“No real advancement on forest revision plans”

I actually took this headline from an article about the status of the Salmon-Challis forest plan revision, but it pretty much describes planning in the Forest Service as a whole.  With the exception of a batch of mostly Region 3 forests nearing the end of their planning journey, not much is happening.  There are no signs of any new forests moving into the pipeline as the aforementioned revisions are completed.

The national status chart (source of this graphic – the last column shows the age of the plan) was updated April 1 (was there an inside joke here?).  It doesn’t include where each forest is in the process, so I checked each of their planning web pages and produced the summary below (roughly in order of where they are from the end to the beginning).

  • Carson – Currently reviewing objections, final plan projected in spring 2022
  • Cibola – Currently reviewing objections, final plan projected in 2022
  • Santa Fe – Currently reviewing objections, final plan TBD
  • Nantahala-Pisgah – Currently reviewing objections, final plan TBD
  • Tonto – 60-day objection period began March 25, final plan TBD
  • Nez Perce-Clearwater – FEIS/draft ROD projected Fall 2021 (yes, that is the projection on the web page)
  • Ashley – FEIS/draft ROD projected October 2022
  • Grand Mesa Uncompahgre and Gunnison – FEIS/draft ROD projected late 2022 or early 2023
  • Gila – FEIS/draft ROD TBD
  • Lincoln – FEIS/draft ROD TBD
  • Sierra/Sequoia – FEIS/draft ROD TBD
  • Manti-La Sal – DEIS/draft plan TBD
  • Salmon-Challis – Notice of initiation 2018, NOI TBD
  • Malheur/Wallowa-Whitman/Umatilla – FEIS/draft ROD withdrawn in 2019, draft plan/NOI TBD
  • Black Hills – Currently in Assessment phase, NOI TBD

There is more information available in these charts, but they have not been updated for over a year (note the individual charts for each “service group,” the national “new planning model.”  I used it to check out the forests that, at least at one time, appeared ready to start revision.  From this list of forests that should have been “in revision” or “pre-revision” sometime this year, the only references to plan revision I found on any of the web pages have been quoted below.  So there’s going to be a big gap in completed revisions.

  • In revision 2021:  Shasta-Trinity, Mendocino, Six Rivers, Klamath, Rogue River-Siskiyou
  • In revision 2022: Cimarron Comanche, Bridger-Teton, Midewin, Humboldt-Toiyabe
  • Pre-revision in 2022: Fremont-Winema, Umpqua, Siuslaw, Willamette, Lolo, Caribou-Targhee, Curlew, NFs inTexas, NFs in Florida, Kistachie, Wayne, Allegheny

Bridger-Teton, – “unlikely that BTNF will receive funding to begin Forest Plan Revision until 2022.”

Humboldt-Toiyabe – “Work on Forest Plan revision has been suspended as resources and personnel are devoted to travel management, environmental analysis of grazing, fire and fuels management, and implementation of the American Recovery and Reinvestment Act.”

There is also this note from the Wayne explaining why they have stopped revising their forest plan.

Meanwhile the Bitterroot National Forest is doing some planning of another kind that is fairly unusual (but may be becoming more common), recently releasing a draft climbing management plan.  Issues being addressed include the placing of permanent anchors (including in wilderness areas) and the need to buffer nesting raptors.  However, “Work on a final NEPA-approved climbing plan will have to wait until the agency’s Washington office completes a set of national directives focused on climbing. Those could come as soon as this summer.

19 thoughts on ““No real advancement on forest revision plans””

  1. Due to the 2020 and 2021 fires in Oregon, Washington and California, the work on revisions in R6 (and northern R5) is “on hold”….

