May 21, 2009

Fred Kelly Grant

President, Stewards of the Range

As you can see from this memo, I don’t and never have advocated abandoning the concept of cooperating agency, but I also have always advocated establishing the coordination status, so that when a county operates as a cooperating agency it still has the coordinate role which stands apart from the cooperating standpoint and gives the county the right to consistency between federal and county policies.

RE:  COORDINATION AND COOPERATING AGENCY STATUS

Coordination:

            Recently, I attended a conference on Coordination and Cooperating Agency relationships sponsored by the Arizona-New Mexico Coalition, headed by Executive Director Howard Hutchinson.  I spoke on coordination and Karen Budd Falen spoke on cooperating agency status.

            The point we both made, and both believe in, is that one is not mutually exclusive.  If a county advises the Forest Service, Fish and Wildlife Service, EPA, state agencies serving as designees of EPA, BLM, Corps of Engineers, Dept. of Agriculture, NRCS, and other federal agencies which work together with BLM and Forest Service on projects that it is exercising its coordinate authority under the National Forest Management Act and the Federal Land Policy Management Act, and the National Environmental Policy Act, the coordination link is established.

            Those three acts mandate that the federal agencies coordinate with the county, or any element of local government, which chooses to exercise its authority.  The duty to coordinate is not subject to limitations—except one: the failure of the county or local unit of government to exercise its authority granted to it by Congress.

 

            Many believe that coordination is a complicated procedure, but it is not.  It is brought into being by local government simply advising the federal agencies that it is exercising the legal authority already given to it by Congress.

 

            Many federal agency personnel will try to divert the local government from exercising its authority to require coordination, because they do not want to be bound by the requirements of FLPMA, NFMA and the regulations relating to the Forest Act which require that the federal agency make every legal effort to make their plans and actions consistent with the county’s plan and actions and policies. 

 

             One of the arguments they use is that the county has no authority to require coordination and consistency because of the Supremacy Clause in the United States Constitution.  Nothing could be further from the truth.  It is because of the Supremacy Clause that coordination is such a strong weapon for local government.  The Supremacy Clause creates the key to the federal system by providing that federal law, if it is constitutionally passed, is supreme over conflicting state and local laws.  That is all it holds.

 

            Now, why is the Supremacy Clause the post upon which coordination stands?  Because coordination authority is provided in FEDERAL LAW, constitutionally passed by Congress.  Local government is not creating new law by exerting coordinate status, it is not relying on state law (except as to state agencies where state statutes may also provide for coordination).  It is relying on FEDERAL STATUTES which are supreme as to federally managed lands under the very SUPREMACY CLAUSE that is used as a threat by federal employees.  So, the very simple answer to the argument is that “We exert our coordination authority under FLPMA or NFMA or NEPA or all of them pursuant to, not in contraction of, the Supremacy Clause.”

 

            Keep in mind that coordination authority includes more authority than simply being involved in general planning.  The coordination authority includes management actions that are put into place to implement plans, and it includes development of rules and regulations and permit decisions and other decision that the agency makes which effects the jurisdiction of the local government as to tax base and protection of the rights of its citizens including property.

 

            (That is an important element of coordination.  If a coordinating county also chooses to become a cooperating agency in plan development, it then has the coordination authority to require the agency to deal with it on an equal basis when it develops projects and other actions under the plan that was developed.)

 

            And, finally, for purposes of this shortened explanation of coordination, the real “kick” of coordination is that the agency must deal on an equal basis with the county, and then must make every lawful effort to make its planning implementation consistent with the county’s plan and/or policies.  This element of consistency is the real power behind coordination.  The agency can’t just listen to a county, or local government unit such as a town, city, school district or other unit of government with elected officials, and ignore what it hears.  It must make every lawful effort to achieve consistency.

 

Cooperating Agency

 

I won’t spend a lot of time explaining the cooperating agency procedure, because I know that John Williams will be there and he is expert in knowing how to work that process.

