People collaborate best when they are in the woods talking about real forests and what to do with them. On the other hand, put them in a conference room to debate the merits of hypothetical silvicultural standards and you end up with the sort of nonsense we are seeing in northern Arizona. There several prominent, litigious environmental groups have made peace with local timber mills and workers regarding which trees to log on several national forests. The Forest Service, however, doesn’t want to play ball. Instead, its regional staff in Albuquerque is busily re-writing northern Arizona NFMA plans to include silvicultural standards that are inimical to agreements reached in the woods between the green groups and industry.
This bureaucratic passion play could be avoided altogether if NFMA plans were based on projects, not standards. Recall that NFMA requires only one thing of forest plans: “the planned timber sale program and the proportion of probable methods of timber harvest within the unit necessary to fulfill the plan.” Recall also that NFMA does not mandate one forest plan for each national forest. The Forest Service has broad discretion to decide the geographic scope of each plan, i.e., a single national forest can be divided into several NFMA plans.
Under the current two-tier planning regime, the Forest Service and its protagonists get to fight twice over what to do with national forests. The forest plan fight is all about the adequacy of standards, the aspirational zoning of land, and the magnitude of largely irrelevant allowable sale quantities. The second fight, at the project level, often repeats all of the above (because forest plan standards become ripe for legal challenge only when implemented in a project), with plan-consistency arguments thrown in for good measure.
Let’s just cut out the middle man altogether. A forest plan should be no more than the logging projects the Forest Service proposes for the next several years. The plan’s NEPA document (probably an EIS, but an EA is not inconceivable if the logging projects are environmentally modest) would evaluate alternatives, disclose effects, and form the basis for any required inter-agency consultation. The plan’s Record of Decision would set forth the site-specific projects to be undertaken, eliminating separate project-based planning and decision-making. Forest planning collaboration, if pursued, would consist of people talking in the woods about each of the projects.
24 thoughts on “Project-based Forest Planning and Collaboration”
Andy- are you defining “logging projects” as those using the timber sale contract, or any one that removes trees (say fuels reduction using service contract)? Is it “timber harvest” if it is piled or scattered and burned on site?
Yes — any decision that cuts down trees, regardless of purpose, method, or fate thereof.
So things like grazing, travel management, and oil and gas leasing would be handled by those NEPA decisions, and protections for species through ESA and water would be laid over the top of all these decisions? Some would argue, then, that there is then no place for cumulative effects, as those folks who responded to the last rule by saying forest plans need an EIS, otherwise there would be no overall discussion of cumulative effects.
Yes. Grazing, travel management, oil & gas leasing, roadless area management would all be decided (as they all have been) by separate decision. Each of these decisions, just like the logging decisions in a NFMA plan, must comply with the ESA and other environmental laws.
There is always a place for cumulative effects! The NEPA process for each of these flavors of decisions will have to disclose the cumulative effects. That’s true regardless of whether the NFMA plan is a “rational, comprehensive” plan that tries to do everything for everyone or the more limited tree-management plan that Congress actually required.
While I understand where you are coming from Andy, I cannot agree with such a limited view of plans. I agree completely with getting people out on the land to look at things and discuss what to do; that is what we did with the Alabama plan. Yes, the plan. It is a restoration plan and is based on MANY in-the-field trips with anyone and everyone concerned. My point of disagreement is with the premise that only projects, and never plans, can be reviewed in the field as they are developed. I have seen it done.
In fact, the way it happened was not to reduce the number of levels of review from two to one but to increase them to three. Alabama’s national forests have three levels: the PLAN for all forests, a restoration PROGRAM for each forest and then PROJECTS that tier to the program and the plan. I agree that a system of review that is too big and general (a plan) tied to then review that is too small and limited (projects) tends to lose a LOT of the needed cumulative and indirect impacts analysis that is needed to manage well. Instead of reducing the larger, general review to the bare minimum and then have to, somehow, hash out everything else at projects (which I have NEVER seen done), what we did is put a third, middle-level review in. The plan has the goals and aspirations for what everyone wants to the forest to look like, with broad standards and guidelines expected to meet those over the next 15 years. The program level then takes a good look at how do we meet those goals and aspirations over the next five years and exactly where that will occur on the landscape. What opportunities are there? What has the most need? What can wait? What tools are available? What things do we want to avoid? Etc. The program is more akin to what you are describing, the what and where active management (whether logging, fire, invasives treatment, etc.) will happen, just over five years instead of 15. That program them leads to projects, which look at the same issues at the site-specific level and see what of the plan and program fit there at each specific stand. Being reviewed and updated every 5 years, the program can provide the mid-course corrections and changes a forest needs without the burden of a full plan revision. What is working keeps going, just on new places. What isn’t working is changed.
