BOSTON PUBLIC LIBRARY 



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subject to state adjudication proceedings and "are beyond 

 the scope of this EIS", but then states "Conditions upon' 

 which this document is based are predicated on the 

 availability of instreara flows sufficient" to provide for 

 the needs under which the Forests and BLM lands "were 

 established" . If the standards and guidelines established 

 by this BIS are adopted, the impact on private water rights 

 will be severe, because the federal government will have to 

 increase its already formidable effort to tcUce water rights 

 from private owners . 



Even though it is clear that impacts on federally managed 

 lands will impact adjacent and often dependent private 

 property, the BIS makes no allowance for protection of 

 private property rights. 



The EIS drafters recognize that the planning and 

 itt^jlementation projected in the document are not based on 

 authority extended by Congress. One of the sections of 

 Chapter 4 is entitled "Barriers to Implementation" . The 

 following statement is made in that section: 



A related barrier is that ecosystem 

 management is an internal policy shift 

 rather than one based on new legislative 

 direction. Because it is not anchored 

 in legislation that redirects multiple 

 use management into ecosystem management, 

 ecosystem management is being implemented 

 as a management response to changing 

 conditions and new information under 



; existing laws. THESE EXISTING LAWS 



DO NOT NECESSARILY CONTAIN CONSISTENT 

 DIRECTION, AND CANNOT BE VIEWED AS 



i REFLECTING A SOCIAL AGENDA TO PROCEED. 



(Barriers to Inclement at ion, page 5) ' 



Even recognizing that the statutes enacted by Congress are 

 not consistent with the ecosystem planning outlined in the 

 BIS, the federal planners move ahead to implementation. 

 This attitude demonstrates a bureaucratic arrogance which 

 holds in little respect the constitutional authority of this 

 body of Congress. • 



We call upon you to set the project teams straight with 

 regard to the authority to manage the public lands, and, with 

 regard to the need of all executive agencies to follow the 

 laws as written by the Congress . We urge you to rein in 

 the^e projects at least iintil there has been compliance with 

 statutory mandates of coordinated local planning and until 

 there is created adequate protection of private properzjf 

 rights and interests. In short, we urge you to reclaim the 

 authority to manage the public lands conveyed only to you by 

 the Constitution of the United States. • 