 

It has been my experience in most counties with which I have worked (over 100 now) that the cooperating agency status works far more meaningfully if it is taken on by a county which has also, or already, advised the agency that it will exercise its coordination authority.

 

What the “double” relationship brings is that when the agency deals with the county at the planning table as a “cooperating agency”, it knows that it might as well listen AND HEAR and respond, because ultimately it is going to have to come to terms with the County through the consistency portion of coordination.  Those counties with which I have worked which took on only the cooperating agency status did not, and have not, had the success that the coordinating counties have had through the cooperating agency status.

 

Owyhee County in Idaho, which has been recognized as one of the leading coordination counties in the west, has in fact participated as cooperating agency in the development of two BLM plans.  But, since the BLM knows that everything in the process is subject to the coordination status, it has paid more attention to what it hears from the County.  Still, in both cases, the County’s position on a key issue, which was in conflict with an element pushed by the agency, was ignored in the plan draft.  But, when the County then brought the issue to the “coordination” table, the agency had to change to its position when faced with the requirement of explaining what federal law prevented consistency.

 

Modoc County in California had to exert its coordination authority in the beginning years because the BLM and Forest Service refused to deal with it.  Exercise of that authority brought the county right to the litigation stage at one time in order to save a substantial percent of its grazing economy from an overzealous young biologist for the Fish and Wildlife Service.  The biologist issued a draft biological opinion which would have ended grazing in a portion of the County because of the biologist’s belief that grazing might in some way harm endangered fish which had survived and thrived near the grazing for 100 years.  The Forest Service intended to follow the b.o. and prohibit the grazing.  I recommended that the County adopt as part of its County Plan the prior biological opinion under which the Forest Service had been operating for several years.  In that way, the new b.o. was inconsistent with the County plan.  The County then served a letter on the Department of Justice that demanded that the federal agencies achieve consistency, and stated a threat to sue to enforce the County’s coordination authority to achieve consistency.  The Department of Justice sent a high-ranking member from DC to the County to settle the issue.  The prior b.o. was reinstated.  The County won its position without going to court, and won it on the basis of coordination and consistency which is part of that authority.  Today, Modoc County experiences real success through cooperating agency status with the agencies which have come to recognize the coordination authority and work within it.

 

It is clear that exerting of coordination authority does not compromise in any way the local government’s opportunity to participate as a cooperating agency.  In fact, in some cases where the federal agency denied cooperating agency status, and the local government then announced that it was exerting its coordination authority, the agency changed its mind and offered cooperating agency status.  Plus, both Owyhee and Modoc counties have experienced some success in cooperating agency capacities after once establishing their coordination authority.

 

I sometimes wonder why any unit of local government would sacrifice any element of its authority mandated by Congress.  If a county, city, town, school district or other unit of government with elected officials, wants to participate as a cooperating agency and have someone sit at the table through the endless meetings, why would it not want to take the very simple, inexpensive step of advising the agency that it was exerting its coordinate authority.  It costs the county to have someone at the planning table, either in payment of a consultant for many hours of work or in time spent by county officials or employees.  It costs the price of stationary, envelopes and postage to advise of the coordination authority.  And, normally, in the coordination process, the county or local unit of government has volunteers who have expertise in natural resources ready to help as Natural Resource Committees in the coordination authority exertion.  Such groups are of some help in the cooperating agency role, but are not nearly as effective because of the requirement that much of what goes on at the planning table cannot be publicly released until the documents are ready for public review.

