Analysis of Plan Proposal

Click a topic to go directly to that section

ACCESS 

 ECOSYSTEM MANAGEMENT 

 FOREST AND PRIVATE INTERFACE 

 FOREST PRODUCTS 

RECREATION 

 WILDERNESS AND ROADLESS

SUMMARY

Other Pages

Forest Planning Regulations

Critique of Amendment 19   the road rip rules

Public Input to Forest Planning

The first paragraph of the Proposed Action sets the tone of an obvious bias found throughout the document when you define Forest Plans in terms of application of the National Strategic Plan, and other National and Regional guidance with no mention of State, local and Tribal coordination needs as required by both the National Forest Management Act (NFMA) and the National Environmental Policy Act (NEPA). There is no indication that any coordination with other public plans has been undertaken as required by 36CFR219.7. The issuing of a "Proposed Action" predicting the outcome of the planning process before there has been any public participation even in identification of public issues (36CFR219.12(b)) expresses a strong bias that indicates the Forest Plan revisions are not being pursued in good faith as required by NFMA. Our detailed comments that follow will prove the revision process is biased and not being conducted in good faith.

Your plan to combine 3 forests into one planning process and the associated public participation process so far has not complied with the requirements of NFMA and implementing regulations (36CFR219). Nothing in NFMA or in the implementing regulations indicate the planning process is to be conducted by anyone other than a Forest Supervisor directing and supervising an interdisciplinary team to prepare the proper planning criteria, inventories, analyses, forest plan and environmental impact statement for a single unit under that supervisors’ responsibility (36CFR219.12). MFMU has previously commented on this in our February 14, 2004 letter to Regional Forester Abigail Kimbell and in an April 6 meeting with members of the planning team. It is our understanding that the Flathead Legislative delegation will be conducting public workshops to facilitate public input. MFMU will support that effort. The lack of public meetings on the Flathead is just one example of the inequities involved in a three forest scheme that does not account for the unique situations and custom and culture of each National Forest Unit.

"While OHV use has increased, the amount of motorized trails for OHV use has not kept up with the demand." This statement is truly an understatement and masks the cause of much public dissatisfaction with current Forest Service management. What has actually happened is that the ‘85-‘86 Forest Plans have been illegally revised through many cumulative and significant amendments misrepresented to the public as insignificant amendments. Massive OHV and other motorized recreation, road obliteration, closures of areas, roads, and trails in a piecemeal chain of events over the past 10 years has completely changed the recreation opportunities and vegetation management planned and disclosed in the original integrated Forest Plans. Every National Forest failed to evaluate the cumulative effects and changed conditions that should have triggered Forest Plan revision as required by NFMA. Those changes have been particularly damaging to multiple use public access and recreation opportunities as admitted in your finding.

Action AM-F1-A1: Identifying "areas with the highest potential for OHV use" is inadequate and does not comply with 36CFR219.7, 219.12, and 219.21. There must be a complete analysis of lands available and capable for motorized use as well as analysis of inventory and monitoring data, and coordination with other Federal agencies, state and local governments, and Indian tribes. Criteria must be developed and made available for public review for how motorized recreation will help achieve maximizing net public benefits in the analysis and decision making process.

Finding AM-F2:

The inventory data and your evaluation of that data to support this finding must be disclosed as required by 36CFR219.12(d). Contrary to the unsupported finding that "there is a need for consistent direction across forest boundaries", there is nothing in NFMA or the implementing regulations that require consistency. In fact, RPA and NFMA were passed by Congress because of the failure of "top down" management and the paramount need to consider local resource conditions, and local social and economic needs, custom and culture. We consider the Regional Foresters’ OHV amendment illegal and we have filed a lawsuit to see if we are correct.

Action AM-F2-A1: You cannot control, block or otherwise interfere with user built routes that belong to the public as granted by Revised Statute (RS) 2477. The proper planning action that should be undertaken is for each Forest to work cooperatively with other Federal Agencies, State and local governments, Tribes and affected public to determine which routes on National Forest System lands are RS2477 public Rights Of Way.

Action AM-F2-A2: A statement that "We propose that cross-country wheeled motorized travel would continue to be prohibited." is another illegal, biased, totally inappropriate unsupported pre-analysis and pre-decisional statement supporting our evaluation of bias in the general planning process under INTRODUCTION section above.

Action AM-F2-A3: The Flathead and Lolo Snowmobile Amendments cited are more examples of the illegal revision of Forest Plans through cumulative significant amendments improperly portrayed to the public as insignificant. As we discussed under the Finding F-2 above carrying illegal amendments into the revision will not stand and there is no need or requirement to "remedy inconsistencies across jurisdictional boundaries."

Finding AM-F3:

Roads are not a stand alone issue. The need for roads is primarily tied to a decision of what potentially suitable timberlands will be economically managed as a regulated forest for long term sustained yield. Roads and their maintenance costs should be integrated into the economic analysis of alternatives for determining which timberlands should be managed as suitable for timber production and harvest. There should be no stand alone functional "roads analysis" as an issue separate from the long term land use decision. Instead, roads and their maintenance costs should be integrated into the land use alternatives as required by NFMA (16USC1604.(a) and (36CFR219.1).

The Forest Service has illegally implemented alleged "insignificant amendments" which violated both NFMA and NEPA by deciding to destroy roads in suitable timberlands without an integrated revision of the Forest Plan as required by law. Access to thousands of acres of lands has been removed. These site-specific decisions not to protect and manage the suitable timberlands to produce the public benefits as disclosed in the original integrated Forest plan is not only a violation of law but also of the public trust. No other Forest Service actions have been cumulatively more harmful to the environment, natural resources, the economy and local custom and culture. The current MFMU lawsuit will determine if our argument is correct.

Reducing roads "…to a level that can be maintained with current budgets." is not a viable multiple use alternative because the level of commercial timber harvest has been so insignificant that no significant funds are being generated to maintain the roads required by the Forest Plan. No "Roads Analysis" without being integrated into the timber management yield and economic analysis will provide a workable solution. Each National Forest must develop the criteria for analyzing the road needs and associated economics of a long term timber management program and harvest of commercial timber. Current budgets are not a valid constraint for formulating long range plans (36CFR219.(e)(1) and 219.12(f).

Access management is a major public issue because the majority of the public disagree with the way the Forest Service has been doing it under current plans. The lack of timber sales has resulted in no money coming in for maintenance. The more roads that are destroyed, the less opportunity there is to for timber sales and forest protection. Current management is a death spiral for the forest, the Forest Service, the resources, and the local economy. If a forest is actively protected and managed, there will be adequate revenues for road maintenance.

