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"As a matter of both good business sense and environmental concerns, many private industry owners in the south are strong proponents of practices that ensure sustainability of multiple resource values." This sentence appears to be a form of rhetoric, rather than a truly scientific statement. What is the evidence for this? who has defined sustainability for the purposes of this study? What are the multiple resource values? -- Draft Report
Misplaced. This comment addresses S4.53. -- Final Report
Misstates the authority of states and local governments with respect to control of pesticide use. There is no "delegation" by EPA; states may engage in supplemental regulation and enforcement. -- Draft Report
Revised the paragraph to reflect the EPA has regulatory and enforcement authority, although states, counties/parishes, and municipalities may enact more stringent standards that operators must follow in addition to the Federal statute. -- Final Report
The report (page 42) incorrectly suggests that a "take' under the Endangered Species Act can be caused simply by habitat modification. The Fish and Wildlife Service defines "take" to require an "actual death or injury" in all instances. Moreover, the habitat modification itself must be "significant". Revised the paragraph and qouted the exact content of 16 U.S.C.S §1531 where significant habitat modification is deemed to be a "take" of a T&E species. -- Draft Report
Revised the paragraph to reflect the EPA has regulatory and enforcement authority, although states, counties/parishes, and municipalities may enact more stringent standards that operators must follow in addition to the Federal statute. -- Final Report
The study places excessive emphasis on government subsidies role in the productive state of the southern forest. At best, according to the numbers in the report, only 1.5% of landowners are even participating in any type of direct government subsidies. Conversely, this means that 98.5% of landowners are responding to marketing signals and other management objectives. -- Draft Report
Misplaced. This comment addresses S4.55. -- Final Report
Section 9.5: This section lacks an adequate discussion of the role that professional foresters play in influencing and implementing forestry regulations, and in developing alternatives to the increasing number of new forestry regulations. -- Draft Report
Several sentences of new text were added to sections 9.4.1.2 and section 9.5 to more particularly detail the role of professional foresters. -- Final Report
The discussion of State Statutes in Section 8.3.5 would be greatly improved by a comparison of the voluntary, nonregulatory approaches that render the South "unique among regions of the United States in that none of its States have a comprehensive forest management act" with the programs in those states that do have such programs. -- Draft Report
The entire Socio-3 section covers all the forms - - voluntary and regulatory; Federal, state, county/parish, municipal and local-- that make the South unique. Time and space constraints preclude any meaningful comparison of comprehensive forest practice acts and other forest management legislation among regions of the United States. -- Final Report
Now that the problem has been clarified the next step, as I see it, is for the same coalition of scholars to address the question of what can be done; what steps will slow or even reverse the present trends. Tax policies and cost-share incentives should be examined, as well as conservation easements. -- Draft Report
No change. To the extent possible, impacts of laws, policies, and regulations are addressed, as are needs for additional research. Policy recommendations are not part of the Assessment. -- Final Report
I suggest you check out the Land Trust Alliance studies on use of conservation easements. Might be worth adding info that there are now 1,400 land trusts operation in the US, and a growing number of land trusts operating in the South. (see www.lta.org) -- Draft Report
The number of private land trusts was updated from more than 600 to more than 1,200. -- Final Report
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created: 4-OCT-2002 |