Currently within the Forest Service, there a number of initiatives of local and national scale that will greatly effect the condition of the national forests in the first decades of the 21^st century. National forest management policy is being developed and revised at every agency level. Locally, five of the six national forests in the Southern Appalachians are revising their resource management plans. At the same time, the Forest Service’s Washington Office is changing its Roads Policy. President Clinton has also directed the Forest Service to develop a comprehensive plan to protect the remaining Roadless Areas on the national forests. And the Washington Office is changing the regulatory measures that are intended to provide specific direction for implementation of all Forest Plans. Many of the relationships between these initiatives are complimentary and could provide strong direction for the Forest Service in the coming decades. On the other hand, there are many instances in which these initiatives are clearly oriented in different directions

FOREST PLAN REVISIONS: Sumter and Chattahoochee national forests

Perhaps the most publicly visible Forest Service initiative besides the President’s Roadless Initiative is the Forest Plan revision process currently underway on the Sumter and Chattahoochee National Forests. This costly and time-consuming effort was begun in 1996 with a Notice of Intent, which was required by the National Forest Management Act (NFMA). The current Forest Plans were completed and implemented in 1985, and were the first under the NFMA.

In the current Plan revisions, agency direction and public comment were used to generate several significant region wide issues that were the basis of the range of alternatives that would eventually become what’s known now as the "rolling" alternative. This "rolling" alternative was presented by staff members of the various national forests, at public meetings that were held in North Georgia and northwestern South Carolina. In general, the discussion following the presentation was punctuated by stalemates resulting from the polarized views expressed by those in attendance. Forest Service planners are now faced with the daunting task of coordinating divided public opinion with requirements for implementing sound science to ensure species viability. The end result of this activity will be the Draft Environmental Impact Statement (Forest Plan) that will be available sometime late next summer.

The region wide issues that were chosen as focal points for the Plan revision process emphasize the language of "restoring and maintaining forest ecosystems through the application of management prescriptions" to biodiversity, water, recreation and "use issue clusters." These clusters are further divided into specific issues that are arranged to meet the Forest Service’s multiple use requirements. Because of that, the issues are arranged out of numerical sequence within the clusters.

The Biodiversity Cluster is the first grouping of issues that is presented in the "rolling" alternative. The issues discussed in this section are 1, 2, 3, 9, 10 & 14. Issue 1, Terrestrial Plants and Animals and Their Habitats seeks to provide a diversity of plant community types and structures. A variety of early successional habitats (0-15 years) would be sought through this alternative, providing forage for certain game species. Habitats as well would be maintained or enhanced for species needing large, contiguous forested landscapes. Issue 2, Threatened, Endangered and Sensitive/Locally Rare Species has the ultimate goal of conserving and recovering Threatened, Endangered, sensitive, and locally rare species and their habitat. These protections were provided by a far-sighted Congress in the form of the Endangered Species Act of 1973.

Issue 3, Old Growth would provide natural old growth forest areas and areas where management would maintain old growth conditions over time. It is important to note that out of the 28,500 acres within the range of this issue, only 600 are to be maintained as core areas where management actions would not be allowed. The remaining acreage would be subject to timber harvest, prescribed burning and vegetation control. Through the implementation of these prescriptions the Forest Service’s definition of old growth would be far removed from the archetype of primeval forest. This process of redefinition can be seen as an integral part of the "rolling" alternative.

Issue 9, Health of Forest Vegetation is associated with management prescription "9H" that emphasizes the "Management, Maintenance and Restoration of Plant Associations to Their Ecological Potential." Among the goals of this issue and its related prescription is to provide the desired composition, structure, function, and productivity over time that can be attained through sustained yield timber management. Issue 10, Special Areas and Rare Communities is a recognition of the special geological, paleontological, botanical, zoological, cultural, or heritage characteristics present on national forest lands. These areas will be managed to protect o to restore these characteristics.

Water Issues 4,11 & 13 range in complexity from recreation to the restoration of watersheds. Issue 4, Riparian Area Management, Water Quality, and Aquatic Habitats would include management to provide resilient and stable conditions, to ensure the quality and quantity of water to protect ecological functions and support intended beneficial water uses and resources. 68,400 acres of riparian areas would be classified as unsuitable for scheduled timber harvests. This restriction would apply to all management prescriptions. Issue 11, Wild and Scenic Rivers recognizes rivers and streams with "outstanding, remarkable values." All rivers eligible Wild and Scenic status are either recommended to Congress for the National Wild and Scenic Rivers System designation, or managed as if they had been designated. The streams recommended are the Conasauga and Jacks Rivers; portions of the Upper Chattahoochee River; the Tallulah and Coleman Rivers; Overflow Creek; Murder Creek; and, the Ocmulgee River. Panther and Davidson Creeks were initially recommended for Wild & Scenic status, but were removed from consideration because this designation would exclude management options such as the construction of in-stream structures.