Action AM-F#-A1: As stated above, a proposal "…to continue the overall trend of decreasing the amount of roads within the National Forest …to a level that can be maintained…" based on a functional "Roads Analysis" and current road maintenance budgets is not a viable alternative and will not comply with statutory requirements of NFMA.

If your statement about mountain bike use causing "…user conflicts and resource damage…" is true, then it should have been managed as required on a site-specific basis. Failure to implement existing Forest Plan standards and existing laws and regulations in not a valid reason to implement massive closures to major recreational uses as illustrated by the illegal Regional Foresters’ OHV Amendments and now this ridiculous proposal to restrict pedal bikes. Local unique problems such as this do not define a major public issue that will affect formulation of alternatives on millions of acres across three National Forests. National Forest System lands are mandated by the MUSYA to be available and used as multiple use lands. You must make your evaluation of inventories of resource damage and other problems created by OHV, bicycle, and snowmobile use and your maps of areas potentially suitable or areas not capable of mechanical or motorized use available at each Forest Supervisor’s office (36CFR219.10(h) and 219.12(d)). The inventory and monitoring data should be explained within the public geographic working groups.

Action AM-F4-A1: As discussed above the proposal to limit bicycles to designated routes is a violation of NFMA and MUSYA, is not a major public issue, should not affect formulation of alternative land uses, and is not supported by credible data and inventories.

Minimum criteria for grizzly bear security requirements must be developed. If they determine significant constraints on formulation of land use alternatives, then the prescription must become an allocation at some minimal level from which legal alternatives can be formulated.

Modifications made to current Forest Plans through amendments alleged to be insignificant has in practice turned out to be major forest plan revision. Many folks believe that the US Forest Service has turned the management of the National Forests over to the US Fish and Wildlife Service. Endangered species management is a wild card that appears to eliminates any possibility of predictability of public benefits on National Forests.

Perhaps this should be the number one issue to drive the development of alternatives for analyzing predictability for uses and outputs from the National Forest, especially the Flathead National Forest. If the requirements for the various listed species means that no multiple use of Federal Lands can occur, then be honest and tell the public and Congress the portions of the National Forests are required to be allocated to recover the various listed species and where, if any, land is left for multiple use. Over 18 years ago, the Flathead allocated a sizeable portion of land in the North Fork to emphasize Grizzly Bear Management and Research. To our knowledge no active management of any kind has taken place and apparently the model is to keep as many people out as possible and eventually for it to burn. If that is the "best science" for grizzly bear management, then that is the management that should be described and allocated as necessary to recover the bear and people will then know what to expect.

Current grizzly bear access management standards are illegal because they effectively canceled the allocated land use or replaced the prescribed land use without proper public disclosure. Critical grizzly security areas that cannot have road access to implement forest protection and management because of grizzly bear requirements must be disclosed at the beginning of the planning process. The grizzly bear habitat minimum management requirements (the basis or floor from which legal alternatives can be formulated) for grizzly bear habitat must be defined, analyzed, and the costs disclosed in Analysis of the Management situation as required by 36CFR219.12.

This issue may be the most compelling issue that illustrates the folly of trying to blend three National Forest, each with distinctly different existing conditions and potential grizzly habitat into one analysis and EIS process. The grizzly habitat constraints as they affect land use alternatives are vastly different on each National Forest, they must be addressed as required by law. The AMS and the Proposed Action are totally inadequate in defining this issue in a way the public can understand and offer reasoned comment.

Action AM-F5-A1: The proposal to develop grizzly bear security to "better integrate social concerns with recovery needs of the grizzly bear." is only one facet of the issue. The action should include the need to better integrate the costs, outputs and effects of management of all grizzly habitat component requirements into minimum management requirements and alternative land use prescriptions, so the environmental, economic and social effects can be analyzed and tradeoffs evaluated by the public and responsible official.

TOP

If "…ecosystem management has become the overall scientific framework for implementing multiple use management…" how has it made the National Forests better off today than 10 years ago? The public does not understand what ecosystem management means to them. If "ecosystem management" means the forests will continue to be closed to public access, and will continue the downward spiral in forest health and explosion of catastrophic fires that has occurred in the last 10 years, then you will not find many people who think the National Forests have been managed in a "sustainable" way that enhances "viability" of anything in the last decade. You must explain what principles of ecosystem management implementation to date has accomplished in terms of natural resource and public benefits.

NFMA’s implementing regulations require the planning process, analysis, and evaluation to be structured in a way so the Forest Plan decision will maximize net public benefits (36CFR219.1(a), 219.3, and 219.12 (c). We find the lack of commitment or reference to any effort to produce public benefits in this issue and throughout the Proposed Action document another glaring example of bias.

There is only one natural resource component of the "ecosystem" that your agency has any direct ability to manage and that is the timber resource. All other components (climate, topography, soil, water, wildlife, fire, etc.) you have no direct control except through manipulation of the vegetation (fuel) density, age class structure, composition, and continuity. The timber resource is mandated by the Organic Act, the MUSYA, and NFMA to be managed to produce benefits for all other resource and forest protection issues on a sustained yield basis. Not only can the timber management produce and protect non-timber resources, it can generate the revenue to pay for the timber and non-timber benefits with excess money left for sale area improvements, support of local roads and schools, and the US Treasury (Fiedler, et.al., 2001. A Strategic Assessment of Fire Hazard in Montana, U. of MT.). Ecosystem management, (if that means there is going to be active management) has to be implemented through a cost effective timber management program if it will ever be successful. Economics and public benefits has to be considered in ecosystem management. The total lack of reference in this section to a sustained timber harvest program as a cost effective tool to achieve long term ecosystem management goals and public benefits again illustrates the bias of the proposed action relative to timber management and forest access.

ActionEM-F-1-A1:   A proposal to use "sustainability and viability ecosystem management principles...to provide for human needs and to conserve species for present and future generations." is a great string of buzzwords that mean nothing in terms of comments. Unless the action defines what or how the sustainability or viability is going to be achieved there really is no way to evaluate what, if anything, is being proposed.

The current state of forest health and wildfire hazard is not just the result of "the exclusion of fire". The statement is misleading. Current conditions and fire and forest health threat is equally a lack of access and lack of effective active management. There is no analysis of fire and timber harvest monitoring data along with recent timber inventories compared to inventories on which current Plans are based as required by NFMA (36CFR219.12(c-e). The obvious relationship of the increase in catastrophic fires as access and timber harvest has declined over the years is common knowledge, has spawned the passage of the Healthy Forest Act and a National Fire Plan, yet is ignored in the Proposed Action. The lack of analysis of timber harvest as an agent of change and the role it has played shaping the current ecosystem condition along with analysis of fire and related access and suppression costs is additional proof of overt bias in the document and does not comply with NFMA (36CFR219).

