Failed planning for power lines on the Coconino

(Modoc National Forest photo)

The Coconino National Forest Plan was revised in 2018.  They have just announced that a proposed powerline requires a forest plan amendment because, “The proposed power line and associated roads would not comply with the following forest plan guidance after all reasonable stipulations to minimize impacts are applied: ‘Management activities and permitted uses should be designed and implemented to maintain or move toward the desired SIOs.'” “SIOs” are “Scenic Integrity Objectives, which are forest plan components.  It also appears to conflict with several plan guidelines for special uses (though the letter doesn’t directly acknowledge that).  Nobody saw this coming during the recent plan revision?  Did the forest plan include things that really weren’t that important?  (Scenery doesn’t seem to often rise to the level of litigation.)  Is this just more “energy dominance” from the Trump administration?  The scoping letter doesn’t attempt to answer these kinds of questions.

This article includes a link to the scoping documents.  From the map, it looks like the power lines are needed as a shortcut, and is often the case, conservation lands are the easiest target.  All of the action alternatives would violate the forest plan.  A compliant alternative seems like an obvious omission.  (And there is a requirement for special use permits that locations off of the national forest be not feasible.)  While the Forest discusses burying  the line, it’s not clear that they are considering an alternative that would bury all of it in areas where it is not consistent with the scenery objectives, or whether doing so would meet them.  Of course we can’t actually tell exactly where it would violate those objectives because the scoping letter doesn’t distinguish between the areas where the objectives are “high” or “moderate,” but maybe it’s the entire route.  While the amendment would be “project specific,” meaning it wouldn’t affect future projects, does that make any sense if the landscape would no longer meet the objectives in the forest plan?  ( Some of the scenery management science is not intuitive to me.)  At least they included the amendment in scoping for the project (some have popped that out at the last minute).

This summary dismissal of the forest plan unfortunately suggests a lack of respect given to forest plans and the effort put into them.  I don’t know anything about the scenery here, or who looks at it, but if it was important enough to put into a forest plan a couple of years ago, it seems like it should be important enough to take a little more seriously now.

19 thoughts on “Failed planning for power lines on the Coconino”

  1. When I worked on the A-Rock Fire Salvage, adjacent to Yosemite, we had to take into account the “Yosemite Viewshed”. In the end, cable corridors could be seen from Highway 120. Within the Park, hazard trees were cut (and flown out) around private homes in Foresta, under administration of the Park Service.

  2. Couldn’t agree more, Jon…and the fact it will be a project-specific amendment (and not affect future projects) is naive. A power line will be long-term in its existence, and thus, affecting resources during that time. If the Forest Plan currently does not account for such projects, amending the plan by “piece meal” projects will eventually bring the Forest to the realization that such projects SHOULD be addressed by the plan.

    To the Forest’s defense though, the frequency of these power line projects is likely very low. Hence, their choice to approach the amendment as project-specific rather plan-wide.

    • But pipelines and powerlines are (a) individual and (b) not likely to be predicted “in advance”. For example in 1990 people had no idea where other people would have shale plays or solar or wind projects.
      It makes sense to me to do a plan amendment, and then during revision see if the fact that there’s a pipeline or powerline makes you want to change anything else about the plan.

      Whatever happened to the planning idea that a forest plan is a living, loose-leaf notebook of ongoing decisions? I think it was FS planners who were advocating that idea in the 2000’s…

      • Yep, I was one of those planners who advocated for the “loose leaf binder” approach. But, that idea seems to be wholly embraced by planners only and no other group in the FS, particularly the decision makers (at all levels). There was no quicker way to get someone to state, “no, we are not going to do that” than to suggest to a decision maker that a plan amendment would be the wisest course of action.

        • Really? I remember many folks including decisiomakets who avoided plan revisions and were perfectly happy with amendments. Of course if you have an old plan maybe plan amendments get to be no big deal. And some decisions always seem to need plan amendments like oil and gas leasing decisions.

          • I must have been unfortunate to work in regions where I encountered decision makers who wanted nothing to do with planning, either amendments or revisions. I believe they saw very little upside to the amount of work/cost to accomplish the planning action. I guess I understand that mindset, but it does not say much for “doing the right thing” for the benefit of those working years from now.

