Getting Revisions Done: Stay Tuned for New Forest Service Planning Implementation Model

Current plan revision schedule.  You can click on this and get higher resolution. I recently heard that the Pisgah-Nantahala (which started in 2012 with assessing) is about to release its draft.

Sure enough, the FS doesn’t actually have a “can’t do” attitude as it appeared from my read of the recent hearing. From chatting further with Chris French, it turns out that they are well down the road with an innovative approach to deal with LMP revisions, and to actually get them back on schedule (!).

Sure enough, (this will not surprise anyone) the 2012 Rule is difficult and complex to do, and the FS decentralized approach makes for inconsistencies.  We’ve observed those here at TSW. Despite the unduly optimistic Q&As from the 2012 Rule:

Under the 2012 planning rule the agency should be able to revise more plans with the same amount of money. The 2012 planning rule should reduce the amount of time (3-4 vs. 5-7 years) and the amount of money ($3-4 vs. $5-7 million) that it takes to revise individual forest and grassland land management plans, as compared to the current 1982 procedures.

That’s not the way it’s worked out. Using simple logic, if you do more analysis and involve people more, it takes more time and costs more money.  This seemed obvious to everyone at the time, apparently everyone but the people who did the PR for the Rule. So the reality has been more like 7-8 years. And the FS folks noticed that this was a problem, especially since the desired target of NFMA is a plan that is revised every 15 years. It makes sense for them to try something different, because next year will be 10 years since the 2012 Rule was published, and it is a reasonable time to assess how it has been working and to do some adaptive management.

So to that end, the FS is in the process of figuring out the details of a new way to approach forest planning. It’s a hybrid model, with decision authority and stakeholder involvement remaining at the forest level, while analysis and other technical issues are provided in geographic teams that handle multiple revisions. There will also be some national teams or other efforts to ensure consistency. The idea is to be able to get on a national planning rotation of 10-15 years with an expected timeframe of 3-4 years per plan.

Chris also made clear that this hybrid model was developed prior to the current discussions on the Reconciliation bill, which as you may remember calls for (in October 28 version):

$350,000,000 for National Forest System land management planning and monitoring, prioritized on the assessment of watershed, ecological, and carbon conditions on National Forest System land and the revision and amendment of older land management plans that present opportunities to protect, maintain, restore, and monitor ecological integrity, ecological conditions for at-risk species, and carbon storage.

Chris noted that that this funding would indeed be helpful in getting plans done.

So stay tuned, and more information will be forthcoming on the details of the model when the Forest Service has the complete package finalized.


My view: this approach sounds eminently sensible to me. After all, decentralization is a philosophy, not a commandment. Some regions do some versions of this already, as I understand.

It also reminds me of the BLM RMP approach in Nevada that we looked at here and their rationales. If you do something once every twenty to thirty years, it’s unlikely you will get very good at it compared to those who do it all the time. And in the case of the 2012 Rule, if you’ve never done it, you’re probably not as good at using it as someone who has.

As a wonk, I would have preferred a more formal open process with public involvement in “what is working and what isn’t” after ten years of experience, including the views of stakeholders, scientists, and so on, who actually have been involved in the guts of a revision process. It would include the possibility of tweaks to the Rule itself. Like an LMP, doing a new rule is opening Pandora’s box, whereas specific amendments can be very helpful based on the concept of a “need for change.”

Side note: If the FS chose to prioritize fire amendments instead of revisions (OK, which seems unlikely, still..), the bill language does include “amendment of older LMPs” which almost all are, the FS would have to argue they are protecting eco integrity, conditions for at-risk species and carbon storage. And fire amendments (managed wildfires, prescribed burning, POD delineation and analysis of specific treatments) would do that, IMHO.

25 thoughts on “Getting Revisions Done: Stay Tuned for New Forest Service Planning Implementation Model”

  1. What have folks heard about revisions for the West side Spotted Owl forests in Region 6?
    LRMP for Mt Hood NF was adopted in 1990!
    It’s a joke that the basic plan with land allocations, etc. is that OLD and OUT DATED !!! Yes, there have been amendments but the basis for the LRMP is way out of date.
    There have been just a few changes in the communities within an hour’s drive of the Hood; demographics, economy, population growth, etc.
    And more than a few changes in forest ecosystem science, climate change science, etc.