  2. I don’t know about the other forests on that list, but I know for the Pike San Isabel NF you can blame the Wilderness Society and Quiet Use Coalition for the delay in revising the forest plan. The PSI was getting ready to start working on a forest plan revision back in 2015 or so but had all their planning resources diverted to travel management as a result of the lawsuit settlement with the aforementioned groups. Which is kind of hilarious because now the travel plan is having to amend the forest plan in order to correct mapping errors from the 1983 plan which accidentally put motorized routes in non-motorized emphasis zones and nobody noticed for 30 years. That was a major issue raised by their lawsuit, which seems like it could have better been addressed by proceeding with the forest plan revision rather than taking 7 years to create a new travel plan first, which amends the forest plan which will soon be revised anyway. I believe the plan is to finally start work on a forest plan revision after the travel plan is done.

    Meanwhile in the ongoing GMUG NF forest plan revision process, the motorized community is trying to head-off the same issue from arising there, as the last draft of the revised plan also put a ton a major motorized routes in non-motorized areas with no direction about the effect that is intended to have. Seems to me it shouldn’t be that hard to put non-motorized recreation zones in areas that are actually non-motorized, but maybe I’m expecting too much.

  3. Here’s what the Planning Rule says: §219.15(e) “Consistency of resource plans within
    the planning area with the land management plan. Any resource plans (for example, travel management plans) developed by the Forest Service that apply to the resources or land areas
    within the planning area must be consistent with the plan components. Resource plans developed prior to plan decision must be evaluated for consistency with the plan and amended if necessary.”

    I agree that it would therefore be much better to do a forest plan before doing a travel plan, but I have seen it done the opposite way (and a forest may have to reopen the issues just decided in the travel plan to the extent they become issues with the forest plan).

    Putting “motorized routes in non-motorized areas” sounds like what a forest plan would have to do if they want to change the long-term direction in an area from motorized to non-motorized. Then they would have to make a closure decision to implement that. I would have preferred for the FS to just issue the closure orders based on the plan decision, but one of the mantras of forest planning is that forest plans do not make project decisions, purportedly because the NEPA isn’t site-specific enough. Little or no NEPA is needed to close a road or prohibit motorized use so I don’t think this is a real issue that forest plans need to avoid.

    • Jon, I don’t think “and a forest may have to reopen the issues just decided in the travel plan to the extent they become issues with the forest plan” is a great argument for the utility of forest planning.. like I have said previously “let’s reopen all the large and small decisions we’ve made previously and renegotiate them!” is not a good marketing slogan for forest planning.

      I’m not sure that “little or no NEPA is needed to prohibit motorized use” but that’s an interesting question. Would “little or no NEPA” be required to prohibit other current or proposed uses?

      • Your first point is not a problem with the Rule, but with how some units are choosing to use it. On the second point, NEPA is not needed for actions that do not have physical adverse effects, including actions that have only beneficial effects. Stopping actions that have only adverse physical effects would be beneficial. The adverse physical effect of a closure order is that of putting up a sign. (I did some extensive research on this in law school and it did not please the NEPAphiles who would like it to apply to everything.)

        • A bit of an oversimplification though. How could the FS prove an action only as beneficial effects if they did no NEPA? And there’s usually some negative effects people can argue for just about anything. For example, one big negative effect of motorized route closures is that it concentrates motorized users on fewer routes and displaces them to other areas, increasing impacts in the areas that remain open. Agency travel plans usually acknowledge this somewhere in the NEPA documents even though they typically don’t care about it. But it shows that even eliminating supposedly harmful uses can in fact have negative effects. Given the world we live in and the basic fact that everything we do has tradeoffs, I strongly doubt you could find anything that everyone would agree only has beneficial effects.

      • Two things. First, in both the case of the PSI and the ongoing GMUG revisions, there was no conscious decision to convert motorized areas to non-motorized areas. With the PSI, the stated intent of the 1983 plan was to keep all existing motorized routes open, but the maps showing the management areas were low quality and didn’t show parts of a few roads which caused them to mistakenly draw the boundaries of some non-motorized zones in the wrong place. Those errors were further compounded later when the FS attempted to input the old paper maps into modern GIS software. Pretty much everyone agrees the non-motorized zone boundaries were erroneous, but the anti-motorized groups hoped to use that error to get those routes closed.