The last of the Water Issues, Issue 13, is The Chattooga Watershed and is a consequence of the efforts of Chattooga River Watershed Coalition staff to encourage the Forest Service to manage the Chattooga as a single ecological unit across administrative boundaries. In 1994 $1.4 million was appropriated for the Forest Service’s Ecosystem Management Demonstration Project, which coordinated a variety of biological and cultural studies that were intended to provide management direction for the Sumter, Nantahala and Chattahoochee National Forests. In fact, this study resulted in a fair amount of good scientific inquiry, although actual management practices have been inconsistent with the recommendations made in that study. Nonetheless, the opportunity exists again in the form of the Chattooga River Watershed Restoration Project (CRWRP), to implement sound measures to protect the watershed. Funding for the project is around $2.1 million for the first year, with the possibility of additional funds to follow in subsequent years. The primary objectives of this project will be "to improve water quality and aquatic habitats through the relocation and improvement of recreational facilities, roads and trails, conservation education with state, private, and federal recreation users and landowners." Issue 13, the Chattooga Watershed as presented in the "rolling" alternative lists 26,792 acres under management prescription 9A3, Watershed Restoration Areas, which does seem consistent with the goals of the CRWRP. However, within Issue 13, 23,792 acres are listed under prescription 9H: Management Maintenance and Restoration of Plant Associations to Their Ecological Potential. This prescription allows far too much discretion on the project decision-making level, essentially leaving the whole area open to a new brand of forestry that has been created to "remedy" the ill effects of past management.

Recreation Issues 6, 7, 8 & 15 cover the vast spectrum of recreational opportunities/experiences from vehicle travel corridors to Wilderness management. Issue 6, Aesthetics/Scenery Management essentially deals with the maintenance of scenic areas along scenic drives that pass through the national forest. Issue 7, Recreation Opportunities/Experiences would include prescriptions for a wide variety of uses ranging from motorized to remote non-motorized backcountry. Issue 8, Roadless Areas/Wilderness Management would result in the recommendation of Roadless Areas contiguous to Wilderness areas being submitted to Congress for that same protection. However, some Roadless Areas would be compromised by "restoration maintenance" (prescription #9H). In all, 33,861 acres would be recommended for addition to Wilderness Areas.

Issue 15, Minerals-Recreational Gold Collecting was a relatively uncontested issue at the public meetings. All agreed that gold collecting methods that compromised water quality should not be allowed. The "rolling" alternative says specifically, "Water quality is a condition that takes priority over other resource uses such as recreational activities, road construction, and gold collecting, and so on."

"Use" Issues are the final category that you will have to endure, if you have made it this far. Use Issues are 5, 12 and 16. Issue 5, Wood Products suggests that "supplying wood products would not be an emphasis but would occur as a result of" other management activities. By a very conservative estimate, 50% of the prescriptions would allow timber harvests. The fact that timber outputs would decrease has more to do with past management and availability of wood than with the "restrictive" nature of present Forest Service policy. The Resource Planning Act (RPA) of 1974 requires the Washington office of the Forest Service to establish outputs of timber, recreation and other outputs based on certain budget levels. Therefore, the appropriate level of timber harvest is arbitrary when considered with market demand and forest capacity.

Issue 12, Access/Road Management deals with the massive road system on the national forests. The intention is to decommission unneeded roads and to improve more heavily used roads that are causing environmental damage. What will actually occur will have a great deal to do with the Transportation Policy Guidelines that are discussed briefly in this article. Issue 16, Special Uses deals with areas that are unsuitable for utility corridors or electronic sites. Military use is mentioned as well.

WASHINGTON OFFICE: Transportation policy

On January 28, 1998 the Forest Service gave notice of its intent to revise its regulations for maintaining roads within the National Forest Transportation System. On that same day a proposed interim rule was published that would suspend road construction and reconstruction in certain roadless areas until "new and improved scientific and analytical tools are developed to better evaluate the need for and effects of roads in sensitive areas." The final interim rule was published on February 12, 1999 and has been effective since March 1, 1999. According to an update on the proposed Road Management Policy, a draft environmental assessment has been completed and will be released at the same time that the proposed road policy is published. According to Forest Service correspondence, this information should be available on May 15^th. The interim rule will expire upon the adoption of a revised Road Management Policy or 18 months from the effective date, again March 1, 1999.

On February 28, 1998 the agency extended the public comment period on the proposed interim rule for an additional 60 days due to requests from individuals, organizations and elected officials. Ninety-six percent of the comments were from private individuals; 3% were from recreation user groups, wood products companies, and county, state, and federal agencies; while 1% were from "conservation oriented groups." According to the analysis prepared by the Forest Service, public comment was divided on most of the issues involved with the interim rule. Comments in opposition often referred to the interim rule as a "massive land grab" that violates the Forest Service’s multiple-use-mandate. On the other hand, comments in support generally cited scientific evidence that Roadless Areas were the cornerstone of ecological diversity, while a few claimed that the multiple use mandate was no longer feasible because society’s needs are far greater than the national forests can support.

