The new Forest Planning Rules certainly change the landscape of Forest Planning. The overriding change is the explicit definition of the Forest Plans as "strategic", defining planning as perhaps a useful exercise in communicating with others, but not of much real consequence.

This view has certainly not been communicated to our local officials who continue to doggedly assert that they have no choice except to implement certain provisions contained in Forest Plans, especially the more recent prescriptive amendments (A-19 and A-21).

I see positive aspects and some negative ones, especially as they affect local communities.

Multi-forest planning—The new rule legitimatizes planning for more than one administrative unit. This has already been implemented by the Forest Service for amendments and forest plan revisions for a number of years. This is just one aspect of the new regs that moves the planning process back toward a centralized process, which I believe is contrary to what NFMA and the old regs intended - local control at theForest unit level where local land capabilities and local economic and social needs could be better addressed and coordinated.

General nature of plans—The new regs only require establishment of general desired future conditions, objectives, guidelines, and suitability designations (all defining aspirations not commitments). This clearly changes the old concept of a Forest Plan being a "contract with the public" on what to expect from their National Forest in the decade ahead even though what we actually experienced had little to do with what was promised in the original Plan. A plan under the new regs simply tells us up front what may happen

On the plus side, the Forest Service is freed from the substantive, quantitative and analytical analysis requirements in the old regs, and that will substantially reduce planning costs. In addition, the complex and costly Environmental Impact Statements will no longer be required, and that compliance with the National Environmental Policy Act can be achieved with a Categorical Exclusion. This should be a huge savings in the cost of appeals, and litigation regarding compliance with those requirements. This may be one of the most fought over aspects, because of the huge environmental conflict industry that depends on contesting these requirements.

On the minus side, the entire process will be more subjective and political in nature, and more centrally controlled out of Washington DC. The public and the decision maker will have less quantitative information on tradeoffs between various resources and economics, and local needs and desires will be diluted even more than what we have experienced in the last 10-20 years.

The new plans seem to provide an administrative structure using an Environmental Management System (EMS) to systematically guide planning, evaluation, monitoring, and adaptive change in the future.

Finally, the new regs make the entire process more administrative in nature. "Administrative Corrections" may be made at any time without processing a formal amendment to the plan. The appeals process is replaced with an opportunity to file an "Objection" to a Plan decision.

The new regs potentially appear to permit local officials, who are supposed to be unbiased professionals, to do a better job of stewardship of National Forest lands and resources to meet the needs of the American people (more benefits) at less cost to the taxpayers. On the other hand, the reduction of analytical requirements and increased administrative discretion provided by the new regs could be used by officials to more easily implement social or ecological agendas such as the Agenda 21 Wildlands project to the detriment of the American people and our natural resources.

The new regs permit Responsible Officials who are already in the process of revising or amending plans to choose to continue under the old regs, or to incorporate the required components of the new regs into their process and complete the plan revision under the new regs. Comparing the new regulations with the requirements contained in the old regs, I do not see why a Responsible Official would choose to proceed with the old regs and fight the legal challenges that can be brought against the compliance with those old regs. On the other hand if they use the new regs and those are later overturned in court the whole planning process might be overturned.

Written by Fred Hodgeboom and edited by Gary Hall