        In the case of the GMUG revision, the FS officials in charge of planning have stated repeatedly they intend to leave the motorized route network alone and not close any existing routes. They just accidentally drew non-motorized zones over motorized routes in several of the alternatives. Considering this plan revision has already been in the works several years I don’t understand how that kind of thing happens by accident and doesn’t get caught in the review process before being released to the public, but that’s what they say happened. Hopefully they’ll correct it before the draft ROD comes out.

        So yeah, it would be one thing if the FS was making conscious decisions to turn motorized areas into non-motorized ones, but that doesn’t appear to be the case for either forest. All in all, I’ve been surprised about how much stuff in forest management happens by accident and then the FS has to double down on its mistakes because it’s in the plan now.

        Second regarding Jon’s point, NEPA is very much required to close a motorized route, at least permanently. Temporary closures don’t need NEPA but permanent ones do, and the courts have stuck down motorized closures where there was insufficient evidence in the NEPA process to justify it. I know a recent case struck down a OSV travel plan that closed a huge area to snowmobiles based on lynx habitat because the court found the FS had not produced sufficient evidence that it actually was lynx habitat. Just like everything else in NEPA, the FS still has to show its work and provide evidence to support its decisions.

        • The Forest Service requires NEPA for permanent closures; I would argue that NEPA doesn’t. There was a series of cases early in the post-NEPA years that concluded that when a military base is closed, it does not require NEPA. However, I agree that it is usually possible to come up with some arguably adverse physical impact, and some courts buy that even where the goal of the complainant is clearly to increase adverse physical impacts. Concentrating motorized use is a good example of that, but there are also cases that would say that adverse effects that depend on third party actions (maybe deciding to recreate somewhere else) are not caused by the federal action, so are not a basis for requiring NEPA.

  4. Jon, thanks so much for rounding this up!

    I’d argue that this situation could have been foreseen from the time of the discussions of the 2012 Rule.
    At the time (perhaps in this space) it was argued that we (I was employed then) should start rule-making by asking the question “have forests and stakeholders found this to be a useful process? What is their lived experience of the positives and the negatives?”

    Instead we ended up with something even more unwieldy than the 82 reg – as many of us noted at the time. Andy proposed his KISS rule. Strong statements by those running the show that “we can do more work using this rule, but it will go faster and we’ll get them done more quickly” were made, dissenters were punished, but as we have seen by these experiences, it was always wishful thinking.

    So the FS has co-evolved by not doing them, or not finishing them, because they have actual real work to do… managing the Covid-promoted hordes of recreationists, and doing fuel treatments, prescribed burning and fire suppression, fire recovery, and doing whatever planning/analysis they are required to do by litigation. And spending the new Infrastructure funds and GAOA funds as Congress intended.

    I for one support this emphasis, and if it were up to me, as I’ve said before, I’d put them all plan revisions on hold and put the emphasis on forest fire plans EIS’s including designing and finding PODs, fire for resource benefit sideboards, ignition management and so on, including decisions for prescribed fire and fuel treatments and ongoing maintenance.

    • I think I could have written this comment for you. In my opinion, the Forest Service has learned that forest plans limit their discretion, so they are happy to use any or all of the excuses you mentioned above to avoid forest planning. They could actually make project planning life easier for themselves if they could just make some decisions at the plan level to not do some things (which would not even require NEPA!), but giving up some of their authority is too high of a price to pay.

      I thought about adding to my post after “big gap in completed revisions …” –
      “… if there are ever any more revisions. They seem to have mastered the art of putting them off indefinitely, and there is no way of holding them accountable for the NFMA requirement to do them if Congress doesn’t care. This may be an omen telling me that I should consider actually going out of business, for real this time.” :-J

      • Jon, I don’t think Congress probably cares that much. They are hearing from their constituents who are concerned about a variety of things more pressing than the lack of a revised plan.

