For more information from the Forest Service, get out the pry bar

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January 3, 2016 – UPDATE: Just received this answer from the Forest Service, on whether there is a character limit on text that can be entered in the comment box on their web site: “The answer from our IT folks is “There isn’t a limit to how much text can be entered into the field on the web page. Technically there is an upper limit to how much text can be stored in a single field in the database but it should be around 2 gigs.”

We also just discovered this: While flying Navy training missions on weekends is not mentioned in the Growler DEIS, the Forest Service’s Draft Permit says the Navy will be allowed to fly on weekends so long as it does not interfere with “…opening day and associated opening weekend of Washington State’s Big Game Hunting Season for use of rifle/guns.” To see this incredible statement for yourself, go here, scroll down to “Decision,”and  click on the 4th link down, called “2016-11-29.NavyPermitDNAppendixC_DraftPermit.” Go to page 11, bullets 5 and 7. And ask yourself, why would our government do this behind our backs?

Why was this additional flight time period not mentioned in the Navy’s Growler EIS? It has long been understood, and the Draft EIS acknowledges, that the Navy will cooperate with local officials and populations by not flying training missions on weekends and holidays. No communities have had the opportunity to evaluate these additional noise impacts. Weekends are peak times for local economies, and to have that quiet obliterated by jet noise from a rapidly expanding mega-base is a threat to local economies. People come here throughout all 4 seasons to relax in peaceful, unspoiled surroundings. To not disclose weekend flying in the EIS, and then to extend such a courtesy to the big game hunting industry without consulting with municipalities and other economically viable (and vulnerable) tourism and recreation entities, is unwise, irresponsible, and does nothing to rebuild trust between the Navy, the Forest Service, and the public. 160 jets (yes, another 42 are coming after this EIS ends) and weekend flying will also make the Navy’s current noise level projections obsolete even before they are finalized.

There are several days left to comment on the Forest Service’s draft permit before it ends on January 13. Please participate. We have created draft comments for your consideration in this post. You can find them between the big arrows. To comment on the Forest Service’s web site, click here.

December 22, 2016 – This is an email exchange with Forest Service representatives in which we tried to find out the answer to two simple questions:

  1. In the Forest Service’s comment box where we are supposed to write or paste our comments, is there a limit to the number of characters? For example, Navy and Congressional comment boxes normally limit it to 5,000 characters, which is about 500 words. This precludes the public’s ability to participate by limiting what they can say in a public process. So it’s important to know if content will be cut off by such a limit.
  1. Is there an email address to which the public may send comments? There always has been in the past, and it is the most simple and convenient method of participation.

One would think answers would be simple, forthcoming and easy to understand. One would be wrong.

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To: Greg Wahl, gtwahl@fs.fed.us   From: Karen Sullivan                                                            Date: December 21, 2016

Subject: Can comments be emailed to you?

Hi Greg,

What if anything is the character limit on the Forest Service’s online comments box, and will the Forest Service accept comments by email if they are sent to you?

Thank you,

Karen Sullivan

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To: Karen Sullivan  From: Wahl, Gregory T, USFS

Hello Karen, you can always attach your comments (word, pdf, etc) if you think there will be a concern with length. Please visit the project website here (https://www.fs.usda.gov/project/?project=42759 ) for more information about the proposed activities and the current objection period (and how to submit objections). Let me know if you need any other information.

Thanks,

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To: Greg Wahl  From: Karen Sullivan

Thanks, Greg.

I have visited this web site, and the information I asked you about is not clear, which is why I’m asking, because usually there is an option to email comments in a public process, and people have noticed there’s no email option in this one, though in 2014 you kindly accepted comments by email and forwarded them to the database. The pertinent paragraph says:

Objections must be submitted to Reviewing Officer Reta Laford. Electronic objections should be submitted to: https://cara.ecosystem-management.org/Public/CommentInput?project=42759. Objections may alternatively be submitted by FAX (360-956-2330) and by mail or in person (1835 Black Lake Blvd. SW, Olympia, WA 98512) during business hours (M-F 8:00am to 4:30pm). In all cases, the subject line should state “OBJECTION Pacific Northwest Electronic Warfare Range”.

No email address is listed, but the public is used to being able to email their comments. This lack makes it harder. The character limit concern comes from the Navy, which limits its characters in comment boxes to 5,000, which for complex topics like this is insufficient. So, that’s why I’m asking what the Forest Service’s character limit is, because people who copy and paste their comments will have content cut off unless they check before hitting send. This is a real concern.

So, sorry, but I’ll have to repeat my questions: what is the character limit in the comment box, and if there is one, is there an email to which comments may be sent? Knowing the character limit will help people decide on whether or not to attach a file or paste contents in the comment box.

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To: Karen Sullivan   From: Wahl, Gregory T, USFS

Karen, objections should be submitted to the link below through the project website. I have asked our IT people if there is a limit but I probably won’t get an answer from them today.

Thanks,

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To: Greg Wahl   From: Karen Sullivan

If you could get me an answer whenever possible it would be much appreciated.

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(No answer.)

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Next day:    To: Greg Wahl    From: Karen Sullivan

Hi Greg,

It would be great to get an answer asap about a comment box character limit before everyone at IT goes on Christmas vacation.

