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Although there is a long history of public participation in decision-making in the United States, citizen involvement in environmental decisions is rare given the level of ecological change occurring without formal or direct involvement by independent citizens or interest groups (National Research Council 2008). Law governing Forest Service decision-making, however, is unique for the substantial access and oversight offered to the public for forest-wide and project-level management relative to other environmental decisions that proceed with no public participation. In fact, the Forest Service is the only federal agency in the country with statutory language specifically requiring an administrative appeals process for project-level decisions (Coulombe 2004). Public participation is a useful indicator for analyzing democratic theory, and the

Healthy Forest Initiative provided a worthy case study to explore the strengths and weakness of elite, pluralistic, deliberative, or agonistic democratic theories.

According to a GAO study of vegetation management CE projects in the United States from 2003-2005 (GAO 2007), of the nine regions governed by Forest Service, the agency approved the largest number of project-level CE decisions in the Southeast

(Region Eight), with 633 CE projects covering 1,608,973 acres. This accounts for more than twice the average of CE projects per region. Of all CE’s issued nationwide from 2003-2005, the GAO found Region 8 accounted for over 29 percent of the projects nationally. The GAO also showed that for the number of CE’s proposed from 2003-2005 in North Carolina (n=32) was well above the national average by individual forest (20) and was the median compared to other forests in Region Eight.

In Region Eight, North Carolina’s 1,251,710 million acres of national forests also contain the most representative sample of the geographic and demographic variation among the southeastern federal land, with four national forests covering the Southern Appalachian Blue Ridge, Piedmont, and Mid-Atlantic Coastal ecoregions (Griffith et al. 2000). No other state in the region contains all three forest types. The state also has highly-populated cities within a one-hour drive distance of each forest. Finally, the Pisgah National Forest is ranked second behind the Angeles National Forest in California as the most heavily visited national forest in the country.

North Carolina also has a unique history with respect to active citizen

involvement in Forest Service management. This includes controversy over an appeal over the 1987 Forest Planning process (Syden 1998), the 1997 Bluff Mountain

controversy in Hot Springs North Carolina (Syden 1997), and a 1999 forest-wide moratorium on logging in the Nantahala National Forest after the discovery of undocumented endangered Indiana Bats (Bagby 1999). This rich history of public participation in national forest management in North Carolina provided for an uncommonly large number of public comments (n=171) for the CE project-level

decisions relevant to this research. This level of participation is substantial given the obscure and expedited CE approach that theoretically do not “individually or

cumulatively have a significant effect on the quality of the human environment” (40 CFR 1508.4).

Case-study methodologies were appropriate for this dissertation due to the attention to decision-making processes used by bureaucratic federal agencies (Patton 1980; Yin 1980). “Federal agencies have made surveys and questionnaires a

bureaucratically hazardous affair due to the clearance procedures required. Case studies have therefore become the preferred method” (Yin 1980). Furthermore, case studies provide an empirical approach for investigating “a contemporary phenomenon within its real-life context” using “multiple sources of evidence” (Yin 1980:13, 97). Unlike descriptive or exploratory case study methods, this dissertation relied on an explanatory case study design aimed at documenting competing structures or processes of decision-making under elite, pluralistic, deliberative, or agonistic democratic theories to determine which model most adequately described the process of public

participation under the Healthy Forest Initiative in North Carolina.

This dissertation investigated the presence of decision-making and forest management characteristics in 67 site-specific project-level actions in North Carolina from 2003-2008, using records research, content analysis, and archival documents. The Forest Service is required to maintain a project file for each proposed project, which includes documentation of the scoping process (public participation), the potential

extraordinary circumstances present in the project area (documented in an “Biological Evaluation”), and a notice of the final decision (Decision Memo).

First, records research was used to identify and obtain primary source records. This allowed for a process of discovery of 67 project files from the Forest Service’s regional, state, and district offices. Next, a content analysis was used to catalogue process and participant characteristics present in 171 individual comments sent to the Forest Service during what is known as the pre-decisional public scoping period. Finally, archival analysis used published newspaper announcements, notarized correspondence, and letters mailed to interested parties. Archival documents were used to verify data obtained during the records research and content analysis methods. These strategies allowed for a “triangulation” of data types to strengthen the research design (Patton 1980; Yin 1980).

The majority of public comments analyzed for this study were received by the Forest Service during the NEPA required “scoping” of the public attitudes. This process is limited to providing information in short announcements in local papers and brief

letters sent directly to members of the public who have previously expressed an interest in Forest Service management and are presently on the agency’s mailing list. This official scoping process, required by the NEPA, was the only process available for the public to address HFI projects until federal district and appeals courts (Earth Island v Ruthenbeck 2005) invalidated portions of the HFI. After three years when the HFI was in use, this ruling effectively returned the right of administrative appeal guaranteed by the National Forest Service Decision-making and Appeals Reform Act (ARA).

Records Research

Records research and archival document analysis were used to identify and verify each individual project-level CE management action in North Carolina beginning in 2003 with the promulgation of the Healthy Forest Initiative. This included discovery and analysis of public and internal Forest Service and General Accounting Office (GAO) publications and databases to document the names and locations of North Carolina’s 67 vegetation management CE projects.

Until 2009, the Forest Service maintained no central database of vegetation management projects occurring across the different national forest districts. Instead, the Forest Service published quarterly listings, or a “schedule of proposed actions” (SOPA), on a non-standardized and inconsistent posting on the Forest Service’s website. The SOPA postings were difficult to use because, during the course of this study, many postings about projects were found to be inaccurate, incomplete, and poorly identified. The information was useful, however, in providing a rough list of the vegetation

management CE projects in NC.

