Another organization heard from.. TRCP
Here is the link.
Conservationists over the past year have warned the draft rule gives forest supervisors too much discretion to decide which species should be monitored for stronger protections.
Tom Franklin, director of policy and government relations for the Theodore Roosevelt Conservation Partnership, said resource monitoring is key if the Forest Service hopes to successfully implement adaptive management, which is designed to give managers the flexibility to modify projects as resource conditions change on the ground.
“They’re giving tremendous authority to line officers,” he said last June. “It appears the use of best available science is kind of optional in a sense. The line officer will determine when it is appropriate to use it.”
While forest planners are required to use best available science in decisionmaking, such information must only be “taken into account and documented,” rather than given a lead role in planning, the draft rule stated.
Now, why would “best available science” be given the “lead role” in plans?
Whose science, what discipline? Are these folks familiar at all with the field of science and technology studies or the difference between normative and empirical observations? Doesn’t it seem a bit odd not to use the “best scientific information” in determining the ways that the best scientific information should be used in decision-making?