by Norman L. Kincaide, Ph.D.
The 1984 Management Plan for the Cimarron and Comanche National Grasslands was governed by the 1982 Planning Rule, 36 CFR part 219. The current Draft Assessment is governed by the 2012 Planning Rule (The Rule).
The preamble of the 2012 Planning Rule for land management planning recognizes that ecological, social, and economic systems are interdependent, without one being a priority over the other. As such, the Rule requires the consideration of social, economic, and ecological factors in all phases of the planning process. The Rule also recognizes that, though national forest management can influence social and economic conditions relevant to a planning area, it cannot ensure social and economic sustainability because many factors are outside the control and authority of the responsible official.
Plan components must contribute to social and economic sustainability within Forest Service authority and the inherent capability of the plan area. Economic sustainability refers to the capability of society to produce and consume or otherwise benefit from goods and services including contributions to jobs and market and nonmarket benefits. Social sustainability refers to the capability of society to support the network of relationships, traditions, culture, and activities that connect people to the land and to one another and support vibrant communities.
To address the issue of social and economic sustainability, within in the assessment for plan revision, the responsible official shall identify and evaluate existing information relevant to the plan area for 15 identified items: 1: Terrestrial ecosystems, aquatic ecosystems, and watersheds; 2: Air, soil, and water resources and quality; 3: System drivers, including dominant ecological processes, disturbance regimes, and stressors, such as natural succession, wildland fire, invasive species, and climate change; and the ability of terrestrial and aquatic ecosystems on the plan area to adapt to change; 4: Baseline assessment of carbon stocks; 5: Threatened, endangered, proposed and candidate species, and potential species of conservation concern present in the plan area; 6: Social, cultural, and economic conditions; 7: Benefits people obtain from the NFS planning area; 8: Multiple uses and their contributions to local, regional, and national economies; 9: Recreation settings, opportunities and access, and scenic character; 10: Renewable and nonrenewable energy and mineral resources; 11: Infrastructure, such as recreational facilities and transportation and utility corridors; 12: Areas of tribal importance; 13: Cultural and historic resources and uses; 14: Land status and ownership, use, and access patterns; and 15: Existing designated areas located in the plan area including wilderness and wild and scenic rivers and potential need and opportunity for additional designated areas.
Two types of indicators are required to measure the human relationship with the ecological environment: those that help to understand social and economic conditions in communities near the Grasslands and those that measure human uses of the forest’s lands and resources.
Indicators relevant to understanding social and economic conditions of the Grasslands include: population, age, racial and ethnic composition, employment, wealth, economic diversity, land use and access patterns, and area-specific values, beliefs and attitudes. Indicators to measure human uses and values of the CCNG’s land and resources include recreation visits, mineral removal, authorized animal unit months, payments to states and counties, Forest Service direct expenditures, and ecological integrities.
Other guidance to meet requirements of the Rule include Forest Service Manual 2380 and Landscape Aesthetics – A Handbook for Scenery Management, which describe the framework and contain additional information on the Scenery Management System. Public engagement and stakeholder input can be included to ensure that the values of the public and how they relate to and interact with the landscape can inform decision-making processes on desired scenic integrity objectives and plan components.
The Rule which establishes ecological integrity as the criterion under which to evaluate ecological consequences of landscape change. Ecological integrity is the quality or condition of an ecosystem when its dominant ecological characteristics occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.
This measure can inform planning priorities by identifying ecosystems that are threatened while identifying the features that have led to low integrity. In fragmented Comanche grasslands areas with higher ecological integrity can preserve biological variability and species richness and allow for species movement and recolonization to areas of lower integrity.
The Rule directs that forest plans must provide for sustainable recreation: “the set of recreation settings and opportunities on the National Forest System that is ecologically, economically, and socially sustainable for present and future generations.”
Among other plans considered in the Draft Assessment is the 2020 Colorado Forest Action Plan that seeks to accommodate Colorado’s goal of reducing greenhouse gasses that requires adopting a strategic carbon plan. As a result, a “cohesive, statewide strategic carbon plan for sequestration is needed to address many complex issues, including land-use planning and conversion; urban and community forestry; afforestation, reforestation and regeneration; forest age, structure and composition; timber and wood product markets; silvicultural practices; natural and uncharacteristic disturbance types and regimes; climate change; soil health; watershed off-site flows; carbon markets; and continued data collection, analysis and modeling.” To help meet these goals, lawmakers introduced House Bill 19-1261 (signed into law, May 30, 2019), which requires a statewide goal to “reduce 2025 greenhouse gas emissions by at least 26%, 2030 greenhouse gas emissions by at least 50%, and 2050 greenhouse gas emissions by at least 90% of the levels of statewide greenhouse gas emissions that existed in 2005.”
