Forest Planning Update – September 2021

As Steve reminded us in his post on the Santa Fe forest plan revision, forest planning was the original focus of this blog, and it’s something I have a particular interest in.  As it happens, a number of national forests are currently engaging the public in their forest plan revision processes.  Links are provided here to the plan revision webpage for each forest, as well as to related articles.  The Forest Service home page for forest planning includes links to the national revision schedule, the status of each forest plan, and a story map of revisions occurring nationally.


The final revised Land Management Plan, FEIS and Draft Record of Decision for the Santa Fe National Forest are available and the 60-day objection period began on September 2 for those who have previously submitted comments.   Steve posted about this here.


Comments may be submitted until November 5 on the Draft revised forest plan and EIS for the Lincoln National Forest.  (You can attend public meetings on Zoom!)

On August 31, the Grand Mesa Uncompahgre and Gunnison National Forests released their draft revised forest plan and EIS for public comments until November 12. There has been a lot of press coverage.  Highlights to me are the interests of the local governments in LESS timber harvest, the extent to which climate change is now an issue, and … drones.  No surprises that recreation and wilderness are also key issues.


On August 25, the Mant-LaSal National Forest published its Notice of Intent to prepare an EIS for its revised forest plan, initiating the 60-day scoping period.  Its draft forest plan and assessment report are available for review.  This article based on the Forest Service news release discusses some of the issues.


  • Coconino (Arizona)

For those more interested in travel planning (which must be consistent with the forest plan), the Coconino National Forest is working on an OHV plan:  “Currently, the agency is performing something of a “stern parent/nice parent” routine with local off-highway vehicle companies in order to enlist their help, floating the possibility of road closures or a permit system for OHV routes if progress isn’t made.”


  • Monongahela (West Virginia) and Wayne (Ohio)

Here’s an example of how including adequate protective measures in a forest plan can facilitate removing species from the threatened and endangered species list.  The running buffalo clover is being proposed for delisting based on its recovery, due in large part to national forest plans.  This article provides a link to the Federal Register Notice, which says:

“Delisting criterion 3 states that the land on which each of the 34 populations described in delisting criterion 1 occurs is owned by a government agency or private conservation organization that identifies maintenance of the species as one of the primary conservation objectives for the site, or the population is protected by a conservation agreement that commits the private landowner to habitat management for the species…

The forest management plans for both the Monongahela and Wayne national forests include direction and guidelines to avoid and minimize impacts of forestry practices on running buffalo clover. These forestry management practices, as conditioned through running buffalo clover measures included in their respective forest plans, are compatible with running buffalo clover conservation. The forest plans include forest-wide standards and guidelines; compliance with standards is mandatory.”


6 thoughts on “Forest Planning Update – September 2021”

  1. The draft GMUG Forest Plan is a doozy. I’m heavily involved with that one both with motorized issues and drone issues.

    The unofficial preferred alternative B looks generally ok, but Alternative D based largely on the Gunnison Public Lands Initiative (GPLI) is a disaster. Its proposed summer ROS map would put most of the most popular 4×4 trails in southern Colorado (including multiple Jeep Badge of Honor trails like Black Bear Pass and Imogene Pass) in non-motorized ROS zones, forcing them to be closed in the next travel plan. Though several of those are county roads that the Forest Service probably doesn’t have authority to close, so the ROS zones would just be inaccurate. Then there are a ton of special management area designations from the GPLI that are basically “wilderness lite” which the GPLI claims would not close any existing roads but absolutely would. It’s a mess.

    The drone issue is also rediculous. Across all alternatives, they are proposing to ban drones from being operated from all forest roads and trails, trail summits, developed rec sites, recommended wilderness, and special management areas. While I get that some people may find drones annoying for their noise, there is no way a drone is noisier than a UTV or dirt bike, so banning them near motorized routes makes no sense. They are also commonly used by off-roaders, mountain bikers, etc. to film themselves on trails, so they would be banning a popular activity with no real explanation or justification. Because drones are primarily used for photography, that raises 1st Amendment issues as well.

    We’ve got a good group of people working on the drone issue and we hopefully will be able to meet with FS officials about it during the comment period, so hopefully we can get that can that proposed rule changed. While it’s probably reasonable to restrict drones some places like campgrounds, I think that would be much better decided in project level location specific management plans rather than in the Forest Plan.

    • While use of a camera may bring up 1st Amendment questions, the issue of the vehicle can and should be addressed separately. (I don’t think it’s a good argument to say that carrying a camera allows you to break any other rules that would otherwise apply.)

      • Maybe this would be better discussed in the drone thread, but at least in the Manti La Sal draft Forest Plan, they are proposing to ban drones from this Elk Ridge Special Management Area, and the only reason they have given in the EIS for doing so is because they are worried that people might use drones to discover and photograph previously unknown cultural sites and then post about them on social media and draw hordes of visitors to them. So there the concern is actually with the First Amendment expression enabled by drones, not with the impacts of the vehicle. They will of course try to conflate the two to get around 1st Amendment concerns, but they’ve already admitted their goal is to prevent photography and public discussion of cultural sites, which is a clearly unconstitutional goal.

    • “Because drones are primarily used for photography, that raises 1st Amendment issues as well.”

      Please explain. Are you suggesting that use of a drone to film oneself is protected by freedom of expression? Or freedom of the press??

      • Photography generally is a form of First Amendment protected expression. Governments may place certain reasonable time place and manner restrictions on photography but can’t regulate its content. The courts recently struck down the Department of Interior’s arbitrary restrictions on commercial photography that didn’t apply to private photography because they were content based and had nothing to do with environmental impacts.

        Similarly with drones, restrictions could be upheld if the Forest Service could prove they were reasonably necessary because of specific impacts from drones as vehicles, but could not ban them out of concerns about the content of the photography. And they would have to prove some actual justification for restricting the vehicles, which so far none of the proposed restrictions I’ve seen provide any.


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