Draft Planning Rule Framework – July 2010 concepts

Possible Planning Rule Framework -- Schematic

This post will lay out the overall framework that we are considering for the structure of the rule as well as for land management planning. This new framework was designed to address key themes we heard during our collaborative efforts, as well as incorporate lessons from our history of land management and past rules. Since we intend to organize the rule around this new framework, we will really be looking for your feedback to let us know we heard you and are on the right track. Subsequent posts will share our ideas for addressing specific topics through the framework, such as the all-lands approach, public involvement, and other critical issues discussed at the roundtables.

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.

During our collaborative effort to develop a new planning rule we’ve heard an incredible range of opinions. Within this range, we’ve identified areas of consistent agreement. People agree that the planning process needs to be simple but effective. There is agreement that the planning rule should be developed to persist through changing times. We heard that the new planning rule needs to build in up-front collaboration that focuses on national forest system units (NFS units) which includes national forests, grasslands and prairies taking into consideration the landscape beyond the boundaries of the NFS unit. We also clearly heard that the new rule needs to include a strong monitoring component that improves accountability and reinforces the need to work with cooperators and partners through a mutual learning process.

We are proposing a new planning framework that is responsive to what we’ve heard throughout the collaborative process. The framework we are suggesting represents a shift from how planning has been viewed in the past, and from the way past rules were constructed. This new framework will provide a blueprint for the land management process, creating a structure within which land managers and partners can work together to understand what is happening on the land, revise management plans to respond to existing and predicted conditions and needs, and monitor changing conditions and the effectiveness of management actions to provide a continuous feedback loop.

We believe the new framework will move us away from “once in a generation” planning toward a more responsive and agile process that allows the Agency to adapt management to changing conditions and improve management based on new information and monitoring. We also believe the framework will support a more integrated and holistic approach to management, recognizing the interdependence of each part of the ecosystem. This interdependence includes the communities (biotic and human) and systems (functions and values) that are part of each forest.

The Planning Framework:

(Link to an interactive graphic of the framework.)

The framework consists of a three-part planning cycle: 1) Assess, 2) Revise/Amend, 3) Monitor. Each responsible official would move through the planning cycle in a collaborative way, moving towards an adaptive loop that improves management and accountability, and is triggered by new information and changing conditions on the ground. Through the process, each responsible official would:

(1) Assess conditions and stressors on the NFS unit and in the context of the broader landscape;

(2) Revise or amend land management plans based on the need for change (identified through assessments); and

(3) Monitor to detect changes on the unit and across the broader landscape and to evaluate the ability of management actions to produce desired outcomes.

Collaboration is a critical component throughout this three-part planning cycle. This framework would give our land managers guidance to engage the public and partners before, during and after plans are written.

Assess

In the assess phase, the responsible official would conduct a review of conditions on the ground and in the context of the broader landscape, using available ecological, social and economic data to the extent possible.

The purpose of assessments would be fourfold: (1) to develop upfront collaborative relationships among government entities, tribes, private landowners, and other partners and interested parties; (2) to develop an understanding of existing and predicted conditions and management needs on the ground; (3) to develop a mutual understanding of the complex issues across landscapes as well as roles and needs of various stakeholders; and (4) to enable each NFS unit to identify distinctive contributions or niches within the landscape and determine the need to change land management plans. The desired result is a shared vision of how to proceed with management actions within the broader landscape context. The scale of assessments would vary depending on the landscape and issues of concern. When critical gaps exist, the responsible official could work with partners and other interested parties to collaboratively prepare new assessments, some of which might encompass areas beyond NFS unit boundaries.

The assessment phase would build in collaboration and dialogue with partners and interested parties. This responds to stated desires for early collaboration—well before a proposed action—so that stakeholders can engage in joint fact-finding and develop a mutual understanding of the interconnections among social, economic, and ecological communities and systems.

Example 1 All- lands: We discussed the all-lands approach, which would lead to understanding each unit in the context of the broader landscape, in many of the roundtables. Building that approach into the new framework, in the assess phase, the rule could require that responsible officials review other relevant resource or land and water assessments, such as the State Forest Resource Assessments required by the 2008 Farm Bill or wildlife conservation plans.

