Angeles Volunteer Association

SOURCE: USDA Forest Service, Pacific Southwest Region, December 31, 2001



Subject:  Sierra Nevada Forest Plan Amendment Appeal Decision

To:  Chief

In your November 16, 2001 appeals decision you stated that: "As I see it, the Forest Service’s mission is to work with local individuals and communities to protect and restore the health of the land. Partly, that means finding intelligent, farsighted ways of using some of our natural resources. Partly, it means working together to diversify economies while putting people to work for the health of the land. We need to accomplish our land stewardship goals by looking for creative new ways to get needed work done on the land, get products from it, and build communities together."

Your appeals decision will be the basis for how we will proceed.

In response to your appeals decision, I propose to immediately initiate a broad review of the elements of and basis for the Sierra Nevada Forest Plan Amendment and associated Final Environmental Impact Statement. In partnership with the Pacific Southwest Research Station, I propose to complete the review, implementation refinements, and any amendments, if needed, within 12 months.

In your appeals decision, you also stated that: "Our central mission is to sustain the health, diversity, and productivity of the Nation’s forest and grasslands to meet the needs of present and future generations. Over the last several years we have sought to accomplish this goal by building large scale, and sometimes overly prescriptive, management direction. I believe local decision makers acting in collaboration with interested and affected parties can develop flexible solutions that fit specific needs, rather than one-size-fits-all solutions."

Your statement clearly establishes a benchmark for our review. Our emphasis will be to develop flexible solutions primarily focused on improving local decision-making capabilities, while meeting our obligations under applicable environmental laws.

This letter summarizes my thinking as to how the review would proceed and amendments to the plan would be made, if needed. After your review of these initial thoughts, we will finalize our approach; the enclosed action plan provides further details.

Our proposed review will focus on the three key elements of your appeals decision, but I expect that the scope and substance of the review will be broader. For example, I expect to review and assess the decision in light of its effects on grazing, recreation, and impacts to local communities. I invite your continued suggestions for the work that lies ahead, and will confer with other agencies and interested parties as I proceed to design and implement the review.

Some refinements in the decision can be immediately identified and implemented, others are identifiable but will require a longer period of time to implement, and others must await the outcome of the reviews, and if needed, proposed amendments to the plan.

We intend to apply the principles of adaptive management to further refine and adjust implementation of the Sierra Nevada Forest Plan Amendment decision. The adaptive management strategy includes a comprehensive set of monitoring and research tasks that address the five main problem areas (old forest conservation, fire and fuels management, aquatic and riparian ecosystem conservation, lower Westside hardwood conservation and noxious weed management) of the Sierra Nevada Forest Plan Amendment decision.

The Plumas/Lassen administrative study also contributes to the adaptive management strategy for the entire Sierra Nevada. The Administrative Study investigates the response of California spotted owls and elements of their habitat to group selection. The study design is complete and immediately permits planning and decision making to proceed on implementation of group selection on 4,000 acres annually beginning in the 2002 field season. The administrative study examines how variables (owl populations, prey base, fire behavior, vegetation, and terrestrial bird community) respond to three different forest management regimes involving varying levels of group selection, Defensible Fuel Profile Zones (DFPZ), and area treatments. This work will examine the response variables over a range of spatial and temporal scales.

Additionally, I have decided to establish a small team to review the entire record (including the FEIS, the existing record of decision, public and agency comments, the appeals and responsive statements) to evaluate any needed changes to the record of decision, and if necessary, propose them. The team will tentatively consist of the following; however, I reserve the right to add additional people to the team and will notify you in advance should this become necessary:

This team will have access to the interdisciplinary team for assistance and analysis necessary to develop their recommendations. The review team’s top priority, until their work is complete, will be to assess the need for and, if necessary, develop a new record of decision based upon the alternatives described within the FEIS and your appeals decision. The team and I will share this assignment as our highest priority.

I will draw upon your appeals decision for general guidance in developing amendments. We are especially mindful of the fact that in your appeals decision you identified all or part of several alternatives in the FEIS that provided opportunities to meet a wide variety of goals without unnecessary risks to the natural resources of concern.


As requested, we will review the Sierra Nevada Forest Plan Amendment decision "for possibilities of more flexibility in aggressive fuels treatment while still providing short-term and long-term protection for wildlife and other resource values." We will re-examine elements of Alternatives 4, 6 and 7 that may deserve further attention, particularly the acreage of fuels treatments to reduce the risk of severe wildfire.

