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4 

 timber sales, 381 appeals were filed on 1,897 sales- -about 20 

 percent, a rate similar to that for other types of projects. 

 With respect to litigation, lawsuits were filed at a rate of one 

 lawsuit for every 50 appeals. Clearly, the appeal process 

 provides resolution for the vast majority of contested Forest 

 Service project decisions. 



Possible Changes to the Project Level Appeals 



In preparation for this heraing, we asked the nine Forest Service 

 Regions how the revised appeals process is working. Only one 

 criticism of the current system was common to most respondents. 

 This criticism is that the criterion for establishing the right 

 to appeal (Section 322(c) P.L. 102-381) is overly broad. Persons 

 are not required to express any specific concerns during 

 predecisional project development. This allows parties to file 

 appeals that are vague or that raise specific concerns for the 

 first time on appeal, and prevents the Forest Service from 

 addressing these concerns before decisions are made. Having 

 noted this concern, our records show that less than two percent 

 of the appellants did not participate with written comments 

 during scoping or the 30 day notice and comment period. In light 

 of these facts, we do not believe that limiting standing to those 

 individuals who had filed written comments during predecisional 

 project development would improve the process signif icatnly . 

 Certainly, when considering disadvantages of destabilizing the 

 current appeals process, we would not advocate changing the 



