After two years of public pressure from Standing Trees and allies, the State of Vermont is embarking on a first-ever rulemaking process that will shape state land management policies for years to come. Join in for an upcoming public meeting and submit a comment to help put the "public" back in public lands!
JOIN US AT AN UPCOMING PUBLIC MEETING HOSTED BY VT ANR:
Monday September 16, 6:00-8:00 PM: Okemo Mountain Resort, Jackson Gore Inn, Roundhouse Room, 111 Jackson Gore Road, Ludlow, VT 05149
Thursday September 19, 6:00-8:00 PM: Hazen Union High School, 126 Hazen Union Drive, Hardwick, VT 05843.
*No live-stream virtual meeting option is available, but a recording will be made of the state's presentation. We are asking the state to hold a virtual meeting for anyone to provide spoken comments.
IMPORTANT DETAILS:
Website for the State of Vermont's "Lands Management Planning Rule"
Link to RSVP for a 90-second comment slot at a public meeting (*you must register in advance if you wish to comment at one of the two public meetings)
Email address to submit written comments: ANR.StateLandsPlanning@vermont.gov (subject line: ANR Planning Rule)
Comment deadline: November 1, 2024
BACKGROUND:
We're in an "all hands on deck" moment for Vermont state lands, and it's time for you to raise your voice! The State of Vermont is conducting a scoping period for its proposed "Lands Management Planning Rule," which will govern how the state drafts management plans for state lands, how the public will be involved in decision-making, and how the state will weigh the costs and benefits of logging compared to forest protection. Sounds just a little important, right?
For decades, the state of Vermont has issued management plans for landscapes like Mt Mansfield State Forest, Groton State Forest, Camel's Hump State Park, and many other beloved areas without ever issuing rules, or a set of legal requirements that ensures transparency and accountability in decision-making. By relying on internal policies (some of which are nowhere to be found on state government websites) that can be bent and broken at will, the state has effectively made land management planning into a "choose-your-own-adventure" exercise where the state can manufacture the process and outcome to suit its own ends, cutting the public out of public lands.
To correct this situation, the VT legislature required the Vermont Agency of Natural Resources (ANR) to promulgate rules for state land management, but the state has failed to follow through in a timely manner, choosing instead to rush new management plans for the Camel's Hump, Worcester Range, and Castleton Management Units before their hands are bound by a new rule. Standing Trees petitioned ANR and filed suit two years ago to force rulemaking, at which time the state committed to beginning the rulemaking process.
The long-awaited start of this rulemaking is welcome news, but here's the catch: the state has put forward a draft that is little more than a recipe for maintaining the status quo instead of moving state land management into a new era. As written, the draft rule would formalize the state's current policies that prevent meaningful public engagement and review of state agency actions. The draft would also allow the state to build or upgrade logging roads and engage in "limited habitat management," which could include logging activities, without completing a management plan or seeking public input first, as long as the actions fall into a list of pre-approved "Universal Management Actions."
We need you to speak up at public hearings on September 16th (Ludlow) and 19th (Hardwick) and via written comments before the end of the scoping comment period that concludes on November 1st. The formal rulemaking process will begin in 2025.
Here is a short list of high-level talking points to help you formulate your comments at next week's hearings and in your comment letter:
This rulemaking is about putting the public back in public lands, but the Vermont Agency of Natural Resources' (VT ANR) draft rule continues to keep the public at arm's length, preventing meaningful public input and purposefully evading transparency and accountability in both the development and implementation of Long Range Management Plans.
Nothing in this rule gives Vermonters the assurance they deserve that the state will prioritize flood attenuation, climate change mitigation, biodiversity protection, and clean water when developing future management plans. In the face of devastating floods, worsening water pollution in our lakes and ponds, and the potential extinction or extirpation of numerous state and federally-listed endangered species, the Vermont Agency of Natural Resources (VT ANR) must reprioritize and rebalance land uses. A well-crafted rule can help to ensure that ecosystem services and habitat protection are prioritized over logging in future management plans.
As currently written, after a Long Range Management Plan is issued, the public will have no further opportunities for meaningful input on or review of the state's implementation for the duration of a plan, which could last well over 20 years. To illustrate, that's a whole generation of Vermonters that will have zero input on the future of the Worcester Range after that plan is finalized (likely this fall). This is not only unethical but also prevents a plan from evolving and adapting to the latest science. The state must issue notifications for any major agency action that tiers to a Long Range Management Plan, including timber sales and road construction, and it must provide time for review of the state's site-specific analysis and an opportunity for public comment.Â
Vermont ANR is letting itself get away with minimal public notification for agency planning processes. ANR is proposing to commit itself to nothing more than issuing a press release and posting information on its website to notify the public of decisions that could impact state lands for decades to come. At a minimum, the state should be required to alert any citizen who has registered for updates via email.
Making matters even worse for the public, the state's proposed rule fails to provide sufficient opportunities for the public to learn about and weigh in on draft management plans. As written, VT ANR would only be required to offer one informational meeting when the state plans to revise a management plan, and it's unclear if the public would ever have a chance to weigh in on supplemental guidance documents that provide additional direction for state agency staff, including the intricacies of how to develop a management plan or balance priorities. First, the state should be required to hold at least two public meetings: one in-person meeting and one live-streamed virtual public meeting. Second, VT ANR should commit to 60-day public comment periods, at a minimum, to allow for public review and participation. And third, the state should be required to provide public input opportunities on any guidance documents that further implement the ANR Lands Management Planning Rule.
Thanks for taking a stand for public forests!
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