Would the proposed Admin Study provide the needed valid long term research?
The Proposed Action is said to be an “administrative study,” but its title says “Integrated Research,” and in fact it is very much closer to a “research study,” as those terms are defined in the Forest Service Manual, sections 1991 and 4000 respectively. This mis-characterization is a potential legal deficiency, as noted below; but perhaps more importantly it betrays an underlying confusion in the Forest Service about purpose and methods, and this confusion raises serious questions about whether results of the Study would be valid or would be used correctly if valid. The HFQLG Pilot Project itself is already structured as an administrative study in every essential characteristic except name. Its purpose is to “demonstrate the effectiveness” of the specified management activities, and its methods, as described in HFQLG EIS Alternative 2, are well-suited to make that demonstration and report those results. In contrast, the proposed Administrative Study is actually structured as a scienti
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- Would the proposed Admin Study provide the needed valid long term research?
