When Do Old Forest Plans “Need” To Be Revised?


The Circle of Life- Plan Revision Style without the Litigation Loop

Recently I was asked to speak to students at neighboring Colorado College, a liberal arts school in Colorado Springs. They asked me questions about why a neighboring forest was still operating with a 1984 plan and is only now starting plan revision. I agree with Susan Jane Brown that “you can’t live with an outdated plan forever”  comment here. That is true, but where should we be between 15 years, 35 years and forever.  I notice that no ecosystems have unraveled the PSICC with its 1984 plan, that is 35 years old now.  If we think about the 2012 Rule, and that this is now 2019, and relatively few plans have actually finished being revised (Flathead? El Yunque? Francis Marion?), perhaps the plan revision process has gotten so cumbersome that it is even more unlikely that forests will revise every 15 years.  And if we use the “latest science” in project decisions, it’s a bit awkward to be roped into keeping plan decisions for 20-30 years. That was the idea behind the concept of a forest plan as a loose-leaf notebook of the most current decisions,  rather than a process that is so lengthy that conditions change while the process is ongoing.

The Smokey Wire was originally started to have public conversations when the 2012 Rule was being developed, and Andy Stahl presented the KISS rule linked here. Clearly you can make plan revision more or less complicated (the Rule and Directives are a certain level of complicated, and then forests can do their own processes on top of that). Then ultimately case law will come about that may require even more complicated analysis.

The following is only my opinion, so I welcome discussion and others’ views.

What do current NFMA plans do? They develop desired conditions, objectives, standards and guidelines, and management areas.  Desired conditions IMHO tend to be either rainbows and unicorns, or detailed vegetation conditions designed to replicate the past with the idea of “natural range of variation.”  Objectives are always a function of budget and over 15 years tend to change, but they may be useful guidance. Still, wouldn’t it be better for the Forest to sit down with their program of work and budget through time and involve stakeholders?  Management areas- tends to be about making more areas Wilderness,  and as we’ve discussed before, that is essentially a political decision- except for how you manage them in the interim. I’ve been at public meetings about plan revisions in which this is basically all people care about.. who in the recreation sector is allowed to continue doing what where.  Many members of the public could care less about DCs, objectives, standards and guidelines.

If there is a specific reason that the “old plan” isn’t working, you can amendment it surgically and remove that reason.  Transportation planning? New endangered species? Oil and gas leasing decision? Wildland fire use? New standards?

So here are my reasons not to revise, or at least not to get in line early on a new Rule.

  1. There is not a pressing reason. No one is knocking on your door. You don’t have enough $$ in your budget to do what is crying out to be done.
  2. It’s a lot of work and uses much time that could be used for other potentially more useful/important to stakeholder activities (although planning is funded separately, it tends to draw in everyone else to the effort, and many of those dragged in lack enthusiasm for planning.)
  3. The 82 Rule had so much case law behind it that you could be relatively sure of what you were doing.  Do you want to be the forest that is in litigation for years while case law is being made? And do you want to go back and redo that EIS two or more times?
  4. Some Forests used some energy on the 2005 Rule, and found that opening the can of worms of revision (e.g., some groups say you need to analyze an alternative that takes all the cattle off the grassland and get a free roaming herd of bison- will a judge agree that that’s reasonable?) only got (some) stakeholders excited about shutting down activities, and others dismayed by the first groups efforts to shut down their activities (you can think about mountain bikes here). There is lots of emotions released on both sides and to what end? You are most likely to end up somewhere in the middle and the groups may have made some serious enemies of each other in the meantime. If you are basically at some kind of equilibrium, why disrupt it?  What situation would be bad enough to require disruption?
  5. Related to #4, no matter what you do, some people are going to hate it.  If you are a big contentious forest, you will have threats of litigation.  You’ll attract media attention. Of course, part of that is the cost of doing business, but do you have to do it ( a plan)? After all that, will the forest, the employees or the stakeholders be better off in any way?

13 thoughts on “When Do Old Forest Plans “Need” To Be Revised?”

  1. It’s interesting that you bring this up, since I had been thinking that much of the issues with bikes, RW, travel planning and such in the Bitterroot NF had to do with dealing with a 30+ year old Forest Plan. I think the last revision was 1986. The planned revision in 2006 was scrapped after the process at that time as litigated.

    Of course back at that time, bikes weren’t really much of a consideration. I don’t think the work mountain bike, or bicycles, or mechanized appears in the plan. So over 30 years they were managed as any other quiet non-motorized use including in RW.

    I have read some more strident voices that believe that the FS is obliged to maintain RW to the same degree of wilderness character as it existed at the time of the Forest Plan. Yet somehow this only applies to bikes. Since inevitably with population growth many areas of the forest are seeing increased use by all user groups. In theory, if you need to maintain wilderness character as it existed 30 years ago all users would need to be restricted. Of course the reality is this a more stringent standard that designated wilderness.

    Along with bikes, climbers have discovered areas for sport climbing and started bolting routes, another activity not contemplated in 1986. On the other side the travel plan was not consistent with the Forest Plan when it came to motorized end of the ROS, with the travel plan being far more restrictive in access than the Forest Plan envisioned.

