76 



multiple use and the sustained yield of all resources is achieved. Meeting these re- 

 quirements often reduces the level of timber output that would otherwise be possi- 

 ble from a given area of land, but also increases other resource values. 



Integrated Standards and Guidelines in Management Prescriptions 



A management prescription includes combinations of management practices and 

 intensities for the various resources. A vital part of the prescriptions is the stand- 

 ards and guidelines associated with these practices. Each forest, using an interdisci- 

 plinary approach, develops their standards and guidelines consistent with existing 

 forest conditions, regional standards and guidelines, national direction, and applica- 

 ble laws and regulations. The standards and guidelines vary across the forest in 

 order to tailor the prescription to specific areas. 



Standards and guidelines are at the heart of forest planning. They are designed to 

 ensure the necessary integration and resource protection will occur and the multi- 

 ple-use goals and objectives will be achieved when the prescriptions are applied on 

 the ground. This includes consideration of the cumulative effects of both our own 

 actions and those occurring on other, nearby ownerships. It is also through stand- 

 ards and guidelines that the minimum management requirements discussed earlier 

 are incorporated into our plans. 



Question 19. The Forest Service has more than 500,000 timber sales annually, but 

 a large proportion of these sales is firewood permits, Christmas trees, and other per- 

 sonal use of wood from the national forests. Can personal use be segregated from 

 commercial operations? What standards or definitions are needed to distinguish 

 such programs? Are the size classes used for timber sales in the annual report ap- 

 propriate? What difficulties arise in TSPIRS in trying to separate these programs? 



Answer. Personal use harvest is separated from the commercial program in 

 TSPIRS. The program covers sales of forest products that are intended for personal 

 use and not for resale or remanufacture. Forest Service regions have limits they 

 place on the amount of product that can be sold under any one personal use permit. 

 The agency has recently developed new definitions for timber sale purpose catego- 

 ries, including the personal use category — a copy of the definitions is enclosed in 

 Appendix 2. [See page 88.] We believe that the size classes used in the annual report 

 are appropriate, although the information could be developed using different size 

 class information if needed. The separation of personal use in TSPIRS is relatively 

 easy after the sales are coded as to their purpose. We have experienced some prob- 

 lems getting the costs of the program coded properly in TSPIRS. Recent oversight 

 reviews of TSPIRS have indicated that some forests have not properly coded their 

 sale administration costs to the personal use category. Regional foresters have taken 

 steps to correct these problems. 



Question 20. Is a third category — minor commercial products or very small opera- 

 tors (e.g., five or fewer employees) or operations (e.g., less than one MMBF pur- 

 chased annually) — relevant, warranted, and feasible? How could such a program be 

 distinguished, in legal requirements and in reporting, from the personal use and 

 commercial programs? Is the originator of the sale (the purchaser or the Forest 

 Service) a relevant criterion? What difficulties might result, in TSPIRS and else- 

 where, from such a distinction? 



Answer. We currently have no data indicating the size of the company purchasing 

 timber other than the Small Business Association (SBA) classification. In order to 

 develop a class based on purchaser size, we would have to request this information 

 from each purchaser and would have no way to audit the information to ensure it 

 was correct. We could develop a class of very small operators based on the amount 

 of timber purchased from the Forest Service each year, but would have no way of 

 knowing how much private timber is purchased and processed by those companies. 

 This division would probably only be warranted if there was an intent to treat those 

 companies differently from others with regard to a policy on below-cost timber sales. 

 Potentially, current SBA classifications could be used for this purpose. It should be 

 noted that some analysts believe that the SBA program affects the below-cost issue 

 because revenues received for SBA sales are not as high as those for sales open to 

 competitive bidding from large businesses. We do not see the originator of the sale 

 being a relevant criteria since small companies buy both types of sales. As the 

 number of categories of sales increases in TSPIRS, the amount of effort and money 

 spent to track costs increases. There are options to separating costs for each catego- 

 ry, some of which would cost substantially more than the methods currently being 

 used but would not necessarily produce better cost data. 



Question 21. Please identify, for a recent FY, the number of sales and the volume 

 and value of timber sold in each national forest in each of these categories (personal 

 use; minor commercial; significant commercial) or at least by the classes used in the 