Action EM-F2-A1:  The blanket proposal to "…expand the use of management ignited fire to include wilderness and recommended wilderness areas, and increase the area where natural ignitions are managed for resource benefits." is misleading and irresponsible. Current wilderness management fire plans for the Great Bear-Bob Marshall-Scapegoat already provides for management ignited fires. The Flathead National Forest Plan also provided prescribed burning direction to be developed for "…other similar areas that are designated as wilderness or unroaded dispersed recreation ."(Flathead LRMP, Ch. II, Forest Wide Management Direction, O. Fire Management, Item (3)).

Once again the authors of the Proposed Action exhibit a biased intent to discredit current plans, when the real problem was a failure to implement Current Plans. There is no analysis of opportunity areas through evaluation of the current conditions (capability and suitability) in the proposed action or the AMS which supports the viability of this ill defined proposal in other wilderness, recommended wilderness or other areas (36CFR219.12(c-e). If there is no definition of the potential to resolve public issue and management concerns, then there is no basis for formulating and analyzing alternatives relative to this proposal. This issue relates to management standards and costs. It will not define decision space for developing alternative land use allocations, thus is not a major public issue.

Action EM-F2-A2:   Here is another fuzzy proposal so ill defined that it defies a reasoned comment. Are you admitting that you have not been using "…values and ecosystems at risk as primary considerations when managing to reduce the hazard of large-scale insect and disease infestations and severe wildland fires." By recent experience that is indeed the current situation, because nothing of positive significance has been accomplished and significant values and ecosystems at risk have not been protected. We will be anxiously awaiting your map to see where there is National Forest land that is not "…threatened, endangered, or sensitive species habitat." that does not need to be managed "…to reduce large-scale insect and disease infestations and severe wildland fires". No such map appears in the AMS as required by 36CFR219.12(c-e).

Action EM-F2-A3:   This statement of intent to "…use management treatments such as thinning and prescribed burning to emulate ecosystem patterns and process while providing public goods and services." is the only one in the ecosystem section that indicates there might be some active management to produce some public benefits. The issue of managing the landscape for diversity of vegetation to protect multiple resources from insect, disease, and catastrophic fire is your number one public issue. It seems that everyone knows that, probably even the planning team, but there is no straightforward public acknowledgement in the Proposed Action. Instead we have the convoluted rhetoric of "Ecosystem Management" and ("Management of National Forest and Private Lands Interface Areas." as statements of this major public issue.

Is "…habitats for species at risk…" the only wildlife you are going to take action to improve? Is thinning and prescribed burning the only treatments to be used? Of course not. All the management tools available will be applied to this problem. This is what ecosystem management is all about. Analyzing current conditions in relation to desired future condition, determining the need for change, and alternative types and scale of treatments will determine the costs and outputs of alternatives more than any other issue. The public needs to know what is the criteria for how this action will be applied and evaluated in the formulation of alternatives(36CFR219.(c-g)?

The invasive plant issue is stated in a misleading manner. There is no doubt that the current situation is atrocious, that the USFS did not comply with the Federal Noxious Weed Management Act of 1974 nor the Montana County Noxious Weed Management Act of 1948, and that the current forest plans did not address the severity of the problem we face almost 20 years after the plans were approved. However Current Forest Plans were based on the weed inventories at the time, and assumed that those infestations would be controlled and that monitoring would be conducted and annual control adjusted as needed as specified by existing law and Forest Plan standards. The fact is that no Forest did the monitoring or weed control specified in the current forest plans in the 80’s and 90’s and now the situation is beyond control for many noxious species.

For example, the Flathead N.F. had a standard to "Develop management direction for noxious weeds." (FNF LRMP, Ch. II, G. Range, Item 5.) Chapter V of the FNF LRMP, Item 30a, provides for annual monitoring of the noxious weed inventory to determine the extent and kind of weed infestations, to develop biological vegetative, mechanical and chemical control systems. Once again the biased authors of the Proposed Action cover up past failure to implement current Forest Plans by attempting to blame those failures on the current Forest Plans. The AMS compares a recent weed control report to the 1985 Forest Plan projection of treatment needs, but does not disclose any annual monitoring, control, or analysis of intervening years. At best this issue relates to establishing forest plan standards and budgets, and is not an issue that will affect formulation of land use alternatives.

Action EM-F3-A1:   This action statement is nearly verbatim what is currently in the Flathead National Forest Plan monitoring requirements, yet alleges to incorporate "…new information and technology." If the action had been taken 15 years ago as specified in current plans, the current weed situation would not be what we have.

Finding EM-F4-A1:

The "old growth" issue has been around for over 20 years. Old growth like any other timber stand condition is ephemeral, changing over time as natural succession proceeds and agents of change modify stands. It is likely that more "old growth" has been destroyed by fires in the past 4 years than all the timber harvest ever. For example, approximately 350,000 acres (15%) of the Flathead National Forest has ever had a timber harvest of any kind. Less than 250,000acres (10%) have been regenerated through timber harvest over a period of 60 years less than 0.2% per year. Approximately 350,000 acres have burned just in the US portion of the Flathead river basin since 2001. Allocating land to a long term old growth land use is infeasible. Such an allocation does not insure that old growth will actually be produced. Any land capable and potentially suitable for timber production has the potential to produce old growth if a catastrophic fire does not interrupt natural succession. In a managed forest, existing old growth stand structure can be restored and protected through management practices controlling the fire fuel and insect and disease environment. The old growth issue must be resolved by establishing minimum management requirements, assessment of existing conditions and need for change as required (36CFR219.12). No such analysis exists in the AMS or proposed action.

Action EM F4-A1:   "We propose to modify management direction for old growth, snags and downed woody material to use consistent definitions." This action certainly should have been done a decade or more ago, and it certainly should have been done as part of the AMS (36CFR219.12(c-d). This is an issue that the USFS cannot solve alone. Collaboration with other Federal agencies, State agencies, and professional and academic institutions on standard "best available science" definitions of "old growth" for the various forest vegetation groups is something that must take place in order for the issue to be addressed as required by NFMA in Forest Plans. It is ridiculous for special interest groups to be able to obstruct reasonable forest management projects, including old growth restoration projects, because no such widely accepted standard definitions and inventories exist. Old growth criteria is necessary to assess current conditions or make any progress in resolving the issue.

Snag and down wood issues deal with standards specifying a desired future condition. Given the current inventory data on the amount of snags and down wood, and the rate at which they are being created in the vast majority of stands, the real public issue is the unnatural extreme fire hazard that is known on Federal land. The desired future condition for snags and dead wood in managed stands ought to focus on achieving the desired level of fire hazard and resistance to control.