  2. Despite fits and starts, the USFS is “pausing” Northwest Forest Plan revision – and revision of the plans under the NFP – until FY22. In the meantime, the agency is going to focus on “post-fire recovery” after the 2020 and 2021 wildfires.

    I think that means we get a bunch of contentious salvage logging rather than updated forest plans.

    • Susan, isn’t it already FY22 (Oct. 1)? I know lots of people want “updated forest plans” but I’d be interested in your views of specifics that you think need to be updated. It would make a terrific guest post IMHO.

      • Sorry, I meant FY23 – calendar year 2022.

        I would like to see the “Iron Triangle forests” (Malheur, Wallowa-Whitman, Umatilla) revised to address large landscape restoration, encourage the use of prescribed and managed fire for resource benefit (some forest plans prohibit the use of fire as a tool), update wildlife movement provisions (i.e., look at landscape permeability rather than “corridors”), address the unsustainable road network, and otherwise infuse ecological integrity into the planning process.

        • By unsustainable, do you mean fiscally or environmentally or both? Didn’t the forests do travel planning at some point? Do you think it’s outdated?

          • I mean both. The Malheur NF has neither begun nor completed travel management planning. The other forests have made very little progress in getting to a minimum road system due to local opposition from motorized recreation interests.

            • I find this fascinating. When I read your post I assumed Malheur must have at least completed Subpart B travel planning and published MVUMs by now since I thought all forests had. I checked their website and apparently not! I assume motorized use is restricted to existing roads then, like BLM field offices that have not done travel planning yet?

              If local motorized advocacy groups have been able to get the Malheur NF to stall on even Subpart B travel planning for this long, that is a remarkable achievement. That would make them probably the most effective motorized lobby in the country. Now I want to know what their secret is lol.

              As for the Subpart A minimum road system, I think probably both motorized groups and anti-motorized groups could agree that process has been an unmitigated disaster. Only a few forests have attempted to designate a MRS, and I know of at least two cases where it was struck down because they didn’t follow the proper process.

              My group will be challenging the Pike San Isabel National Forest’s attempt to designate an MRS because they also didn’t follow the proper process, and just adopted the recommendations of their travel analysis reports basically wholesale without allowing any meaningful opportunity for comment on the TAP report’s underlying recommendations or scoring or the designations adopted based on it.

              The entire travel plan was based on a matrix of arbitrary risk/benefit scores the Forest admitted were just made up by agency staff during a series of 1-2 day conferences for each ranger district without any kind of site visits or scientific analysis. Then they had a series of 30 day comment periods of each ranger district’s TAP report which they gave no public notice for and received only 20 comments on total. In contrast, each comment period for the travel management process that followed elicited thousands of comments. But every time a comment on the travel management plan challenged one of the recommendations or scores in the TAP reports and asked for a different designation, the forest just said revising the TAP reports was out of scope and their conclusions were beyond challenge. We believe this violated both NEPA and the TMR’s requirement that public input be considered on actual route designations.

              So yeah, if forests actually want to designate a Subpart A minimum road system, they’ve got to start following the proper process. To start with, they need a better, more standardized, and more transparent travel analysis process.

              • Well, in fairness, I’m not sure that it is the “effectiveness” of motorized rec groups that has stalled travel management, but rather it’s more the local community opposition, particularly county government opposition, to closing roads for any reason. Frankly, I think the Forest Service is scared of the counties: this is solid Bundy country.

                • Don’t you think that individuals who use forest roads to recreate have a legitimate point of view? I mean, who among us is not a motorized recreationist in some sense?

                  • In this case, no, I don’t think these particular stakeholders have a legitimate concern. The Malheur NF has more open roads than almost any other forest in R6, which is amazing given how little recreation pressure it gets – those roads are the legacy of a workhorse forest. We do not “need” *all* of those roads, which is what I hear from those folks. What we DO need is a rational road system that is sustainable, both ecologically and fiscally, and that’s what the travel management process was supposed to get us – in theory.

