Some tips from a participant in the Manti-LaSal forest plan revision process, which includes developing a “conservation alternative” that “will emphasize the long term health of the forest.”
I’m afraid I’m pretty cynical about the payoff from this approach, but I’d be interested in stories from anyone who feels they had some success. Part of the problem comes from the fact that the Forest Service creates its own structure for the alternatives it develops (such as the choice of management areas, what the different kinds of plan components should look like, how the plan document will be organized), and an outside alternative that doesn’t line up with this would be difficult for the planning team to document and evaluate. Then of course there is the, “I am the professional” bias that resists outside ideas, the “don’t take away my power” bias that resists any actual obligations (standards) in the plan, and the “no-change” inertia bias that defines “reasonable alternatives” as those that aren’t much different from the current plan. At best, it seems like there might be a few surprises that the Forest Service actually likes and tries to use. Tell me I’m wrong.
It looks like Mary is already encountering some bias:
For instance, the Moab Sun News’ article on the public meeting reported that forest service grazing manager Tina Marian said people won’t see a lot of grazing changes in the new plan that aren’t already being implemented on the ground. She shouldn’t predetermine that outcome. The conservation alternative will recommend changes to how grazing is implemented in the forest (which is a part of Moab’s watershed), like reducing the rate of cattle grazing.
It’s not possible to tell where exactly the Manti-LaSal is in the revision process from their website, but there was a comment period on the “Draft Assessment Report” in June of 2017. I think the best time to influence alternatives is probably when the Forest must “Review relevant information from the assessment and monitoring to identify a preliminary need to change the existing plan and to inform the development of plan components and other plan content” (36 CFR §219.7(c)(2)(i)). Any reasonable alternative would have to be traced back to that information, and if there are disagreements at that point it’s not likely that later suggestions would be well received.
In the example above, what did the assessment say about the effects of cattle grazing? The Forest seems to take the position that “historic” grazing was a problem, but “… (C)urrent grazing practices are not having as large an effect on stream stability, as evidenced by the many greenline transects rated as stable in 2016.” But then there’s this proof of bias in the Assessment (I’m not familiar with these “directives,” and unfortunately, “Shamo” isn’t in the “Literature Cited”):
Livestock grazing has occurred on the Forest for over 150 years and will continue as part of the Forest’s directives to provide a sustained yield and support local communities (Shamo 2014, USFS 2014).
They’ve got some other interesting issues on the Manti-LaSal:
The alternative will ensure that pinyon and juniper communities are not removed on thousands of acres for the purposes of growing grass for cattle and artificial populations of elk.
It will require the forest to remove the non-native mountain goats that are tearing up the rare alpine area above 11,000 feet in the Manti-La Sal Mountains. It will not allow honeybee apiaries, which would devastate native bees.