There are no data or studies that have shown viability problems of any kind related to an actual shortage of snags and down wood due to past timber harvests, even the most extensive clearcuts of the ’60s and ‘70s. There is no data that indicates snags and down wood have ever been evenly distributed in any minimum levels over the landscape. The variability in these habitat components created by past timber harvest is well within the natural range of variability, and the effect of any human caused shortage in these components is soon recovered, even to excess, by forest growth and mortality as shown in current inventories.

Specifying minimum numbers of snags and down wood by size class over every acre, especially based on analysis of the excess number already on the landscape, is unnecessary, unnatural and inefficient. The Flathead National Forest standards established by Amendment 21 are excessive and preclude meeting fire hazard and resistance to control needs. The snag and down wood issue and the rate at which they are being created is a major component in the fire hazard issue. The amount of snags and down wood to leave in managed stands is a minor issue, ephemeral in nature, a theoretical problem not supported by actual monitoring data, and it only effects management costs not land use alternatives.

Action EM-F4-A-2:   This action to maintain or restore old growth conditions and reduce threats is already part of Current Direction in the Flathead Forest Plan, but there has been practically no implementation due to obstructionist lawsuits. A big factor in being able to defend analyses on the old growth issue is the lack of the Forest Service promoting some settled science on the issue as discussed above.

This finding that "…fragmentation and altered habitat…" creates barriers to wildlife movement and causes local declines and inbreeding is theory and hype more than a real problem. Where is the actual monitoring data that supports these problems really exist? The "landscape connectivity" through "linkage zones" appears to be a scheme to promote Federal acquisition and control of private land.

Action EM-F5-A1:   The proposed action to identify linkage zones to "…retain or enhance wildlife security and hiding habitat." has definite implications to the Access Management issue implying more restrictions on access and management. There is no analysis of monitoring data or other information to show the need for this proposal as a minimum management requirement or an alternative. The AMS is deficient in this regard (36CFR219.12(c-d).

The proposal to have a Forest Plan to promote strategies "…(such as land exchange, conservation easements, land purchase, and right-of-ways)" is a biased pronouncement of the Wildlands Project policy that is totally inappropriate to a good faith revision process at this point in time. With millions of acres of Federal land already at risk due to lack of management, the last thing local communities and the State of Montana needs is for more property rights to transfer into failing Federal management. To advocate use of tax revenues to promote expansion of National Forest inefficiencies and remove land from local tax base is totally inappropriate. You have admitted in the finding above that if National Forest gets more land, there will be little public use or management. This is not a public issue, it is not a viable alternative, and it should not be considered in developing alternatives.

Human caused bear food sources is certainly not a major public issue and would not affect development of alternatives.

Action EM-6-A1:   The proposal to develop consistent guidance on three forests to eliminate or minimize human-caused food sources is certainly no long term land use issue, and that is the sort of thing that could have been handled by a routine non-significant amendment if it had any importance. We understand that you were, and continue to be to this day, too busy doing significant amendments and disguising them as insignificant to bother with this one.

The road issue is raised again in this section as if it were an issue to be addressed on its own without being integrated into the other issues (access, fire hazard, and timber management). The biased and unsupported presentation appears to attempt to portray roads as the cause of environmental problems. For the USFS to attempt to portray roads as the cause of additional species to be listed under ESA or listed as sensitive is misleading. Species are listed as a result of lawsuits not roads.

Action EM-F7-A1:   "We propose to develop access management goals, objectives, and standards that would better address the needs of big game and other wildlife species, aquatic species, water quality, and invasive species. …. This direction would mainly focus on reducing the miles of road." These arbitrary and capricious statements illustrate the consistent lack of consideration of timber management, fire protection and recreational and other local needs as public benefits of roads. Roads are consistently portrayed as harmful and undesirable. Roads must be integrated into the economic and long term land use alternatives as previously discussed under Access Management.

The disparity of management indicator species and related Forest Service problems with monitoring are not a public issue and certainly will have no effect on alternative land uses.

Action EM-F8-A1:   The proposal to update management indicator species is another example of a non-public issue that if a decade or more of monitoring revealed a problem, should have been addressed with non-significant amendments. Apparently it wasn’t significant enough to justify a non-significant amendment.

Finding EM-F9:

"At the time the forest plans were approved, more emphasis was placed on protecting wildlife and fish from other management activities rather that actively managing and restoring habitat for these resources." This is an outrageously false and biased statement. Anyone who knows anything about current forest plans knows better. Critical winter ranges for ungulates had specific land allocation and treatment objectives scheduled to increase carrying capacity of critical habitat. Grizzly bear also had specific land allocations with goals to optimize grizzly habitat components. Fisheries habitat improvement projects, including fish passage barrier removal, were scheduled and budgeted. Here again is a glaring lack of implementation of existing forest plans on wildlife and fisheries habitat improvement. If there was any real effort on the part of the planning team to analyze monitoring data, both habitat and populations, and actual habitat improvement accomplishments as required in the Forest Plan, it does not appear in the AMS and that may the reason for the Proposed Action author’s lack of knowledge on the subject.

Action EM-F9-A1:   A proposal to continue to contribute to recovery of threatened and endangered species? As if this were an option? We previously discussed under the grizzly bear security issue above what the requirements of law are regarding criteria for analyses and establishment of minimum management requirements if needed for threatened and endangered species. The AMS is so deficient in these areas that it should be withdrawn and reissued with some valid information and analyses rather than rhetoric. And you are also going to emphasize management of habitat for species important for hunting and viewing? These are totally meaningless statements when there is no information put forth as to what or how this would be integrated into the analysis and decision making process. These generalized statements provide no basis for public understanding or comment.

There is no discussion of actual fisheries or water quality monitoring and required to determine effects of past management and need for change. Instead there is a re-hash of INFISH and PACFISH standards developed outside the Region and illegally thrust upon the Forests in a sweeping Regional Amendment. As admitted in the Proposed Action discussion, the INFISH and PACFISH need to be modified to meet local conditions and potentials. This issue is another one dealing with standards that affect costs and does not provide decision space for alternatives.

Action EM-F10-A1:   A blanket proposal to continue INFISH and PACFISH with only minor modifications is arbitrary and capricious without the analysis of effectiveness, costs or need to resolve a public issue as required by 36CFR219.12.

