Modernizing Planning Discussion in R-6/R-5 Bioregional Assessment: Which Would You Pick and Why?

Many, many thanks to folks who write the RVCC newsletter for finding this in the voluminous Bioregional Assessment Steve posted here pp. 37-38.

This discussion touches on many topics that we talk about.

Simultaneous Plan Revision—All 19 forests and grasslands in the BioA area would complete plan revision at the same time. This approach, like the landscape-level approach used during the NWFP, would ensure consistency and compatibility among the plans and would contribute to standardizing the formats of land management plans to help develop a common understanding of management direction. Completing simultaneous plan modernization presents significant capacity and coordination challenges across 19 responsible officials and their staff; however, efficiencies might be realized if phases of the process are streamlined and expected timelines are met. If, during simultaneous plan updating, the required analyses are integrated and conditions change significantly on one national forest or grassland requiring different or additional analysis, all 19 units would likely be impacted. Finally, this strategy might present a challenge to meaningful engagement with the public in the planning process because of the amount and complexity of information and the breadth of the geographic scope.

Incremental Plan Revision—We would revise three to six land management plans at the same time based upon similar challenges and geography. As an example, we could start with five units in the southwestern BioA area based on growing departure in desired ecological conditions, vulnerability to fire cost and behavior, and dependency of local communities on benefits from national forests and grasslands. The planning effort on the next group of units would begin approximately 1 year before the process is complete on the first group, and so on until revisions for all 19 units are complete. This option would allow the Forest Service to focus on the units with the most urgent needs for modernization first and would support our ability to learn as we go, which will help us continually improve land management planning efficiencies. Budgeting and staffing needs would be extended across a longer period than under the simultaneous plan revision option but would be lower per year and therefore, potentially more sustainable. Under this approach it would take at least 12 years to complete revision on all 19 units and would maintain the outdated condition of many plans for a longer time. Ensuring consistency and compatibility between plans that are in different groups would require close coordination between planning teams as one group of plans is finalized and updating is started on the next group.

Amendment(s)—Under this option, we would complete a range-wide amendment of all or a subset the land management plans to address one or more of the topic areas identified as needing change in the BioA. For instance, this option could be used to develop up-front, standardized agreements on range-wide management for listed species such as the northern spotted owl. This method could specifically address issues like northern spotted owl habitat connectivity throughout its range and facilitate Engendered Species Act consultation on future plan revisions. Amendments could also be used to better align late-successional reserve boundaries with late-successional habitat. An amendment process, even at a large scale, would be shorter than full plan revisions, and might take only 2 years to complete. This approach would allow the Forest Service to focus on the most immediate needs within the BioA area and might be a more streamlined option for creating direction that is compatible with the various ecosystems and conditions. Opportunities for public engagement would be more focused on specific areas and issues, which might allow for more robust public involvement. A drawback to this approach is that it would not completely address the problems associated with overlapping management direction. In addition, while this approach would focus on the most urgent issues within the BioA area, it would not be a comprehensive modernization of all plans; plans would remain outdated and many important updates would not be completed.

Individual Forest Plan Revision—Historically, land management plans are revised or amended by individual national forests or grasslands. However, many of the ecological and socioeconomic conditions in the BioA area span many forests and grasslands and are therefore, best addressed at a landscape scale. Completing individual land management plan modernizations wouldn’t meet the agency’s goal of reducing the time and cost to produce efficient, effective, and high-quality land management plans to accomplish more work on the ground and be more responsive to our public.

Incremental Plan Revision and Amendment—We would begin modernization on a prioritized group of units, as in the incremental plan revision option, and simultaneously complete amendments on other units that are facing some of the same urgent issues. For instance, as a group of plans are updated to include refined and improved direction associated with the natural role of fire in frequent-fire dependent ecosystems, all other plans on units with similar ecosystems could be amended to incorporate the same language. This approach would allow for a broad-scale modernization of plan components to meet immediate needs without the complexity of updating many plans at the same time. The approach would contribute to consistent management of similar issues across the landscape as well as management that is compatible with the varied ecosystems. Potentially, this approach would contribute to more robust public involvement related to the specific issues on which amendments were focused. However, comprehensive modernization of most plans would still be delayed and amending plans rather than revising them would still result in overlapping layers of management direction.