Here is the nutshell:
* The Plan says what is the forest like (the baseline), what to we want it to look like (the goals), and what general areas are available for restoration to meet all that. Along with that are the other things plans do, like special areas, recommended wilderness and the like.
* The Program takes the areas where restoration is outlined in the plan and fleshes out what that should look like at the landscape or watershed level. Where are the opportunities in those areas that work best in the next five year, what can wait until the second five years, etc. The program also gives a run-down of the projects proposed to meet the plan goals on that lands cap-level view.
* The Projects then implement the program to meet the plan goals.
Together, instead of doing NEPA twice, or as is more likely, not at all. This three-tier system divides NEPA analysis into appropriate chunks. Plan = broad, long-term review. Program = restoration management specific review for implementing the plan in the mid-term. Projects = site-specific review of the impacts anticipated from the plan and program reviews. Indeed, we did for restoration management (the tree-timber stuff) what you point out has been done for roadless, travel management and other issues. None of those are done at the site-specific level; they are all forest-wide reviews of one set of issues. Still not a plan, but not project level either.
I want to keep an overview plan for what we want a forest to look like in the future, with the 15-year time frame (and including a 100-year one also). It is the North Star and constellations to guide the rest of the work. Program level work (whether roads, timber or whatever) is the dropping of the navigation from the stars to the sea and land around us. The projects are then the trimming of the sails and the movement of the helm that move the ship. Look just at the North Star and you run into things. Look just at the sails and the helm, and you run into things. Look at just the landscape (the things) and you don’t know where you are going or how to get there. You have to do all three. And at each level, you do what is necessary for that level and for how that level works with the other two, but you do not do it all at any level or even any two levels combined.
Andy- Based on press clippings from the 05 and 08 Rules, it sounds like there are many who think that the cumulative nature of cumulative effects analyzed from oil and gas and travel management and timber is still not enough, without cumulative effects in a plan EIS. I agree with you but last time we ran into a lot of flack. See this New West article, but there are many similar press clipping I could find.
The K.I.S.S. forest plan I propose includes an EIS that discloses the effects of the tree cutting projects that constitute the plan.
As I so presciently predicted in the 2006 New West article you cite, the FS did violate NEPA by failing to write an EIS on its forest plan rule revision. That’s, of course, a different issue than whether a forest plan requires an EA or EIS (it does).
Ray — things are sure different in Alabama, aren’t they?
but Andy- a forest or grassland is so much more than a timber program!
When you say “tree cutting projects constitute a plan”, I think that is not the big picture the people in the article are talking about
When I read “big picture”, I think of timber + grazing +oil and gas leasing + impacts of recreation + powerlines + …
I don’t think a separate cumulative effects analysis at one point in time buys us anything because each one of these decisions has their own cumulative effects analysis at the time they are decided.
So I think you and I may agree on this but perhaps not these others.
PS Reasonable people can disagree with various court decisions..
Yes, Alabama is different, but not for long. That is how they now do things in MS, LA and FL. I preach this gospel wherever I go. I think all the forests could be managed this way. It also took a LOT of work to get things this way. 15+ years of lawsuits, field trips, beer drinking and much more.
Keep in mind that the original 1986 AL plan (as well as MS, LA and all the others down here) WAS what you seem to want–an outline of all the timber projects they planned in the next ten years with little else in the plan. They really were “no more than the logging projects the Forest Service proposes for the next several years.” Each had an EIS with straw dog alternatives to what they wanted to log. And they were all unmitigated disasters, causing damage that is shocking by any standard. And each was able to be litigated into an absolute standstill because the NEPA work of analyzing indirect and cumulative impacts (which were HUGE) was NEVER done.
A cumulative effects analysis is required of all EISs, regardless of the nature of the decision it seeks to inform. Thus, if the decision is “where should the FS allow BLM to lease oil & gas,” the EIS supporting that decision would have to disclose cumulative effects. So, too, an EIS disclosing the effects (including cumulative effects!) of a FS decision to permit powerline construction or ski area expansion.