There certainly is no question that current conditions place a lot of National Forest lands "…at high risk of uncharacteristic disturbance events such as fire, insects, disease, windthrow and invasive species." As discussed under EM-F2-A3 above this is the number one public issue and the AMS and Proposed Action are woefully inadequate in disclosing monitoring and inventory data that realistically portrays the existing situation and how it evolved over time. The lack of discussion of integration of economics, timber management and forest access relative to this issue has to be one of arbitrary and capricious purposeful exclusion.

Action EM-F11-A1:   The proposal to "Identify areas such as watersheds or landscapes having the highest potential for improving ecosystem components through passive and active restoration." appears to have some potential to affect decisions space analysis, and should have been done as part of the AMS. The statement to develop strategies to improve social and economic conditions is extremely important and should be public issue number 2 right behind the extreme fire hazard issue.

Most of the statements on developing restoration strategies are to vague to comment on directly, however some could effect the benchmark analyses required by NFMA (36CFR219.12(a-e). Although these may be important considerations, they are ephemeral or an implementation policy statement, and they will not determine the long term land use alternatives. Instead they define a management policy or intensity type of decision that will affect costs and may impose constraints..

EM Conclusion:

With no analysis of minimum management requirements, Current Direction, and production and economic potentials required by law it is difficult to understand and make substantive comment on all the undefined and arbitrary and capricious statements in the Ecosystem Management Section. We intend for our comments to help the Forest Service identify ways to improve the revision process so that it will be a scientific and legally defendable product. We recommend Ecosystem Management be dropped as a public issue and instead substitute Forest Health and Fire Hazard, Local Economic and Social Conditions, and Threatened and Endangered Species Recovery as public issues.

TOP   PREVIOUS

This issue is actually only one facet of the forest wide forest health and fire hazard issue. The interface zones would not be the issue that it is today if reasonable management of neighboring National Forest Lands had been implemented as authorized by current Forest Plans. Private interface lands are not just at risk due to negligent conditions of adjacent National Forests (1/4 mile). Private lands, private economics, and quality of life are currently and routinely damaged year after year due to the annual export of insect, disease, invasive weed seed, and fire from National Forest System (NFS) lands. The NFS lands provide the habitat conditions for the vast reservoir of breeding populations and vectors to effectively spread these destructive agents. Few private landowners have the resources to suppress the onslaught of destructive agents spawned on Federal land.

There is nothing in current Forest Plans that prohibited these area from being first priority for any site specific vegetative management treatments needed and other multiple use projects involving recreation, access or wildlife habitat. The fact is very few forest managers, if any, used their authority or resources under their control to implement strategic treatments or projects under current forest plans. Current problems causing the interface issue is a direct consequence of the leadership and professional abilities of current forest managers. A special interface management area is not necessary to implement the management that is needed. Here is another case where the Proposed Action authors biased presentation attempts to blame forest plans for current conditions rather than current management because "…no special management direction exists for the interface areas."

The map displayed on p. 4-50 of the AMS is very misleading because all the white space on the map is labeled "No Risk". Ask any of the people whose property has already been destroyed by a fire exported from Federal Land if that fire came from the colored area on the map or from the "No Risk" white space( people from Choteau, Lincoln, Condon, Darby-Stevensville, Blankenship-West Glacier, Polebridge-Moose City, MT). No explanation of criteria for the map is given. We surmise the map only rated a small area (1/4 mile or so?) around inventoried dwellings. If that is true, the white area on the map should be rated "unclassified". To lead people to believe there is "No Risk" as labeled on the map is extremely unprofessional if not downright dishonest.

Action NF-F1-A1:   Using "values and resources at risk" to prioritize treatments is only common sense and should have been implemented years ago.

Action NF-F1-A2:   The proposal "…to emphasize social and economic needs over ecological components, where appropriate,…" is not only a good idea but required by law (NEPA and NFMA). As we recommended in the EM section above improvement of social and economic needs should be a major public issue. The above statement should be applied to all multiple use management areas.

Action NF-F1-A3:   It is very good news to hear that you are proposing to "…retain current Forest Service recreation facilities within interface areas and improve them to accommodate increasing use." On the other hand, we hope this statements does not reflect an unstated intent to remove recreational facilities in other areas of the forest.

Action NF-F1-A4:  A proposal "to work cooperatively with counties, homeowner groups and other groups to address infastructure needs such a roads…" should also apply to other multiple use management areas.

Action NF-F1-A5:   A proposal to "develop land adjustment goals…" sound like a proposal for more government acquisition of private land and is totally inappropriate in a scoping document which is supposed to focus on major public issues.

The only thing that is unique about the fuels hazard and risk of wildfire in the interface is the negligence of the US Forest Service in initiating management actions. There must be disclosure of the annual fuel management budget and accomplishments from each forest. The statement "The amount, size and intensity of fires that occur in the private land and forest interface have increased since the 1980’s." is misleading. If the facts were presented honestly, the monitoring data would show that in nearly every case fires that affected the interface areas and destroyed and damaged private property originated miles from the private land. These fires did not "occur" or start in the interface area. The catastrophic fires were exported by firestorm winds from deep within the interior of the forest, often from wilderness or inventoried roadless areas, and they will continue to do so until the fire hazard is reduced in multiple use areas.

It is not clear that the comparison of 21% of private lands within ¼ mile of NFS lands classed as "moderate to high risk" to the "59% of NFS lands adjacent to private land can sustain high intensity fire…" in the next sentence is fair. Is there additional NFS lands adjacent to private land that is classed as moderate? If so, the "Finding" is deliberately biased by leaving out the NFS lands classed as moderate. Even without the moderate NFS lands classification, it is easy to see that NFS lands are a minimum of triple the risk on private lands, an unacceptable existing condition and a powerful indicator of need for change.

Another illustration of false statements is "In the past, a wildfire may not have been considered a threat due to its location on forested lands, whereas now it can quickly become a threat to homes, structures and property." Why would current forest plans specify a fire management policy of "Control" that you have so bitterly complained unreasonably restricted fire management options in previous sections of the Proposed Action? Please show us the map of the areas where wildfire previously was not considered a threat. We would also like to see a map of the current forest plans, especially in interface areas, which do "not allow harvest of trees or burning" to manage fuels. The only management area we know of that do that may be a Wilderness and there really is no decision space on that area. This "Finding" is so biased and misleading it offers no positive contribution to a good faith revision process.

Action NF-F2-A1:   A proposal to "concentrate fuel management activities to the interface near areas of moderate and high hazard to wildfire." may be reasonable when just considering the interface area. If it means that fuel management activities will be ignored beyond the interface area, then the statement is arbitrary, capricious, and not a viable action.

The potential for noxious weeds was adequately covered in the EM section. It is not an issue that affects long term land use alternatives. At least there is no analysis in AM S or the Proposed Action that indicates otherwise.

