The Conservation Alternative
The Conservation Alternative Story
Since 2019, several non-governmental conservation organizations have been contributing to the development of a Conservation Alternative to the Manti-La Sal NF (MLNF) initial draft plan. It is our vision of how the Manti-La Sal NF should be managed and cared for by the Forest Service and users in the coming 10-15 years.
The MLNF released its preliminary draft plan to the public on October. 1, 2020. We released a draft Conservation Alternative to the public on Oct. 5. The Conservation Alternative parallels the MLNF draft plan for all sections and elements (Goals, Desired Conditions, Objectives, Standards and Guidelines) so that the two plans can be directly compared. The two plans are similar for some elements, but also differ in significant places.
Compared to the MLNF draft plan, the Conservation Alternative places greater emphasis on the following:
Reasonable sideboards on uses of the forest and its natural resources in light of the climate crisis
Protection of native species and habitats over intense commercial and recreational pressures
Meaningful inclusion of Tribal perspectives and proposals in planning and management
Important commitments of the MLNF to the public throughout the life of the plan
The Conservation Alternative is currently in a draft form. A final version will be submitted to the Manti-La Sal NF before October 25th 2021, the end of the public scoping period. Therefore, we welcome your specific suggestions for how this Conservation Alternative can be improved.
Why should the Conservation Alternative be in the Manti-La Sal 2022 Draft EIS?
While the Trump Administration has gutted much of the National Environmental Policy Act (NEPA) regulations (the legality of which is currently being litigated), alternatives remain in Draft and Final Environmental Impact Statement (EIS) processes because they are part of the original National Environmental Policy Act of 1969. Thus only Congress would be able to remove consideration and comparison of the potential impacts of alternatives in an EIS.
As the 1979 implementing regulations (amended in 1992) noted regarding alternatives,
“This section is the heart of the environmental impact statement . . . sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public.”
Even the 2020 Trump Administration NEPA regulations still require comparison of alternatives (at §1502.14) in EISs:
The alternatives section should present the environmental impacts of the proposed action and the alternatives in comparative form based on the information and analysis presented in the sections on the affected environment (§ 1502.15) and the environmental consequences (§ 1502.16). In this section, agencies shall:
Evaluate reasonable alternatives to the proposed action, and, for alternatives that the agency eliminated from detailed study, briefly discuss the reasons for their elimination.
Discuss each alternative considered in detail, including the proposed action, so that reviewers may evaluate their comparative merits.
Generally, the federal agency (in this case the Manti-La Sal NF, or MLNF) that is undertaking an EIS develops alternatives out of comments provided by the public (including Grand County, other agencies, businesses, scientists, citizens) during a scoping period. But in fact, other agencies and non-government organizations and even individuals can submit comprehensive alternatives that parallel the agency alternatives. If an alternative is reasonable and different from the agency’s alternative(s), it can be expected to be published and compared to agency alternatives in the Draft and Final EIS. This has happened many times before.
It is important that the Conservation Alternative appear in the Draft EIS because the MLNF will then need to compare the environmental consequences of implementing each of the alternatives. It also allows the public to comment on which pieces of which alternatives they would like to see in the final forest plan.
In its final forest plan (in Summer 2023), the MLNF can incorporate pieces from any/all of the alternatives displayed in the Draft EIS (Summer 2022).