Example 2 Water Resources and Watershed Health: We discussed understanding and protecting water and watersheds for humans and the environment at many roundtables. Building water concerns into the assess phase, the rule could require that responsible officials review what water resources are on the NFS unit and where water is flowing into and out of the unit, build understanding of what values that water is providing or supporting, and assess what positive or negative effects forest management or stressors are having on the resource.

**Please note: these examples are just snippets to spark your thinking and build understanding of how the framework would incorporate specific issue topics: later posts will focus on the major issues discussed at the roundtables.

Revise /Amend

In the revise or amend phase, the responsible official would work with government agencies, tribes and the public to use the information gathered in the assessment phase, including partnership roles and the need for change within a landscape context, to shape a proposed action that responds to the need for change on the NFS units. The responsible official would continue to work with the public through this phase, within NEPA requirements. This approach encourages the development of a proposal that has fully engaged the public. As part of the formal revision/amendment process, the responsible official would initiate the notice to begin the NEPA process. Alternatives to the proposed action and environmental effects would be included in the NEPA document, and a decision document would approve revisions or changes to the plan. Plans would continue to include components required by NFMA, as well as requirements identified in the new planning rule.

The revise/amend component of the framework responds to the public desire to help develop proposals for land management plans. Additionally, this approach could make the NEPA process more efficient by using information developed during the upfront collaborative assessment.

Example 1 All-lands: Building on what was learned about habitat conditions and trends in the assess phase, land management plans could include desired conditions and objectives for how management actions on the NFS unit could contribute to reconnecting corridors for wide ranging species.

Example 2: Water Resources and Watershed Health: Building on what was learned in the assess phase about the conditions and trends for water, land management plans could include desired conditions and objectives for watershed health and public water supplies. A specific example of this might be riparian area restoration.

Monitor

In the monitoring phase, the responsible official would implement a monitoring plan to determine the level and effectiveness of implementation on the unit and changes across the broader landscape. This will give managers data to evaluate management actions and make adjustments to both projects and to the land management plan, where needed.

The planning rule would recommend that each planning unit develop a land management plan monitoring strategy using a two-tiered approach: (1) monitoring at the planning unit level, and (2) monitoring at the broader landscape scale. Unit-level monitoring would be focused on detecting changes on the unit and determining how well the land management plan is being implemented and how effective management actions are in achieving objectives and moving toward desired conditions. Each NFS unit would be responsible for creating and implementing the unit-level monitoring plan, in conjunction with partners and scientists. NFS unit supervisors would participate in landscape-scale monitoring plans and strategies developed collaboratively by one or more regional foresters, Forest Service research station directors, other government entities, private landowners, and others, and would be designed to detect changes caused by stressors outside the control of an individual NFS units. Landscape level and unit level monitoring would compliment each other and would be focused on questions related to land management plan implementation.

The monitoring component of the framework responds to stakeholders’ desire for a systematic, unified, monitoring approach rather than “random acts of monitoring.” They want a system that will track issues that transcend national NFS unit, such as wide-ranging wildlife species at risk. Both stakeholders and the agency recognize the potential efficiencies of a unified monitoring approach and hope to increase information sharing and learning opportunities.

Example 1 All-lands: Monitoring for habitat connectivity may occur at the both the regional and unit level and may answer questions about the conditions and tends of wildlife corridors across the landscape and about how well the NFS unit is doing in meeting objectives for habitat connectivity within the unit.

Example 2 Water Resources and Watershed Health: Based on a Plan objective for riparian restoration, we could monitor how much restoration had been accomplished and how effective the treatments are for meeting objectives like improving stream bank stability, reducing water temperatures or improving habitat.

Comments
27 Responses to “Draft Planning Rule Framework – July 2010 concepts”
  1. Grey Hayes says:

    I agree with other comments on the need for 1) SMART objectives (specific, measurable, achievable/ambitious, realistic, and time delimited) and 2) detailed thresholds that would trigger changes in management- this is state of the art and where land management science rests currently.

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  2. W.V. (Mac) McConnell says:

    Here’s a comment for the Planning Rule Framework Blog that I was not able to submit via the usual channel because it contains graphics that are needed to clarify the text. I felt compelled to write this comment because I’ve been continually astonished by how little the public, their elected representatives and, yes, Forest Service line and staff officers know about what’s happening on their national forests. Attempting to plan, manage and legislate without this background can end only in failure, which is certainly what we have today (See the attached graphic for the Dixie N.F.!).