In a forest plan that purports to be a plan for all national forest uses one ends up with rather silly results. As we have seen, rather than make decisions, such an omnibus plan eschews all decisionmaking, leaving every decision to a subsequent level of planning. With no decision to make, the FS then figures it’s okay to forego a forest plan EIS altogether, because, after all, plans that don’t make any decisions must have no environmental effects. We’ve already been down this road — it’s a dead end.
In the alternative, in seeking to be truly comprehensive and make real decisions, we end up with forest plans that take 15 or more years to write, making them irrelevant to the real world when they finally do issue. And, on top of that, those “real decisions” didn’t end up being all that real as everything that happens on the ground still requires a second level of planning and NEPA analysis.
Focusing the forest plan on the only problem Congress actually spoke to in 1976 — logging — allows the Forest Service to take advantage of the many decisions already made, e.g., everything Ray talks about for his Plan and Program layer.
Remember, the FS is now (and forever after) only revising its previously-written forest plans. Revising means making only those new decisions necessary to make the plan current and relevant (revise: “to alter something already written or printed, in order to make corrections, improve, or update”). In fact, the only such review required by NFMA is the decision classifying land “as not suited for timber production,” which must be reviewed “at least every 10 years.” I see no advantage to zero-based planning, i.e., re-visiting every land allocation or standard, every time a NFMA plan issues. That’s why it makes so much more sense to focus the NFMA plan on what Congress directed — the planned timber sale program.
Andy, I am aware that cumulative effects analyses are required of other NEPA documents. In fact, I have argued that the “layer by layer” cumulative effects analysis is better analysis because it occurs in real time as decisions are made. Our knowledge of the science, the effects, the past and reasonable future, grows year by year, so latest is best. In fact, I argued this as part of the 2005 Rule.
I was simply pointing out that while you and I are in agreement that the plan EIS’s were not useful, other people’s rhetoric seemed to be that we would be trashing the environment unless we wrote them. Now this might have been not so much love of real world plan EIS’s as rhetoric based on a theoretical construct, or just partisan hype.
So we are at “does Ray’s vision for plans really need an EIS?”
To my mind, such a plan is a set of micro alternatives (guidelines, which special areas) and the broad plan alternatives never hung together in any kind of meaningful way. For example, guidelines- if current scientific information says that you should be 400 feet from a creek, why would you have alternatives? In fact, we have a Regional Watershed Conservation Practice Handbook, so many of these requirements are above the plan level anyway.
Yes, my visions for plans means each plan requires an EIS. Why? The trigger for an EIS is whether the proposal MAY have significant impacts. Not will, may. The test has nothing to do with conveience or agreement. But asking if a plan needs an EIS is asking the wrong question; it is taking time away from where the real improvements will come from.
Look at it this way: here is how I convinced the first ranger to EVER do a forest-wide restoration EIS to do an EIS instead of an EA. Me, “Will this proposal have significant impacts.” Ranger Gary Taylor, “No, all this will improve the environment. There are no significant adverse impacts at all.” Me, “Why are you even proposing this if it will not make any significant improvement to the forest?” Gary,”Oh, the benefits are going to be tremendous, huge.” Me, “Significantly beneficial?” Gary, “Absolutely.” Me, “Then, congratulations, you just triggered NEPA’s EIS requirement. If the benefits are going to be significant, why wouldn’t you want to highlight that?” Then he got it.
But that EIS was NOT a huge, fat, traditional EIS; quite brief, no larger than most EAs. It focused on what was to be done and what the impacts would be, mostly positive, and highlighted them instead of trying to reduce them to insignificance. By embracing what the real meaning of an EIS is, which is NOT increasing paperwork over an EA, Gary produced a great NEPA analysis that has guided that forest for 11 years now and still going.
If a plan is NOT going to have significant positive impacts on the next 15 years of a forest, why do it? That does not mean an EIS like plans have always had. Instead of focusing on the trigger for an EIS, we need to focus on what an EIS for a properly-done plan should look like. That is where the increased efficiencies will come from. If that needs an amendment to NFMA to make it clear and easier to do, I am all for that. But I do not think that is needed. We can get to where we all want to go with an EIS that is NOT burdensome to produce. In fact, I guarantee that a plan EIS will be LESS burdensome than an EA, if the EIS is done right over an EA done wrong. Thanks.
