Forest Plan Participation 101

by


Adam Romanowitz, Photographer

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.

And that’s where part of the Bears Ears National Monument is/was.  There was a lawsuit on the goats, and there are several on Bears Ears. 

 

 

7 thoughts on “Forest Plan Participation 101”

  1. I have seen some good Forest Plan alternatives developed outside of the Forest Service – I think that it has been a good way to get some meaningful public “comment” on Forest Plans instead of form letters or non-constructive comments. Most of the time it is not a complete alternative in terms of land allocations or suitability determinations or PSQ calculations – usually these externally developed “alternatives” focus on a set of standards and guidelines or on desired conditions for an area of concern, like road access.
    And other times I have seen things not work out so well with these external alternatives when the Forest Plan revision process takes a fairly long time and the external alternative is developed early in the process, but then many of the people who worked on that alternative are no longer in the community or the FS just ignores it and makes no attempt to show how all or part of that external alternative is included in the alternatives that are analyzed.

    I tried to Google Shamo and grazing and 2014, but didn’t come up with anything, even in Google Scholar. It was interesting to see however that “Shamo” is a term used in China to identify a sandy desert (!).

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  2. Thanks, An. Articulating what you want the plan to say is far better than form letters or non-constructive comments. If proposed plan components are viewed in this way, or as something that could be a “module” included in an alternative, expectations are probably more likely to be met. Can I infer from your comment that these kinds of proposals were actually included in a forest plan? (Example?)

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  3. Regarding citizen/stakeholder alternatives.
    Disclaimer first. I worked as a OHV/Snowmobile advocate for nearly 15 years and participated in scores of site specific and programmatic plans across all federal land management agencies.

    This is an interesting and important topic, IMO. Kudos to Jon for posting.

    Jon wrote:
    “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 “reasonablen 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.”

    I’m surprised to learn Jon is cynical about the payoff of submitting a “stand alone Alternative.” I can cite several planning efforts where conservation groups submitted such and thereby achieved many of their goals. One of the best examples is the most recent Moab BLM plan. BLM adopted a conservation alternative into the analysis that was very similar, if not identical, to a stand alone alternative submitted by the Southern Utah Wilderness Alliance (SUWA).

    I also suspect planning teams opt for incorporating parts of stand alone alternatives from conservation groups into their range of action alternative as a defensive strategy. IMO, Moab BLM was wise to incorporate most of SUWA’s alternative. Not doing so would have left open the “failed to analyze a valid range of Alternatives” challenge.

    I’m confused by Jon’s idea there is a “no change inertia bias.” My experience is the opposite. Seems to me every specialist brings their wish list to the planning process and vigorously lobbies for the changes they desire. If there is an inertia, it is in implementation. I think land managers should plan less and implement more.

    I also think, when developing alternatives, agency planners too often miss the importance of s thorough discussion of the “need for change,” effective articulation of the “purpose and need” and sometimes totally miss the importance of the proper development (and sometimes definition) of a formal planning issue.

    I saw planners view “planning issues” as how the public felt about this or that proposed change. I used to think planning issues were: “A matter of controversy or dispute over resource management activities or land use that is well defined or topically discrete and entails alternatives among which to choose or decide. Planning issues may have two or more of the following characteristics: 1) Concern expressed by the public, state, tribe or local government, 2) Existing or potential serious deterioration of public land, 3) possible significant impacts, and 4) proposed uses which may or may not be in the best public interest and which may be in substantial conflict with other uses.” But… what do I know?

    Anyway… Here is my cynical view. Federal land managers want to do what they want to do and they think what they want to do is the right thing to do. Public involvement gets in their way and so alternative development and analysis is often viewed as a series of boxes to check. “Meaningful public input,” as it is mandated by planning regs and NEPA, is a total sham.

    For stakeholders the challenge is to move them off of the agency’s pre-conceived plan and toward their goals. I believe submitting a stand alone alternative is often an effective strategy.

    I’ll add a view from behind my handlebars. Forest visitors who enjoy OHV and Snowmobile use are usually presented a planning effort where each action alternative represented a significant reduction in recreation opportunity. OHV/Snowmobile people often saw conservation stakeholders get significant portions of a stand alone alternative incorporated into the range of alternatives and often the final plan. However, in the numerous times we proposed an alternative that at least did not significantly reduce our opportunity, we were told the “no action” alternative would suffice. Except everyone knew the “no action” was not a viable “action alternative.”

    As time goes by I’m finding it difficult to give any constructive criticism. There is a lot of NEPA and case law that mandates federal agencies “…rigorously explore and objectively evaluate all reasonable alternatives.” (40 C.F.R. § 1502.14). Considering citizen/stakeholder alternatives should be an effective way to comply with these mandates.

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  4. Thanks for the optimistic angle and example, but then I’m surprised by YOUR cynicism, which doesn’t sound much different from mine. I agree that it is mis-use of the no-action alternative as a straw alternative to bury issues. (Maybe they learned it from the National Enquirer.)

    I also agree with your point on the “need for change” being a missed opportunity. In the 2012 Planning Rule, it’s an explicit step in the planning process that was envisioned as a way to focus on what is important, where there is disagreement and what the best science is to address it. What I’ve seen is short, bland statements of “there is a need to do X,” instead of “this is a problem with the current plan that is best addressed by this kind of solution based on this reasoning and supporting science.” This is likely to mean that the public really won’t get a sense of what the agency is thinking until after a proposed action (at least the Forest Service seems to be including a proposed plan earlier in the process than it used to, but the concrete is still starting to set at that point).

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