 

No one should misunderstand what I have said in the prior paragraph.  Coordination will work without cost, with help of a Natural Resources Committee.  That does not mean that all counties elect to enter coordination without professional help.  Owyhee County for example has paid professionals to help with the effort—–largely because Owyhee County ranchers have been a target for the anti-grazing Jon Marvel for years and because many of the anti-grazing environmental national organizations have wanted to push the ranchers off the land so that a national monument could be established without running the risk of “takings”.  When Owyhee County undertook coordination, there was BLM draft plan ready for announcement which would have provided for a minimum 40 percent grazing reduction immediately.  Through the coordination efforts, we held off that plan for about 5 years, and the automatic grazing reduction was eliminated.  In those early days, I promised the ranchers and commissioners only one thing:  I could show them how to use the NEPA process and bureaucracy to delay reductions for about 5 years.  Now, 15 years later those ranchers who were imminently threatened are still in business.

 

Modoc County has also determined that it is in the county’s interest to pay for assistance, and Sean Curtis serves in that coordination role.  The County Farm Bureau has been very cooperative by furnishing Sean with office and communications facilities.  The County and Farm Bureau made those decisions because Modoc County is under virtually the most all encompassing multiple overlays of plans and restrictions that I have ever seen.  The County planning office (land use, not natural resource) has a map in the office showing all the overlays and when antelope corridor, fish areas and all the rest are put in place, the map shows a governmental attempt to control all land in the County.

 

So, why any local government would waive, i.e., give up, its authority to require coordination for the good of all its citizens, and elect to proceed on only one front is and has been a mystery to me.  As an old trial lawyer, I wonder why anyone would give up a tool useful in the work of achieving an effective county policy to protect its citizens rights.  Either as prosecutor or defense attorney, it was always my practice to use everything I had that would help gain the jury’s verdict.

 

Some case histories:

 

Fremont County, Wyoming:

Fremont County in Wyoming has been involved for some time now as a cooperating agency in the planning process by which the Forest Service plans to issue a new management plan for the Shoshone National Forest.  Fremont County through the years has seen its timber/lumber industry destroyed by failure to log.  Grazing continues, and tourism is all the economy that is left for many towns and areas in the County.  Through the time that the County has participated in the Cooperating Agency process, the Commissioners have seen campgrounds closed, roads threatened with closure and other restrictive actions that threaten the access and thus tourism.  One reason the campgrounds are being closed is that the trees at the grounds are infected by some sort of beetle and are so diseased that they are a threat to campers because of the probability that they will fall.  But, rather than cut the diseased trees, the Forest Service closes the campgrounds.

 

For the past several months, the Commissioners have requested that the forest supervisor initiate coordination meetings with the County as called for by the County plan.  The supervisor has not responded favorably, in fact not at all to the effort to coordinate.  At one point, the Supervisor used the “red herring” argument about the “Supremacy clause” which I have discussed above.

 

The Commissioners began to point out to the Forest Service that none of their comments and none of their suggestions even showed up in drafts of the plan which were put together by FS staff.  Some months ago, the meetings of cooperating agency participants stopped, and then the Forest Service announced that over a period of months their staff had put together a “new draft” on their own.

 

The Commissioners asked that Stewards come there to discuss coordination.  In the meantime, with our assistance the Natural Resources Committee appointed by the Commissioners put together a letter by which the County insisted on coordination.  The letter quoted the National Forest Management Act requiring coordination, the Congressional definition of “coordination” contained in FLPMA (the Federal Land Policy Management Act, applicable to the BLM) which is relevant because of the case law that holds that when Congress defines a term, that same definition applies when the term is used in any similar act.  The Forest Management Act is a land management act like FLPMA, and there is no question under case law that the definition of coordination in FLPMA attaches to the word when used in the Forest Act. 

 

The letter also quoted the Forest Service regulations which require coordination among management “agencies”, and a county is in fact such management agency because of the County’s responsibility for the tax base, for land and road management, and for the welfare of its citizens.

 

The letter insisted that the Supervisor schedule a meeting with the Commissioners within a month.  When the Supervisor agreed to meet with the Commissioners, the invitation to us became imminently important, so I placed a priority on the request and went to Lander on May 5.  I spent the entire afternoon with the Commissioners explaining all aspects of coordination, going through the various sections of the Forest Management Act which make it clear that the Service must work with local government.              During the presentation which lasted from 1pm until after 5pm, many questions were asked and answered, and at the end of the session I felt that the Commissioners fully understood their authority which already exists in the federal statutes.

