Comanche Grassland Management Plan Revision Governed by 2012 Planning Rule
- Anne Boswell Taylor
- 11 hours ago
- 6 min read
~Norman Kincaide, CNYW Contributor
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.
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.
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