Santa Fe Mountains Project:
public comments on
draft environmental assessment
On September 13, 2021, The Forest Service released a draft environmental assessment for the Santa Fe Mountains Project. During a thirty day period for public comments which ran through October 29th, comments on the document were submitted via web form, email, and mail.
The Forest Service has released comments submitted via web form in their Reading Room for the project, while comments sent via email and mail are so far not being made available to the public.
The Forest Advocate is making a Freedom of Information Act (FOIA) request for all comments, regardless of how they were submitted, and will post them on this website when received.
In the meantime, we are featuring some comments on this page, including some not in the Reading Room which we have obtained privately from submitters.
While we recognize that the Santa Fe does not have complete information regarding resource conditions on every acre in the project area, we fail to understand how that excuses the complete lack of transparency or effort to compile that information. We cannot support, and will likely challenge to the extent practicable, any approval of this project without “complete information regarding the conditions found on every acre of the project footprint[.]” EA at 29.
This lack of information is likely the best evidence available that this project needs to be analyzed via EIS rather than EA. See Southeast Alaska Conservation Council, et al. v. U.S. Forest Service, 443 F. Supp. 3d 995 (D. Alaska 2020) (rejecting an EIS for a project with a similar lack of information) …
There are many well-researched and supportable forest health opinions contrary to the scientific opinions used as the foundation of this project. In fact, we know that the Santa Fe received numerous scoping comments highlighting in great detail alternative scientific positions on forest health. We are concerned that a bias towards achieving the goals of this project was applied when the decisionmakers reviewed the available science on this topic… it appears that the “best available science” used to defend this project was subjectively and specifically selected because it supported the goals and strategies from the outset, rather than letting the science instruct the Santa Fe National Forest on what those goals and strategies ought to be. We again urge you to initiate an EIS review of this project to thoroughly and publicly analyze the available science on forest health, climate change, and a healthy fire regime before continuing to exert human influence on natural processes.
Joint comments by WildEarth Guardians,
The Forest Advocate, and Santa Fe Forest Coalition
NEPA mandates that “federal agencies shall to the fullest extent possible . . . encourage and facilitate public involvement in decisions which affect the quality of the human environment.” 40 C.F.R. § 1500.2(d).
This project has been presented to the public as utilizing a “collaborative” approach, but it was only collaborative with organizations and individuals who agreed with the fundamental perspectives of the Forest Service…
NEPA further mandates that the agency provide the public “‘the underlying environmental data’ from which the Forest Service develop[ed] its opinions and arrive[d] at its decisions.” WildEarth Guardians v. Mont. Snowmobile Ass’n, 790 F.3d 920, 925 (9th Cir. 2015). The Forest Service’s policy prevents public access for evaluation of “specialist reports” cited in the EA, until after the Forest Service’s final decision about the project is made. Parts of the Forest Service’s analysis of the project underlying the EA are being withheld from the public during the public’s final opportunity to comment on the EA…
The SFMLR Project is highly controversial both in terms of the science and to residents of the Santa Fe area. The nearby forest is a critical aspect of why people choose to live in this area. Conservation organizations and members of the public have been urging the Forest Service to do comprehensive analysis, an EIS, since the project was conceived of. The Forest Service has so far not heeded the outcry of those concerned about the serious potential impacts to the vegetation, soils, wildlife, IRAs, riparian areas, scenic quality, and all that we value in our forest. We urge the Forest Service to hear us now, to complete an EIS, with disclosure and analysis of site-specific locations and methods, and utilizing a full range of the best available science. Such analysis must abandon the conditions-based management approach and provide the site-specific analysis NEPA requires.
Carbon Sequestration: While uncertainty remains around climate change mitigation strategies, it is well-known that carbon sequestration by trees and forests have the potential to positively impact climate change. Unfortunately the SFMLRP does the opposite by cutting and burning our forests, causing carbon to be released into the atmosphere. While I applaud the Santa Fe National Forest for reducing the size of the trees cut from diameters of 24” to 16”, a sixteen inch diameter Ponderosa is over 150 years old. It will continue to contribute to carbon sequestration for hundreds of years. If cut and burned it may not be replaced due to climate change. A young tree will not store carbon for close to one hundred years. Thus when we “thin” our forests of mature trees we are killing all life on our planet. The Forest Service must place a priority on land management which promotes forest Carbon storage.
