Chattahoochee-Oconee 3941 Highway 76National Forests Chatsworth, GA 30705Conasauga Ranger District (706) 695-6736

File Code: 1570 Date: October 23, 2013Route To:

Subject: ARO Recommendation Landscape Analysis Unit 8 on the Homochitto RangerDistrict, National Forests in Mississippi

To: Appeal Deciding Officer

This letter constitutes my recommendation for the subject appeal filed by Charles Chapman.

My review was conducted pursuant to 36 Code of Federal Regulations (CFR) 215. To ensure theanalysis and decision are in compliance with applicable laws, regulations, policies and orders, Ihave reviewed and considered the point raised by the appellant and the decision documentationsubmitted by the District Ranger. My recommendation is based upon review of the Appeal andProject File.

ISSUES

The Issues raised in this appeal that are within the scope of the review and meet the requirementsof 36 CFR 215.14 are:

Issue 1 Whether the project was properly scoped based on requirements of 36 CFR215.5 and 36 CFR 215.6. [Appeal, p. 1]

Issue 2 Whether the EA used inflated numbers for timber values. [Appeal, p. 1]

DISCUSSION OF ISSUES

Issue 1 Whether the project was properly scoped based on requirements of 36 CFR215.5 and 36 CFR 215.6.

The appellant contends (Appeal, p. 1) that "This project was not properly scoped, the letter dated2/04/2010 and the letter dated 4/28/2010 failed to meet the requirements of 36 CFR 215.5 and 36CFR 215.6 (copy's attached) that clearly states that the Responsible Office shall gave [sic] thepublic the opportunity to comment on a Proposed Action, which they already had in place butfailed to inform the public". The appellant further contends that ".. .each time the Decision waspull [sic] only 8 organizations or people received a letter stating that there was anotheropportunity to be involved with this project again." The appellant questions "Why wasn't thenotice not in any of the local papers or a mailing sent to those on the list for this type ofprojects?"

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Guidance for scoping of Forest Service projects is described in Forest Service Handbook1909.15_10 and states:

The methods and degree of the scoping effort undertaken for a given project varydepending on scope and complexity of the project (see the CEO scoping guidance).

Scoping shall be carried out in accordance with the requirements of 40CFR 1501.7. Because the nature and complexity of a proposed actiondetermine the scope and intensity of analysis, no single scopingtechnique is required or prescribed. (36 CFR 220.4(e) (2))

Selection of scoping techniques should consider appropriate methods to reach interested andaffected parties. For example, a project with potential localized effects to a small communitymight consider posting fliers at locations where they are likely to be seen. Requirements forpublic notification pursuant to 36 CFR 215 are described as follows:

§ 215.5 Legal notice of proposed actions.(a) Responsible Official. The Responsible Official shall:(1) Provide notice of the opportunity to comment on a proposed action implementing theland and resource management plan.(2) Determine the most effective timing for publishing the legal notice of the proposedaction and opportunity to comment.(3) Promptly mail notice about the proposed action to any individual or organization whohas requested it and to those who have participated in project planning.(4) Publish a legal notice of the opportunity to comment on a proposed action as providedfor in paragraph (b) (2).

§ 215.6 Comments on a proposed action(i) Environmental Assessment. Comments on the proposed action shall be accepted for 30days following the date of publication of the legal notice.

§ 215.7 Legal notice of decision.(a) The Responsible Official shall promptly mail the Record of Decision (ROD) or theDecision Notice (DN) and Finding of No Significant Impact (FONSI) to those whorequested the decision document and those who submitted substantive comments duringthe comment period (§215.6).(b) The Responsible Official shall publish a legal notice of any decision documented in aROD or DN in the applicable newspaper of record (§ 215.5(b) (2)).

Appendix B of the EA identifies over 100 groups and individuals that were mailed a scopingletter for the project. A copy of the scoping letter mailed on February 4, 2010 is included inAppendix C of the EA.

A legal notice for the required notice and comment period was published in the newspaper ofrecord on June 4, 2013 pursuant to 36 CFR 215.5.

A legal notice of decision was published in the newspaper of record on July 21, 2013 pursuant to36 CFR 215.7.

Finding

I find that the project was properly scoped and appropriate legal notifications were filed.

Issue 2 Whether the EA used inflated numbers for timber values.

The appellant (Appeal, p. 1) contends, "The deciding office used inflated numbers in the E.A. onpage 66 in Table 3.17, the deciding officer use [sic] a $75 per ccf figure for sawtimber and a$9.00 figure for pulpwood which is not valid". The appellant further states that based on salesinformation obtained from the Forest Service that "Using the average of Timber sales over thelast 18 months, along with the volume from the Homochitto in A.U. 8 (copy attached) we show anegative Net Value on this Project".

A financial efficiency analysis "provides a comparison of anticipated costs and revenues that arepart of Forest Service monetary transactions" (FSH 2409.18, 13). As described in FSH 2409.18,13, "In project level analysis, use financial and economic analyses to:

a. Promote consistent development and systematic use of financial and economicinformation in timber sale project decision making.

b. Integrate analyses of timber economic factors with other resource considerations toprovide decision makers with an understanding of the financial and economicimplications and trade-offs.

c. Ensure that financial and, if needed, economic efficiency measures are consideredas decision criteria when evaluating timber sale proposals, and when selecting aproject alternative in accordance with the objectives and standards and guidelines ofthe forest plan.

d. Improve cost efficiency by evaluating and identifying opportunities to reduce costsand to enhance benefits, including revenues."

As further explained in Forest Service Manual 2432.22c, "Use the financial and economicanalyses in making decisions about whether to proceed with project investments and, if so, whichalternative will be implemented to achieve Forest plan objectives. Operate timber sale projectsin the most cost-efficient manner practicable to achieve the objectives outlined by Forest plansand to produce a program where long-term benefits exceed costs (FSM 2430.3)".

A financial analysis was documented in the project record and summarized in the EA on pages66-67.

Finding

I find the deciding official adequately considered the financial efficiencies associated with thisproject.

RECOMMENDATION

After reviewing the project record and the issues raised by the appellant, I recommend thatDistrict Ranger Bruce Prudhomme's July 16, 2013, Decision for the Landscape Analysis Unit 8project on the Homooffitto Ranger District, be affirmed.

JEFF GARDNERAppeal Reviewing OfficerDistrict Ranger