Next, this study used a 2007 GAO compendium of all Forest Service projects nationally from 2003-2005 to improve and verify the original list based on SOPA postings in the four national forests in North Carolina. On March 25, 2009, the GAO officially released their new data collection instrument and spreadsheets for the purposes of this dissertation, and a quick comparison between the GAO’s data and the SOPA-based list uncovered several projects missing from each source. The GAO study, based on surveys of the Forest Service, only identified 32 out of 48 vegetation

management projects in North Carolina for calendar years 2003-2005, including several controversial “Southern Pine Beetle Prevention” projects that were clearly identified in the Forest Service SOPA.

During the summer of 2009, the Regional 8 Headquarters in Atlanta, GA

disclosed that the Forest Service had a new internal database (separate from the GAO) of all management projects, called the Planning, Appeals, and Litigation (PAL) tracking system. On June 19, 2009, employees from the Forest Service Supervisors Office in Asheville, NC ran a report of PAL of all CE projects from in the Croatan, Pisgah,

Nantahala, and Uwharrie National Forests beginning in 2003, and released a digital copy of the report for this dissertation. This report was then culled to document and verify all vegetation management CE projects in North Carolina, which produced a total population of 67 projects.

After a July 6, 2009 Freedom of Information Act (FOIA) request was filed to obtain copies of the individual project files listed in the PAL report, the Forest Service Region 8 Headquarters in Atlanta approved the FOIA and determined that the research adequately met the criteria for a fee waiver. Based on the FOIA agreement, the Forest Service was required to release all vegetation management CE’s identified in the PAL database, although the agency was not required to provide non-HFI prescribed burns or maps of the specific projects. On October 2, 2009, the Supervisors Office began

releasing copies of the individual project files listed in the FOIA.

Based on the project files obtained for this study through FOIA, this dissertation collected public comments (n = 171), environmental surveys, and internal Forest Service

correspondence documented in the public record. On December 1, 2009, the final project files were received from the Forest Service. Policy and project characteristics (analyzed in Chapter Eight) were identified through an analysis of the Decision Memos (DM) and Biological Evaluations (BE) to determine the nature of the individual projects with respect to the size, location, and composition of rare-species identified in each project. The Forest Service tracks rare species called “Proposed, Endangered, Threatened, and Sensitive” (PETS) for each project. Then, NEPA requires the Forest Service to document the BE in the public record, and the final decisions (DM) discusses the public comment, the BE, and other surveys (e.g. archeological). Unlike an

environmental assessment (EA) or environmental impact statement (EIS), a categorical exclusion is exempted from more rigorous analyses if the Forest Service determines no extraordinary circumstances or potential significant issues were identified in the surveys and scoping process. Chapters Five and Six discuss the rules governing CE management projects for U.S. National Forests.

These data collected during records research were analyzed in Chapter Eight to determine the ecological outcomes of the individual Forest Service CE projects. The prevailing management type was understood as a function of the policy and project characteristics (Figure 3). The type of management for each project (either commodity forestry or ecological forestry) depended on where it was proposed, what type of CE classification and stated purposed was used, and when the projects occurred (see discussion below).

Content Analysis

Content analysis is a common research methodology for natural resource policy, and it has been used to measure attitudes about a number of different environmental cases, including measuring attitudes toward animals (More 1977), wilderness areas (Fazio 1979), and management proposals (Stankey 1972). Berelson presents a commonly cited definition for content analysis as “a technique for the objective, systematic, and quantitative description of the manifest content of communication” (1952:18). Stempel described the objective as defining categories so different coders can get the same results consistently, and the "results depend upon the procedure and not the analyst” (1989, p. 125). Manheim and Rich (1981) defined this process as the “systematic counting, assessing, and interpreting of the form and substance of

communication,” which can be used to provide a set of methods for summarizing direct physical evidence (behaviors and relationships) of political actors. As long as a

researcher has access to the primary documents, content analysis can be used whenever there is a physical record of communication among participants.

A content analysis of the management proposals and comments documented in the project files was conducted to determine the process and participant characteristics for each project. This followed Stankey ‘s (1972) four steps for selecting the appropriate categories for considering process and participant characteristics, including 1) Who commented on the management proposal; 2) What they said; 3) Why they said it; and 4) Where the response came from (1972: 149). More broadly, Burrus-Bammel et al.’s methodology (1988) was used following five steps for content analysis research: 1)

defining the population; 2) determining the sample; 3) isolating the unit of analysis, 4) undertaking the substantive or structural content analysis (encoding the data), and 5) coding the statistical analysis (1988:33). This process mirrors other studies in the policy and conservation literature that relied on content analysis (Fazio 1979; Ferguson 1981; Nachmias & Nachmias 1987; Denq 1990; Oh 1992; Steelman 1996).

A coding sheet was adapted from Steelman’s 1996 study of public comments made during the Monongahela National Forest planning process, and was modified to address specific characteristics of the North Carolina process. A pretest was conducted on the modified coding sheet for inter-rater reliability using the Kappa statistic, and the test found substantial agreement among coders (.72 Cohen’s Kappa). Coding began during the first week of October 2009 and continued for eight weeks until 171 comments were coded. A copy of the coding sheet is included as Appendix D.

To describe the data set, the results of the content analysis and records research were imported into Microsoft Excel to produce percentages and totals for analysis. These data were then imported into Microsoft Access to provide for additional analysis based on relationships between different tables and variables. Finally, the statistical software R 2.10 (RDevCor 2009) was used to test hypotheses relating to participation predictions and project frequency identified in Chapter Seven and Chapter Eight. Contingency tables were created using outputs from Excel and Access, and were then used in R 2.10 to test for independence and goodness of fit using chi-square to determine the variables which contributed to significance.