    Mac

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  3. Dawn Lipton says:

    I read the FAQs trying to understand how the list of 8 topics that have been developed failed to include the globally important topic of “sustaining biological diversity.” This topic isn’t overlooked in the 1982 planning rule, and we understand more about the serious implications of biodiversity loss today than we did in 1982. The FAQs state that “The principles suggested in the NOI reflect modern challenges that we know land managers will face, including addressing climate change, restoring forests, protecting watersheds, supporting local economies, improving collaboration, and working across landscapes. They were developed from a variety of sources, including: new understanding about emerging challenges such as climate change; agency planning experience over the last 27 years; public comments on past planning rules; the 1990 Critique of Land Management Planning; the 1999 Committee of Scientists’ report; and updated suggestions regarding contemporary planning practices from professional planning associations.”

    After reading this I’m even more confused by the omission. How can the FS envision that maintenance of biological diversity is not a modern challenge of upmost importance, deserving of specific principles addressed in the plan? The global challenges and ecological implications associated with maintaining biological diversity are outlined in numerous scientific publications and were important enough to spawn the Convention on Biological Diversity at the 1992 UN Conference on Environment and Development (the “Earth Summit”). 192 countries, plus the EU, are now Parties to that convention. With the serious implications of species extintions, habitat loss, and losses of gentetic diversity being closely related to land management approaches and strategies, how can this topic be so avoided or discounted in the planning rule framework?

    Silence on this challenge will do little to promote the agency’s scientific credibilty. If the intent is to subsume this important topic in a broader “motherhood” topic or statement, such as “resilience” or “climate change” it shows little committment to truly addressing the difficult challenges and choices faced in land management planning. I would love to hear from anyone who can help me understand this omission.

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  4. slucero says:

    Under the current concepts the final decision on Management Plans will be done by Unit Line officer or Regional (Forest Supervisor or Regional Forester). There needs to be oversight of final decisions (currently the objection procedures allows for objection before final decision).

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  5. Kevin Hood says:

    1) The quickest way to have a court throw out this new rule as unconstitutional would be to curtail the right to litigate. Congress has consistently upheld the right and responsibility of the people to oversee and balance government land management actions. See: the National Policy Environmental Act, the Administrative Procedures Act and other laws securing public review. A more practical approach would be to set up an office/branch that compiles lessons learned from lawsuits such that we can inform planners where we have been deficient and where we have been reaffirmed.

    2) The Multiple-Use Sustained-Yield Act defines multiple use as:

    The management of all the various renewable surface resources of the national forests so that they are utilized in the combination that will best meet the needs of the American people; making the most judicious use of the land for some or all of these resources or related services over areas large enough to provide sufficient latitude for periodic adjustments in use to conform to changing needs and conditions; that some land will be used for less than all of the resources; and harmonious and coordinated management of the various resources, each with the other, without impairment of the productivity of the land, with consideration being given to the relative values of the various resources, and not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output. [16 U.S.C. 531]

    This deliberate language mandates a comprehensive consideration of all of the resources afforded by national forests – not just timber. This also includes resources that may not have been previously considered, such as biodiversity, carbon sequestration and wilderness solitude.

    3) The law mandates that we manage “without impairment of the productivity of the land.” It follows that we must identify “stressors” and mitigate their effects, or at least have indicators and standards that establish thresholds triggering action (or perhaps a ceasing of action) such that “impairment of the productivity” does not occur.

    4) As noted by Jim Gerber, plans should state desired future conditions for the forests and then have clear goals to achieve those conditions and quantifiable objectives to mark progress.

    5) If we want true collaboration, there will be processes where people can attend in person as well as processes allowing on-line participation. Using the Wiki approach to allow the public to create/modify NEPA alternatives for plans would be an example of the latter.

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  6. NIck Dennis says:

    The monitoring component of forest planning is described as containing two levels: the planning unit (i.e., national forest) and a larger “landscape” level. “Landscape” is a flexible term, often referring to any expanse of land the user desires. Traditionally, it connotes an area that can be viewed from one vantage point. But I’m not sure I’ve ever seen “landscape” applied to an area larger than a national forest, which typically comprises 1-2 million acres and can rarely be viewed from one vantage point. When discussing an area larger than a national forest, I suggest using the term “regional” rather than “landscape”.