This is great. I now have two clearly articulated planning alternatives in my head—Andy’s and Ray’s visions are both worth considering some more. But questions…
How to ensure consistency? (or the harmonizing of different decisions made in different planning processes?) In both visions, there will be multiple NEPA analyses going on for various plans, projects, and programs. I get the plan-project consistency thing. But there obviously needs to be some consistency between programmatic decisions too (oil an gas, grazing, travel, restoration?). Without a more holistic and inclusive forest plan (that goes beyond timber), how does such coordination/harmonization happen? Might problematic inconsistencies arise without some inclusive forest plan guiding the ship, as Ray suggests?
And Ray, how did you and others deal with the timing of all this? Did the restoration decisions get made before other decisions pertaining to such things as travel, oil and gas, etc.? Seems to me whatever planning process gets done first enjoys some advantages—sets the stage for others.
“How to ensure consistency?” to which R.W. Emerson responded, “A foolish consistency is the hobgoblin of little minds, adored by little statesmen and philosophers and divines.” Are the inconsistencies Martin raises “foolish,” i.e., of little real world concern or cured easily, or do they merit an all-resource, comprehensive planning effort to avoid?
The most conspicuous inconsistency, which led Congress to pass NFMA, is between logging, on the one hand, and fish, wildlife, recreation, scenery, soil productivity, and watershed integrity, on the other. To address these conspicuous inconsistencies (landslides from clearcuts, terracing, obliteration of mast trees, regeneration failures, and the like), Congress told the FS to write timber plans that protect environmental values. If done as Congress directed in NFMA, the timber plans will ensure that logging is not inconsistent with fish, wildlife, soil, water, etc. The plans do so by logging a whole lot less timber, using different methods, on fewer acres, than the Forest Service was cutting in 1976.
In fact, much less logging has been the only real world result of NFMA planning, with logging levels slashed from 12 billion board feet annually to fewer than 3 billion bf today. No other change comes even close. I invite readers to suggest what other FS management has changed, and by how much, between 1976 and today as a result of NFMA.
Most other potential inconsistencies fall in the “foolish” camp. That is, they are readily solved by means other than all-resource, comprehensive planning. Single-resource planning can assure that oil and gas exploration does not foul groundwater; just don’t lease where groundwater contamination is a concern. Single-resource planning can assure that livestock grazing does not degrade riparian vegetation; just fence out the livestock. Single-resource planning can assure that no more roads are kept open for travel than the FS has budget to maintain properly; just close the surplus roads.
Ray says,(#5 above)
Problem is, as usual, “Wicked Problems”. There are just too damn many things in play to deal with them on an “every 5 years” basis, worse on an “every 10 to 15 years” basis.
So I’m in agreement with Andy that perchance we ought to restrict attention under RPA/NFMA to the timber problem that brought NFMA into being. Or, on the other hand I’m still of the opinion that we need to play adaptive governance games that allow for, say, a every five years evaluation of the AG process on each administrative unit of the national forest system as I been arguing for on this blog.
If I am wrong on the wicked problem front, as I may be, I want to know more about what decision packages are likely to come from Ray’s vision, and how we deal with the nastiness of, say, “wilderness as an issue” in trying to deal with that in a forest plan. Simply put Ray: What is in? What is out? when addressing “goals” and even worse perhaps “standards”. How do we avoid the “wicked problem” trap?
Complexity and uncertainity are definitely contributing factors when it comes to land management planning. However before we can simplify anything we need to have some idea of the system and we need to have some idea of the function or purpose of the system. I can see Andy’s and Dave’s points about if in fact you have a current Forest Plan and what you want to do is adjust that plan to respond to a particular influence it can be done with special attention specfic to the influence. However most often what I see on revision efforts are more in response to what is it we want the system (National Forest) to be known for and do – the outcomes? More similar to what Ray laid out that the Forest went to being known more for restoration outcomes – a change in the strategic direction. Now to meet the linear requirements of NFMA you need to analyze what this does to timber delivery outputs.
