Here’s a little more (added to this) on the Nez Perce-Clearwater revised forest plan. Mostly I wanted to share this graphic of how they are “reaching out” to the public. They ask an important question: “What can you do?” The obvious meaning seems to be what can you do about the forest plan, and the answer for most people is “nothing.” They say that the plan is in the objection period, but don’t tell us that the only people who can participate are those who have already done so. They invite us to “learn more,” about this nearly-done deal, which they misleading label as a “draft Forest Management Plan.” (At the draft EIS stage, the Planning Rule refers to it as the “proposed plan,” and at the objection stage it is just the “plan.) While they have must have included similar outreach at earlier stages in the process, for those encountering this for the first time, it’s almost disingenuous.
But while I’m at it , there was also another article recently that focused on the State Line Trail, which runs through the Hoodoo Recommended Wilderness Area in the Great Burn between Idaho and Montana. (I’ve been there but haven’t been directly involved in the planning, so know only what I read.)
“It used to be a marquee backcountry ride for mountain bikers, too. That ended in 2012 when the Nez Perce-Clearwater National Forest, which controls the Idaho side of the trail, approved a new travel management plan that barred bicycles from its portion of the trail. On the Montana side, the Lolo National Forest has long allowed bicycles on the trail.”
A new revised forest plan for the Nez Perce-Clearwater could change that, by determining that bicycles are an appropriate use in the portions of Idaho around the trail, which would mirror access on the Montana side. If the changes in the plan are finalized, possibly later this year, that would set the stage for the Nez Perce-Clearwater to revisit and alter its 2012 travel plan to formally re-allow bicycles on the trail.”
The rationale behind these changes, according to the forest supervisor, don’t seem to include consistency (more on that later): “We have these types of very primitive, amazing, out in the middle of nowhere experiences that you can get to no matter what your matter of conveyance is.” No apparent agency recognition that the conveyance is part of the experience for those who encounter it, and for some it makes it feel unpleasantly more like “somewhere.”
One of the supporters added, “It’s a small segment of the sport that this is going to appeal to,” he said. “It’s not that close to Missoula. It’s hard. The trail’s in deteriorating condition. But this opportunity is, for certain people, something they really, really want.” That small segment of certain people (who apparently want to deteriorate the trail even more) must be pretty special to get this kind of personalized attention.
“Some mountain bikers are drawn to remote, rugged, and challenging backcountry trail experiences on wild and raw landscapes,” a group of supporters commented. “These are places where it is uncommon to see other trail users, and where riding requires a high level of physical fitness and technical skill — in many cases it involves pushing a bike instead of riding at all.” That would be like hiking, wouldn’t it? So, it’s not like closing the area to this use would exclude these physically fit people from these wild and raw landscapes. I’ll admit that I don’t understand the rationale of wanting to experience a “wild and raw landscape” on a machine, which (to me) reduces the rawness and wildness of the experience.
The aura of personal opinion and politics behind these wilderness debates is why I focus my energy on other things. Here there is also talk about snowmobiles and mountain goats, and why mountain goats are treated differently in adjacent national forests.
As for the effects of snowmobiles on mountain goats, the Idaho Department of Fish and Game blamed them for disappearance from one part of this area, but the founder of the Backcountry Sled Patriots says otherwise (citing other research). The Lolo National Forest cited the negative effect of motorized over-snow machines as reason for designating them a species of conservation concern. The Nez Perce-Clearwater is not concerned about mountain goats. The Forest Service minimizes the importance of the areas at issue to mountain goats (though they apparently used to be some places they are not found now).
About the Lolo, Marten, the regional forester, who determines which species are SCC, wrote:
“Compared to other ungulates, the species appears particularly sensitive to human disturbance. Motorized and non-motorized recreation, as well as aerial vehicles, are well documented to affect the species, particularly during winter and kid-rearing season, with impacts ranging from permanent or seasonal (displacement), to changes in behavior and productivity.”
