Planning Rule Advisory Committee Recommendations

Received a press release today (copied below) about an independent advisory committee’s “recommendations for the implementation of the U.S. Forest Service’s 2012 Planning Rule.” The release doesn’t say much about those recommendations. Here’s a more direct link to the committee’s report:

A transmittal letter says “The committee spent the last year carefully reviewing, learning and building consensus recommendations on revisions to the draft directives (manual and handbook) in a stepwise fashion.”

Looks like there’s enough in the committee’s work for a year’s worth of blog posts. Here are a couple of items from the transmittal letter:

Desired Conditions and Natural Range of Variation (NRV): Both terms were defined to
improve clarity. Ensure forests understand that managing for NRV is not required by the
planning rule, and that forests can manage for desired conditions outside the NRV

Species Of Conservation Concern (SCC): The draft directives are ambiguous as to when
how, and under what process, identified SCCs become determined SCCs. Efficiency and
efficacy would be greatly enhanced by 1) clarifying the timing of SCC identification, 2)
stressing the regional forester SCC determination be made early, clarifying the role of
responsible officials and regional foresters in SCC identification and determination; 3)
directing the regional forester to provide public access to the list of determined SCCs, and
(4) encouraging that the expertise of local, state and Tribal agency expertise is utilized in
identifying SCC.

Lots more to digest.


For Immediate Release
Contact: (202) 205-1005
Twitter: @forestservice
Planning Rule Advisory Committee presents recommendations to Forest Service
Committee’s efforts help ensure new rule meets public’s expectations
WASHINGTON, Nov. 21, 2013 – A first-of-its-kind independent advisory committee presented its recommendations for the implementation of the U.S. Forest Service’s 2012 Planning Rule to U.S. Department of Agriculture Deputy Undersecretary Robert Bonnie and Forest Service Chief Tom Tidwell today, recommending strengthened collaboration, improved planning efficiencies and more effective and informed decision making.
The Planning Rule Federal Advisory Committee ( FACA) also made recommendations that strengthen ecological, social, economic and cultural sustainability objectives of the rule.  This includes  recommendations intended to deepen the level of stakeholder collaboration in forest planning, as well as recommendations regarding outreach, adaptive management, monitoring, wilderness, climate change, intergovernmental relations, species protection, and water resources.  
 The committee, formed in January 2012, advises the Secretary of Agriculture through the Chief of the Forest Service by providing advice and recommendations on the new rule and its directives. The proposed planning directives guide implementation of the planning rule which was published in the Federal Register in April 2012, and became effective a month later. 
“The members of this committee collectively bring to the table a vast amount of knowledge, passion and interest in our national forests and grasslands,” said Bonnie. “We thank this diverse group of members for their hard work in rolling up their sleeves to provide us recommendations on the 2012 Planning Rule.  This committee further illustrates our commitment to an open and transparent planning rule and process for implementation.
“This committee worked long and hard through a host of difficult issues to present us with these recommendations to help us manage our public lands for the greatest good,” Tidwell said. “The recommendations reinforce the importance of this Planning Rule and the role our national forests and grasslands serve for the American public – whether that be through recreation, clean water or supporting local economies.”
The committee is comprised of 21 members with varied backgrounds, who represent the full range of public interests in management of the National Forest System lands and who also represent geographically diverse locations and communities.
All FACA meetings are open to the public, and all proceedings and relevant documents are posted online.  The agency’s planning rule website has the latest information on the committee, the planning rule and its directives.
The mission of the U.S. Forest Service, part of the U.S. Department of Agriculture, is to sustain the health, diversity and productivity of the nation’s forests and grasslands to meet the needs of present and future generations. The agency manages 193 million acres of public land, provides assistance to state and private landowners, and maintains the largest forestry research organization in the world. Public lands the Forest Service manages contribute more than $13 billion to the economy each year through visitor spending alone. Those same lands provide 20 percent of the nation’s clean water supply, a value estimated at $7.2 billion per year. The agency has either a direct or indirect role in stewardship of about 80 percent of the 850 million forested acres within the U.S., of which 100 million acres are urban forests where most Americans live.
USDA is an equal opportunity provider and employer. To file a complaint of discrimination, write to USDA, Assistant Secretary for Civil Rights, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, S.W., Stop 9410, Washington, DC 20250-9410, or call toll-free at (866) 632-9992 (English) or (800) 877-8339 (TDD) or (866) 377-8642 (English Federal-relay) or (800) 845-6136 (Spanish Federal-relay).

5 thoughts on “Planning Rule Advisory Committee Recommendations”

    • I just don’t see any way that this will reduce the time it takes to renew Forest Plans, or reduce litigation. I waded through about a third of the recommendations and see that most of these definitions can be contested. I’ll bet that some lawyers are “licking their chops” over the new Rule. I know that the Sierra and Sequoia National Forests are working on new Plans but, the media hasn’t been detailing their progress. At least one group has a very long response to the draft, here. In browsing their response, they seek to add over 200,000 acres as designated Wilderness Areas but, Congress has to make those designations. They also want to add more Wild and Scenic River designations, even below reservoirs. They also want more of all kinds of “managed fire”, including Let-Burn fires. They sure don’t want to mention that “fires managed for ecological benefit” often turn into large and destructive fires that escape “containment” (meaning lines on a map, and not actual firelines, necessarily). Indeed, most Let-Burn fires do not have already-existing firelines, in place, until a full suppression strategy is in place.