            • Yes, I’m perhaps remembering more “site specific plan amendments” where doing a plan amendment is adding more verbiage to an existing document, just another box to check when NEPA or planning folks say it’s necessary.

              I also experienced forests who didn’t want to do plan revisions and I think the fact that they saw little upside, and often citizens see little upside as we have seen, is worthy of a group of citizens and planners getting together and saying “how can we make start from scratch and make plans do something more useful?” but of course no one would ever want to revise the 2012 planning rule because… of the work/cost (including social/political costs) involved with no certainty of success.

              I think it’s absolutely coevolution, people make planning rules so that plans are complicated and difficult with questionable real-world payoff- when lately many allocations have been made by Roadless Rules and Wilderness Bills, and other people don’t want to go through the effort and spend the money.

              Again, I’m not exactly sure what “doing the right thing” is here. Having been through a couple of started and stopped plan revisions, I’d tend to shy away myself.

              • I worked on every planning rule from 1985 to 2012, including major roles on 3 of them. Every one of them was intended to “streamline” the process (not necessarily substance), not make it harder. That meant both making amendments easier and more frequent and limiting the scope of revisions to the “need for change” (based on an assessment). In my opinion, the main reason for why that hasn’t worked is the failure to provide the funding needed to keep plans current through amendments (it always had to be taken from project or monitoring funds), meaning there is a big need for change when the plan has to be revised (which NFMA requires every 15 years). I have also not been impressed with the way assessments have been used to frame the revision process. As I think the FACA committee pointed out, there is little connection between the changes proposed and the identified need for change (supported by the assessment). This leads to something that looks more like starting from scratch.

              • My answer? “Commitment” – that is the desired approach, which has been difficult to attain with revolving-door line officers, planning team member exits, and fleeting people opinion. BUT, it does take time to accomplish planning actions, and many people do not want to commit to/invest in the time needed.

  3. Jon,
    FYI, the Scoping Documents do include a map that shows the High and Low SIOs in relation to the proposed line.

    I know a bit about this project and it is not just a “shortcut”. The news article states that it is needed for electric reliability of the town of Oak Creek. This has nothing to do with Trump, its just a small town in AZ. They currently only have one wire going into the town and placing a second one means they are less likely to lose power. The town is essentially surrounded by National Forest, so any infrastructure development in the area would impact the Forest in some way.

    I would disagree that this is a “summary dismissal of the forest plan.” First, as Anthony noted, it is impossible for a forest to anticipate all proposed development in an area, especially one-off infrastructure projects. So I think it makes sense to designate SIOs but to reevaluate them when a project is proposed.

    One example of the kind of trade-offs that would have been difficult or impossible to include in the forest plan: If the alternative along the existing road is chosen (in an areas of High SIO) there will not be a need to build or improve roads. However, if the SIO around the road is deemed paramount, other forest resources may be impacted by placing the line “out of sight”, in areas that are currently less impacted.

    These trade-offs will be evaluated through the NEPA process. The NEPA for the Forest Plan could not have anticipated all of the details that are now being considered for this project.

  4. Can you explain why they can’t put their second wire in the same place as the first one?

    The map shows the different SIOs, but nothing explains whether that distinction makes any difference for power lines.

    What do you suppose would have happened if the Forest had put it to the public honestly like this: “We’re not going to plan for utility corridors. The SIOs do not apply to them, and we could put them anywhere on the Forest.” I think the public might have wanted a decision that there are some places that should not have power lines. The forest plan should also provide guidance to proponents of power lines for when they start to think about where they could develop with the least impacts and controversy.

    I don’t see much on the maps that looks like it would qualify as “out-of-sight,” but managing for that is exactly the kind of strategic choice that should have been made in the forest plan, based on effects on any other resource values present there. That’s another key requirement and benefit of forest planning – that it integrates resource considerations across the forest so that those kind of trade-offs can be made at an appropriate scale.

    Sure, if you’re the Forest Service, there’s incentives to not put things in forest plans that you might have to be accountable for. That’s why NFMA requires it.

  5. Jon,
    I’ve learned a lot from you on this blog (and elsewhere) about legal requirements for Forest planning, but sometimes I think you imagine almost superhuman abilities for the Forest service employees engaged in this planning, and I don’t think that’s what NFMA intends.

