proceedings, p. 55)

In closing, I must emphasize the important point that rural people deserve protection from fires originating on lands owned by the U.S. Government. Communities should be extended the normal legal and human relationship that any neighbor would be forced to abide by. No person is allowed to create an extreme fire hazard to the homes, property and lives of his neighbors! It is the duty of the United States Government to eliminate fire hazards to neighboring properties that originate on the Government-owned land.

In summary, implementation of the proposed categorical exemption for the purpose of fuel reduction and improvement of the health of our National Forests would help to protect the assets of the People of the United States; reduce danger to life, limb and private property that is threatened by extreme fuel buildups; protect wildlife and the environment in the National Forests; reduce carbon dioxide emissions; and help transform the United States Government's posture from being a dangerous neighbor to the status of a good neighbor.

This statement is to offer whole-hearted support for the President's proposed changes to the Forest Management System and urge that the Healthy Forests Initiative be fully implemented.


Carol W. LaGrasse
Property Rights Foundation of America, Inc.


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