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A guideline to commenting on the forest plan revision


The current forest plans for the Nez Perce and Clearwater National Forests have measurable, quantitative standards. For example, streams have fishery habitat potential percentages based on cobble embeddedness (sediment), the agency must preserve minimum percentages of old-growth drainage-wide, and in some areas of the forests there are elk habitat effectiveness calculations. The draft plan, unfortunately, has few quantitative standards. Instead, the agency seeks to achieve the desired condition of “ecological conditions capable of supporting self-sustaining populations of native species,” a standard is to maintain the desired condition or to not “retard attainment of desired conditions” without more information, or to use “best management practices,” which offers no guarantees other than the Forest Service tried their best.


Current forest plans project timber harvest levels between 50-60 million board feet annually combined for these two forests. In the agency’s “natural processes dominate over anthropogenic influences” revision alternative (Alt Z), the one that is supposed to be the most environmentally friendly and ecologically driven, the Forest Service (FS) proposes to increase logging levels to 60-80 million board feet annually or by 1/3. Two other alternatives in the draft plan remarkably propose logging levels over 200 million board feet annually.


Greenhouse gas emissions are the leading cause of the earth’s rapidly changing climate. The leading sources of emissions are from burning fossil fuels and deforestation, which includes logging. Trees, however, can capture and store carbon dioxide, thus reducing levels in the atmosphere—this is called carbon sequestration. Pacific Northwest forests can sequester more carbon than other forests in the West.[1] Instead of specifically recognizing human-caused global warming, the FS states rather simply in the draft plan that we are in a natural warming period. In failing to acknowledge anthropogenic causes, the agency avoids discussing how its’ management actions might contribute to global emissions by substantially increasing logging (see above Logging) or how it could, instead, mitigate for it by preserving more of the Nez Perce-Clearwater National Forests.


The current Nez Perce forest plan has 26 management areas. The Clearwater plan has 17 management areas. Each of these areas is managed for specific values. For example, the Nez Perce forest plan has a management area for timber, where the goal is timber production. The revised plan for both forests, however, has only three management areas in total. One management area includes federally designated Wilderness and Wild & Scenic Rivers, meaning the FS cannot legally log in the management area, even if it wanted to. The other two management areas (MA 2 and MA 3) allow lots of logging, both in the frontcountry and backcountry.


Current forest plans have specific management areas for old-growth protection, as well as other areas where logging is prohibited. The revision would allowing logging in old-growth, and prohibit it only if the FS concludes that logging would not “likely modify the characteristics” of old-growth for more than 10 years. This is an incredibly squishy, qualitative conclusion that cannot hold the agency accountable. Species like fisher, pileated woodpeckers, and goshawks, which are all found in the Clearwater, are old-growth dependent.


Current forest plans on both forests acknowledge the potential for grizzlies to return to the Clearwater Basin. Several grizzly bear observations in the Clearwater were in fact confirmed last summer. The Fish & Wildlife Service (FWS) recently sent the Nez Perce-Clearwater Forest Supervisor a letter stating that the agency must consult with the FWS when projects may potentially impact grizzlies. Unfortunately, the new draft forest plan barely mentions grizzly bears, much less discusses essential migration corridors and the habitat security necessary for recovery. This is gross negligence on the part of the Forest Service.


Current forest plans have quantifiable standards for fish habitat, such as 300-foot buffer zones around streams and maximum allowed cobble embeddedness (percentages of rocks/pebbles not smothered in silt). The draft plan, however, effectively reduces riparian buffers to 150-feet, and doesn’t contain measurable standards to protect stream substrate. This could negatively affect macro-invertebrate communities and already imperiled fish populations.


There are 1.5-million acres of unprotected roadless areas on both forests combined. They provide crucial habitat for rare species because they are undeveloped. The draft plan, however, would not protect much of these irreplaceable wildlands from the maniacal logging alternatives and the roads, ostensibly temporary, needed to log them. There should be an alternative in the plan that recommends all 1.5-million acres for wilderness.


When the FS was developing alternatives for the revised forest plan (2014), FOC submitted an alternative, which used the best available science to advocate for measurable, quantifiable standards to be included in the new plan. Indeed, the agency received over 10,000 comments in support of the alternative. Yet, the FS refused to analyze the citizen-science alternative in the (2020) draft plan environmental impact statement. The agency did, however, develop an alternative around a local rural county’s desire to radically increase logging levels.

The public comment deadline is April 20, 2020. You can email your comments to sm.fs.fpr_npclw@usda.gov. Or you can mail them to: Zach Peterson, Forest Planner, Nez Perce-Clearwater National Forests Supervisors Office, 903 3rd Street, Kamiah, Idaho 83536.


[1] Buotte et al. (2019). Carbon sequestration and biodiversity co-benefits of preserving forests in the western USA, Ecol Appl. 2019 Dec 4:e02039. doi: 10.1002/eap.2039.