Timber Sale Comment Writing Strategies


1) Frame your comments around the question of "Is the proposed action likely to achieve the intended results?"  This is a useful framing question especially where logging is proposed in ecologically sensitive areas such as Riparian Reserves, mature and/or old growth areas, recently burned or previously logged areas, or areas on steep slopes. To build this type of argument, use the information in the Environmental Assessment to find out what rationale is being used to make the claim that logging will improve conditions in a given area, then review any scientific studies cited on that issue. Is the Forest Service's claim widely accepted by peer reviewed science or only shown in the agencies own studies? Is the science they've referenced the most recent? Are there other studies that contradict the Forest Service rationale? You do not have to make an argument that the Forest Service use different or new rationale, all you need to do in the comment is make a request that they complete further analysis or take new information into condsideration if you find their rationale to be questionable.

2) Scour the Environmental Assessment for internal inconsistencies or incomplete information. Look for descrepancies in the data they've provided. This framing is most useful when focusing on one specific area of environmental impact rather than looking at the entire project. Consider what kinds of information could be skewed to make the project look less impactful and triple check the numbers (miles of roads, acres of logging, rates of change, etc.). Point out inconsistencies and request clarification.

3) Question whether they have properly analyzed the cumulative, componding, or intersecting impacts of multiple influences. This document compartmentalizes the impacts rather than addressing the complexity of interrelated impacts. Each impact seems lesser when taken individually. Look for common sense examples of impacts that would certainly be more significant if they were considered together rather than sepearately. Ask for further review of the relationship between different impacts that you are concerned about. 

4) Question whether they have given appropriate consideration to "alternative" actions or if the Project Design Criteria (PDCs) are strong enough to reduce the negative impacts. They are proposing "regeneration harvest" in some areas, for example. You could raise concerns that such heavy logging is not necessary to achieve the goals they have stated for the project. Ask them to prepare more "alternatives" that would have a lesser environmental impact on the ecological feature that you are concerned about. You can also advocate for the "no action alternative" if you have reason to believe, and have some science to back it up, that leaving an area to naturally develop/change/mature would be the best way to achieve the stated goals with the least environmental impact.

5) Question whether the Environmental Analysis is thorough enough to meet the requirements of NEPA. Has the agency truly taken a "hard look" at the impacts?

6)You may have other clever ideas about challenging the information or rationale presented in the Environmental Assessment. Use your critical thinking skills and reach out to Bark for support!

View of proposed logging unit 182 from Trillium Lake













View of proposed logging unit 182 from Trillium Lake


Issue Focused Comment Writing Workshops (presented on Zoom):