Many of the identified opportunities for modernizing the land management plans in the BioA area cross multiple national forest and grassland boundaries. Some management opportunities on some national forests and grasslands are more urgent than others, while other
challenges experienced across several national forests and grasslands would benefit from a consistent approach. Some forests have a more urgent need for restoration activities to improve the resiliency of the landscape than others (figure 2-6). The need for management consistency arises when multiple national forests and grasslands face the same management challenge; an example is managing habitat to facilitate the recovery of the northern spotted owl across that species’ range (figure 2-7). We gain efficiencies by combining modernization efforts around similar management needs.

(In the document is this sidebar)

Combination approach—An Example
Relevant direction from the US Fish and Wildlife’s Conservation Strategy for Grizzly Bear in the Northern Continental Divide Ecosystem 2019 63 has been incorporated as amendments to the land management plans for the Helena, Kootenai, Lewis and Clark, and Lolo National Forests. The Flathead National Forest incorporated the relevant direction into its land management plan revision. This combination of revision and amendments ensures that habitat for this wide-ranging species is managed consistently and appropriately across all affected national forests.

I wish they had specific examples of why there is an “urgent” need to change, that might help us compare the different approaches. How urgent is urgent and why? Anyway, which would you pick and why? And how did they manage to do so many in 1990?

8 thoughts on “Modernizing Planning Discussion in R-6/R-5 Bioregional Assessment: Which Would You Pick and Why?”

  1. Quick reply to Sharon’s question re: how was the agency able to do so many plans in 1990?
    1 – The FS was much better funded then
    2 – Probably each NF had some planning staff in the supervisor’s office if not a full planning team. That capacity is now gone!
    3 – There was probably more support for the value of planning then whereas now, there seems to be much less. Especially from the Trump admin; have you noticed the distinct absence of a national plan to combat the Covid pandemic?
    4 – A couple of years ago I had a conversation w/ the planning director for R6 in Portland. She told me how limited the funding for planning was and how directors from other regions complained that planning in R6 is too expensive compared to other regions.
    Having worked in three different region of the agency (R5, 6 and 9) I can see that some areas are more complex both biologically and in terms of economy, demographics, etc. Heck, within R5 and 6 there are major differences between NF’s in the more rural parts of the regions and the forests next to major urban areas. If nothing else, the process to engage stakeholders in planning is going to be more complex for the Angeles and Mt. Hood than say the Klamath or a forest in rural eastern Oregon.

    • OW

      3. I don’t think we can blame Trump for slow NFMA planning, I remember it was slow long before him and before the 2012 Rule.. in fact, I seem to recall that the 2012 Rule was supposed to speed things up. It didn’t make sense that you would have to do more stuff but it would (somehow) be speedier.
      4. Some things never change. I’m sure planning directors in my time frame were making the same complaint to her predecessor..

  2. All of the mentioned plans were revised by either the Northwest Forest Plan in 1993 or the Eastside Screens Amendment in 1994. Both amendments were far-ranging for forest and riparian management. So, to me, it’s a little disingenuous to show that the plans date back to 1990, etc. Parts of them do, but a large part was updated in the early 1990s. The Northwest Forest Plan was designed to be a 50-year plan and set up a bioregional network of Late-Successional Reserves. The individual forest plans prior to the NWFP were not well-coordinated across forest boundaries and had late successional areas that were relatively small, and a larger-scale solution was needed, hence the NWFP. The Eastside Screens were intended to be a temporary way to maintain options until plans could be revised (and plan revision was thought to be imminent at that time).

    • That’s a good point, it is very readable and the infographics are helpful. If I worked in the NW, I would certainly have read all 90.

  3. The choice should depend on how the FS weights the pros and cons. Is speed most important? Consistency? Fixing particular urgent problems?