 

During dinner that evening, the Commissioners asked what role I would play for them at the meeting on the next day, the 6th.  I told them that I was confident that they understood their authority and how to express it, but agreed that if any issue came up from the Forest Service which I had not explained, that they could ask me and I would provide the answer.

 

On the 6th, the Supervisor appeared with her chief planner and two other local personnel of the Service.  Obviously, either the Supervisor had done research in view of the County’s letter, or someone above her had explained the statutory mandate to her.  As the Commissioners explained that they were going to insist on coordination, not only as to the plan but as to management actions like campground closures.  They explained that by coordination they meant meaningful discussion, with a goal of both sides to make actions consistent with county policies.

 

At no time during the meeting did the Supervisor question the authority of the Commissioners, at no time did the “Supremacy clause” come up.  The Commissioners laid out their understanding of the statute and rules, and agreed that they would continue in the cooperating agency meetings, but with the complete understanding that no matter what came out of those meetings, the plan had to be coordinated with the full Board of Commissioners.

 

They then presented the Supervisor with a Memorandum of Understanding setting up a procedural protocol for coordination meetings and resolution of conflicts on issues as to the economic status of the county being impacted by Service decisions.  The Supervisor promised to review the protocol, and meet again with the Commissioners within a month.  She stated that the “new draft” would be sent to the Commissioners and then coordinated with them.

 

The Commissioners pointed out that they intended to take the same approach with the BLM and with the Fish and Wildlife Service.  I also suggested that they offer the same coordination prospect to the NRCS, so that coordination would also exist with a generally producer and user friendly agency.

 

Representatives of two other counties and two conservation districts were present on the 5th and 6th at the invitation of Fremont County.  All those representatives stated their intent to forge ahead with exerting their authority mandated in the federal statutes.

 

After observing the Forest Service attitude on the 6th, which was a 360 degree turn-around, all the members of the Natural Resources Committee, the Fremont County Commissioners, and the visiting representatives from the other counties and districts were enthused about the prospects of bringing the Service to the table on a basis of coordination.  As the Fremont County Commissioners explained to the Supervisor on the 6th, coordination means equality of discussion, not a “subordinate” role on the part of the County.

 

The process success is still ahead, but it was clear that the Forest Service realized that it was entering a new relationship on the coordination basis, different from the cooperating agency status.

 

Tuolmne County, California:

 

Last November, Sean Curtis of Modoc County and I presented the coordination authority to a workshop at the California Association of Counties annual meeting.  Within two weeks after that meeting, a Supervisor in Tuolmne County called and asked for assistance in drafting a resolution stating the intent of the county to exercise its coordination authority with the Forest Service.  I helped with the drafting, and included in the Resolution all the state statutes, which require that state agencies coordinate with the County.  The County adopted the Resolution.  Since that time, I have assisted the County planners and the County attorney in drafting an MOU similar to that presented to the Service by Fremont County.

 

Within the next two to three weeks, I will work with the County to take the next step if the Forest Service has not responded favorably.  The assistance given by me for Stewards to this County was without charge, as was the service given to Fremont County.  Travel expenses only are requested.

 

Inyo County, California:

 

After the November meeting, the executive officer of Inyo County called for assistance.  In a conference call with him, county attorney and planner, I explained the strategy for exerting the coordination authority.  They have moved ahead with their insistence to the Service that it coordinate with the County.  I will be visiting with their Supervisors, counsel, executive, and planner on a day in June yet to be set.