                    There’s a middle road (pun intended!): we can remove from the landscape some roads that are causing resource damage (mostly aquatic – we built a lot of roads in valley bottoms adjacent to streams), seasonally close others for wildlife security, and keep the roads open that folks use during hunting season or for restoration. But that’s a potential solution that has so far not gained traction in Grant and Harney Counties, and the Forest Service is scared to try (in my view, and perhaps rightly so).

                    • Your idea sounds reasonable, but perhaps the local people don’t want to go there, because they don’t trust that their concerns will carry the day (or that closures will, at the end of the day, be reasonable). It also seems like this could be done without doing a plan revision. The Black Hills worked theirs out through their FACA committee, does the collaborative group on the Malheur work on this kind of thing?

                    • I don’t think we need a plan amendment or revision either to deal with roads.

                      Our collaborative isn’t a FACA, but we have started having tentative conversations about roads. There’s some early agreement that temp closures – as opposed to obliteration – are more palatable, and we’ve started talking about *where* across the forest we might have larger seasonal closures (or even annual) to encourage elk to stay on the national forest as opposed to coming down on to private. We’ve got some great Starkey research we’d like to utilize and test, but there’s a fair amount of local skepticism about whether its legit “outside of the elk zoo.”

                    • It sounds like you are using the trust network you all have developed to explore what it would take to test out different interventions. And as you all have found out with restoration, developing your own joint experience and data is a path forward. So it sounds as if you are doing the right thing, even if it seems slower than optimal.

                    • I think it’s likely your perspective on what roads are “needed” or “sustainable” varies significantly from the local motorized recreationists. In every travel management process I’ve been a part of, environmental groups have targeted the most valuable motorized routes in the area for closure. Ie. the most scenic, the most technically challenging, the ones that lead to important destinations, have the best campsites, and are heavily used and featured in published guidebooks. Environmentalists can always come up with reasons why these routes are “unsustainable”, either because of their sheer popularity (“overuse”) or because of their technical challenge (ruts, steep grades, mud bogs, water crossings, etc.).

                      Basically anything that makes a motorized route fun and desirable to drive is cast as reason why the route is “unsustainable.” If environmental groups had their way, the only motorized routes kept open would be boring dirt roads on flat terrain nowhere near bodies of water, mountain tops, slopes, or anything scenic or challenging. So that is why we get very worried when environmentalists start calling to close “unneeded” or “unsustainable” roads.

                      Ironically, in the travel plans I’ve worked on so far, the truly unneeded roads are actually more likely to be kept open, as both sides spend the comment periods fighting over the high value routes and completely ignore the routes that nobody uses and knows nothing about. Those routes end up staying under the radar for the whole process and are usually kept open by default.

                    • Maybe my views differ, but we may never know, since the Forest Service has no plans to initiate the travel planning process any time soon.

                      Regardless, I would hope and expect that all planning processes were based on the best available science regarding ecological impacts of the road system (getting to the sustainability issue), but also recognize that some ecologically damaging roads are extremely socially popular: can’t there be some common ground on how to improve these roads if they must stay open? I don’t hear enough about those types of solutions.

                    • That makes a great deal of sense to me. I wonder if it’s related to the 50% reduction in engineers who might think up those things…(see capacity post). I think we’re running out of space here and it sounds important for further discussion, so I’ve asked Patrick to write a guest post on travel management and maybe we can continue the discussion there.

                    • I’m actually replying to Sharon’s comment below (but I wasn’t given that option there!?). Travel planning designating open areas and routes does not require a plan revision. However, it might make it easier to do travel planning if the forest plan decision about suitability for motorized use could be made beforehand. I’m assuming the Malheur’s inability to revise its forest plan is hung up partly on that question. (SJ knows a lot more about the specifics.)

  3. They finally listened to me.
    There’s nothing that obviously warrants “tweaks to the Rule itself,” but there’s no reason to foreclose that if there is an unreasonable procedural hurdle to achieving ecological integrity more quickly. I’ve also always said that the “do-not” part of forest plans could get by with a lot less NEPA/ESA.

  4. What the heck is an “ecologically damaging road,” and who gets to make that determination? And why? My BS was in the study of forest recreation and the most common form of activity — especially for older and younger people — is sightseeing while traveling existing roads. Hunters, fishermen, hikers, bikes, botanists and photographers are other users. Maybe the roads were initially established as part of a “workhorse legacy,” but riparian and ridgeline travel routes have a much longer history — thousands of years longer — than recent forest management operations.

