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 I agree with Susan Jane Brown that “you can’t live with an outdated plan forever” comment here.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.
- 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.
- 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.)
- 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?
- 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?
- 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?