To the Editor:
An op-ed published in The MV Times recently, “Conduct environmental impact report on the State Forest” (Oct. 23), drew attention to an important circumstance in the history of the project to clear-cut acres of conifers in the Manuel F. Correllus State Forest (MFCSF): the requirement, on Oct. 9, 2001, that an environmental impact report (EIR) be conducted before the project as outlined in the environmental notification form (ENF) filed by the Department of Environmental Management on August 31, 2001, could legally go forward. This requirement was ignored, and the project has been carried forward in a zigzag fashion since it was first conceived sometime in 2001 — probably well before then. Much work was done on the forest without proper permitting. These zigs led to bureaucratic zags that always ended up mandating that more acres be clear-cut and “restored” to a previous condition for which there is virtually no evidence. Sometimes it seemed as though the zigs and the zags were coordinated.
State agencies have rejected the validity of the EIR requirement, and have argued that the current project is actually a new project. An examination of documents relevant to the MFCSF project will show the opposite.
It has been exceedingly difficult to put together a clear chronology of the zigs and zags leading up to the present moment, in which clear-cutting of acres of mature white pine trees is due to begin on Dec. 1. However, some dated documents have been made available by state agencies, and others were obtained via Freedom of Information Act requests. Readers are urged to read them carefully and critically. The following six documents relevant to the MFCSF project produced by the Department of Environmental Management (now the DCR), the Division of Fisheries and Wildlife (now MassWildlife), and the Executive Office of Environmental Affairs (EOEA) are available online:
- 2001 ENF MEPA0513 Public Comments: tinyurl.com/2t8ktsan
- 2001 Division of Fisheries and Wildlife (DFW) Conservation Permit: tinyurl.com/ybdec67j
- 2001 ENF MEPA0513 Durand EIR Requirement: tinyurl.com/3ypme6kf
- 2001 Environmental Notification Form for MFCSF Project: tinyurl.com/33uvwd5w
- 2021 Divisions of Fisheries and Wildlife Amended Permit: tinyurl.com/4px4zx7r
- EOEA 12592 (MEPA) Folder: tinyurl.com/2ktexea
The documents show that the original and amended permits that the DFW issued to the DEM/DCR have the same number: 01.012.DFW. State agencies have not produced a new environmental notification form, as the MEPA (Massachusetts Environmental Policy Act) process requires for all new large-scale projects. The descriptions of the project and specific long-term goals listed in detail in these documents strongly suggest that the main purpose of this project was long-term ecological re-engineering of the terrain of the MFCSF via the removal of conifer forests — not fire-hazard reduction. The ENF also seems to have been something of a rush job (note the document dates), which seems curious in light of the detailed long-term plans it contains. Read and decide for yourselves.
Those who wish to gain a clear overview of the legal requirements of MEPA need only do an online search for “requirements of Massachusetts Environmental Policy Act.”
Katherine Scott
Tisbury