We will review the relationship between the Sierra Nevada Forest Plan Amendment decision and national wildland firefighting and fuels management. Specifically, we will review the Cohesive Fire Strategy (October 2000), the Western Governors’ Ten-Year Comprehensive Strategy (August 2001) and experience with the National Fire Plan to identify new science, policy, and approaches to land management that might help refine the Sierra Nevada Forest Plan Amendment decision

We recommit to the intent and objectives of the HF-QLG Pilot Project and embrace the spirit of community involvement that underlies the Pilot Project.

We will review:

We will use the results of the review to adjust our implementation of the Sierra Nevada Forest Plan Amendment. We will also propose a plan amendment that would allow implementation of the HF-QLG Pilot Project. If these activities take us beyond the authorized years of the HF-QLG legislation, we will continue implementation of the HF-QLG Pilot Project, as appropriate, under existing authorities to capture the full lifespan of the Pilot Project.

In addition to the three areas of concern identified in your appeals decision, we will also evaluate other issues raised in the administrative appeals. We are sensitive to the interdependence between family owned ranches and grazing on National Forests. We will review the Sierra Nevada Forest Plan Amendment for adverse effects that may lead to increasing urbanization of private lands adjacent to national forests. For example, we will carefully review the standards and guidelines that may reduce grazing such as those for willow flycatcher and Yosemite toad. In the spirit of your desire to: "work with local individuals and communities to protect and restore the health of the land," we will work with groups such as the Range 2000 Working Group to implement riparian habitat enhancements and restoration to attempt to maintain grazing near current levels.

We are also sensitive to the concerns from recreationists that the Sierra Nevada Forest Plan Amendment restricts their access to national forest lands. We will review standards and guidelines as to their effects on developed ski areas, recreation residences and other recreation uses. We will engage home owners associations, off road vehicle groups, the ski industry and others to assure that we have carefully considered their concerns.


During the first field season of the Sierra Nevada Forest Plan Amendment implementation, local managers employed an inter-disciplinary review to refine the wildland urban interface zone boundaries. Over winter and during the coming season, local managers will work with Firesafe Councils and other local communities to further refine the wildland urban interface boundaries and identify priority areas for aggressive fuels treatments.

During the first field season of the Sierra Nevada Forest Plan Amendment implementation, local managers identified three issues that, if clarified, might improve the flexibility of implementation and increase the likelihood of successfully achieving the objectives of the Sierra Nevada Forest Plan Amendment decision. They are:

These needed clarifications can be provided without changing the record of decision. Therefore, as an initial matter, I will be issuing clarifying direction about Sierra Nevada Forest Plan Amendment standards related to these concerns to ensure appropriate protection of wildlife habitats and provide for more effective treatment of fuels. This clarifying direction will facilitate implementation of strategic fuels treatments across the landscape.


At present, we cannot specifically predict the opportunities for increased flexibility in the Sierra Nevada Forest Plan Amendment decision that might come from the review of the areas of concern. However, several possible improvements in the decision were identified during the 2001 field season; taken individually and collectively, they may facilitate fuels treatments and accomplishment of the National Fire Plan. They are:



We recognize the need to carefully respond to the concerns identified in the appeals decision as quickly as possible. We expect to complete the entire response to the appeals decision within 12 months, including any proposed amendments to the plan. The management direction approved in the Sierra Nevada Forest Plan Amendment record of decision will remain in effect during the review, as affirmed by the appeal decision of November 16, 2001. The immediate actions component of the reviews will be completed between now and the next field season. The exact timeline for the long-term will depend on the outcome of the assessment phase of reviews, but we expect to complete those actions within 12 months. We will conduct our work, in an open, collaborative process.

We have enclosed an action plan that provides further details on the short and long-term actions we propose to address the concerns identified in the appeals and the decision.

I reiterate my intention to conduct a broad review of Sierra Nevada forest Plan Amendment. I believe that the scope of the review and subsequent refinements to the decision will necessarily be broader and encompass more steps than those summarized in this letter. To that end, I consider the review itself as a work in progress.

We look forward to this opportunity to further refine the progress that has already been made in stewardship of the Sierra Nevada National Forests.


/s/ Jack A. Blackwell

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