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Various organizations with a decidedly preservationist agenda use the 

 appeals process to halt management actions they deem objectionable. 

 Habitat development through timber harvest, especially even-age 

 management, for those species of forest wildlife that require young forest 

 habitats is one action that is commonly appealed. Activist organizations 

 have learned that with the investment of only a 32-cent stamp, land 

 management decisions and programs that have been reviewed in detail by 

 agency staff rep^'esenting numerous disciplines can be derailed. 



The current appeals process is a significant hindrance to land management 

 on our National Forests in several ways. First, an inordinate amount of 

 Forest Service staff time is expended in an attempt to ensure that 

 decision documents are appeal proof, that all of the "i's" are dotted and 

 "t's" are crossed. A recent report by the General Accounting Office 

 estimated that 30% of Forest Service field unit staff resources are 

 annually used to respond to filed appeals or in preparation for expected 

 appeals. In summary. Forest Service professionals are forced to 

 concentrate their efforts on paperwork rather than land management. 



Second, the Forest Service is often reluctant to issue decisions that it 

 feels may be appealed by local activists. Hence, the mere knowledge that 

 a decision may be appealed has a significant inpact on the Forest 

 Service's decisionmaking process and, therefore, on land management 

 policy. 



Finally, the continuous barra-ge of appeals has, more than any single 

 factor, led to a significant decline in the morale of many within the 

 Forest Service. This erosion of motivation nnay, in the long run, prove to 

 be the most damaging aspect of the administrative appeals process. 



I have enclosed the following itans that document how those publics 

 philosophically opposed to forest management use the appeals process not 

 to pranote meaningful dialogue, but to promote their very narrow agenda. 



1. S ing- to- the- trees appeal 



Appeal of a timber sale on the Pisgah National Forest (North Carolina) 

 filed by Preserve Appalachian Wilderness (PAW) stating that forest 

 health is best addressed by singing to the trees. PAW offers to 

 provide the required singers if the Forest Service isn't able to do 

 so. 



2. More-the-merrier appeal 



Three appeals filed against one timber sale on the Pisgah National 

 Forest. Appeal documents were obviously prepared on the same word 

 processor. These appeals use identical text including the same 

 spelling errors (page 3) . This strategy is commonly used to attenpt 

 to assert that a given project has engendered significant public 

 opposition when in reality action is taken by only a handful of 

 individuals. 