 

Del Norte County, California:

 

For some time now, the Del Norte County Supervisors have been on the list of counties to be visited, at their invitation.  Personal health problems and critical deadlines in the coordination process in Texas with which local towns are taking on the State Department of Transportation as to the TransTexas Corridors, have delayed my work with the County.  But I am going there on May 26 to meet with the Supervisors on the 27th, then with the county attorney, planner and committee members on the 28th.  After a Stewards meeting in Yreka, California over a year ago, the Supervisors passed a two page resolution calling upon the Parks Service to coordinate with the County with regard to renewal of commercial fishing permits.  The result was that the Parks Service met with the Supervisors and then the fishermen to work out details for the renewals.

 

Texas:

The Texas Department of Transportation has projected corridors through which a 1200 foot superhighway will be placed.  Both corridors will destroy prime and rare farm

ground known as the Blackland Prarie.  A University of Texas study shows that human habitation will be impossible within 1000 yards of each side of the superhighway because of noise and pollution, and that mitigation will cost millions of dollars.  That means that all other species will be eliminated within the same area because there is no method for mitigating the noise as to species.

 

These corridor proposals were moving ahead in spite of the fact that Texans by the thousands were protesting them at public input meetings.  Stewards and American Land Foundation, using a Texas statute that requires state agencies to “coordinate” with local regional planning commissions, helped four small towns in central Texas form such a planning commission with their respective school districts.  In response to a demand for coordination, the Texas Department and the Environmental Protection Agency have met with those small town mayors and discussed in meaningful fashion methods for avoiding adverse impacts on the towns and districts.  The total population of the four towns is less than 10,000, yet a powerful state agency which had ignored public input is now coordinating with them.  The Texas Supreme Court in an early insurance case defined “coordinate” in the same way Congress has defined it—-it creates an equal, not subordinate, relationship for resolving issues.

 

In the wake of the first commission, there are now 6 additional commissions all consisting of small towns and/or counties demanding coordination, and more are being planned.

 

South Dakota:

 

In South Dakota, several years ago, the coordination authority was exerted by the county attorney in Hot Springs County in an effort to force the Forest Service to recognize the danger to public health created by, and the damage to natural resources caused by, a ferret considered as “sensitive” by the Service.  The Forest Service reconsidered its plan position on the ferret and recognized the points made by the County.

 

Owyhee County, Idaho:

 

During this past year, the coordination authority was exerted against the BLM as to a specific grazing allotment.  The BLM had failed to meet court mandated timelines for issuing a decision on the Hardtrigger allotment two years ago, forcing the ranchers to spend $20,000 for outside pasture leasing.  Again this past year the BLM acknowledged that it would miss its timeline again.  At that  point, the County put almost daily pressure on the BLM to complete its decision process in time for cattle turnout.  The County threatened to sue on the inconsistency basis if the timeline prevented turnout.  The ranchers on this particular allotment would have been forced out of business had the BLM missed its timeline.  They could not afford another cash outlay for pasture.  Under the coordination pressure from the County, the BLM barely made the deadline, the ranchers turned out their herd and are still in business.

This application of coordination to a specific allotment demonstrates that the coordination authority extends not only to plans but also to management actions.

 

Owyhee County has proved the success of coordination as to management actions relating to access issues, i.e., particularly RS 2477 access.  The BLM has backed away from any confrontation with the County as to keeping access roads open after the County adopted a process for validating such access.

 

Again, during the past year, Owyhee County adopted a recreation-travel plan for an area designated by the BLM resource management plan as “open”.  Safety hazards in the area had lead to several serious “life-flight type” accidents in the past three years.  Pipelines for watering stock had been damaged by off road vehicles which had branched out from the “open” area into non-designated areas.  For over a decade the BLM had “planned” for improving safety and for avoiding use conflicts in the area.  The County created a recreation task force composed of ranchers, all types of off road vehicles, and conservation groups, with the Sheriff serving as chairman.  The task force developed, for the County, a plan that included speed limits, specific approved crossings, restricted parking lots, and signs prohibiting use in the areas in which there would be conflicts with grazing.  The County then amended its natural resource plan to include the transportation-recreation plan and insisted that the BLM issue a consistent plan for the area.  Within a month, the BLM issued an Environmental Assessment using the County plan as the preferred alternative.  A decision followed, and the County plan is now the BLM plan for the area.