An example of this is when I was the planning staff officer on the Carson National Forest and we were amending our plan to include 100,000 acres of land we acquired known as the Valle Vidal. Approximately 30,000 acres of these lands had coal bed methane natural gas that could be extracted in an economical manner while meeting any established environmental threshold (water quality, air, etc). The land also had great wildlife values including elk, martin, and migratory birds. All this despite it had been heavily logged for over 40 years while in private land – roads everyway on probably 60% of the land. While working on the amendment I kept asking the question – what it is you want the land to be? Most often the response we received was I don’t know but I don’t want it to be natural gas production. Only problem is even prior to NFMA there are other laws that allow/promote the development of these resources – at least without good cause. My problem was without a strategic direction and a desire outcome for the land I could not evaluate it for good cause. Basically I could say whether gas development could occur without threaten values we wanted the system to provide as the largest or most significant impact associated with the development was the road system; however that still met every “standard” we were being held to at that time.
To me this is the important role an integrated plan does for us – set desired outcomes or sideboards for which to measure activities against. It is this type of direction I believe folks want to influence as part of revision – at least the important aspects. In absence of this type of dialogue all we are going to do is to continue to agrue about the value of a particular type of activity (logging, mining, grazing, hang gliding, mountain biking, etc) which will perpetuate wicked problems.
Hi David, you say, “this is the important role an integrated plan does for us – set desired outcomes or sideboards for which to measure activities against.”
OK. I guess this is a way of saying that a forest plan might help to better define and/or amend a previously defined national forest “niche,” as embedded in the broader national forest system, embedded in the regional landscape/social scape, embedded in the nations public lands, embedded in larger ecosystems/social systems, etc.
Let’s run further with this important yet seemingly simple endeavor as NFMA forest planning. But like my idea, which seems to limp along without such, except as “a manifestation of all decisions great and small” we will have a long way to go to get public buy-in as well as congressional buy-in, and so on.
Your comment got me to thinking of something I wrote in 1996 about a Forest Service Niche re: ecosystem management. I mentioned there that we needed to talk further about “scales”. Maybe you’ve just done that.
If I recall correctly, Emerson’s quote is about the necessity of questioning—everything. In that spirit, I’m trying to honestly work through your proposal. The issue of consistency is tied to that of coordination. Doesn’t NFMA call for “integrated planning”? How do we ensure that all these separate single-resource planning processes make sense when viewed collectively? Certainly decisions about roads (and their plans) have something to do with decisions about restoration (and their plans); and decisions about travel (plans) have something to do with access to grazing (plans) leases.
Don’t these single-resource plans have to be coordinated to some extent? If so, how? If not, isn’t there a risk of having some haphazard mishmash of plans with no vision and no overall purpose?
Martin asks “[I]sn’t there a risk of having some haphazard mishmash of plans with no vision and no overall purpose?”.
That’s why I advocate for an Adaptive Co-Management/Adaptive Governance approach with an information system — “loose-leaf compendium” — of assessments/decisions/evaluations etc. that affect an administrative maintained for public and managerial use and inspection. An every five years evaluation/assessment of “what is/has been/might yet be” going on the the unit, would add value and might be a key to connect with the NFMA as well as to allay your concern.
I’ve been thinking of that too. But there needs to be some underlying vision or goal/objective/purpose for adaptive co-management/governance. Once we agree on the goal, then the methods of adaptive management/governance becomes the means/methods to an end. Embracing adaptive management/governance does not address the fundamental political choices that are made in plans.
Martin says,”Embracing adaptive management/governance does not address the fundamental political choices that are made in plans.”
Which political choices? Other than what David talks about in #16 and I add to in #17 above. Keep in mind what I asked Ray about in #15:
Martin asks “[I]sn’t there a risk of having some haphazard mishmash of plans with no vision and no overall purpose?”.
Isn’t that what we have now???
Martin also says:”But there needs to be some underlying vision or goal/objective/purpose for adaptive co-management/governance. Once we agree on the goal, then the methods of adaptive management/governance becomes the means/methods to an end.”
YES! But instead of “theorizing” about what “might” work, why aren’t we looking at examples of plans that DO work? What I lay out above and elsewhere is NOT theory. It is actually working, in various forms, in practice, in several forests, in several states. How to get projects that conform to a program? How to get a program that conforms to a plan? My three levels of analysis and planning. It HAS been done, several times.