Action NF-F-3-A1:   It is great that you propose to treat invasive plant species using integrated pest management concepts. If this had been done 15 years ago, the potential for spread would not be nearly what it is today.

TOP   PREVIOUS

This "Finding" doesn’t say anything! The biased tone of the entire paragraph sounds as if the current forest plans classification of suitable or not suitable for timber management was incompetent or just plain wrong with no supporting evidence.

ActionFP-F1-A1:   The biased arbitrary and capricious pronouncement of "The number of acres classified as suitable for timber production as an emphasis would probably be less than identified in current forest Plans." with no supporting analysis is very unprofessional. Yet another indication that the revision process is not being conducted in good faith. To make such statements before there has been public scoping of issues or any effort to assess supply potentials and demand as required by 36CFR219.12(e).

Why is there no discussion on the only analysis in the AMS that at least is a start on compliance with NFMA (36CFR219.3, 219.12(c-d), and 219.14)?

The analysis displayed in the AMS apparently is intended to be the first step in determining timber suitability as required, and that is defining forest lands available and capable of timber production resulting in lands classed as "tentatively suitable". The tentatively suitable timberlands define the base from which the required analysis of productive supply and economic potentials and ability to meet RPA goals and produce public benefits begins. There is no discussion of the rationale for the criteria used for the various classifications listed in Appendix D of the AMS. For example the majority of physically unsuitable land is so classed because timber harvest on those landtypes would allegedly cause irreversible resource damage to soils, productivity or watershed condition. The scientific data and rationale for these classifications must be disclosed and subject to public review and comment.

The calculation of forest roads 33 ft. wide as non-forest land and subtracting those acres from potential forest production is not supported by science. Trees along the edge of roads commonly develop limbs reaching 15-20 feet across the road thus making effective use of the growing space provided by the road. Research has demonstrated that the trees on each edge of the road have increased compensating growth and production compared to trees with more competition away from the road. This increased growth is due to benefits from extra light, water, and nutrients made available to road edge trees by presence of the road. No timber production is lost due to 33 foot wide forest roads. Studies of historic tree stocking levels before European settlement shows natural tree stocking to result in tree spacing of 33 feet or more. Subtracting acres from potentially suitable land base by calculating a total area represented by the road prism, and subtracting that area is just one more indication of the bias against timber management exhibited throughout the AMS and Proposed Action.

Action FP-F1-A2:  It is an especially strong indication of bias for you to propose "to exclude inventoried roadless areas from the suitable timberlands". Another announced intent to promote defacto wilderness management outlined in the "Roadless Area Conservation Rule" which was declared illegal in Federal Court in July, 2003. How can you make such a proposal as if it is a viable alternative in January 2004 and expect the public to believe this is going to be a science based fair revision? The roadless area discussion in the AMS has no evaluation of resource capability, suitability, or manageability, or alternatives as required by (36CFR219.17). The "Possible Forest adjustments to IRA’s Appendix C acres if RACR is implemented.", (AMS p. 4-71) is still another illegal analysis that should not have been published, yet another indication of bias.

Action FP-F1-A3:  The lands along the private land interface are some of the most accessible and productive lands in the National Forests. Trees grow fast on these lands, and trees grow and die. Trees yield forest products. NFMA permits managers to decide on tree stocking levels and reforestation criteria needed to achieve multiple use objectives (36CFR219.27). Unless you are going to prescribe the area be permanently cleared of trees, there is no reason that these lands should not be classed as suitable and intensively managed for a fire resistant stand structure, tree density, and species composition while yielding forest products over the long term. You admit these lands will yield substantial forest products and if the suitability definitions (36CFR219.4) and requirements (36CFR219.12, 219.14, 219.15, and 219.27) are complied with, these lands would be classed as suitable. There is no reason other than a biased attempt to reduce the suitable timber base and allowable sale quantity (ASQ) to recommend removal of interface lands from the suitable base.

This finding describes very well what NFMA defines as suitable timberlands (16USC1604.(g)(2)(A) and1604.(k)).

Action-FP-F2-A1:  We do not understand why you are proposing timber harvest as a routine management tool on lands classed as "not suitable for timber production" This position the opposite of your proposal to class interface lands as "unsuitable for sustained yield timber harvest" and is illegal. If there is a long term need for timber harvest to achieve vegetation habitat and social goals, the treatments needed must be included in a multiple use prescription and the costs and outputs estimated for alternative land uses (36CFR219.12 (f). If long term periodic treatments will yield predictable commercial forest products, the land should be classed as suitable for timber harvest (36CFR219.14(b). . Lands classed as "not appropriate" for timber harvest as a result of all the evaluation of costs and benefits of alternatives (36CFR219.12, 219.14,and 219.27) are then added the unsuitable class as the last step in the timber suitability decision process. Tentatively suitable timberlands that are not appropriate for timber harvest due to economics and other multiple use values have always been available for unscheduled timber harvest under special circumstances (16USC1604(k) and (36CFR219.27(c ). It is apparent that the Proposed Action authors do not know what the law requires for determining suitability.

A finding of "…significant tree mortality, combined with declining availability of commercial timber from NFS lands have led to increased public interest in salvage sales." If there ever was a spin doctor warped statement this has got to be the perfect example. Any analysis of real monitoring data on timber harvest, insect and disease infestations and catastrophic fires will show the exact opposite, that in fact the declining timber harvests on NFS lands has resulted in recent large disturbance events. Timber mortality and salvage sales are a by-product of declining forest access and timber sales as everyone knows except the WMPZ planning team and the Forest Supervisors who approved the issuing of this pathetic illegal "Proposed Action". Salvage sales resulting from unnatural fires and massive insect attacks are not a separate public issue rather a facet of the Forest Health and Fire Hazard issue. Salvage sales do not affect long term land use alternative. This is another meaningless "red herring" issue.

Action FP-F3-A1:   Thank you very much for proposing to "…encourage salvage logging following fir, insect and disease outbreaks, or other forest disturbance when compatible with management area goals." Does the author believe this is a need for change from current direction?

We firmly believe that you are covering up the obstruction of reasonable forest management by special interest appeals and litigation by blaming "unrealistic budget projections", "large disturbance events", and "public controversy" for the lack of timber sales in the past decade. By not disclosing the cost and value of the timber sales obstructed and delayed to the public and to Congress, you are bias and overtly supporting those special interests. "An economically viable timber industry needs to be maintained as a partner to help achieve management goals." Finally a straightforward statement of fact. It is a disservice to the public that this Proposed Action and the "Draft AMS" was issued with no information on production or economic potentials for timber or anything else as required by law, and conclude "The maximum allowable sale quantity would probably be less than the level allowed in current Forest Plans." If there was ever a reason for examining a base sale harvest schedule that departs from non-declining even flow due to high mortality losses this is the time (36CFR219.16).

