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.