The 2023 Strategic Plan for Climate-Smart Natural and Working Lands (NWL) is referenced, which identifies priority actions across Colorado’s landscapes to reduce emissions, increase carbon sequestration, and create a climate resilient Colorado. While focused on climate mitigation and adaptation strategies, the Strategic Plan also values the multiple community and ecological benefits that NWL create and prioritizes diversity, equity, inclusion, and environmental justice considerations. Only by centering environmental justice and supporting disproportionately impacted and underserved communities can we ensure that our NWL are benefiting all Coloradans now and in the future.
The Strategic Plan evaluates ways to align state programs to promote climate-smart NWL and supports and leverages other state, regional, and local planning processes, including but not limited to Colorado’s Greenhouse Gas Pollution Reduction Roadmap, the Colorado Water Plan, Colorado Resiliency Framework, State Wildlife Action Plan, Forest Action Plan, Statewide Private Lands Conservation Plan, Regional Resiliency and Recovery Roadmaps, and sustainable land use planning efforts led by the Department of Transportation.
A 2024 State Wildlife Action Plan (Colorado) is also referenced in the Draft Assessment but a summary from AI came back with: “The Colorado Parks & Wildlife does not have a “2024” State Wildlife Action Plan, the most recent version is the 2015 SWAP. A new plan is under development with public feedback being sought for a future “2025” version.” To what degree will these referenced plans and plans within plans influence the revision process?
Staff shortages within the Forest Service raise questions about the quality of plan development within the time constraints of the current schedule to finalize a management plan. Changes to the management plan are supposed to come from the comments. Also, recent executive orders relating to National Forests do not necessarily apply to the grasslands since harvestable timber is not extant in the Grasslands and there is little oil and gas in Comanche, while the Cimarron field is declining.
From the September 9, 2025 chat, Beth Davis, Forest Service, Colorado: The Forest Service is not moving forward with Wilderness Designation for Picket Wire Canyon because of management conflict with Pinon Canyon Maneuver Site, which borders the proposed Wilderness Designation area. The Forest Service is moving forward with the next phase for Wild and Scenic River designation for the Purgatoire River.
Community Zoom chats by the Forest Service concerning the revised management plan were held September 4 (18 participants), September 8 (15) and September 9 (12), with another scheduled for September 16 at 5:30 to 7 P.M. With the twelve participants from August 26, 2025, the total number of individuals to these chats was 57. Of which 16 were private individuals. Otero County Commissioners Rob Oquist and Tim Knabenschue attended the September 4 chat expressing their concern on how the revised management plan may impact regional businesses, farms and ranches.
These chats hardly represent a minimum threshold of public outreach and engagement. The deadline for comment is September 25, 2025. How are residents of southeastern Colorado and southwestern Kansas supposed to digest a 1500-page Draft Assessment and comment under time constraints imposed by the Forest Service? How can a viable management plan revision be developed, when public outreach and engagement has thus far been minimal? Furthermore, it appears the Forest Service serves the 2012 Planning Rule as opposed the residents who live and work near the Grasslands.
https://www.fs.usda.gov/r02/psicc/planning/forest-plan/grasslands-plan-revision
Sources:
- 2012 Planning Rule, 36 CFR 219.6(b)
- Cimarron & Comanche National Grassland (CCNG) Draft Assessment Final 508 Revision, Appendix A, p. 1-2.
- CCNG Draft Assessment Final 508 Revision, Appendix D, p. 1.
- CCNG Draft Assessment Final 508 Revision, p. 20
- CCNG Draft Assessment Final 508 Revision, p. 115.
- CCNG Draft Assessment Final 508 Revision, p. 11.
- Colorado Forest Action Plan 2020, p. 16
- 2023 Strategic Plan for Climate-Smart Natural and Working Lands (Colorado), p. 5-6.