The effects of the Healthy Forests Initiative, corresponding administrative reforms, and the Healthy Forests Restoration Act on the U.S. Forest Service’s implementation of the National Environmental Policy Act: does it serve the common interest?

Abstract

This study investigates the effects of the Healthy Forests Initiative (HFI), corresponding administrative reforms, and the Healthy Forests Restoration Act (HFRA) on the implementation of the National Environmental Policy Act (NEPA) by the U.S. Forest Service (Forest Service). Specifically, the study investigates whether HFI and associated reforms have resulted in decisions that serve the common interest. Fire Danger Sign at A-S National Forest The units of analysis for this study are three Environmental Assessments (EA) and corresponding decisions that were conducted under HFI and HFRA to reduce fuel loads in the Apache Sitgreaves (A-S) National Forest in Arizona. Archival document review, in-person, and telephone interviews were conducted to examine whether the three case studies of HFRA implementation represent common interest solutions. The analysis revealed that HFRA offers a savings in process time, a shift in focus to the WUI areas for treatment, and an increase in the number of proposed treatment acres with a completed environmental document. The analysis also revealed a concern for funding of “NEPA-ready” projects and concern that the pre-decisional appeals process under HFRA forces objectors to comment on a project before enough data are available to substantiate their concerns. The analysis revealed that the Apache County Community Wildfire Protection Plan (ACWPP) represents the common interest, as do two of the three EAs. The proposed action in one of the three EAs did not serve the common interest and fell short of addressing environmental concerns. This EA was objected under HFRAs pre-decisional appeals process by environmentalists. The study also found that participation in the ACWPP process did not necessarily include participation by individuals affected by the site-specific EAs. Thus, their interests may not have been represented in the ACWPP process.