    I have been driving USFS roads both recreationally and professionally for more than 50 years and it is really sad to see how badly many of these roads — and connective trails — have been allowed to degenerate the past 30. The “let it burn” wildfires are one related result, damaged rural economies are another. I just returned from a trip to the Umatilla, Malheur and Deschutes National Forests and was very pleasantly surprised regarding the thinning and prescribed burning practices that have been successfully implemented on the Deschutes in recent years. Roads and trails are in great shape, lots of local work is being created, and the forests are far safer and more attractive for people and wildlife for many years to follow.

    • Like I said, pretty much anything that makes road worth driving is considered “ecologically damaging” by some. And I know that I’ve seen at least one forest plan revision in Arizona that would require all roads on steep slopes, ridge tops, and near riparian areas to be closed. I guess in their next travel plan they’ll pretty much close everything because I don’t know what else will be left.

    • The most damaging ecological roads I have seen are roads that are poorly maintained by the FS.
      Its the plugged culverts and poorly maintained ditches causing erosion and washouts.
      I just read were a judge has enjoined the hazard tree removal on the Willamette National forest. I hope the enviros are happy when we can no longer access our forests. Careful what you wish for.

      • Most of those people taking these actions, Bob, are city kids and their lawyers. They could care less about our access to “their” public lands. The only time I see most of them out in the woods is in protest photos. Total agreement on the damaged roads and will add dangerous fuel build-ups due to gross mismanagement as further evidence that NEPA isn’t working.

        • Regarding roads, it’s more the travel management rule that’s not working, rather than NEPA itself. The TMR was enacted as a mandate to close roads and provides a dozen reasons to close them and zero to keep them open. And the way it’s actually been applied in practice belies the statements to the contrary in the text of the accompanying decision.

          The text of the original decision to adopt the TMR paid lip service to the idea that motorized recreation is a legitimate activity on the Forest, while the actual rule about user conflict has been used to subordinate it to non-motorized recreation. The accompanying text claims the goal is to minimize impacts rather than total millage or the road system, but the rule directly requires forests to establish a “minimum road system”. And while they text acknowledges that “minimize” doesn’t mean “eliminate” impacts, in the real world that’s a distinction without a difference. You can always “minimize” more by closing more roads, so that’s what forests tend to do, no matter how badly needed those roads are.

          A rule that focuses solely on impacts and not at all on benefits can only really lead to one result, more closures. Unless the TMR is amended to put an affirmative duty on the Forest Service to keep high value roads open, I don’t really see things changing.

          • The Travel Management Rule implements Executive Order 11644 (1972, amended in 1977)–“Use of off-road vehicles on the public lands…
            The regulations shall further require that the designation of such areas and trails shall be in accordance with the following–
            (1) Areas and trails shall be located to minimize damage to soil, watershed, vegetation, or other resources of the public lands.
            (2) Areas and trails shall be located to minimize harassment of wildlife or significant disruption of wildlife habitats.
            (3) Areas and trails shall be located to minimize conflicts between off-road vehicle use and other existing or proposed recreational uses of the same or neighboring public lands, and to ensure the compatibility of such uses with existing conditions in populated areas, taking into account noise and other factors.”

            It is what it is.

  5. A lot of the problems with roads in the Blue Mountains relate to their proximity to streams with ESA listed fish and their disruption of water flow. The road density is also off the charts, primarily because most of the logging there is ground-based, not cable-based. When I first went to work on salvage sales on the Wallowa-Whitman NF in the early 1990s, I could not believe the road density – you could not see the topo lines on the 1″ to the mile firemans’ map due to all of the roads. Thankfully that particular area that I worked in has had a lot of road restoration done in the mean time, but our team proposals on road closures of excess roads were not well received by the Forest Service due to public opinion even back then! And there are a lot of good road analysis packages out there to show that most of the road-related environmental issues related to water are found on a relatively small part of the road system, which can help focus limited funds on high-priority places. There are also deep Mazama ash deposits in the Blue Mountains that easily erode when roads and trails are built across/through them.


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