The Manti-La Sal National Forest Plan … and the Conservation Alternative

The Manti-La Sal National Forest (MLNF) is currently managing under a 34-year old forest plan, but for the past three years it has been preparing pieces (e.g., Species of Conservation Concern, Need for Change) for initiation of the Environmental Impact Statement (EIS) process that is supposed to then be completed within a year for a new plan (i.e., Final EIS and Record of Decision). 

A forest plan governs all aspects of management  on a forest (in this case, MLNF). This includes recreation, transportation, grazing, mining, logging,  wildlife, fish, roads, utilities, water, soil, fire, pinyon and juniper, aspen, wetlands, riparian areas,  climate, science, partnerships, Moab Geographic Area, Blanding watershed, Cultural Areas,  Areas of Tribal Interest, Research Natural Areas, wilderness, Wild and Scenic Rivers, etc.

For each of these areas the Forest will describe Goals, Desired Conditions, Objectives, Standards, Guidelines, and Monitoring. Each of these are defined in the Forest Service 2012 planning rule for forest planning.

The MLNF has three Ranger Districts. The Moab-Monticello District encompasses the La Sal Mountains, Abajo Mts and Elk Ridge, in Grand and San Juan Counties. The new District Ranger (located in Moab) is Michael Engelhart and the new Associate District Ranger (located in Monticello) is Louis (“Ted”) Neff. Both are archaeologists by background. The Ferron-Price and SanPete Districts span five central Utah counties.

Here is the tentative schedule from here on in, with what will happen at each stage:

• End of July/early August:  Release of an initial draft plan to Cooperating Agencies and Tribes for comments and suggestions. The public doesn’t see it.
• Last two weeks of August (?):  Posting of MLNF initial draft plan on MLNF website for the public. This begins the formal period of public commenting on the draft plan
• 7 days later: The reasonable Conservation Alternative, written by seven conservation groups over the past two years, is made public. The Conservation Alternative emphasizes: 
  • management changes that are needed in light of the climate crisis
  • increased responsiveness to public and tribal input; and 
  • prioritizing native ecosystems and native species over extraction and excessive recreational impacts.
• For 60 days (Mid-Sept to mid-Nov 2020): Everybody can submit comments on the MLNF draft plan and the Conservation Alternative, including, hopefully, requesting that the Conservation Alternative appear in the Draft EIS (see below) and supporting its management proposals.  Also, all scientific information, data, photos, etc. should be submitted during this period
• Mid-Nov 2020-Spring 2021: The MLNF develops a range of reasonable alternatives and compares them for their different environmental consequences.  We are aiming for the Conservation Alternative to be one of these alternatives.
• Spring 2021: Draft EIS (DEIS) is published, which begins the second major public comment period. For 60 days, everybody can submit comments. Did the DEIS include a full range of reasonable alternatives – including the Conservation Alternative? Is the DEIS ignoring scientific information that was submitted in 2020 during the scoping period, and which contradicts their conclusions? Did the DEIS ignore a significant comment of yours?
• Fall 2021: Final EIS (FEIS) and Record of Decision are published. Appeals? Litigation? Acceptance of the new plan?

Four notes about the Conservation Alternative:

• Legally, any EIS, including a forest plan, can include alternatives that have been developed by non-governmental entities.  Past examples exist. The alternative need only be “reasonable” and different than the agency’s alternatives. The federal agency, however, ultimately decides on which alternative or parts of alternative it will adopt in the Final EIS.
• The Conservation Alternative is the ONLY comprehensive, non-agency alternative that has so far been developed for any of the forest plan revisions currently underway in the U.S.  
• It is critically important that the Conservation Alternative be included, unaltered, in the Draft EIS. We have been talking with the Forest about this for three years.
• Support from our Grand County council, Moab City Council, and Castle Valley Town Council for inclusion of the Conservation Alternative in the Draft EIS will be crucial.

Coming in the future here on MADAR:  a description of significant differences between the Forest draft and the Conservation Alternative