Applied Ecosystem Services, LLC

The Environmental Issues Doctor

The current paradigm used by all federal agencies when preparing NEPA documents is descriptive. It is a qualitative assessment with a decision made subjectively. There is no standardized process used to determine what components are included in the assessment. Scoping too often is separated from public participation. Descriptions of the existing environments are described in words with large technical appendices filled with tables of numbers and graphics. However, there is no attempt to explain what this description means. Is the environment “good” by some criteria? The affected environments associated with each alternative are also described by words, tables, of numbers, and graphic charts and plots. How is a regulatory decision-maker to know what it all means? How can she have confidence that the decision is sound and easily explained and justified to anyone who asks? She cannot. Regardless, BLM staff and managers have helped to establish and maintain an environmentally-responsible and economically worthwhile mining industry on public lands in the US, with direct and indirect societal benefits beyond the immediate project site.

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Providing essential environmental services since 1993.