      A 64 page response to the Sierra NF’s draft is not encouraging, within the framework of reducing the time and litigation associated with updated Forest Plans.

      • Long article on Greenwire (subscription) today: “Advisory panel optimistic about future of national planning rule.” Not much new, but here are a couple of excerpts:

        Previous attempts to update the rule in 2000, 2005 and 2008 drew lawsuits from the Center for Biological Diversity and other environmental groups and were either enjoined or abandoned, leaving the Reagan administration’s 1982 planning rule in place.

        The 2012 rule is ensnarled in a lawsuit of its own brought in August 2012 by more than a dozen logging, ranching and off-highway vehicle groups that argued it elevates ecological sustainability above multiple use (Greenwire, Aug. 14, 2012).

        But committee members from both the extractive and conservation community left yesterday’s meeting in Arlington, Va., hopeful that the rule will not be as contentious as many had thought.

        “I’m more optimistic,” said Tom Troxel, executive director of the Intermountain Forest Association in Rapid City, S.D., who said there is widespread dissatisfaction with the current 1982 rule. “This is a whole different model. With some luck, it’s going to work better for all parties.”

        Troxel and the committee’s co-chairs yesterday said members were able to find consensus on historically controversial issues including wilderness, wildlife protections and management objectives.

        For example, forest planners should not feel obligated to manage forests for their historical natural conditions. Rather, they should use those conditions to determine desired conditions, which could require active management to achieve resiliency to climate change and disease, the committee recommended.

        The committee also recommended clarifying which agency officials determine species of conservation concern, when those decisions are made, and the need for public input and transparency in those decisions.

        “That’s going to be a tough issue still, but I think we improved how it’s going to operate and how people are going to participate,” Troxel said.

        And this:

        Bill Imbergamo, executive director of the Federal Forest Resource Coalition, a Washington, D.C.-based group challenging the planning rule in a D.C. federal district court, said that the committee’s work helps but that litigants remain concerned with the underlying rule’s emphasis on sustainability and “restoration,” which he argued could trump productive, multiple use.

        “While the committee has made some improvements to how the rule is implemented, the rule is still the rule, and the lawsuit still stands,” he said. “It’s plodding slowly through the courts.”

  1. Another item from the committee’s letter:

    * Social, Economic and Cultural Assessment, Plan Components and Monitoring: To achieve
    the necessary parity between the Forest Service’s ecological expertise, greater clarity must be
    provided to ensure that the Forest Service will assess, plan for, monitor and adaptively
    manage social, economic and cultural questions that are important to those who rely on the
    forest and use the plan area and will put these priorities on par with ecological assessment
    at every stage.

    So now we have a four-pronged approach, rather than the three-pronged Ecological, Economic, and Social impacts/issues? Cultural would fall under Social, it seems to me, and adding Cultural weakens the traditional three.

  2. I have to disagree with the language from the FACA committee quoted here on NRV (and at the same time follow up on a point I made in my book club post on this topic).

    The rule says that a plan must manage for ecological integrity (219.8). Ecological integrity is defined for dominant ecological characteristics as being within the natural range of variation (219.19). Therefore the planning rule does require managing for NRV, and the directives can’t say otherwise.

    The rule does not define NRV, however, so the directives can take that on (within some limits imposed by accepted scientific concepts of integrity). The FACA committee deleted a line from the draft directives that tied NRV to historic conditions. However, it left a requirement that NRV consist of characteristics under ‘historic disturbance regimes during the reference period.’ There is some flexibility to determine the reference period, but this remaining language seems to foreclose using future climate projections.

    There is also a statement in the draft directives (that was not changed) that NRV ‘does not necessarily constitute a management target or desired condition.’ To the extent that this statement conflicts with the rule’s requirement to manage for NRV the directives language would have to be ignored.

    In response to Steve’s question about ‘cultural’ issues, I would agree that way the term is being used here it is probably redundant. I wonder if it was derived from county supremacy arguments that frequently use the phrase ‘custom and culture’ of local communities. (However, within the Forest Service, ‘cultural’ resources and uses are normally those with historic value, often Native American, and these are viewed as something different from ‘social’ considerations.)

    In response to Sharon’s comment on ‘commercial data’ in the planning rule lawsuit, that is a term used in ESA in addition to ‘scientific data’ as a requirement for decisions to list species and evaluate effects on species. Since neither of these processes can consider ‘commercial interests’, I’ve always thought the intent of this phrase was to distinguish between academic and commercial sources of scientific data. The plaintiffs may view this as a way of diluting the influence of scientists, but I don’t think there is any precedent for that interpretation.


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