Editor's Opinion

Neither my American Heritage dictionary nor my Webster's Ninth New Collegiate dictionary contains the word "biodiversity." These tomes date from the late 1980s, so their compilers probably had not suffered from the overload of meaningless green jargon that afflicts us today.

Whether or not, in the intervening 20 years, the term "biodiversity" has been accepted as an actual word, our forest-management agencies could do just as well to leave it out of their planning documents. "Ecosystem," a word that does appear in my dictionaries (its date of origin is listed as a relatively recent 1935), also strains the language credibility barrier.

Maybe our land managers in Washington, D.C., should invest in a sturdy set of dictionaries so their planning staff can draft clear, concise and meaningful documents.

The modern language of environmental planning follows a practice that many of my less studious classmates cultivated in high school. When these procrastinating students had run out of time and discovered they had nothing meaningful to write in their essays, they would throw in a lot of elaborate but basically meaningless language. It was their hope that they could bluff their way through the class and earn a passing grade from an instructor who was too busy to wade through their verbiage.

Apparently, the drafters of a new proposed federal rule, "36 CFR 219, for National Forest System Land and Resource Management Planning," learned the same trick of essay huckstering.

Here's what former Forest Service employees - the National Association of Forest Service Retirees, writing in a comment letter to the Forest Service - had to say about the proposed rule:

"In sum, the Proposed Rule suffers from three principal infirmities which neither the Forest Service nor the public can afford. First, the rule lacks a framework for the basic function of identifying issues and selecting multiple-use objectives, instead substituting process for decision making (i.e., the rule is a bogged-down blueprint for "analysis paralysis.")

"Second, the biological diversity requirements of the rule far exceed the statutory requirements of NFMA (National Forest Management Act) by mandating excessive data collection and analyses that exceed reasonable budget and time constraints (i.e., the rule suffers from regulatory overkill).

"Third, the regulatory requirements for the use of 'best' science, validation that science was appropriately applied, and disclosure of uncertainties and risks are highly subjective in nature, redundant, unprecedented, not supported by any statute and likely to invite legal challenges on matters not easily proved in litigation. As written the Proposed Rule will not significantly shorten the inefficient and unacceptably long four-year plan revision process. By limiting the proposed rule to the explicit statutory requirements of NFMA, the Forest Service can and indeed must substantially simplify the land management planning process."

The rule writers failed to stick to their subject, which is the federal law. The same tendency appears to have occurred within the Oregon Board of Forestry, a state body which has drafted the 2003 Oregon Forestry Program for Oregon.

Oregonians in Action, a land-rights group, took a swipe at this unwieldy document:

"This massive document calls for protecting, maintaining, and restoring 'biodiversity' (biological diversity) and 'ecosystems' - which includes all animals, birds, plants, insects and organisms in the soil, regardless of whether they are endangered. They are tools extreme environmentalists are using to preserve land in its natural state, or greatly restrict human activity on land, public and private. Such policies will lead to regulations that restrict or prohibit forest harvesting and management. At the least, trying to integrate biodiversity and ecosystem protection with productive uses on forest land will be extremely complex and costly. Just inventorying all such resources would be mind-boggling. Assessing impacts of harvesting would be even more complex. We have already witnessed the virtual shut down of harvesting and deterioration of forests on federal land because of application of such concepts."

Oregonians in Action may be overreacting to the state document's phony buzzwords and overkill of verbiage, but the group's criticisms highlight the basic failure of these documents. For my money, I'll take a 20-page summary that concisely lays out goals and legal requirements for public-lands forestry without resorting to the latest green gobbledygook - vague, meaningless terms such as "biodiversity" and "ecosystem health" that can immerse us in a bottomless swamp of regulation. And, hey, it might not hurt to include the word "logging" (date of origin: 1699) so we can remember why we call forests renewable resources in the first place.

The text of the state plan is on the Board of Forestry's Web site (www.oregonforestry.org). The public also can call or write for a copy (503-945-7200; 2600 State Street, Salem, OR 97310).

Comments or questions about the Forest Service Planning Rule can be submitted to: Content Analysis Team, P.O. Box 8359, Missoula, MT 59807; or via e-mail to planning_rule@fs.fed.us.

Opinion" can contact David Carkhuff by calling 575-0710 or by e-mail at editor@bluemountaineagle.com.

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