The regional director for ecosystem planning said that she didn’t see the different listing decisions as being in conflict with each other. Rather, she said, they reflect that mountains goats are doing better overall on one forest than the other. This may be technically/legally possible since SCC are based on persistence in an individual forest plan area. However, it doesn’t make a lot of sense to me to manage one national forest to increase the risk to, and to contribute to SCC designation on, another forest. Moreover, the Planning Handbook states that “species of conservation concern in adjoining National Forest System plan areas” should be considered by the regional forester in making this designation. This all has kind of an arbitrary ring to it.
As for consistent management across national forest boundaries, The Nez Perce-Clearwater plans to change the shape of the Hoodoo RWA to remove the key snowmobile areas from it, so that boundary between the national forests becomes a boundary for the RWA. The Forest Service points out that the plan revision process in the hands of forest supervisors, not the regional office. The forest supervisors disclaim any obligation for consistency, and even suggest that travel planning may produce a different result, and “forest plans and travel management plans are continually updated and amended” so they could change again. That doesn’t square well with history. The every-third-of-a-century Forest plan revision should be the time to get it right. Even if the regional forester doesn’t want to say what the plans must do, that person could simply order them to be consistent along this boundary.
Arbitrary is just the start. The Nez Perce-Clearwater also said that grizzly bears outside of designated Wilderness are “socially unacceptable.” Based on results from a credible national polling firm? Nope. Local timber interests.
I hope they did a good job of explaining the effects if they intend to deliberately discourage the use of federal lands by grizzly bears. Discouraging bears may be acceptable on private lands, but ESA says federal agencies “shall, in consultation with and with the assistance of the Secretary, utilize their authorities in furtherance of the purposes of this Act by carrying out programs for the conservation of endangered species and threatened species listed pursuant to section 4 of this Act.” And the 2012 Planning Rule requires forest plans to contribute to recovery of listed species. I’m not sure where they said this, but it sounds like they are digging themselves a legal hole.
As Ninemile District Ranger (Lolo NF) for 10 years (1988-1998), we witnessed snowmobiles routinely violating the closures on the Montana side. The NPC plan will dramatically worsen violations of closures. The only way to have a decent chance of containing snowmobiles is at highly visible trailheads. Signs on some ridgetops never have nor never will be effective.
Winter mountain goat habitat is normally very restricted to isolated windblown ridges and terrain too steep to hold snow. In such restricted areas, they are extremely vulnerable to snowmobile disturbance forcing them to leave these tiny areas into deep snows, expending unsustainable energy and extreme risk to immature goats. New incredibly powerful snowmobiles can and do high mark into the heart of snowmobile habitats.
And it seems inconceivable to me that the NPC Forest would create such a monstrosity and that the Region would stand by and let it happen. Leadership vacuum.
I have not worked for the USFS. My federal service career has mostly been within DOI. Time and again, the way I have observed it working in DOI is that if HQ tells a RO what to do, they listen and do it. If the RO tells the field what to do, they listen and do it. My perspective from the outside looking in on the USFS is that Rangers and Forest Supervisors have a great deal of autonomy and there is not a lot of top down control over them (at least compared to DOI). Is that right? Can one of you USFS folks on here explain the level of control and autonomy line officers have in the USFS? Is my observation right?
Anon, that was my experience in co-leading a joint review with a combined FS/BLM unit during ServiceFirst with dual delegation. At the end of the day, I couldn’t write the review report unless the person appointed by the Supe agreed with everything in it. Which was so frustrating I assigned it to a staffperson of mine, who couldn’t/didn’t finish it either. The BLM side finished their review readily.
I also recall when I worked in R&D we did reviews, but at one point we had to change “recommendations” to “suggestions” because recommendations was thought to be too strong a word.
