The Draft Plan Reduces — Not Increases — Active Land Management

Despite agency claims at public meetings that the Preliminary Draft Plan promotes “active land management,” a closer comparison with the 1990 forest plans reveals this assertion is misleading. The revised plan does not expand tools for management, fails to restore historic motorized access, and instead introduces a regulatory framework that will further reduce the public’s ability to help steward these forests.

🔹 1. Minimization, Not Management, Is the New Guiding Principle

Across the draft, there is a noticeable shift in language from multiple-use and resource utilization to minimization of impact and limitation of access. Rather than encouraging activities such as thinning, prescribed fire, grazing, or sustainable harvest, the draft emphasizes preserving ecological conditions — often through restricting human activity.

This is a fundamental shift in management philosophy compared to the 1990 plans, which were rooted in active use and management.

For example:

• Desired Conditions now promote “natural processes” and “reduced human disturbance” rather than fire resilience, forest health, or economic output.

• New standards limit road construction and route maintenance, even where those tools are essential for fuels treatment, grazing access, or search and rescue.

  
  

🔹 2. Motorized Access Is Restricted Across the Landscape

The 1990 plans assumed forests were “open unless closed” — a principle that enabled effective timber operations, emergency response, and citizen access for firewood, forage, and hunting. The draft plan abandons that baseline, instead aligning with the 2005 Travel Management Rule framework of “closed unless designated open.”

The result:

• No protection for cross-country travel.

• ROS zoning (Primitive, Semi-Primitive Non-Motorized) covers large non-wilderness areas, effectively zoning them for closure.

• Travel management is deferred, but pre-decided by how the plan assigns these zones — limiting flexibility in future NEPA.

  
  

This undercuts the very foundation of motorized active management: the ability to reach project sites, haul materials, manage livestock, and access remote areas.

🔹 3. Grazing Is Significantly Reduced

While officials claim that grazing levels are “retained,” the facts show otherwise:

• The 1990 Wallowa-Whitman Plan allowed 227,000 AUMs.

• The current draft reduces that to approximately 112,000 AUMs, despite the fact that active permits currently exceed that figure.

• No corresponding analysis is presented to justify the reduction or show ecological necessity.

  
  

Additionally, new Standards and Guidelines add barriers to allotment renewal, increased exclusion zones, and greater seasonal restrictions — all of which will result in less grazing over time, regardless of what the plan superficially claims.

🔹 4. Traditional and Sustenance Use Is Marginalized

Rural Eastern Oregon communities rely on these forests not for recreation alone, but for livelihood and survival. Yet the revised plan treats human use as a disturbance, not a value.

• Gathering firewood, subsistence hunting, small-scale mining, and fuel treatment are all deprioritized.

• No language exists to protect local residents’ access for sustenance or traditional uses.

• Cumulative impacts of ROS overlays, road limitations, and access minimization will hit low-income and elderly users the hardest — especially those without the physical ability to access resources on foot or via non-motorized means.

  
  

🔹 Summary

In sum, the draft plan:

• Does not increase active land management — it reduces the tools and access needed to conduct it.

• Minimizes motorized access, limiting both public use and agency capacity.

• Reduces grazing capacity, despite no clear ecological justification.

• Zonally preconditions closures via ROS without the public process required by Travel Management NEPA.

• Removes the policy protections that allowed rural communities to sustainably use these forests for generations.

  
  

If anything, this plan reflects a philosophy of restriction, not stewardship — and it must be corrected before further damage is done to the communities that depend on these lands.