    Ideally, the forest plan would account for any and all management actions and special use permit requests over the life of the plan, but is that realistic? In your hypothetical, the forest would have evaluated the entire forest for power line suitability, despite the fact that no one on the forest is an expert in utility siting or has any way to know the constraints or needs of utility companies in the future. And then multiply that planning effort for every other hypothetical use on the forest?

    It makes more sense to me, practically, that a Forest Plan sets out a series of objectives. And then individual projects either support or contradict those objectives. Hopefully they have more projects that support their stated objectives, but I don’t think its realistic that every project proposed over the lifetime of a forest plan fits the stated objectives. Sometimes it doesn’t. And then that is highlighted in the Scoping Documents with a Plan Amendment.

    There are some areas on the forest that are totally off-limits to development (wilderness areas), but SIOs are not one of those areas. If they were, I think Forests would be much more wary of designating them.

    I could be wrong, but this is how Forest Plans work in the real world. I agree that ideally the Forest Plan would account for this type of project, but I’ve never seen a Forest Plan that didn’t need to be amended in some way based on changing conditions.

    • Especially since some haven’t been revised in 30 years…nor are forests necessarily enthusiastic about doing a plan revision, nor are there the bucks for everyone to do them… Even though this one was done in 2018, perhaps this shows that forest plans need to be living documents because not everything, at every scale, can be predicted in advance.

  6. The Planning Rule requires that the plan must include plan components to provide for scenic character (§ 219.10(b)(1)(i)). The Planning Rule also requires that in the development of plan components, the Responsible Official shall consider appropriate placement and sustainable management of infrastructure such as utility corridors (§219.10(a)(3)). While the Coconino revised plan was not developed under the 2012 Planning Rule, I don’t think this example is idealistic.

    I wouldn’t have pointed this out if it were a 20 year old forest plan; conditions didn’t change this much that quickly, and demand could have been predicted in advance. I also wouldn’t have pointed it out if it were a permit for some new kind of special use with limited potential impacts. This just happened to look like a pretty egregious example of a known potential use with significant impacts the public would have been interested in that seems to have been blown off in recent forest planning. This forest plan was apparently written so that these SIOs are off-limits. If the Forest didn’t mean that, they should have been honest with their public.

    • If the potential of a powerline was truly known, then yes, its potential development should have been addressed. Perhaps this is an example of a “head in sand” moment?

  7. Maybe, but they should know better. Utilities are typically regulated monopolies that have requirements to plan for future needs. They and/or their regulating body are the types of organizations that should have been included in agency outreach associated with the forest plan revision. I find no mention of the Arizona Public Service Company in the planning record section on “Coordination with Other Planning Efforts.”

    • I’m still struggling with what should have been done in the best-case scenario…. Let’s say the Forest had reached out to the utility and learned that they wanted to run a new line to the town. Should the Forest have then designated a preferred utility corridor in the Forest Plan and not designated SIOs in some areas?

      That sounds simple, but consider: the Scoping Notice and maps of alternatives referenced in the article are the result of more than a year of meetings between the utility and the forest and public meeting(s). I saw one of the initial proposals and there were literally dozens of different possible corridors drawn all over the map. The 3 alternatives presenting in the scoping notice were whittled down based on feedback from those meetings.

      So I can’t really imagine that process included in a Forest Plan NEPA. They would have had to either not designate any SIOs anywhere around the town because the utility might want to put a power line there, or they’d have to go through the whole process of public meetings, scoping, etc to narrow down the areas where the potential power line could go…

  8. The Forest should have known that it needed to allow a power line, and it should have determined at a viewshed scale where that would be best. I don’t think that has to be at a level of specific routes, so maybe the choice is between a few viewsheds rather than dozens of routes. Or, it could have excepted power lines from SIOs (forest-wide or just for potential corridors).

    At this point, I see another possible problem/opportunity. If there were specific corridors considered in other viewsheds that would meet the purpose and need, those should be included within the NEPA process. That could also give more legitimacy to the selection of a particular viewshed as a long-term programmatic decision.

    (I remember that forest plans I worked on said something about utility corridors, but I can’t say I ever dealt with this exact situation. I might be worth looking at what other plans may have done.)


Leave a Comment