What people want from the Helena-Lewis and Clark National Forest plan

There’s a summary of the scoping comments available on the Forest’s planning website.  “The number of comments for or against forest uses or management were not tabulated as ‘votes,'” but here’s the top 3:

“The most common topic was the concept of recommended wilderness or designated
wilderness. Roughly 46% of the comments offered input related to these designations,
including desires for more, less, specific area or boundary suggestions, and input as to
what uses should be allowed in such areas.”

“Many comments included input related to motorized uses, nonmotorized uses, trails,
roads, access, and other travel planning issues on the Forest. Comments related to these
topics represent about 28% of all comments received…”

“Comments about wildlife and habitat frequently overlapped with comments about motorized use, recommended wilderness, and other resource management issues. Comments that included input on these topics represented roughly 21% of the total comments received.”

Other categories of likely interest: Water – 10%, and fire/fuels, climate change and vegetation management each at – 7%.  (The %s add to more than 100, so these must represent the % of comment letters that addressed each topic.)

Despite not counting votes, it looks like they aren’t considering any alternatives related to wildlife, vegetation or fire except as a timber harvest and production problem.  I’m not seeing anything ecological here, making me think they just want to meet the legal minimum for diversity.  It reminds me of the current Helena plan I helped write 35 years ago (but I don’t think that’s a good thing).  Hopefully there’s more here than it appears.


    • Sharon: – “Jon, What exactly do you mean by “ecological”? Isn’t it all “ecological”?”

      It’s kind of like the word/term, “organic.” It’s been abused to death. But I think many people prefer a 50 shades of gray definition. The other word commonly and becoming more popularly abused word is is, “Science.” People have differing opinions about what the meaning of science is. It gets thrown around as an authorative tool in debate. Then other words are added by people to illustrate how their version of science is better than your version of science by simply adding words like “consensus” or “settled.” For some people they have their own version of science and if you don’t view science the same way they do, then you are anti-science. Still others will use it in a sort of generalized worshipful worldview sense. Whatever, it’s always remain 50 shades of gray and growing. Go Figure!

  1. Yeah, that was a little rushed. The 2012 Planning Rule was mostly about “plans that promote the ecological integrity of national forests” (36 §CFR219.1(c)), at least in part because that is its interpretation of the NFMA diversity mandate. Most of the discussion on this blog seems to be about vegetation management, ecological restoration and/or fuel reduction. The three scoping issues on the HLC related to vegetation management add up to 21%, and if you add wildlife 42% (more than travel management). Project lawsuits frequently involve vegetation management vs wildlife. Yet the forest plan alternatives will only deal with wilderness and travel management? This just seems like a big disconnect.

    It’s interesting that the public doesn’t seem to care about NRV et al, but that doesn’t excuse the Forest from its legal obligations. And I suppose they will find a way to say that whatever alternative they select meets the legal minimum of ecological integrity and species viability. But why not consider an alternative that does better than that, and provides a more secure future for wildlife (and less controversy for projects)?

    • So when you say “ecological management” you mean managing for “ecological integrity”? Because ever since the days of New Perspectives and the FS ecosystem management derived therein, there have been a lot of definitions. Here’s one that Hal Salwasser published in 1995:
      “Ecosystem management can be defined as the process of seeking to produce (i.e., restore, sustain or enhance) desired conditions, uses, and values of complex communities or organisms that work together with their environments as integrated units.” Although I don’t think that that was the FS one.
      “Ecosystem management can be defined as the process of seeking to produce (i.e., restore, sustain or enhance) desired conditions, uses, and values of complex communities or organisms that work together with their environments as integrated units.” https://digitalcommons.usu.edu/nrei/vol5/iss1/2/

      Here’s what looks like a current one. It sounds very different from “managing for ecological integrity.”

      I think what you mean is perhaps “less human intervention”? But then that raises the question of “which interventions”? Less wildfire suppression? Fewer vegetation treatments? Removing roads and making more Wilderness? Fewer hunters/OHV’s/mountain bikes/ hikers in the woods and potentially disturbing wildlife? –seems like any of these might increase controversy. Maybe I’m missing something.

      • There is only one legal definition that the Forest Service needs to worry about (and my point is that they do need to worry about it):
        36 CFR §219.19
        “Ecological integrity. The quality or
        condition of an ecosystem when its
        dominant ecological characteristics (for
        example, composition, structure,
        function, connectivity, and species
        composition and diversity) occur within
        the natural range of variation and can
        withstand and recover from most
        perturbations imposed by natural
        environmental dynamics or human

        • As I’ve said before, if we take the CFR (which doesn’t seem to have anything to do with the intent, history, nor previous implementation of the statute that the FS was making a regulation to implement (sigh)) the new White River plan will remove all current ski areas because the plan will otherwise not be promoting “ecological integrity”.

          We all know how that would (not) go. Otherwise, “ecological integrity” will be used intermittently or possibly at random, probably against uses and users that don’t have teams of lawyers lined up to defend them.

          Anyway, it would be interesting to have an “optimizing ecological integrity” alternative and see how much that is in congruence or not, with MUSYA.

          • A ski area in an ecosystem does not prevent the ecosystem from having integrity (unless it is a real big ski area in really small ecosystem, and the FS gets to pick the ecosystem).

            If a forest plan does not use “ecological integrity” it would violate the law, and likely lose in court.

            I’m not sure what “optimizing” would mean when the requirement is a “range” of natural variation. But in any case, nothing has ever violated MUSYA.

            • If a ski area doesn’t keep an ecosystem from having “integrity,” then I guess timber sale programs or oil and gas leases won’t either.

              As you know “ecological integrity” is part of the NFMA regulations, which is not exactly “the law” in the sense that entities can go and have gone to court and have had regulations overturned. I like to keep statutes, regulations and policies separate because of the different ways they can get changed.

              Folks lobbied to have this vague abstraction put into the reg for whatever reason. But what it means in practice, or on the ground remains to be seen.

              • I guess we have a semantic disagreement, but courts consider violations of regulations to be violations of the law that those regulations interpret. For example: “In sum, because the Long Prong sale threatens the viability of certain of the species at issue in this litigation, it violates NFMA” (Idaho Sporting Congress, Inc. v. Rittenhouse, 305 F. 3d 957, 975, 9th Circuit 2002). “Ecological integrity” will be treated as law by the courts just like viability (also a term not found in the statute) has been. I think most people would interpret your statements to suggest that compliance with NFMA regulations is more discretionary, which would be wrong.

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