Notice of Intent to develop National Forest Planning Regulations

The opportunity to comment on the proposal to develop a new planning regulation for the National Forests is appreciated. My comments will respond to questions in order asked under the listed substantial principles. Responses will be kept as  brief as possible, but will attempt to make what I believe are key points for your consideration.

My comments are based upon a lifetime involvement with the national forests and Forest Service with 33 years of full time service, six seasons as a temporary employee in four regions and 17 years of voluntary work for the national forests. My professional training is in forest management.

I should like to offer several general comments concerning the planning regulation effort before responding to specific questions.

In my view a basic question that must be resolved before any regulation is developed is: What are the forests to be managed for? Are they to be managed for the sustained production of renewable resources to meet public needs, or have the original enabling laws, primarily the Organic Act of 1897 and the Multiple Use Sustained Yield Act of 1960 been shelved in favor of other management directions?  And who made the decision to deviate form the original management direction? I don't consider this an idle question. In the past decade I have heard increasing confusion at the regional, forest and district level as to the priority and direction for forest management activities. I have reviewed several forest plans and plan amendments over the past several years that indicate sustained yield of renewable resources is no longer a priority.

For example, is advocating restoring the forests to pre-settlement conditions a Forest Service official direction? This direction is seen in various Forest Service writings and heard in presentations. If this is official policy and not just an intellectual consideration, who made that commitment of the national forests, and how does it square with the legislated direction for management of the forests?

In my view there is no rational reason to develop a new planning rule until leadership can reaffirm the mission of the national forests, or clearly articulate a new management direction as prescribed by Congress.

The need for restoration and conservation:

The biggest threats to forest and grasslands: As mentioned above, I believe the lack of a clear understanding by the people of the Forest Service as to the management mission, and a lack of public awareness of the national forests management mission is a critical issue needing resolution.

There is also the continuing "guerilla warfare" by individuals and groups to stop human management activity in the forests, especially activities involving the manipulation of vegetation for forest health, human needs/desires and economic benefits. Given the federal deficit, and economic conditions of forest-impacted communities, the potential for generating income from the forests should not be ignored.  It is appropriate, in my view, to once again exam income producing forest management activities.

The use of the Equal Access to Justice Act and the Appeals Regulations have been abused, in my opinion, by some anti management groups and individuals to use legal minutiae to stop management activities without any consideration of the consequences to the natural resources or the public.  If this issue is not resolved, I see no reason to spend millions of dollars developing a planning regulation that will be stymied by a minority of people who have little concern for the future of the forests or people dependent upon their resources. 

How to define Restoration? I define it as silvicultural prescriptions utilizing a combination of mechanical systems such as loggings and prescribed fire to structure a forest that will resist wildfire, insect and disease attacks, maintain a defined wildlife population, provide for human use of the forests, while also meeting the needs for off site resources such as water, wood, appropriate foods, clean air and appropriate carbon storage in perpetuity.

How can the planning rule foster restoration? By clarifying the mission of the national forests and by clearly stating the role the national forests are to play in producing renewable resources for the nation's well being. I believe it is critical for the planning rule to establish the capacity for production of renewable resources for public use such as acre feet of water, cubic feet of cellulose, livestock and recreation use, and to establish the limits of output to preserve the forest's basic resource, soil. This is not an easy task, but it is necessary in this time of expanding population and resource demand to establish limits for what the forests can produce.

What kind of conservation effort can enhance ecosystem?.....

The biggest and most important action to enhance the forests is to find a way to end, or at least reduce the impact, of the continuing "30 Year War" over how to manage the land. The resource damage from this continuing battle and stalled management is staggering as more and more land is subjected to the ravages of wildfire, insect attacks, diseases and human abuse. My personal "cuff records" of national forest land degraded by these activities in the last decade is approaching 20 million acres. And there is little the Forest Service can do to reverse this trend when it is unable to do effective management because of being treated as a political football and, like the other federal land agencies, last in line for budget priorities.

A specific action would be an aggressive public information program to help the public and political leaders understand these lands they take for granted are the country's lifeline. If they are degraded to the point they can no longer provide people with basic natural resources, the country will be irreversibly weakened as has happened to countries of the Mediterranean and Europe.

