Rulemaking:

National Forest System Land and Resource Management Planning Rules

Stated Purpose:

"Ensure that national forests are properly managed for multiple uses"

Summary of RSP Comment:

The proposed forest planning rules fail to solve the problems that originally led to planning, such as the incentives to emphasize timber over other resources. Nor, except for the elimination of the timber targets, do the rules solve the problems that planning created, such as polarization, the drain on Forest Service resources, and the fact that plans are obsolete before they are done.

Markets can help solve the problems that led to planning as well as the problem that planning created. While markets are not perfect, their imperfections will lead to far fewer problems than a planning process that spends more than one billion dollars yet produces no tangible results. The Forest Service needs to consider alternatives to planning and prominent among these alternatives should be an increased reliance on markets and incentive-based mechanisms.

Relying on markets does not necessarily mean turning the national forests over to private owners, but it does require that national forest managers act like owners. Rather than give resources away and get funding from tax dollars, they must bear the costs and enjoy some of the benefits of forest management. Forest users, meanwhile, must be allowed to purchase, trade, use, and not use forest products with a minimum of red tape and transaction costs. Use-it-or-lose-it requirements must be eliminated so that people can buy, for example, grazing or timber cutting rights and not exercise those rights if they so choose.

The difficulty with central planning as envisioned in the Forest Planning rule is the inability to collect and integrate all the data needed to understand a forest or alternative ways of managing that forest in a timely fashion. Planning requires special insights into the future, yet most of the predictions built into planner's computer models have turned out to be wrong. Finally, planning gives interest groups incentives to polarize the public rather than to cooperate with the forest service and each other.