A Few Questions about "Strategic and Aspirational" Forest Plans Martin Nie

The other day I had a chance to comment on the forest planning process for the Western Montana Forest Planning Zone. It provided me a chance to think through my frustrations, stemming from the fact that the US Forest Service is only providing direction that is "strategic and aspirational" (often vague in other words), but asking the public to focus on particulars. There is a lot to like in some of these plans. But the process, as I see it, runs the risk of further diminishing public trust in the agency.

Here is my full comment:

To Whom it May Concern:

Thank you for the opportunity to participate in the forest planning process. There is a lot to like in all three plans, but rather than go through the particulars of each, I would rather ask a few general questions.

First off, I find it a bit frustrating to ask the public to provide specifics and details in providing public comment, when there is no such specificity in the draft plans. It seems that the USFS is able to provide direction that is merely "strategic and aspirational" (often vague in other words) in nature, but the public is admonished to focus on the particulars. I certainly would like to do such a thing, but only if the agency does so first.

It would be helpful to contrast the original forest plan with its proposed revision. What's changed and stayed the same?

I would like to learn more about the binding nature of the forest plan, and how it will be used as a guiding document in the future. I understand how the 2005 planning regulations are different from the 1982 regulations, so no need to respond in that direction. But how exactly will responsible officials use the plan to make and base future decisions? I certainly hope that officials will not say that various matters have already been resolved at the plan level, because many issues have clearly not been resolved—nor have they gone through NEPA's EIS process.

It is also important to clarify how the forest plan revisions interact with all of the other recent regulatory changes to forest management (e.g., the roadless rule, travel management rule, Healthy Forests Initiative, etc.). The plan seems like the best place to explain the decision making environment to the public. How does it all fit together?

I hope that you can provide more detailed information about the future decision making process under the 2005 planning regulations, and how decisions will be tiered to the plan in the future. If any meaningful "decisions" have been made in the plan, with significant environmental effects, then why was NEPA not used? The 2005 planning regulations will fail if the agency plays a type of shell game wherein managers say that project decisions have already been resolved at the plan level, and when plan level direction is challenged, they say that such decisions will be made at the project level. That would not be a good way of building trust and public confidence in the planning process.

Thankfully, the 2005 regulations talk a lot about monitoring. But how exactly will monitoring be done and how will it be paid for? What will happen to various projects and activities if monitoring money, as usual, is not forthcoming?

Most importantly, I’m very frustrated by the agency's refusal to look at the big picture when it comes to forest management. The rapid population growth in the region, coupled with decentralized development and rampant subdivision, should give the agency much to consider (see e.g., RPA Assessment documenting this growth and development). Not so long ago, National Forests in the region lowered their timber harvests because of the liquidation taking place on corporate timber lands. At what point will these National Forests consider what is happening on these private lands, from the amount of timber being cut to real estate transactions?

From Plum Creek divestment to sprawl in the Bitterroot Valley, intermixed public-private lands are a major concern. For all of the talk and rhetoric about ecosystem management, when and where will the agency address these intermixed ownership issues? Will they be considered in future cumulative effects analyses? How will future private lands development be considered and anticipated in the future? NEPA regulations require that agencies consider cumulative impacts in their decision making, defined as "the incremental impact of past, present, and reasonably foreseeable future action regardless of what agency (Federal or non-Federal) or person undertakes such other actions." (40 C.F.R. §1508.7). In short, it is necessary for the agency to seriously consider what is happening on nearby private lands, and modify management accordingly. This was clearly not done at the forest plan level, so when and how will such cumulative effects be considered in the future?

Thank you for your consideration.

Sincerely,

Martin Nie
Missoula, MT