by Norman L. Kincaide, Ph.D.
On February 17, 2026, the United States Forest Service (USFS) held a Cimarron and Comanche National Grasslands (CCNGs) Preliminary Plan Revision Webinar by Beth Davis, Land Management Planner, Plan Revision Project Leader, during which a maximum twenty-seven individuals participated. A follow up webinar with no formal presentation was held on February 25, thirteen individuals attended of whom six were USFS employees or contractors, discussing issues with the revised draft assessment. The objective of the February 17 webinar was to provide an update on release of the Revised Assessment and Public Comments summary. The Revised Assessment Vol. 1, Revised Appendices, Vol. 2 and Species Evaluations, along with the Public Comments summary, were uploaded to the USFS document hub. Furthermore, it was to share information on the purpose of the Need to Change, provide guidance on how the public can engage and inform this process, to share and discuss the public worksheet to prepare for the March 11th workshop. The webinar was also to brainstorm ways in which to reach and encourage broader public participation and remind participants where information exists on the Plan Revision Hub and to continue to build and strengthen community relationships. The Forest Service provided a timeline for engagement activities over the next few months.
There are five phases to the Plan Revision Process: complete an assessment of the plan area; identify the need to change the plan; develop the plan; develop the Environmental Impact Statement; Objection process and final decision. The process is currently in phase two: identify the need to change the 1984 plan. The Need to Change process gives focus to the planning process, defines the proposed action, the purpose and need, and the decision framework for the environmental analysis. The goal of the process is to collectively identify what is working and what is not. The Need to Change document has statements about what does and does not need to change. It is not a plan, it does not have a plan content, nor is it a list of solutions.
The Need to Change requires a clearly written document that describes what parts of the plan are to be changed and which are not. The information used to inform the Need to Change is the assessment for the plan, other documentation that supports a revision, biennial monitoring reports, and laws, regulations or policies. The content of the document includes: requirements of the planning process, process requirements from the 2012 Planning Rule and the National Forest Planning Act, what is not changing in the plan and what is changing in the plan.
Stating what is not changing in the plan further defines the work in plan development, which includes, things that are out of scope for the planning effort such as site-specific decisions, planning actions that will be completed later, and Congressional or statutory decisions and what management is working well and not expected to change.
The role of the public in the need to change process is to use government agencies, Tribes, and the public to help outline the content and direction for the need to change statements drafted by the USFS, opportunities to review development of the need to change document; and share the need to change with the notification of plan development and notice of intent to complete an environmental impact statement for the plan and provide an opportunity for public comment.
The participants are encouraged to provide their input. What is working well and why? What are the problems? Define the problem clearly. Why is it a problem? What is the desired condition you are comparing it to and what actions or conditions changed the desired condition? What needs to change to address these problems? What actions are within our control to address it?
To prepare for the Need to Change workshop on March 11, 2026, participants need to read the Need to Change frequently asked questions section. Review statement examples to be familiar with how these statements may appear in the need to change document. Take time to think through the questions on the need to change worksheets and record these thoughts so you can use them in the in-group discussions for this workshop or submit your thoughts if you can’t attend the workshop in person. This is an informal opportunity for all to better understand each other’s perspectives of what needs to change or remain the same and why.
Need to Change statement example: “Manage traditional resources uses: Livestock grazing is a traditional use that has been an important part of the local economy, lifestyle and culture for over a century. There is a need to ensure that rangelands are healthy and productive, and resilient to drought, fluctuations in climate and precipitation patterns, conifer encroachment and invasive species. The current plan components for rangeland management are outdated and insufficient to address management changes.”
The workshop will create a structured and respectful opportunity for the public to discuss diverse perspectives across the CCNGs. Continue to identify and gain shared understanding of how the public values the grasslands; identify and understand the areas that need to change or remain the same from the 1984 plan; identify some main themes for the need to change document; to inform on the next steps and opportunities to continue to share experiences and feedback for preliminary plan development for the vision and desired conditions of the grasslands.
Four worksheets identify discussion groups: Human use and Heritage Resources (recreation activities, developed and dispersed recreation, cultural and historic, access, scenery, socioeconomics); Active Management (fire and fuels, energy and minerals, range and grazing, air quality); Habitat Management (wildlife, plant, soils, habitats for at risk, species of conservation concern and endangered species); Water Resources (water quality, water availability, municipal waters, wetlands, groundwater dependent systems, riparian areas, fisheries)
“The first step in the plan revision process is to complete an assessment of the plan area. The assessment is a report that was developed with the public on the collective understanding of the existing ecological, social and economic conditions and trends in the plan area . . . Using the assessment along with information from forest or grassland biennial monitoring reports, information from the public, and changes to laws, regulations and policy, a document with need to change statements is drafted.”
Comparing the initial Draft Assessment on the CCNGs with the revised Assessment, the revision appears to be no better, shorter or less clogged with specious species of conservation concern. There is roughly the same page count as the initial Draft Assessment. There is no indication that public comments from September 2025 were incorporated or had any effect upon the revised document. The original was split into two volumes, with the appendices listed separately. The Public Comment summary does not give attribution for the statements as to who provided specific comments. There was no mention in the revised assessment that the original was produced by USFS contractor, AECOM. Was the revised assessment contracted out as was the original? Or was it processed in-house by the Forest Service? If the draft assessment phase has been completed why did a Forest Service employee during the February 25 webinar state that it was a “living” document amenable to change? Is it a final complete assessment or not? Or is the Need for Change part of the Assessment?
The CCNG Revised Resource Assessment document was announced as uploaded in an email the morning of February 17, the day of the webinar. As Tom Schultz, Chief of the Forest Service stated at a meeting with allotment owners in November 2025: “No one reads a 1500-page document.” Especially in one day during calving season. This process appears, again, to be the grinding indifferent, strict time line oriented, statute and regulation driven machinery of the federal government that does not take into account individual or group difficulties in complying with federal government processes. Furthermore, does lack of participation in the USFS webinars indicate a lack of faith and trust in the revision process? The Public Engagement Workshop will be held March 11, 2026, at Otero Community College Student Center Meeting Room, 4:00-7:30 MST, 5 PM-8:30 CST
Sources
USFS Webinar presentation slides, February 17, 2026
CCNG Draft Assessment
CCNG Vol. 1, Revised Assessment
CCNG Vol. 2, Appendices
CCNG Assessment Comment Summary
https://www.fs.usda.gov/r02/psicc/planning/forest-plan/grasslands-plan-revision-library
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