    The problem is the process has become so cumbersome and takes so much energy, it is next to impossible to be comprehensive, and the dated Forest Plans simply do not foresee changes in use patterns decades away. The other problem I see, especially if the Travel Planning processed I have been involved with is the lack of data on recreational use patterns and volumes. Unlike RW where there is a mandate and relatively clear cut guidelines for making these recommendations that is no similar process for recreational use. The fact is our recreational use do have impacts and they need to be managed sustainably, but how do that without reliable data.

    Also having been peripherally involved in the Flathead, Gallatin, Helena – Lewis & Clark plans the whole scope is overwhelming and then compressed into 3 or 4 alternatives. They are almost beyond the ability of the general public to get a grasp.

    I don’t have a solution other than the current process has become too unwieldy to be done frequently enough to adapt to changing conditions. If I do have a thought it’s that we need to transition to more of a continuous improvement style process. Someone in business would know the terminology better than me.

    • Lance, your “continuous improvement style process” was part of the thinking behind the 2005 Rule. My opinion is that environmental law folks were “in the room where it happened” for the 2012 Rule, and seemed to care most about having the right kinds of legal hooks to replace or supplement the 1982 viability provision. But defining ecological integrity, at the end of the day, probably gets us into the same old debates about who do we allow to do what where, only talking less about observable impacts and more about abstractions to be defined in court (and privileging certain scientists’ views).

      In fact, while working on the that continuous improvement process, I noted that all recreation folks were not necessarily thinking about impacts in the same way. So for dispersed camping, for example, some people thought the FS shouldn’t allow it, based on impacts like trash and poop. Some people thought folks in self-contained RVs were fine as there would be no trash or poop. Some people thought any compaction was bad, so any vehicles off the road for camping were bad. Some people said “kick over fire rings” while others said “leave them so only the same part of the area gets burned”.

      This all made me wonder a couple of things 1) Has the influence of veg ecologists on planning (I called the 2001 Planning Rule a “full employment program for veg ecologists”) meant that equally, or more, important data on people’s uses are not collected? If we measure what we care about, what does that mean about recreation?

      2) If NVUM is the standard data collection method, and some people have disagreements with it, what is the process for airing and fixing the disagreements (like FIA, for example)?

  2. NFMA’s idea was that you would revise the plan “when conditions in a unit have significantly changed, but at least every fifteen years.” Since we are essentially ignoring this requirement, you are asking a good question about what is practical and meaningful. One way to answer it would be to require an assessment (§219.6) every fifteen years to determine what has changed, and what needs to be changed in a forest plan, and whether that warrants a priority for revision. That begs the question of what would kinds of changes would warrant a revision, which I don’t think the agency has ever tried to address (a more important question to me than “why not to.”)

    Do you remember “continuous planning?” I think it was part of the discussion of the 2000-2008 era planning rules. I don’t think the phrasing went over well, but the principle was incorporated into the “planning framework” of the 2012 Planning Rule, §219.5. From the Preamble:

    “It is intended to establish a responsive process that would allow the Agency to adapt management to changing conditions and improve management based on new information and monitoring, using narrower, more frequent amendments to keep plans current between revisions.”

    But they didn’t make amendments easier, and the Planning Rule didn’t change the budgeting process. If we let the budgeting process drive planning, recent practice starts about three new revisions a year. There are 130 plans on 110 units, so maybe a 40-year cycle is realistic? That would make it easier to only encounter a revision process once in a person’s career.

    More seriously, NFMA was mostly about how much timber to cut, and after the first round of plans brought a reality-check based mostly on wildlife, why would it change much? I do think that it is important to get one revision done under the 2012 Rule because that will recalculate timber volumes based on ecology rather than economics (a goal of natural range of variation instead of maximizing volume or economic value), and it will factor in the effects of climate change on sustainability. Beyond that, maybe important amendments would suffice, and I’m thinking about those needed to protect species in decline (which I think should be possible under abbreviated “emergency” procedures).

  3. I always said that when we got the second Committee of Scientists, we should have framed the question “what, if anything, is useful about NFMA planning?” and focused on doing those things.

    If as it was started, it’s still all about timber, then let’s do an “ecological” timber calculation. But would that matter to anyone? As we’ve seen timber sales within the calculation are still litigated. Maybe someone could do one giant analysis and amend all the forest plans for timber volume. As to climate change, it seems like every time I turn around there are different predictions for the future, so run a couple of scenarios and talk about it with stakeholders (plus, I thought the FS already did that with Climate Change Action Plans).

    • My read of NFMA is that the main point was integrating timber harvest with other conflicting plans for and uses of the forest. I don’t think that could be done nationally, though maybe regionally (if you like the Northwest Forest Plan example). I don’t think the climate change action plans have been integrated into forest plans, but that should be part of plan revision.

      A plan can’t prevent litigation of timber sales by those who disagree with where a plan says they are appropriate. At best a plan leads to timber targets that are achievable on those lands.

      NFMA says little about recreation beyond coordination with other uses. With regard to timber that would mean identifying areas where timber management or harvest is not allowed or would be limited, such as by visual quality objectives. I’m not sure forest planning had to get into management of recreational users.

