Framework for New Planning Rule Posted on Forest Service Blog

The concepts for the new framework are posted here.

Here are the questions:

Please take a moment to provide us with your thoughts on:

Whether the concepts are clear.
What you like about them.
If there are any major gaps or flaws in the approach.

We encourage posting whether on this blog or the official one or both..we’ll probably highlight and link here the ones we think most interesting on the official blog.

7 thoughts on “Framework for New Planning Rule Posted on Forest Service Blog”

  1. It has been a year since the district court in Citizens for Better Forestry tossed out the Bush planning rule. In that time, the Forest Service has been able to propose a new framework: “assess, plan, monitor.”

    God alone knows what great insights another year will bring.

  2. Preserve the ………. Controversy!!!!

    Preserve the ………. court profits!!!!

    Preserve the ………. eco-lawyers!!!!!

    Everything else is secondary.

  3. Sharon, I think the concepts are clear and the intent is clear. Bravo for trying to build meaningful monitoring and meaninful definitions of changes and needs into the process. I wonder if the “revised” plans will be able to add assessment chapters as needed to deal with the many “non-veg” issues we will be facing together? Seems like our forest plan’s existing chapters just don’t fit the topics of today, so revising them won’t be adequate.

  4. Here are some concerns I have about the general framework. I’m curious what other bloggers think.

    Our goal should be to complete Forest Plan Revisions in two years or less (assessments, plan preparation, public meetings, reviews – everything). But the framework elevates assessment as a prerequisite for planning. If assessments aren’t done, planning can’t start. Instead, since we’ll be doing an EIS, why not do the plan revision and the assessment concurrently like is done in the 1982 rule? Why do we need to do both an assessment document and an EIS document?

    Another concern is that the framework inexplicably never suggests anything is actually ever done, just monitored, assessed, and planned for. Even the 2005/2008 rule’s attempt to incorporate an Environmental Management System (EMS) contained a “do” step. For a Forest Supervisor that needs to devote more resources to planning and less resources on the ground, the framework suggests a potential “wheel of continuous torture”. I would hope that we can include in the planning rule a discussion of the relationship of planning to doing, and address issues discussed on this blog like adaptive management, what happens to projects when monitoring results show a problem, when we might want to be precautionary, or when we might establish “learning objectives” in the plan. We may also want to address Andy Stahl’s comments about the original intent of NFMA plans as a listing of projects, principally where timber is permitted in light of other multiple-use objectives.

    Finally, I’m curious if anyone else sees a disconnect between the idea of two levels of monitoring and assessment, but only one level of planning?

  5. Here is an alternative framework for the planning rule and the land management planning process. Does this make sense to anyone?

    (1) convene, learn and explore;
    (2) plan and commit;
    (3) implement and adapt;
    (4) continuously monitor, research, evaluate and assess.

    Convene, Learn and Explore
    This activity includes identification of participants, designing the planning process, visioning, scenario thinking, and goal identification.

    Plan and Commit
    This includes environmental assessment through the NEPA process, plan development (based on things that need changing from the old plan), “ground truthing” of ideas, and commitment to standards and “sideboards” for management.

    Implement and Adapt
    It’s not about developing perfect plans, it’s about plans that can be implemented. Adaptation can occur within the sideboards established in the plan.

    Continuous Monitoring, Research, Evaluation, Assessment
    Remember that the ONLY place that NFMA refers to assessment is at 16 USC 1604(g)(3)(C): “insure research on and (based on continuous monitoring and assessment in the field) evaluation of the effects of each management system to the end that it will not produce substantial and permanent impairment of the productivity of the land.” Note that this part of NFMA explains that the purpose of assessment is to provide a basis for evaluation of plan activities. It is related to monitoring, not the unanchored large assessment approach proposed in the circle framework. Also, note that the preamble to 16 USC 1604 explains that NFMA is part of the RPA “program”, not the assessment.

    So this step in the framework is about establishment of a “stream of knowledge” that would be available to tap when a forest planning process begins (the convene, learn, and explore step.) However, planning wouldn’t be held up if assessment data is not available.

  6. I truly think it would help, and maybe not now, but I would very much like to see an indepth analysis of the “No-Action” alternatives on Forest Service projects. This could reflect the consequences of litigation, and helps the judges to see the true effects of their decisions, and how they WILL affect lives of rural people throughout the west.

    This morning, I could hear the sound of bark beetles munching away on the pine next to my home. There’s an effect right there! Even with the coolish spring and late-coming summer, the bark beetles are already overwhelming forests in Central California. I’ve always suspected that large wildfires become huge sources of bark beetles, especially when there is a large chunk of it that takes sometimes years to die. Last year’s Yosemite burn might just be one of those areas producing clouds of bark beetles right now.

    Sooo, we already know that we have 22 million acres of dead and dying forests, as well as fires from the last 2 years that might have commercial quality timber in them. With fires expected to be averaging 10 million plus acres per year, how come there has been no mention of revising salvage policies?!? This fits in very nicely with the Rule changes and Vilsack’s speech about climate change, wildfires and bark beetles. Apparently, both the Obama Administration and the hierarchy of the Forest Service seems to be just fine with their current salvage program the way it is. *smirk*


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