 

 

Conclusion:

 

Based on my experiences and observations, I strongly recommend that any county which includes federal lands exert its coordination authority.  Only that authority requires that the federal management agencies seek consistency with county policy.  If the cooperating agency status is pursued, it will only be enhanced by the exertion of coordination authority.

 

One other bit of advice which I have for counties which are establishing their coordination authority while continuing to serve as a cooperating agency is to consider having the coordination process operate along one line with committee members paying particular attention to elements of the emerging plan, as well as on-going management actions, from the standpoint of consistency with county plans and policies, while a second line of committee members (number not important , other than being sufficient to support the cooperating representative at the table) pay attention to the process of making the best, most informed, input to try to get county plans and policies meaningfully represented in the final product. 

 

When this dual approach is taken, usually cost free, all the county’s efforts are not put into development of a plan; some of the county’s support effort can then watch particularly management actions.  Some counties have already witnessed the Forest Service and BLM move quietly along with decisions which they refer to as “incidental”, being put into place while the plan is being developed in cooperating agency meetings.

 

For example, even while the county sits in cooperating agency meetings, the agency “incidentally” closes a few access roads, closes a few campgrounds, delays a few use permits, and quietly sets up the “conditions” which will later justify a far stronger position for closings in the plan.  An example of this is in Fremont County, Wyoming and its surrounding counties.  The closing of access, the closing of campgrounds there to protect campers from diseased trees which might fall on them, sets the stage for identifying an overall condition in the plan which will justify more closings. 

 

The attitude in Fremont County will now change.  Even as the County continues as a cooperating agency, working on the plan, it will be working with its Natural Resource Committee to keep an eye on management actions that are actually damaging the county and its citizens even while the Plan is in negotiation.  And, it won’t cost the County anything for its advisory Natural Resource Committee to help keep watch on the management actions and their specific impact throughout the county.  Meanwhile, there will be no extra cost for the cooperating agency representation because the commissioner and paid staff will work through the plan.

 

The dual process was effective in Owyhee County with regard to the Bruneau Resource Area where a resource management plan went into its initial stages several years ago.  As the planners, which included a county representative at the planning team table (under the same silence restriction placed on everyone at the cooperating agency level), drew out new and expanded wilderness study areas, the Natural Resources Committee watched the beginning of quiet placement of conditions on permits which would have put in place areas of critical concern and “view” restrictions which in themselves placed as many restrictions on grazing as wilderness study areas.  The County Commissioners were able through the watch kept by the eyes of the volunteer committee, to require the BLM to coordinate its actions, even as the county sat at the planning table.  That coordination requirement turned back several grazing restrictions which would have more than established the current condition of the range as consistent with wilderness study areas.  So, at the same time that the cooperating agency representative was trying to hold off wilderness study areas in the plan, the Commissioners were holding off management actions that would have set the stage for justifying establishing wilderness study areas in the Plan.

 

The examples of using the dual process are many.  The value is that there is an entirely different standard of conduct required of the federal agencies in coordination than in the planning process.  In the latter, the federal agency definitely has the upper hand as the planning agency, and the county planning representative is in a position to influence but not overcome a firmly held policy of the agency.  But, in the coordination process going on simultaneously, the conduct of the federal agency is directed, not guided, is directed  to coordinate with the county and to use every feasible manner to reach consistency with county policy.

 

Experience shows, and my experience having worked within the federal and state system for several years makes me know, that the federal agencies will use every tool at their disposal to impose their judgment on the county.  This is because the federal workers are convinced that they know best, and that county and other local agencies are too parochial and too oriented to local problems to be able to see “overall good”.  In my early years in the United States Attorney’s office in Baltimore, that’s exactly the way I felt when I brought a case into the Court and announced that “the United States of America” calls the case of the United States Fish and Wildlife Service against David Jones.