Since science cannot predict with certainty the long-term effects of cutting and burning, this project demands an EIS and alternatives to rampant thinning…
The EA states “Overland travel by vehicles that do not require roads to be constructed (e.g., masticators, UTVs) may occur (U.S. Forest Service 2021).
This sentence indicates that tracked and/or wheeled vehicles will travel overland causing indiscriminate destruction of soils, plants and wildlife habitat. This is contrary to the stated purpose of the Roadless Rule and the SFNF Travel Management Plan and will destroy the primitive wilderness character and the wildlife population. The Thompson Peak IRA has been proposed as a potential Wilderness area.
This plan must include an Action Alternative that does not include logging in IRAs. Maps of the EA supplied to the public must include details of the proposed burning and thinning areas within the IRAs
The use of the word “catastrophic”, which occurs 46 times as a wildfire descriptor in this document, is undefined in the EA glossary, plays purely on emotions without any precise, shared, or operational scientific or ecological meaning, skews opinion without any clear grounding in science or fact, and is thus inappropriate for inclusion in a document of this nature. Since this word has no clear or shared definition in reference to fire, all instances of it should be removed from the EA and all other current and future Project-related documents.
The word “uncharacteristic”, which appears 33 times to describe wildfire in this EA, is similarly undefined in this document…
Anything less than a full and complete edit to correct what amounts to a confusingly incomprehensible stew of emotionally shrill but functionally empty fire descriptors with no substantive definitions, can (and will) be construed as either base ignorance, cavalier negligence, or intentional obfuscation on the part of this Forest…
By side-stepping a full and proper EIS, this Forest irrevocably undermines its credibility on this and all other future projects. The Forest’s failure to initiative an EIS from the very start, and subsequent failure to heed the many voices requesting an EIS, reeks of partisan bureaucratic fast-tracking at the expense of a full, measured, comprehensive scientific planning. I thus reiterate my request that the Forest conduct a proper Environmental Impact Statement…
… I have relocated to NM from CA 24 years ago to escape the impact of herbicide on my condition of severe MCS, and found myself having to constantly defend myself against the negative impact of smoke and all the chemicals it contains, increasingly through the years here. My health and my home have no stability, as I suffer severe relapses in my condition and exacerbation of life threatening symptoms, every time a prescribed burn takes place, if I do not literally pack up and leave the area, for days, weeks or months…
With the increasing amount of acreage proposed to be burned and the increasing frequency, with herbicide added into the mix, I may not be able to maintain any presence in Santa Fe any longer, literally being driven out of here, out of my home too frequently to maintain it any longer, and becoming homeless. If I fail to be able to leave at the right times and/or relocate away from here permanently, I may land in the hospital, due to inability to breathe and/or the results of a smoke induced accident at home or in my car.,.will the forest service pay my medical bills?
I am literally one of the ‘canaries in the coal mine”, and my problems illustrate the impact on everyone that either does occur without being acknowledged (how many people really know where their headaches and spaciness and medical problems are coming from?) or can and will occur over time as more and more people succumb physically and mentally to these impacts.
Please seriously consider all the information submitted by Dr. Ann McCampbell and others concerning the extreme toxicity of smoke/chemicals and herbicides involved in your plan, and alter the plan in favor of the survival of the forest and the people…
Comments by Multiple Chemical Sensitivities Task Force
Smoke from prescribed fires poses a significant public health threat, especially to those with chemical sensitivities, asthma, and other respiratory conditions…
The impact of smoke on the human environment needs to be carefully analyzed in an Environmental Impact Statement (EIS) for this project.
The proposal to use herbicides in the Santa Fe National Forest is also a public health threat. Herbicides are toxic chemicals that can get into the air and pollute land and water. An EIS should also examine the adverse health impacts of herbicides on the human environment, including impacts on vulnerable populations, such as those with chemical sensitivities…
Sensitive Populations
Inhaling smoke is not good for anyone, even healthy people, but there are many populations at increased risk of harm from air pollution. The following data on groups at risk from exposure to air pollution are provided by the American Lung Association in New Mexico:
The total population of Santa Fe County is 150,358.
Under 18 years of age 26,394 (18%)
65 years and over 38,106 (25%)
Pediatric asthma 1,437 (1%)
Adult asthma 10,524 (7%)
COPD (chronic obstructive 7,951 (5%)
pulmonary disease)
Lung cancer 51 (negligible)
Cardiovascular disease 11,248 (8%)
Poverty estimate 18,378 (12%)
The Forest Advocate
Santa Fe, New Mexico