    Procedurally, I am convinced that there is no need for 19 different kinds of wheels, and the R & D that would go into inventing each one. And no, there isn’t much interest in staffing up 19 teams to figure out how to invent those wheels like there was in the ’80s (when I was on the Mt. Hood planning team). And there really isn’t much need or benefit from putting anyone’s personal/professional opinions into a plan that they won’t be around to implement much if any of. There’s minimal long-term payoff from “ownership.” This thinking always leads me to a more centralized planning process (hopefully with some of the few experienced staff that the agency has), and some of these options may work better with that structure than others.

    Substantively, I have always thought that the “minimum management requirements” of the 1982 planning regulations made a lot of sense. That basically amounts to first developing a conservation strategy that adequately provides a coarse filter (desired condition) for all at-risk species, and in some cases species-specific standards, based on the best available science. These should be things that are more species/dependent rather than forest-dependent. I’ve been involved in several amendments that did something along these lines (spotted owls, aquatic conservation strategies, lynx, grizzly bears), and I think they have worked pretty well to provide consistency where it is needed to address controversy, and to define the real decision-space left for individual forests to work with. (The Roadless Rule did something similar.) I think expecting to take some of the biggest issues off the table in 2 years is not very realistic, but I think the option of amending first to provide this conservation template has a lot going for it. (Ideally the process would recognize that meeting minimal legal requirements for at-risk species is not discretionary, and adopting mitigation measures benefits the environment, and both of these factors weigh against triggering a lot of NEPA obligations.)

    Someone will complain that this would “one size fits all” management, but there is no reason it can’t be ecologically tailored. It could also be tailored to prioritize meeting species requirements on forests/areas with the least unpopular tradeoffs. (Though as I’ve said before, I think this complaint is often about “someone else telling me what to do.” Egos can be a barrier.)

    • Jon, I think I agree with you on much of this. Part of this it seems to me has to do with the utility of having a complete plan revision rather than a loose-leaf notebook of different decisions (that was planning thinking for awhile in the 2000’s…). I don’t think many people read a forest plan cover to cover, and so it’s the decisions that are made that are important. And it seems like there is some value to coordinating those decisions at the appropriate scale. What would RW look like if coordinated across 5 forests? 10?. Would it be done differently? Why? My concern would be that the areas with the most vocal interest groups might hold more sway than the concerns of people in the community, especially those without cities nearby. Like West-side-itis.

      But I wonder whether the 82 regs had course filter/ fine filter. Based on this Chris Iverson (01) document, TNC had come up with the idea in 82 .
      Chris’s writeup reminds me how similar the concepts in the 2000 and 2012 Rules were.

      Is this what you mean by mmr ? Diversity.

      “Management prescriptions, where appropriate and to the extent practicable, shall preserve and enhance the diversity of plant and animal communities, including endemic and desirable naturalized plant and animal species, so that it is at least as great as that which would be expected in a natural forest and the diversity of tree species similar to that existing in the planning area. Reductions in diversity of plant and animal communities and tree species from that which would be expected in a natural forest, or from that similar to the existing diversity in the planning area, may be prescribed only where needed to meet overall multiple-use objectives. Planned type conversion shall be justified by an analysis showing biological, economic, social, and environmental design consequences, and the relation of such conversions to the process of natural change.”

  4. My reference to the “coarse filter” was an attempt to bring the the ’82 requirement into today. The language you quoted is part (g) of the section of the regs I was thinking of, §219.27 “Management requirements.” The first part says:

    “The minimum specific management requirements to be met in accomplishing goals and objectives for the National Forest System are set forth in this section. These requirements guide the development, analysis, approval, implementation, monitoring and evaluation of forest plans.
    (a) Resource protection. All management prescriptions shall – (among other things)
    (6) Provide for adequate fish and wildlife habitat to maintain viable populations of existing native vertebrate species …”

    I’m actually thinking of the regional guidance that R6 developed to implement MMRs. It included, for example, a template of “spotted owl management areas” across the range of the northern spotted owl. The NSO science was quickly overtaken as they were found to be too small, but this approach was embedded in the Northwest Forest Plan amendments to the Regional Guide. (Regional guides no longer exist, but the opportunity remains for region-wide or multi-forest forest planning.) I get that there is now a desire for reducing the use of static habitat designations, but that can be a separate debate from whether that choice should be made first and for larger landscapes (as an “MMR).


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