Finding FP-F5:

If the principles of ecosystem management has taught you folks to "…focus more on what is left on the landscape than on what is removed.", when are you going to start doing it? There is no focus on what is left on the landscape in this Proposed Action and AMS. No disclosure of current fire hazard conditions or current high risk habitat for insect outbreak. Not even a disclosure of current inventory and mortality data. Every spin doctored issue is intended to blame the current plans, distort what current plans required, and make excuses for lack of implementing current plans. If you are so proud of the way clearcutting has been reduced, where is the monitoring data, inventories and evaluations of what public benefits have been achieved?

Action FP-A5-A1:   Wonderful, a proposal to reduce the application of clearcut harvest prescription even more? It can’t get much lower than in recent years, and NFMA, Regional Guide already require that clearcutting would be prescribed only when necessary. This is another smoke and mirrors non-public issue.

Yes, lets whine about theoretical rotation ages used in a model to estimate some possible long term regulation of forest age class diversity and economic value which is discounted to practically nothing over a 150 planning horizon. This is another smoke and mirror non-public issue.

Action FP-6-A1:   This pronouncement is just speculation and posturing with no real information on how a proposal to model natural disturbance events and calculate timber yields and estimate costs and returns. Just another smoke and mirrors statement that provides no public understanding of major issues.

Once again the biased statements on the adverse effects of roads and the dogma regarding inadequate maintenance budgets. Again roads are improperly characterized as if it were a separate issue from timber management and economics. A pronouncement that temporary roads will limit the need for new permanent roads is arbitrary and capricious unsupported by any required analysis. Roads are a byproduct of the long term land management and the economic and environmental tradeoffs as to the logging systems to be used. The road system tradeoffs must be evaluated in an integrated analysis as required by NFMA and we have previously discussed under the Access Management and Ecosystem Management topics.

Action FP-F7-F1:   Still another biased arbitrary and capricious pronouncement to construct fewer permanent roads than projected in current forest plans by emphasizing reconstruction and maintenance of existing roads. Still no indication that road requirements will be integrated into timber suitability, forest protection, or long term land use alternative and required by law.

Miscellaneous forest products is a site specific issue and not one that would have any effect on alternative land uses. It is misleading, perhaps more accurately dishonest, to imply that existing Forest Plans are "largely silent" on this issue and stating, "Uncontrolled removal of such products can severely impact forest resources." There are many standards and management direction in current forest plans which in no possible way permit "uncontrolled removal". We think that most people know that permits are required for removal of most anything from the forest, including firewood, Christmas trees, and even mushrooms. Apparently the author and reviewers of the "Proposed Action" failed to read the Timber, Vegetation, Minerals and Land Use sections of current Forest Plans.

Action FP-F8-A1:   A proposal for "Management Areas to be identified where this (miscellaneous forest products) is an appropriate use." Seems to imply that there will be lands identified as unsuitable for miscellaneous forest products? Does the Forest Service really believe making capability and suitability assessments for miscellaneous forest products as required by NFMA a high priority use of planning resources? Another smoke and mirrors non issue that has nothing to do with long term land use decisions.

TOP  PREVIOUS

Thank you for the information on increasing recreation demands from the Interior Columbia River Basin Assessment. This is Bitterroot, Flathead and Lolo National Forests in Montana. Where is the monitoring data and assessment of that data on these National Forests that NFMA requires (36CFR219.12(k)? Where is the evaluation of the Forests’ ability to supply recreation opportunities in relation to demand (36CFR219.12(e)?

Action RM-F1-A1:   This action is nothing more that proposing to continue the opportunity classification systems in current plans and Forest Service manuals. The Proposed Action provides no information on how a broad array of recreation opportunities would be integrated into a broad range of alternatives in the planning process.

We could not agree more that "Managers need better guidance to help maintain desired conditions, reduce user conflicts, and protect resources." Better guidance should include removal of managers who fail to their job and follow the law. The Regional Foresters’ illegal 2003 mass amendment of all forest plans in Montana, North Dakota, and South Dakota to prohibit any off road motorized use was also premised on unsupported statements about damage and resource conflicts just as stated here. In response to a Freedom of Information Act request for documents supporting these claims, no credible monitoring reports or other documents proving resource damage was produced. If there has been such unacceptable resource damage, where have there been site specific closures as supported by monitoring to correct/prevent resource damage and user conflicts as required by current forest plan direction and Executive Order 11644, 36CFR261.50-56, and CFR295? Surely it would have been in monitoring and evaluation reports. Failure to implement existing direction will not be cured by more direction, and it does not justify a need to eliminate multiple uses.

Action RM-F2-A1:   This action is simply to use current standard recreation opportunity classification systems.

Still another finding of increased demand already exceeding some site capacities and more whining about resource damage.

Action RM-F3-A1:   A proposal to "develop trigger points for early identification of deteriorating experience levels and resource conditions…" is exactly what current forest plans do in Limits of Acceptable Change (LAC) criteria and monitoring requirements. Again there is no evaluation of how the existing LAC system was implemented or monitoring results. There is no evaluation of existing capacities relative to projected demand. No proposal for ways to increase capacities or accommodate public needs. Instead of any professional analysis required by law, the proposal outlines "tools" ranging from least restrictive (education) to most restrictive (limited use permits) for managers to reverse degrading trends and concludes "In some places on the three forests, limiting entry and use could become reality during the planning period." There is nothing that indicates there will be a fair evaluation of a full range of recreation opportunities. No indication there will be a hard look at recreation needs of rapidly increasing population composed of a higher percentage of senior citizens. No indication that opportunities to provide for increased recreation capacities will be evaluated.

The two paragraphs of gobble-dee-gook regarding the inadequacy of current forest plan direction for regulating outfitters and guides should leave no doubt that these segments of the recreation economy is being targeted for more restrictions and tough times ahead. Equine recreation interests of all kinds better be paying attention, because your opportunities are coming under increasing attack just as all motorized recreation has been.

Action RM-F4-A1 and RM-F4-A2:   Two more paragraphs of bureaucratic descriptions of how the Forest Service intends to implement their biased conclusions to restrict wilderness and non wilderness recreation opportunities in the forest plan revisions.

Four more paragraphs dealing with site specific problems with outfitter and guide management in certain areas. These are not public issues and it another indication that there is no effective site specific management. Instead current managers sit in their office reading e-mail and going to meetings to promote more restrictions of that terribly destructive public use of their forest.