As mentioned earlier, the final rule should be available by this summer. According to Forest Service correspondence the final plan will change road policy emphasis from road development to "sustaining access within the capability of the land." This would be accomplished by upgrading and maintaining roads that are important to national forest access; eliminating unneeded roads; requiring a scientifically-based analysis to build new roads; and, allowing local-level decisions with appropriate public involvement. Tougher standards would be set for building roads in Roadless Areas as well.

PRESIDENT’S OFFICE: roadless initiative

On October 13, 1999 a memorandum was sent from the President’s office to the Secretary of Agriculture directing the Forest Service to develop, and propose for public comment, regulations to provide appropriate long-term protection for most or all currently inventoried Roadless Areas, and to determine whether such protection is warranted for smaller Roadless Areas not yet inventoried. The Notice Of Intent (NOI) to prepare an Environmental Impact Statement (EIS) was published in the Federal Register on October 19, 1999. The rule making process is being carried out under existing laws and regulations governing the Forest Service and has involved the public in an open, participatory process by way of many public meetings across the nation.

The NOI is divided into two parts. The first part restricts certain activities such as road construction and reconstruction in the unroaded portions of inventoried roadless areas. The second part of the NOI seeks to establish procedures and criteria to be used by each individual forest to determine activities that are consistent with the values associated with Roadless Areas of ALL sizes. The Forest Plan Amendment and National Environmental Policy Act processes require active public participation, and it is the intention of this NOI that ultimately the agency’s final rule will be structured in a manner consistent with that input.

A large percentage of the over 380,000 miles of roads on National Forests and Grasslands are not maintained to federal safety and environmental standards. The Forest Service receives only 20 percent of the annual funding necessary to maintain roads that already have an $8.4 billion maintenance backlog. The cost of building roads into the few remaining Roadless Areas in the Southern Appalachians would only compound this problem. The difficulty and exorbitant cost of building roads into these areas would seem to suggest that it would be imprudent for the Forest Service to do so. The timber receipts from liquidating all the timber in these remaining areas would not begin to provide sufficient funding for this maintenance deficit.

NATIONAL FOREST MANAGEMENT ACT: proposed national forest planning regulations

Despite all the activity within the Forest Service at present, the most important initiative currently is the proposed revision of the planning regulations. As a result of the National Forest Management Act, regulations must govern the planning process such as the ones currently underway in the Chattahoochee and Sumter National Forests. These Forest Plans will replace the 1985 Plans structured under planning regulations that were developed in the late 1970’s and modified by the Reagan Administration in 1982.

The current proposed planning regulations would change many important aspects of this process including, but not limited to: the administrative appeals process; specifics relating to species viability; the suitability of lands in the national forests for salvage logging; and, the decentralization of the planning process. The existing administrative appeals process would be replaced with a "pre-decisional objection period," which would require objections to be filed within 30 days of the release of the final EIS. Inadequate time would be given for concerned individuals to prepare an objection, and there are no deadlines for the agency to respond. As well, citizens would not be able to request stays of activities pending an appeal decision, which the Forest Service Chief would no longer review.

The proposed "streamlining" of planning regulations was in part made possible by the fact that Forest Service planners said that they would place many of the specifics regarding the national forest planning process into Forest Service Manual (FSM) and Forest Service Handbook (FSH) direction. However, the Forest Service has decided against issuing draft FSM and FSH direction, and maintains that comments on the draft of proposed regulations will be used to inform the decisions on the draft Manual direction. The difficulty with this is that the Forest Service has never included the necessary instructions regarding the scope of comments requested. Essentially, the process is streamlined by excluding participation in a very important portion of the planning process.

In general, the proposed planning regulations limit the clear direction given to administrators at all levels in the planning process. These proposed regulations go so far as to say that "a topic...may require one or more Regional Forester or the Chief of the Forest Service to undertake planning and decisions which may amend one or more Land and Resource Management Plans" (Forest Plans). Essentially, many decisions would be made discretionary. This goal is further accomplished by making the Forest Supervisor, not the Regional Forester, the deciding official. A proposed regulation gives the Forest Supervisor the discretion to determine whether a topic is worthy of further consideration, resulting in this official’s opinion superseding all other information available on the topic. A Forest Plan revision is then redefined as being "completed when one or more of the decisions of a Land and Resource Management Plan are revised or determined to continue without change." The Forest Supervisor, with the new discretionary powers mentioned above, could decide that no changes are necessary in the Plan. Therefore the Plan is revised by definition.

The coming year promises to be a landmark time to help shape these new and very important initiatives aimed at managing natural resources on our public lands. The key will be active and informed input by citizens with a clear understanding of these issues. Please express your opinion to the Forest Service and Members of Congress. Make your voice heard! 

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