  4. https://www.bluemountaineagle.com/news/revised-forest-plans-to-be-withdrawn/article_3ad3771e-46b7-11e9-b996-1733201905e1.html

    15 years down the drain. I do remember that they took a long pause somewhere in there, but still… My sincere condolences to any Blue Mountains planning team members who might read this.

    The Pacific northwest is complicated, politically and ecologically. This was a revision under the 1982 planning rule, given that Chris French was the reviewing officer.

    A couple sentences in this article caught my eye: “French said the plan modifications were complex and not well understood, and there were changes in elected officials, stakeholders and Forest Service staff.

    The revised plans also failed to “fully account for the unique social and economic needs of the affected communities,” he said.

    Maybe these are out of context, but if not, I have to wonder if some influence from the Secretary’s office might be involved. But then, the Pacific northwest is complicated.

    • I contacted some folks who were working on a project that seemed to be in limbo on the same forests and they said that they had been working on the Plan instead. So momentum is also lost on projects while working on Plans, and then as it drags on, staff changes on the project.. and the deals that have been done are lost, and partners get restive…

  5. We were doing okay with our old plan, for the most part, and somehow reconciled and managed consistent with current science, so I agree that it often doesn’t seem like revision is necessary, aside from that 15 year NFMA requirement that we never seem to meet.

    But once you get into the process, you find out what in the plan has been ignored. For example, the team biologist noted in the DEIS that due to dropping a current standard, waterfowl nesting protections were less than in the old plan. This seemed to me an inconsequential oversight, (we had been through 4 different bios on the team by that time) so I suggested the standard restricting opening of beaches during nesting season be reinstated. This resulted in a lengthy and heated discussion among the planning staff officer, the recreation staff officer, and the ecosystem management staff officer. I was amazed. Word from recreation was “We have just been ignoring that standard for years.” This is typical of what happens with older plans – things just get ignored and no one questions them. This is only one example; there were also numerous standards (yes, standards) requiring construction of parking lots, scenic overlooks, etc. It is amazing what is in some of these older plans. This one was 1986 vintage.

    • D. I can easily imagine how people might lose track of what is in a plan. We used to talk about in today’s time we should be able to have a program that would pluck out the list of relevant standards for each type of project so that people didn’t have to look through the whole document and depend on their memories.

      I could also see a plan “updating” which would solicit ideas from staff and the public about what was outdated and doing an amendment. Our county Planning Code is updated that way whenever some topic is sufficiently troublesome and the staff have time to amend the Code. Maybe as currently envisioned, a Revision is too big a gulp.

  6. “If we measure what we care about, what does that mean about recreation?”

    We don’t necessarily measure what we care about. We measure what we can get money to measure. And that is usually not recreation. In addition, recreation monitoring does not lend itself to the scientific method as easily as vegetation or wildlife monitoring.

    But recreation comes up in every plan revision – wilderness and snowmobiles and mountain bikes. Every time.

    And because Congress fails to act on our recommendations, we are forced to carry forward and protect recommended wilderness, wilderness study areas, and eligible/suitable wild and scenic rivers for decades.

    • Anonymous, I would push back a little on your comment about recreation monitoring. What “scientific method” are you talking about? Different branches of science have different methods- observations, designed experiments, models without empirical checks, and so on. Observations of peoples’ behavior is not necessarily different from other kinds of observations. You don’t need mice to attract them and you don’t have to put radiocollars on them.. should be easier?

      I don’t think that you are “forced to” carry forward… Another alternative would be to say “we think Roadless is good enough protection, and we’ll work on adding more acres to Roadless” or “we think we are missing ecologically representative Wilderness ecosystems and will focus on buying private land for Wilderness where there are no large expanses of federal lands”. Just a few ideas, I can think of more..

  7. “We don’t necessarily measure what we care about. We measure what we can get money to measure. And that is usually not recreation.”

    Wrong, not according to Patagonia if you surf through their website. It’s all about profiteering in what they consider a righteous way of exploiting the wilderness

    Jim Stiles has a new article with reference to the iconic holymaan Ed abbey and what he would think of the environmentala movement’s direction today. Here are some exceprts:

    “Environmental groups, once dedicated to saving the wilderness that Abbey envisioned, now look at wilderness as a commodity to be marketed. What is the economic value of wilderness? Environmentalists promote the notion of a swarming tourist economy. They’ve taken a favorite Abbey line: “The idea of wilderness needs no defense; it needs more defenders,” and turned it into a Chamber of Commerce promo….the more money that can be made from the product, the greater the chance, in their estimation, of passing wilderness legislation. Nevermind what gets destroyed in the process.
    Even grassroots groups, who once worked for the protection of the land and the satisfaction that they were honest participants in “the good fight,” now parse their battle cries and make a $100K a year. Their boards of directors are filled with wealthy fat cat industrialists that would have had Abbey deported if they could have found a way. Together, they support a massive recreation/amenities economy that brings millions of tourists to the once remote rural West and with it, untold quantities of money and environmental devastation.”



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