Thanks again,

Karen

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AUTOMATIC REPLY

I’m currently out of the office until 3Jan17. If you need immediate assistance, please contact Tim Davis, Natural Resources Staff Officer, at 360-956-2430 or tedavis@fs.fed.us.

If you have questions about the Navy permit project, please visit our website at https://www.fs.usda.gov/project/?project=42759 for more information.

Thanks,

Greg Wahl

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please notify the sender and delete the email immediately.

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To: Tim Davis   tedavis@fs.fed.us

From: Karen Sullivan

Hi Tim,

Can you tell me if there is a character limit in the comment box on the Forest Service’s web page where citizens can write their comments on the Draft Record of Decision regarding the navy permit? Also, is there an email address to which comments can be mailed? Normally there is in a public process. I checked the web page, but neither question is answered; I asked Greg Wahl, but he is now out until January.

Thank you

Karen Sullivan

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To: Karen Sullivan

From: Tim Davis

Hi

I am not aware of a character limit in the comment box associated with the comment method we are using with the Navy permit project. I copied the following from the letter announcing the start of the objection period. We request that electronic comments be submitted using this system.

Objections must be submitted to Reviewing Officer Reta Laford. Electronic objections should be submitted to: https://cara.ecosystem-management.org/Public/Commentlnput?project=42759.  Objections may alternatively be submitted by FAX (360-956-2330) and by mail or in person (1835 Black Lake Blvd. SW, Olympia, WA 98512) during business hours (M-F 8:00am to 4:30pm). In all cases, the subject line should state “OBJECTION Pacific Northwest Electronic Warf are Range”.  The comment method also allows the attachment of a document up to 10 MBs in size. The attached document has a link to the comment page.

I hope this answers your questions. If not please let me know.

(Letter from Dean Millett attached)

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To: Tim Davis   From: Karen Sullivan

Thank you for responding right away.

Are you an IT person? I’m just seeking a definitive answer, because it seems to be the rule that comment boxes have character limits – in fact, I’ve never encountered one without them. All Navy comment boxes have them, and so do Congressional contact pages, so it would be unusual for the Forest Service not to have one. The usual limits are around 5,000 characters, which is about 500 words, but someone who contacted me said he managed to post 7,000 characters without getting cut off. It’s important that we know, because some peoples’ comments are longer than 500 words, and they may not realize when they hit send that all extra content is cut off if the length exceeds the character limit.

Thank you for anything you can do to clarify this.

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To: Karen Sullivan   From: Tim Davis

I am not an IT person so won’t be any help there. I did call a contact in our Regional Office who works on administrative reviews and she is not aware of any character limits in that comment box. I agree that many similar systems have limits but to my understanding the “cara” system does not. If it is not too much trouble it might be safest with longer comments to write them in a Word document and attach them to the comment response.

Hope this helps.

Tim

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To: Tim Davis   From: Karen Sullivan

Thank you, Tim.

I noticed in the letter you attached to your last email that the directions to the public are to address comments to District Ranger Dean Millett, not Reta Laford, as was previously instructed. If you could please clarify this, it would be much appreciated.

Sincerely,

Karen

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To: Karen Sullivan   From: Tim Davis

Sorry for any confusion. Please address objections to Reta Laford, who is the Reviewing Officer. Hopefully I didn’t add to the confusion in my previous messages. We are using a system originally designed to capture comments on projects to accept objections on the Navy permit project. This system helps us more efficiently manage objections.

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To: Tim Davis   From: Karen Sullivan

Got it. Thanks, Tim. I asked Greg this question and haven’t received a satisfactory answer, so I will ask you, even though you may also not be able to answer it. I appreciate that the system helps the Forest Service manage objections, but it may not be that helpful to the public whose comments you are seeking, when a major option for public comment is eliminated.

There has always been a simple email option for comments, but this time there is not. This makes it harder for the public to participate, if for no other reason than it is eliminating a convenient option that people are used to. Unknowns such as whether or not there are character limits, coupled with finding your web site with its byzantine URL and learning the system, add to the confusion.

Back in 2014 the Forest Service’s comment web site malfunctioned in October, and lost a bunch of comments, including mine. It required another input of comments, with no certainty that they were accepted, and no certainty that the people whose comments were lost knew about it and were able to put them back in again. So, many people remember that well, and are leery of comment boxes that have given them too many surprises. The idea behind public participation in a NEPA or any other process is to make the participation of as many people who want to, not only possible but convenient. This system may be going in the right direction for the Forest Service, but not the public.

I know you can’t do much about this as the unlucky person who has to work when everyone else is on Christmas break, but would you please forward these concerns to senior management, including Reta Laford, and ask them, because these concerns have still not been addressed, that the comment period be extended by 30 days to allow the time needed for the public to find, learn and use the Forest Service’s new system for managing objections?

I hope to hear an answer by January 3, when everyone returns from Christmas vacation.

Thank you.

Sincerely,

Karen

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(No answer.)

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As for the message from Mr Wahl’s last email warning that unauthorized use or disclosure of the contents of these messages that may result in civil or criminal penalties to the violator, well, we didn’t get his authorization to publish this, so we are accepting any and all Christmas fruitcakes with nice raspy metal files baked into them.

Thbbbbt

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