TOP   PREVIOUS

This section of the Proposed Action describes the forgone conclusion the all knowing USFS has reached regarding revision of Forest Plan wilderness recommendations down to the acre. This has been accomplished with no public input on update of the roadless inventory, no re-assessment of resource values, wilderness values, wilderness use and demand or any of the other analyses required by law (36CFR219.17). At least it is good to know that the arbitrary capricious nature exhibited in the Proposed Action is not limited to forest health, fire hazard, access, and economic issues.

This section rails about differences in the way areas recommended for wilderness are managed alleging inconsistencies are "confusing" the pubic. The language expresses the authors’ disregard for current forest plans allocations of portions of some recommended wilderness areas to various multiple use prescriptions which generally permitted traditional uses to continue if Congress failed to act (as specified in the Wilderness Study Act) on the recommendations. It was not the intent of current forest plans to manage those areas the same as a wilderness if Congress does not see fit to make a designation.

Action WRR-F2-A1 and WRR-F2-A2:  "Management direction would encourage primitive uses only, and would not allow snowmobile, other motorized, or bicycle access." This sentence succinctly states the bias of the current planning team and forest supervisors who approved the issuing of this proposed action. There is no intent to perform a professional re-assessment of alternatives for these areas as required by law. The previously expressed bias to manage these areas under the Clinton Roadless Area Conservation Rule as if they had been designated by Congress is very clear. How can anyone read this kind of "in your face" arrogance, utter disregard of the law statements and believe that the revision process is going to be professional, science based, or fair?

The Proposed Action express further contempt for current forest plan allocations of inventoried roadless areas that were not recommended for wilderness. The discussion clearly portrays the bias that every acre of inventoried roadless area should be protected from "degrading" activities allowed by current multiple use prescriptions. When current forest managers express such open disagreement and contempt for existing forest plans, it is now more evident why existing forest plan direction has not been implemented in good faith.

Action WRR-F3-A1:   "We propose to provide management direction that doesn’t allow activities, such as road construction, that would degrade the roadless character, as defined by the Roadless Area Conservation Rule (RACR) of inventoried roadless areas." There could not be a more arbitrary, capricious, biased, illegal statement concerning a major public issue.

ActionWRR-F3-A2:   "We proposed to review and update inventoried roadless areas found in Appendix C of the current forest plans as required by NFMA." What? How did this statement of intent to follow the law get into this document? The fact that it is stated proves the requirement of law have not yet been followed. The above statement is the first step in dealing with the Roadless Issue and the complete analysis should be completed and disclosed in the AMS as required by law. The pathetic "Draft AMS" does not have a completed roadless inventory update or required analysis.

The Draft AMS has a major section on the RACR including a chart that alleges to show "Potential Adjustments to Appendix C if RACR is implemented." It is our understanding that Federal Judge Brimmer issued a decision in July 2003 declaring the RACR "illegal" and "unconstitutional" as well as enjoined the Forest Service any further implementation of the roadless rule. Why is the Forest Service in Region one continuing to implement RACR, waste scarce analysis resources on analysis of RACR, and making major public statements in 2004 about intending to include RACR in forest plan revisions?

A straightforward update and evaluation of the roadless inventory as required be current laws and regulations must be completed. The "Draft AMS" and "Proposed Action" should be rescinded and withdrawn. The analyses required by law should be completed and a proper AMS re-issued that provides the public some actual information on potentials and limitations to respond to public issues and produce public benefits.

Action WRR-F3-A3 and WRR-F3-A4:   None of the rhetoric in these paragraphs about what activities might be permitted in inventoried roadless areas while protecting the "roadless character" is just more bias. There is no indication that a good faith effort to examine alternatives or evaluate effects will be made.

All of these "Findings" and "Actions" illustrate why NFMA requires forest planning process to accommodate the unique issues, potentials and limitation, and custom and cultures found associated with each National Forest "administrative unit". These are all unique site specific issues that only a few affected interests will have interest in and further illustrate why a three forest at once process is not practical. These are not public issues which affect preparation of a programmatic long term land use plan. These issues again illustrate things that could and should have been addressed in insignificant amendment if action is needed. There is no indication there will be any alternatives examined or public benefit tradeoff evaluations made. A waste of paper, electronic storage, and time for the vast majority of the public to include these issues in a LRMP proposal.

TOP   PREVIOUS

This section is simply very brief statements about problems that have been experienced with current monitoring plans. Why weren’t these problems corrected by evaluation of monitoring as existing forest plans required? There is practically no disclosure or discussion of actual monitoring data or evaluations of monitoring data for any resource or issue discussed in the "Draft AMS" and "proposed Action." These evaluations along with new information and changed conditions is supposed to provide the basis or "need for change" in forest plan revisions. The Draft AMS and Proposed Action should be withdrawn and reissued when the required data and analyses have been completed as required by law.

Action ME-F1-A1:   This action simply sets criteria for developing new monitoring plans. This is not a major public issue, is up to the scientists to determine and will not affect formulation of alternative land use plans.

MFMU recommends that the major public issues to be addressed in revision are (in order of priority) 

1. Forest Health and Fire Hazard (critical facet: Forest Access)

2. Local Economic and Social Needs (critical facets: Forest Access, suitable timber base and ASQ)

3. Recovery of Threatened and Endangered Species (critical facet: Forest Access)

4. Recreational Opportunity Spectrum Provided (critical facet: Forest Access)

5. Roadless Inventory and Wilderness Recommendations (critical facet: Multiple Use Forest Access)

If the above issues are addressed in a systematic integrated analysis that permits evaluation of values forgone so that the responsible official can make a reasoned decision that is believed to maximize net public benefits as required by law, the access issue will be an integral part of that decision. There is no reference in any of the documents to resource goals assigned to each forest by the Regional Forester as Resources Planning Act (RPA) program goals to be evaluated in Forest Plan Revision as required by 36CFR219.4.

The Proposed Action and associated Draft Analysis of the Management Situation is so biased and inadequate in even making a reasonable start on a competent Analysis of the Management Situation that it should be withdrawn and re-issued when the required criteria, minimum management requirements, economic and resource benchmarks, and legal roadless inventory update is completed as required by law. There is just no analytic baselines or potentials provided in these documents to provide a framework for defining a reasonable range of alternatives.

Sincerely,

Fred D. Hodgeboom, President

Montanans For Multiple Use

cc: Congressional Offices, State Legislators, County Commissioners, news media.

TOP  
ACCESS  ECOSYSTEM MANAGEMENT  FOREST AND PRIVATE INTERFACE  FOREST PRODUCTS  RECREATION  WILDERNESS AND ROADLESS  SUMMARY