 

If a county coordinates and does not consider cooperating agency in particular projects when there is an opportunity for meaningful input; if a county participates in the cooperating agency capacity and waives its right to exert simultaneous coordination, it is voluntarily giving up one of the two important tools which the Congress has provided to it.  Be assured that if the Forest Service has two useful tools, they will use both.

 

Personally and professionally, I believe a unilateral approach is short sighted.  I believe that local government should use every tool it has to protect the interests of its citizens.  And, in counties where the governing board has refused to exert its coordinate authority, we now advise that towns, cities, school districts take advantage of their opportunity to coordinate, so that it is the smaller unit of government that brings the agency to the table.  In several counties right now, there are smaller units of government beginning to organize for announcing their exertion of authority to coordinate.  When coordination has to take the route through smaller units of government, then the larger county issues are left outside the coordination table. As we approach a new administration, and probably a whole new run at Forest Service rules (if the court challenge now in court causes the “new” 2008 rules to hit the same fate as the 2005 rules), no unit of local government should ignore the coordination opportunity if county government will not undertake the opportunity.  In Texas, the small towns have done that, and have proven that coordination will bring the powerful agencies to the table as quickly with small towns and school districts as it will with larger units of government.     

 

                                                           – end –

 

                                                                         

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4 Responses to “Coordination v. Cooperation”

  1. maryhuff Says:

    Way to go in getting this set up; it will be a great forum for folks, and I’m sure will prove to be a third “useful tool” for local governments.

    I would try to add some intelligent comment concerning Fred’s “memo” but somehow that would be like trying to add penny stock investment tips to the end of a Donald Trump memo. I always tell Fred he is leaving a legacy… and I truly believe that he is.

  2. montanan Says:

    What a tough act to follow! Fred is blessed with a way to put the facts into context that no one I have ever met can do. That is why he is in such high demand, and we need to grab every oportunity to help him. I continue to search for ways to help Fred get this message to the people, and the new avenue here may be the tool I have been looking for. It will take me some time to understand the capabilities of this new forum, but I am confident that members of CALL will help me get on top of it.

    I think it is important to recognize the continued success gaind in places like Modak, Fremont, Owhyhee, Inyo and other counties as well as other subdivisions of state. We are winning this battle.

    In regards to Freds summary of Coordination v. Cooperation, I would like to share a quote with everyone.

    “Nothing more discouraging than people faced with problems who don’t desire to do the hard work to make a concept of protection work even when its a proven concept.” Fred Kelly Grant 2006.

    We are working to overcome the compacency and apathy. With the ability to share information, we will prevail.

    Thanks for adding another tool to the shed!

    Tim

  3. Chuck Miller Says:

    What a fantastic tool to share what others are doing and how it appears to be different but in all reality the same. In reading the Hage decision I see a tremendous amount that can be used all over the country. Been searching for a long time how coordination can work hand and hand with a takings and it has come to us here. Adopting coordination in my opinion is the only way to bring everyone together to protect our property at a price we can afford which is Volunteering your time using your wisdom which is education, experience and the ability to see into the future and having an avenue that will make a difference for not only you but everyone around you. The most important thing coordination does is in my opinion is makes State and Federal Government accountable to we the People. Keep up the great work and I see this to be far better than reading the news paper on a daily basis if you have any interest in not only your future but your children and grand children’s. We have a right to vote and a right to protect what is ours. I dont care if you vote but it makes no sense to not exercise your right to protect what is your’s and your neighbor’s.
    It is our job to inform family, friends and our community about this wonderful opportunity so they can use it also. Great place for your commissioner’s to get on and ask the questions they have to be able to move forward with the process.
    Thanks Again
    Chuck

  4. Gary Howden Says:

    Fred, How will the omnibus forestry? bill that the Senate leadership has been trying to ram through effect the coordination and consistency clauses?


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