FRD –0638 Attributes Comments - Content Analysis Group, LLC

FRD –0638
Sustainability. The Proposed Rule does not properly address the various multiple uses the Forest Service is required to
manage for under the Multiple Use-Sustained Yield Act. Under Sec. 219.8 (b) Social and economic sustainability it states,
"The plan must include plan components to guide the unit's contribution to social and economic sustainability…" , effectively
placing ecological sustainability above the social and economic components. The language "contribution" renders the social
and economic sustainability as secondary status and delivers the wrong message to the Forest Service about what they need
to be doing managing natural resources such as timber, mining, and grazing. The Proposed Rule needs to recognize this and
include language for plan components that maintain or restore all three elements of sustainability; ecological, social, and
economical. Alternative C is the right approach.
Role of Science. "Best available science" is identified throughout the Proposed Rules. Sec 219.3 "The responsible official shall
take into account the best available scientific information throughout the planning process" seems relatively harmless. Having
accurate, reliable and relevant information is crucial in Forest Service decision making and implementation, however, proving
what science is "best" is likely to be time consuming and of little value, but will undoubtedly lead to lawsuits. Replace
proposed Sec. 219.3 with the language in Alternative C.
Public Participation. The public participation involvement process (Sec 219.4) is quite detailed and cumbersome and
downplays the current requirement to coordinate with local government. NEPA requires that the analysis conducted be
coordinated with local governments. The call for greater "public input" weakens the existing requirement to coordinate forest
planning with local governments and their plans. Public involvement from all walks of life should be encouraged, but the local
citizens and forest users that are most directly affected by the plan should have a greater influence on the future
management decisions since they are the ones who live, work, play, and enjoy their adjacent federal lands each and every
day. Too much emphasis is placed on using "contemporary tools" to engage the public and not enough emphasis given to the
people who have to live with management decisions (or lack of) that may have great economic, social, and ecological
impacts. Public outreach should be left to the discretion of the responsible official. See Alternative C.
Process and Planning. The Proposed Rule places too much focus on planning, monitoring and assessing and not enough on
objectives and desired future conditions (Sec. 219.5, 219.6, 219.7). These planning requirements are too time consuming
and costly to implement considering the scarce resources and personnel availability. The goal of forest planning should be
timely and efficient completion and implementation of plans, not endless planning. The process is not likely to improve our
forests or make them easier to manage. We need to develop a strategy to make planning faster, simpler, less expensive as
well as staying out of the court systems. Forest plans should be completed within three years of initiation, though the average
10 year plan has taken 7-10 years to implement. The Proposed Rule adds additional levels of process that can only cause
continued damage to our national forests. Only those processes required by Congress in the NFMA should be included in the
Planning Rule.
Assessments. The establishment of a new layer of planning identified in Sec 219.6 which would be prepared apart from the
Forest Plan without NEPA analysis is a violation of the current law. This is another unnecessary process in the planning phase.
I recommend eliminating Sec 219.6 and its requirements.
Monitoring. The monitoring requirements proposed in Sec 219.12 are too complex, time consuming, and expensive; for
instance, the regulation requires biennial monitoring evaluation reports and monitoring of "measurable changes related to
climate change." Instead of focusing on "climate change and other stressors" and "carbon stored above ground" (Sec 219.1
(a) 5 (v) & (vi), the Forest Service should place emphasis on other measurable items like timber outputs, AMU's, recreational
visitor days, etc. identified in Sec 219.12(a)5. Monitoring should not be a Forest Plan requirement as it diverts more money
and people from getting management done on the ground. The biennial evaluation discussed above should be eliminated. The
language in Alternative C should be the Final Rule.
Levels of Planning. I am extremely uncomfortable with the requirement in Sec 219.2(b) that "A plan reflects the unit's
expected distinctive roles and contributions to the local area, region, and Nation, and the roles for which the unit is best
suited, considering the Agency mission, unique capabilities, and the resources and management of other lands in the vicinity."
Each forest plan produces a different mix of multiple use objectives and outputs. Identifying specific "niches", a term
commonly used today, or "distinctive roles and contributions" for each forest to fill a void in the region or national picture will
divert more attention than the tangible outputs, products, and services traditionally provided. The dynamics of each national
forest change so frequently; whether it comes from a new listed endangered species, changes due to wildfire, insect and
disease outbreaks, and mill closures, that the concept of having a distinctive role is unnecessary and quite honestly a
distraction. Having a healthy forest addressing the multiple users' interest should be the direction each forest plan takes into
account. Having a "distinctive role or contribution" assigned should not become required content of the plan. Each national
forest needs to provide the resources and services that are desired at the local level. I believe that 219.2(b), 219.6(b)(3),
and 219.7(e)(ii) requirements should be removed from the proposed rule in its entirety.
Timber Requirements based on NFMA. The Proposed Rule needs to address and re-emphasize timber harvest on suitable
lands providing forest products industry with dependable, predictable, sustained volumes. Timber harvest is the most cost
effective tool to move or maintain the desired future conditions set out in the objectives of a forest plan. Timber harvest
typically has been used to achieve other ecological benefits and multiple use benefits for purposes other than timber