Update on Planning Rule Process

From the Planning Rule Team:

We’ve learned a tremendous amount about what should be in a new planning
rule since the Notice of Intent (NOI) was issued last December. We
received over 26,000 written comments on the NOI, over 300 blog comments
and have had over 40 public meetings attended by over 3000 people. We’ve
worked hard to get input from Tribes through our regional and national
Tribal roundtables; from scientists through the science forum and
scientists’ continued involvement throughout the roundtables; from Forest
Service employees through various internal feedback mechanisms; and from
other federal agencies through the Federal Interagency Working Group.
We’re committed to building a proposed rule and draft environmental impact
statement (DEIS) that reflect the diverse opinions and common themes that
have emerged from the public involvement process.

We’ve now entered a new phase of the rule development process. We are
currently finalizing the proposed rule and DEIS for clearance by the
Department of Agriculture and Office of Management and Budget. We expect
the proposed rule and DEIS to be published in the Federal Register in late

We are committed to keeping planning rule development open, transparent and
participatory. Please take advantage of the following opportunities to
stay engaged over the coming months:
* We will continue to send out periodic updates on this listserv.
Encourage other people who you think would be interested to join as well.
Sign-up can be accessed from the right hand column of the planning rule
homepage or by going directly to this link.

* Check back often to the planning rule website for the latest information.

* While we won’t be looking for additional blog comments on the rule
substance until the proposed rule comes out in December, the planning rule
blog will continue to host discussions on what the public engagement
process should look like when the proposed rule is released. Visit the blog

* You can also follow the Forest Service on Twitter here.

We will seek formal comment on the proposed rule and DEIS, and will hold
additional public meetings when the proposed rule and DEIS are published in

Thank you again for your involvement in the rule development process. Your
continued participation in the process will be critical to its success.

11 thoughts on “Update on Planning Rule Process”

  1. A Happy Holidays present! I can hardly wait. 🙂

    I love this line: “We are committed to keeping planning rule development open, transparent and participatory.”

    As if! I suppose we shouldn’t be surprised that Smokey doesn’t understand the meaning of “transparent and participatory.” Smokey doesn’t and can’t understand the meaning of “adaptive management.” To be able to practice adaptive management, an organization must be capable of adapting. Although I’ve seen the Forest Service pushed into different places/operating methods, and such, I’ve never seen any adaptability. Here is why: Anyone who dares stray too far from the status quo will, one way or another, get their head handed to them.

    Take a look at this little Bureaucratic Problem-Solving Flowchart to see it better. I shared it in 2005 when the FS was trying to link planning and Environmental Management Systems:

    Here is a “Power Point” of a Bureaucratic Problem-Solving Flowchart (right click when done) that floated around the Forest Service many years ago, and then again more recently. Ron Brunner, who teaches public policy at Colorado, said this little show tells more about the reasons problems are ‘buried’ or ‘sat on’ in bureaus than anything else he has seen.

  2. Dave- Welcome Back! I missed you and your unique perspective.

    In my view, this is one of the most interesting times in rule-making- when it goes behind the scenes for clearance across a bevy of agencies, each with its own perspective and agendas. It would be great and a fascinating introduction to government for students, if each agency would post their comments on the planning rule on the web and allow public comment on their comments. With the rationale for the final decisions also posted. I’m hoping it’s not transparent for the FS and then a mystery until the proposal.

    I worked at the Office of Science and Technology Policy (White House) during the clearance of the 2000 planning rule and sent clearance comments; I remember OMB staff who had major concerns with the potential cost. To me it’s just interesting what other agencies think and how that lines up or doesn’t with the FS and externals.

  3. And, we still are hearing nothing about salvage policy adjustments, which SHOULD be a part of the new planning rule. Alas, the Forest Service doesn’t even want to utter that “S-word”, fearing that it would bring down or delay the rest of the rule changes. Are we really dedicated to “preserving” our currently-flawed salvage policy?!?! Is it working so well that we need not even talk about it? *smirk*

  4. And, from the employee sessions, I’m curious as to how the USFS employees feel about how this rule change is progressing? I know there are a lot of really pragmatic foresters across the country who have opinions on how they would manage their RD’s, if given sovereign power. Recreation folks have a lot more on their plates, these days. Special Uses permits will increase, too.

    Hopefully, each Unit would have a had a meeting to discuss the basics of the issues, mostly to cut through any prejudicial mindsets.

  5. Foto-

    Why are you thinking salvage policy adjustments should be part of a planning rule? I don’t remember anything about salvage in previous planning rules. Sounds like a topic for the timber manual or handbook.

  6. Since this new Planning Rule is about “climate change”, it must be intimately tied to our current spate of drought, insects, disease and wildfires. Modern salvage logging is more about fuels reductions and rehabilitation than board feet. If we are going to respond to “climate change” we must make changes to how we’ve been responding to having massive acreages of dead forests.

    I’m sure that studies could be initiated to compare treatments to past outbreaks of bark beetles and/or wildfires. For example, comparing the Eldorado NF’s efforts during 1989-1993 with the much less aggressive treatments on the Lake Tahoe Basin, as well as the Tahoe NF during that same time period.

    Current salvage efforts are almost litigated against in a knee-jerk manner. Most major eco-groups have promised litigation of all salvage efforts in the Rockies. I was just in Yosemite again yesterday and got a very good look at last year’s re-burn of the 1989 A-Rock Fire. The land isn’t recovering well, after high-intensity fire roared through the unsalvaged old growth snags and logs.

    There needn’t be such controversy over salvage projects as valuable rehabilitation processes. Otherwise, are we supposed to ignore dead forests in forest planning?!? I guess the current crop of forest planners just don’t care if wildfires rage, as long as they are “natural ignitions”. They seem to be ignoring a HUGE part of what is wrong in our forests.

  7. Ah.. Foto, what you call “salvage” we call the big question… fuels treatment other than fuel breaks around roads and communities.

    I’m not sure that’s a planning rule question.. it might be a forest plan question. But the strategy is likely to be decided outside the forest planning process. Probably in budget direction for the fuels program.

  8. I tend to think that preservationists fear that salvage operations will generate tons of new roads, especially in Roadless Areas. Of course, we already have plenty of roads, and here in California, even roadside hazard tree salvage projects get litigated.

    It has been proven that re-burns in unsalvaged timber are devastating and large portions of our National Forests are dead or dying. Shouldn’t we be considering the fact that we should be planning for treating all those millions of acres of mortality. Just because one narrow study says that dead trees do not burn doesn’t mean that all trees everywhere won’t be ignited. We NEED a national policy that allows us to reduce fuels that threaten public safety and ecosystem health.

  9. Foto- see my new post on Forest to Faucet with Denver Water. It seems to me that where and when we need to do something with dead trees is best decided locally.. and there don’t seem to be too many barriers due to national policy that we can’t work through. Addressing something in a national rule might actually make things worse.

  10. The Sierra Club, and other eco-groups, have already made a national decision to fight against salvage projects. So, I understand that you are in favor of trying to “slide” salvage projects through, under their radar? Are we supposed to pretend that salvage projects aren’t beneficial to forests and not even try to fix the salvage gridlock? To me, that’s just burying your head in the sand and caving into junk science. Not to mention the massive influx of carbon into our atmosphere, instead of sequestering some of that carbon.


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