I’ve written about this before on TSW and maybe more people can give their own experiences.
https://forestpolicypub.com/2019/08/19/the-cult-of-the-line-officer-i-line-officers-in-the-forest-service-and-their-cultural-importance/
https://forestpolicypub.com/2020/07/03/the-cult-of-the-line-officer-ii-the-complicated-nature-of-forest-service-decision-making/
Once when I was the Region 2 Planning Director, I tried to get coordination across plans in neighboring regions (!), but that did not go well. The other regional planning director wasn’t interested.. so end of story. Point being it’s sometimes staff and not line that doesn’t want to coordinate.
Then there are stories like this one – the old “directed reassignment.” https://hungryhorsenews.com/news/2023/dec/06/ousted-spotted-bear-district-ranger-speaks-out/
I should point out that forest supervisors overstate their authority when they claim the revision process is under their control. The regional forester is the reviewing officer for the objection process, and there is nothing in the objection process regulations that prevents the regional forester from making any changes requested by an objector. And an objection can simply be any statement of “how the proposed plan decision may be improved.” Of course, that is only on paper, and (in my experience as well), the agency culture discourages much oversight.
This all was a major internal issue as the Planning Rule was being developed. As part of a compromise, the Planning Rule codifies national oversight of the forest planning process (which the agency seems loathe to use). I think the regional forester retaining the authority to designate species of conservation concern was also part of this discussion.
Many good points, thanks
Jon – care to comment on an 11+ year timeline? it is disingenuous and shows your obvious bias that you ignore this most blatant agency failure. 2012 planning rule is a disgrace. But you are worried about a hypothetical party who would take interest in a notice upon seeing it for the first time ? I think you missed the real story here.
I’m not sure what you think my bias is, but yes, another story here could be why the Nez Perce-Clearwater couldn’t get this done in a reasonable amount of time. This could be the worst example of managing a forest plan revision process. You can look at the timeline Sharon included in the first post on this (linked at the beginning here) and ask why it took them so long for each of these steps compared to other forests. Whenever I checked in on what they were doing, I was not reassured that they knew what they were doing. I think the timelines envisioned with the 2012 Planning Rule were optimistic, but the NP-C cluster-foolishness is not an indictment of the Planning Rule.
Another view could be that the Forest successfully avoided doing a Plan Revision. As I’ve pointed out that can be seen as unnecessary reopening of Pandora’s Box, and to some degree a waste of resources and employee time that is fully occupied with other important work. I know forest staffs who would see “plan revision avoidance” as a good thing. Maybe they had a Supe who wanted to do it and lost interest when that Supe departed.. or their funding was moved.. or .. there are lots of possible reasons. As to the 2012 Rule, it made things more complicated (I think Jon will agree with me here), so in some way that may have contributed to Revision Avoidance.
Now I’ve also seen Forest take a long time seemingly because they wanted planning $ for as long as they would be given out.. and when the Region might ask “why so long?” the answer would be “involvement and collaboration takes time.” So I’ve seen many permutations..
I think we are agreeing that if a national forest does not try to avoid revising its plan, it could get it done in a reasonable time. I won’t agree that the 2012 Planning Rule made things more complicated than the 1982 Planning Rule.
Just to pick random requirements, the Assessments to me seem more complex than under the 82.. which I don’t think required them?
So what is the shortest time any (complex western) forest has completed a 2012 plan?
https://www.fs.usda.gov/detail/hlcnf/landmanagement/planning/?cid=stelprd3847358.
It would be interesting to compile this for all revisions so we could answer that question, but here is a sample of 1. I was hired to work on the first Helena NF plan (already ongoing) in 1980 and its was approved in 1986. I think that was pretty typical. Here is the timetable for the Helena-Lewis and Clark revision. It shows less than 5 years from scoping to decision (the “official” part of the revision process that was sometimes projected as a 3-year process). Even if you add the assessment, the timelines for the two plans are pretty comparable. (The 1982 regulations required the Analysis of the Management Situation, which was focused on FORPLAN modeling, which was complex and time-consuming, as well as modeled and non-modeled supply/demand analysis.)
I agree it would be interesting to collect that information. It’s kind of surprising it’s not out there somewhere collected by someone.