by The Forest Advocate May 30, 2020 updated June 3, 2020
Between June 10 and July 17, 2019, the US Forest Service held an official comment period for members of the public to provide input on analysis for the proposed 50,566 acre Santa Fe Mountains Landscape Resiliency Project. The project proposal calls for removal of the majority of trees and vegetation from up to 21,000 acres of forest nearby Santa Fe, and for periodic prescribed fire on up to 43,000 acres, including the areas previously cut. 5,024 members of the public submitted comments, including about 4,400 who submitted a personalizable comment through the WildEarth Guardians’ website. The Forest Service made only 58 of the 5,024 comments available to the public by posting them in their online reading room. By the end of July, even these 58 comments were withdrawn from public view, and numerous requests that the Forest Service post these and all the other comments, as is customary, were denied.
It is important for public NEPA comments to be posted so the public can become more aware of forest issues, as an educational forum. It is also an opportunity for the public to become aware of whether a project is generally approved of, or not, so citizens can coalesce in their response. Having public comments available during NEPA analysis is an integral part of including the public in the process.
On February 19, 2020, the Forest Service released all the comments to WildEarth Guardians under a Freedom of Information Act request. The Forest Service still has not posted the public comments online, so The Forest Advocate has published the comments here for public view.
If you would like to see the comments in the form provided by the Forest Service in fulfillment of WildEarth Guardians’ Freedom of Information Act request for the Santa Fe Project scoping comments, click here to download the .zip file (178MB). Note that the alphabetical directories above contain all the same comments as are in the .zip file. Also note that upon request we remove personal information from comments in both the alphabetical directories and in the .zip file.
PDF file combination
The US Forest Service fulfilled its Freedom of Information Act request by providing 8,074 PDF files with filenames starting with the apparent last name of each commenter. For convenience, The Forest Advocate combined multiple PDF files labeled with the names of the same unique commenters into single PDF files. This created 5,024 files from 5,024 commenters; these are accessible above alphabetically and by comment category.
Some of the original multiple and duplicate files were created as the Forest Service divided cover letters and attachments into two files. Others occurred because commenters submitted more than one comment, or the same comment more than once.
In some comment files, readers will find scans of hard copies of letters received by the Forest Service. Other files contain petitions submitted by the commenter, and some comments are signed by more than one person. For the purposes of counting commenters, The Forest Advocate has used the principle of one commenter per combined group of files named for the same unique commenter, regardless of what name(s) may appear within.
Scoping comments are intended to request that important concerns regarding a project be analyzed. However, comments also tend to express approval, or lack of approval of the project as proposed, and this is also an important function.
Over 300 unique scoping comments were placed into three categories of general opinion about the project:
1) Fully or largely disapproving of the project as proposed, requesting an EIS
2) Generally or somewhat approving of project as proposed, requesting an EIS
3) Approves of project as proposed, not requesting an EIS
This categorization was subjective, but it was not difficult to classify them into one of the three categories except in a few cases. Members of the public often simply stated whether they approved of the project as proposed, or not, and gave reasons why. Some also suggested concerns to be analyzed. Conservation groups were more likely to focus primarily on discussing concerns to be analyzed. It was possible to discern generally whether a group approved or disapproved of the project as proposed through their discussion of concerns to be analyzed.
All comments but a few requested an EIS. The requests were almost always in the form of direct statements that were not ambiguous.
The Forest Advocate
Santa Fe, New Mexico