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(/ . '. timber management.' The information developed duri"'the Stage II analysis can be useful to help entify the lands where timber ~duction is economicaJl.1y efficient, as well as to assist in the development of new prescriptions ~ich are more economically efficient when applied to specific analysis areas. The@ exten~ ~n which the Stage II analysis \~as used for this purpose shou~d !be dis 18 cussed in the planning records. If the analysis was not used for thlS ~- pose, an explanation as to why it was not is also necessary. 17 ., RESPONSE TO SPECIFIC ISSUES RAISED BY APPELLANTS This office agrees ",ith appellants that the planning documents for both !the San Juan and G~IUG provide inadequate information on, or discussion of, ltJhe economic implications of continuing and increasing a timber sales progcam where costs substantially exceed revenues and that the planning documents are not adequately responsive to Departmental policy in this regard. By tEni:s ~ecision the Chief is directed to cure this deficiency. Appellants also contend that the NFMA suitability regulations at 36 CFR 219.12 (b) violate Section 6 (k) of NJ:1.lA. The primary rationale for this con- tention appears to be that the regulations do not require that the ide~~ifica- tion of lands unsuitable for timber production be based solely on timbec re- lated economic criteria. Instead, the regulations result in timber land suitability being driven by the timber and other resource production goals that are inherent in the alternative that is selected. The NFMA regula.ltiions provide that the lands identified as suitable for timber production are !those which are the most cost efficient in achieving the gOnls of the selected ~l- ternative. Appellants correctly point out that under the regulations, l~nds that are uneconomic for producing timber on the basis of timber values and costs alone, can nonetheless be identified as suitable for timber production if the timber goals for a national forest are set at a sufficiently high level to cause this result. . It ',QuId be inappropriate for the Forest Service to evaluate timber sui!tabili- ty based on the economic efficiency of lands solely for the production <<llf tim- ber. As discussed previously, timber related investments often produce' <other non-timber outputs and benefits as joint products which must be conside'Ir\f'd in evaluating the suitability of land for timber production. Some of these joint products can be valued in dollar terms, while others cannot. National fumrest decisionmaking must consider both priced and non-priced objectives. Secttion 6 (k) of NF1'lA provides the Secretary considerable discretion to take intOJac- count both economic and other pertinent factors in identifying lands suiitt,able for timber production. It is clear that both the law and Departmental policy requi re that ecol!ll!llmic efficiency to be taken into account at many points of the planning process that ultimately leads to decisions as to the multiple use goals for whiCh the national forests will 'be managed and the management practices that will be applied to those lands. So long as economic efficiency is taken,into account, both as part of the process of selecting those goals and in meeting the :se- lected goals cost efficiently, the approach specified by the regulations for identifying lands unsuitable for timber production is a valid exercise of the Secretary ~f Agriculture's discretion. 186h - 11 - .. ... ". .. .. . ;. ... "-:.~ ~"i'!:".. . . - ... ..,:...........-......