Proactively Address Climate: My expertise in the area of climate change is limited, and what I think I know is confused by the continuing scientific squabbles carried by the media. However, if the goal is to reduce carbon and increase oxygen production then I suggest the Forest Service renew its efforts to manage forests with sound science as mentioned in the section about restoration forestry. The other recommendation is to control wildfire, not encourage it. Current fire policy allowing wildfire use for management is not the way to reduce costs, damage or restore forests. Those of us supporting the use of prescribed fire as a management tool are appalled at the current activities of some forest leaders allowing wildfires to burn the land, and causing great damage to resources, local economies, public health, air quality and waste of the public's money.

Restoration of Watershed Health

Standards to address watershed health and what would they look like:  I would support including updated watershed health standards to emphasize the importance of water from the forests. What would they look like? I suspect that dusting off and updating watershed management standards developed over the past several decades, many of which are in FS archives, would be a good starting point.

Should the agency be held accountable for actions on its NFS lands or take into account water factor outside of Agency control?  

I am not sure I fully understand this question. I would support agency accountability for water resources on the forests. However, if it implies FS getting involved in some type of regulatory role on other ownership, my response is no. The FS has all it can handle to take care of its national forest responsibilities. And at the moment, would be like the pot calling the kettle black to be pointing at problems on other ownerships. Given the amount of watershed damage done by wildfires on national forests and adjacent lands in the past decade it would also be somewhat hypocritical.

Planning in the context of watersheds. I think the concept is worth considering, but I have no experience in this area to allow me to make a recommendation.

Diversity of Species:

I would suggest the discussion of this subject include an intensive review of what diversity of species means from a true scientific standpoint versus an ideological discussion.  My sense is some of the activist groups are using diversity of species as a "shill" to stop land management activities.

NFS Lands and their Contributions to Rural Economies

Sustainability of NFS Lands and reflect interdependency of social, economic and ecological systems.  How to write this is the problem, not the precedence or the legal authority to work with communities to harmonize economic and ecological considerations. Forest related communities are hurting for living wage jobs through out the National Forest System, and the Service should be doing everything possible to help change the situation. 

The issue, as I see it, is to emphasize in the planning rule the historic relationship of forests and communities. In my volunteer work I have contact with people in national forest influenced communities in four western states. Most of my contacts express frustration with their relationships with the Forest Service, especially in the area of economic development. Most of the frustration is because of " Byzantine"paperwork, rather than with the Forest Rangers. 

However, there is an increasing communications and cultural problem in many rural communities as more people in the FS come from urban backgrounds rather than rural. Even in communities where communications and culture are not an issue, the cumbersome management systems are an issue for the ranger district people and communities a like.

How can plans guide FS in achieve natural resource goals in a way that is compatible with vibrant rural and national economics?

This sounds too simple, but good communications is the key. The Forest Service has to have knowledgeable people willing to spend time listening, analyzing and responding to local issues using good information about the forests and honest responses to explain the agency's limitations to do things.  

Process Principles For a New Rule:

Effective and Proactive Collaboration:  What seems to be working best in the Northwest is a combination of informal meetings, field trips to discuss management issues and look at the land  and projects that are the subject of discussion.

Sustainable Northwest, which is a non-profit dedicated to rural communities and good resource conservation, has been a leader in helping the Forest Service and other agencies build relationships and processes to reach good management decisions that help people and the land. I would suggest it be contacted for detailed information about its processes and how it works with agencies and the public: http://www.sustainablenorthwest.org/

For the Forest Service to work effectively with publics requires forest officers understand the overall mission of the organization, know what their decision latitude is, know their subject, be good listeners, speak in non bureaucratic language, take the time to know their audience and tell the truth. While many forest officers do this effectively, there are indicators their numbers are decreasing, as more and more time has to be spent in the office and not in the communities or on the land.

All Lands Approach: I would definitely support closer coordination and cooperation with planning efforts for lands adjacent to national forests and a certain amount of FS planning latitude to encourage harmony with lands outside national forests, but with a condition, the primary reasons for the existence of the forests is not compromised.

The political sensitivity of federal relationships with local governments has always been a "hot button" issue. I do not support planning guidance that gives national forest planning a meddling ability with land use outside of the forests.

Plans Based Upon The Latest Planning Science To Achieve Best Decision.

I have no idea how the procedural issues are to be solved. However, I would suggest that ultimately the plans that get approved and are workable will be the ones that best meet public expectations and are actively supported by the public, not the plans that are technical correct. The public makes decisions based upon emotions, not technical fact. Hopefully plans with public support will also have good science to support them.

 
John F. Marker,  Forester(ret.)
Sentinel Orchards
6681 Highway 35
MT. Hood, OR 97041
541 352 6154