        I recall when it was decided the FS didn’t need to do the RPA Program I was working on it at the time so this made an impression) and Congress apparently didn’t really care either.

        • Congress once gave the Forest Service an appropriations rider that exempts the Forest Service from meeting the “at least every 15 years” revision requirement in NFMA if they can show they are making progress on revising plans (and it might still be there). I suppose someone could use the information above to try to make the case that they are no longer making progress, but I wouldn’t bet a lot beers on that one.

    • By the way, I haven’t followed the R3 revisions too closely, but there’s a lot of them and they seemed to have sailed through pretty smoothly, as did several R1 forests. That seems to me to be evidence of how well the 2012 Planning Rule could work under good management, with the disasters in the Blue Mountains and on the Salmon-Challis showing the other extreme – but they are the outliers.

      • Jon: I would be very interested in your take on the “disaster in the Blue Mountains.” What was it, exactly? And could it have been prevented? Thanks for any insights on this.

        • Here’s their plan revision webpage: https://www.fs.usda.gov/detailfull/r6/landmanagement/planning/?cid=fseprd584707&width=full#Documents

          The letter terminating and restarting the revision process says they’ve been at it for 15 years. I was specifically referring to this disaster of not getting the job done, not alluding to any of the particular reasons for that, because I have not been personally involved in that process. I should point out first that the Blue Mountains revision was being conducted under the 1982 forest planning regulations, so it shouldn’t be used to criticize the 2012 Rule (who knows, maybe they would have done better under the new Rule).

          Here’s the rationale given by the Forest Service in their objection resolution letter:

          “Many factors compounded to produce revised plans that would be difficult to implement,” said French. “While my review did not identify any specific violations of law, regulation, or policy, significant changes occurred over the 15-year time period of the planning process.”

          French added that a number of plan modifications occurred that were often complex and not well understood, and there were a number of changes in organizations, stakeholders, and key Forest Service staff. The Revised Plans also did not fully account for the unique social and economic needs of local communities in the area. “The resulting plans are very difficult to understand, and I am concerned that there will be ongoing confusion and disagreement as to how each Revised Plan is to be implemented,” added French.

          Here’s a post on this from when you were on your hiatus.

          At that time I said, “I think a reason for failure of past efforts could be failure of the Forest Service to make clear at the outset what the scope of the agency’s legal decision-space is. They don’t like to say “no,” but I’d argue that understanding the sideboards is a key to successful collaboration.”

          I also agree with Tony Erba’s comment: “my observation has been county commissioners do not honor the regional or national aspects of public land and can be the main source of conflict when the planning process attempts to describe the future landscape that is agreeable to people.”

          You didn’t ask about the Salmon-Challis, but here’s a previous discussion of that disaster:

          • Wow, that’s hilarious. It really must have been bad if the objection reviewing officer not only didn’t rubber stamp it as usual but actually threw the whole thing out and told them to start over, effectively calling it incomprehensible rubbish. I guess sometimes bureaucratic incompetence gets so bad even other bureaucrats can’t turn a blind eye to it anymore.

          • Thanks Jon: Much appreciated! I agree with your statement that the Forest Service failed “to make it clear at the outset” what they were trying to do, and also with French’s observation: “The resulting plans are very difficult to understand, and I am concerned that there will be ongoing confusion and disagreement as to how each Revised Plan is to be implemented.”

            This, again, is why I think planning should be conducted in Plain English with clearly stated goals and objectives. The entire process seems geared to job security for “planners,” modelers, and lawyers — and to the detriment of local people actually affected by these processes attempting “to describe the future landscape that is agreeable to people.” Trust me, very few “people” are actually ever involved or aware of these efforts. I’m on the side of the County Commissioners in that regard. They know the land and the people directly affected by these exercises.


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