People involved with a forest (including the USFS staff, don’t seem how some “collaboratives” exclude the agency) come together (often times out in the woods, as Andy says to do) to develop a collaborative underlying vision for what the forest should be like in 15 years (100 years in the case of the Bankhead). Broad standards and guidelines flow from what that vision entails and demands. If you want to see a restored native hardwood forest with no more pine plantations in 100 years (the Bankhead vision), that means no more logging of mature hardwoods, or even any hardwoods (except for thinning/salvage due to storm damage). There … standards and guidelines. It means no more planting pines or doing anything that perpetuates pine plantations in extistence. It means doing what science says needs to be done to take exisitng plantations and get them back into healthy hardwoods. There … standards and guidelines. It means that areas that do not need restoration are hands-off management. That includes roadless, wilderness recommendations, old growth, cultural heritage areas … standards and guidelines. The restoration program then starts with the parameters set in the plan and collaboratively develops the proposed set of actions in the areas for restoration. Which pine plantations need thinning to let light in to encourage hardwoods to form an understory to be released later. Which ones are old enough to clearcut now and get hardwoods back in now. Etc. Projects then do it. When things change, a tornado, hurricane or whatever, we adapt the program to meet the change through a new project that was not in the original program (but it entirely consistent with it and the plan). Usually with a CE.
This is not theory. It is working. And with longleaf pine restoration, it has been working since the late 1990s.
The “integrated plan” language of NFMA requires much less than the rational, comprehensive plans the FS has written. The relevant section provides: “form one integrated plan for each unit of the National Forest System, incorporating in one document or one set of documents, available to the public at convenient locations, all of the features required by this section.”
In regard to the plan’s content, the only “feature” required by NFMA is the “planned timber sale program.” NFMA does not require that the forest plan decide who gets to graze how many cows; who gets to built which ski areas; who gets to build transmission lines or where; etc., etc.
A well-accepted alternative to long-range, comprehensive planning is short-term incremental planning. The planning profession denigrates incremental planning as “muddling through.” But, most public policy is made incrementally.
There is no a priori reason that single-resource plans (that is, plans that make decisions for only one resource) must be uncoordinated or uninformed. Congress’ purpose in NFMA was to assure that logging decisions be informed by the needs of other natural resources; that logging decisions protect wildlife, soil, water, and the like. NEPA provides additional assurance that the single-resource decisions made in single-resource plans be well-informed regarding the environmental effects and implications to other resources.
More times than not, the rare (but “wicked” in Dave’s words) conflict inherent in the proposition that “you can’t put an ORV park on the same chunk of ground as a wilderness” is resolved by history, i.e., first-come, first-served. Or these conflicts are resolved by political mechanisms that are exogenous from administrative planning. Planners and those who direct their work would be well-advised to set their sights low and tight on achievable results, particularly when that is all that Congress has required.
John and I worked all day on planning our public meetings so this may not make as much sense as I would like.. they are kind of broad brush observations that may not fit together.
As we worked the 2005 Rule, we found that some people couldn’t resonate with the vision, desired condition thing.
It could be because some people are more practical- it might be a personality type thing.. you know Myers-Briggs, Jungian archetypes. These folks would say something like “DCs are pointless words on a page, why spend all this time sitting around in a room jawing, let’s talk about objectives and standards and what we can do where (lines on maps).”
We also found that, in some cases, people didn’t really agree on a vision- some people would say “all wilderness, remove cows, put on bison, remove all roads, no fuels treatments, if people live around there it’s tough for them, some mountain bikes, no ATV’s, no oil and gas” .
So if we don’t agree on a vision, out here, then we need to find some middle ground. But it’s hard to sound visionary about compromise (well maybe you could, Ray, – maybe we need to import more eloquent people).
The middle ground is based, in my view, on “lines on maps” of areas generally to be more protected and less protected (this may not be the right word, but fewer things are allowed). That will translate, then, across all the fuels treatment, oil and gas, grazing, and where we might focus watershed restoration efforts (not sure we really need vegetation restoration as we haven’t seriously messed with the vegetation here). Our world just doesn’t seem to have a vegetation endpoint the way yours does. Ours would be “native trees growing” and that’s basically what we’ve got, except for insects and disease setting them back, but the serious ones, such as bark beetles, we can’t do much about anyway.
So here is another alternative.. adaptive governance visioning and 5 year course corrections as articulated by Dave, plus Andy’s way of strict NFMA compliance. The reason I don’t see a need for NEPA on the vision is that it in and of itself does not have environmental effects (that can be meaningfully evaluated). A vision is a vision. But I am of the practical personality type, so that may color my thinking.