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^ The Ruffed Grouse Society 



' DEDICATED TO IMPROVING THE EN\ IRONMENT 

 FOR RL FFED GROLSE. W OODCOCK. 

 AND OTHER FOREST WILDLIFE 



PO Box 2 • Rice Lake. Wl 54868 

 I 7 15 I 234-8302 • Fax 1715)234-5051 



Statement of 



Daniel R. Dessecker 



Forest Wildlife Biologist 



regarding 



U.S. Forest Service Administrative Appeals Process 



Provided to 



U.S. House of Representatives 



Subcommittee on National Perks, Forests and Lands 



12 June 1996 



The Ruffed Grouse Society, established in 1961, is a nonprofit wildlife 

 conservation organization dedicated to promoting forest resource 

 stewardship. As the Forest Wildlife Biologist for the Society I work 

 closely with the staff of approximately 30 National Forests in 24 states 

 to further mutually- agreeable initiatives. In addition, my 

 responsibilities require that I interact on a regular basis with personnel 

 at the Regional Office and Washington Office levels. 



The Ruffed Grouse Society recommends that public input remain an integral 

 component of that portion of the Forest Service's decisionmaking process 

 where project alternatives are initially prepared and considered for 

 iiiplementation. However, once a project alternative has been selected 

 using public input, tempered by professional analysis, interested publics 

 should respect and accept these decisions. Therefore, the process whereby 

 publics may utilize administrative appeals to halt Forest- or 

 project-level decisions should be eliminated . 



The appeals process as outlined in the National Forest Management Act is 

 fundamentally flawed in that it is based on the assunption that 

 potentially negative consequences emanate only from active management. 

 The appeals process largely fails to provide recourse to address the 

 deleterious effects that can be byproducts of a failure to implement 

 management activities. In addition, the inherent conplexity of forest 

 ecology renders it possible to appeal any decision based on the fact that 

 any decision, including a no-action decision, will benefit certain forest 

 resources while harming others. This situation literally invites appeals. 



