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AOA Submits Comments to the Forest Service Planning Regulations; Asks for Equal Status for Recreation Component of Planning.
Comments on the Forest Service planning regulations that will govern how Forest plans are developed, revised, amended, and monitored are due by May 16, 2011. Forest plans along with specific resource management plans for Wilderness and Wild and Scenic Rivers determine how much recreation and which types of recreation can occur. The Forest Service is proposing more frequent amendments to Forest plans. The proposed regulations inlcude required plan components and monitoring strategies to enhance sustainable forest ecosystems and biodiversity. Candidates for “endangered or threatened” status under the Endangered Species Act may be elevated to the status of “focal species” before they are listed. In addition the agency may designate certain plants and animals “species of concern” and monitor their viability and limit human induced stressors. Forest plans are required to include components for social and economic sustainability, including “sustainable recreation”. Those plan components are guides, so the importance of a plan's recreation component may vary.
The rule states: “The proposed rule defines sustainable recreation as the set of recreational opportunities, uses and access that, individually and combined, are ecologically, economically, and socially sustainable, allowing the responsible official to offer recreation opportunities now and into the future.” “Socially sustainable” is not defined. AOA is concerned about how this term might be interpreted. The rule also states that recreation opportunities shall be coordinated with States, which according to a recent court ruling (Meister v. USDA Forest Service ) required the Forest Service to consider closing portions of the Huron-Manistee National Forest to certain recreation activities (in this case hunting), because these recreation activities were available on nearby state lands.
AOA’s comments also dealt with the elements of the rule that add complexity and barriers to the already overwrought permitting process. Permit holders may have to pay for higher levels of NEPA analysis or extensive monitoring through provisions in the Forest Service cost recovery regulation. The rule has the potential to expand the number of extraordinary circumstances and further encumber permitting. While all of these issues will not emerge in every Forest and some may be revised in the final rule, AOA feels obligated to raise them, especially since recreation clearly has a subordinate role in Forest mangement.
To view AOA’s comments and to find a Template to use to submit your own comments click here Look for Proposed Rules and Regulations in the list. The comment template is the second item down. You may also submit comments online http://www.govcomments.com/ Click on Forest Service Land Management Planning Rule. Be sure you put Forest Service Planning Rule comments as your subject. You can also fax in your comments using the number on the comment template on the AOA website.