    A national forest is a large area to monitor. I see the utility of coordinating with neigbors to understand regional processes such as migratory wildlife population health in relation to broad habitat patterns. I don’t see much utility in monitoring at both the forest level and the regional level; both scales are so large it’s hard to envision distinguishing separate processes relevant to being monitored at one scale versus the other, or separate methodogies to apply at either scale. More actionable information (which, in the context of adaptive management, is the objective of monitoring) would result from monitoring at the sub-forest (e.g., ecosystem) level, in conjunction with the regional scale.

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    • ccairnes says:

      Being able to monitor forests from multiple levels using new technologies makes it possible to distinguish separate processes, up to and including on the global scale. The forest I work in is not 1-2 million acres, it is 17 million and a significant absorber of CO2 from the atmosphere. Fisheries are being effected by ocean acidification caused by the ocean absorbing the excess atmospheric CO2 from a combination of emissions and deforestation. The most significant contribution the forests have to make are as global ecosystem managers. The 1 or 2 million acre forests can be assessed as carbon sequestration units and manged to remove CO2 from the atmosphere and filter water. No one is immune to nature. Eventually we will have to take the natural world into account as being more than either open to commercial harvest or reserved as wilderness.

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  7. Tom Shea says:

    It all sounds confusing to me. I just want to know, at the end of all this, will I be able to use my forest more or less? So far, it is much, much less.

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  8. John Keeler says:

    Having watched the FS Planning Process for 36 years I have seen progress made in many areas. Standards and guidelines have been refined, Monitoring has advanced from Occular Reconn to in-depth studies. Coordinated Management has given way to Collaboration. Each has possesed some opportunities but the realization of those opportunities has fallen short because of litigation. If all the money spent on lawsuites would have been put on the ground in improvement projects the forest would be in much better condition. There must be a mechanism put in place to discourage litigation and encourage partnering where partners “put their money where their mouths are” If you are a partner in the planning process then you work to develop a plan and then work to implement that plan. You contribute money, time, resources, expertise, etc. If you are a partner then you limit your ability to sue the plan. I have watched time and time again when hundreds and hundreds of human-hours were put into a plan only to have it litigated in the end. This is a waste of time, money and the resource. This framework is good just like other plans were good but let’s make it worth the time and effort by stating in the framework what is required to be a partner.

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    • ccairnes says:

      If, when a lawsuit is brought against a decision of the Forest Service that wastes time, money and resources, the Forest Service were more willing to reconsider the decision, then more time, money and resources could be spent on the forest’s needs than the attorney’s fees.

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      • Fotoware says:

        “Legal Monkeywrenching for Fun and Profit” sums up the desire for eco-groups to litigate government projects. This practice will continue until lawsuits become a break-even situation. Why do they charge the government $600/hr for their lawyers and $300 for their assistants? Do you really think that is what the Sierra Club pays their people?!?!

        It is quite easy to find conflicts in the rules, laws, policies, memos, directions, decrees and “widely-shared public views”. The Forest Service is a fat and juicy target, a true “cash cow” for the eco-extractive industry (meaning the extraction of project dollars from the USFS).

        The Sierra Club and the CBD have both vowed to continue their fights in the courts, and want no part of any consensus or compromise.

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  9. Steve McNulty says:

    Generally, I like the approach, but have two suggestions.

    1) Tip O’Neal was quoted as saying “all politics are local”. The same could be said for decision making, assessment and monitoring. Another layer should be added before the landscape scale called “point level, site level, watershed level” or the like. This is the scale at which monitoring and field assessment will occur. It is the integration of this scale that becomes the landscape level scale (and the integration of the landscape scale that becomes the NF scale). Without this extra level of resolution, there will be a disconnect between the monitoring and assessment.

    2) Forecasting is not expressly mentioned in the framework. Monitoring will be useful for examining historic trends but we need forecasting to tell us what to monitor, and what to look for when we monitor. No assessment would be complete without an examination of historic AND projected trends. Without this knowledge, modification of management plans would be dangerous, especially under conditions of a changing climate.

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  10. Sounds good, but have they tested that framework yet? I guess time will tell, let’s give it a shot.

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  11. The New National Forest Planning Rule framework does not sufficiently address the principal defects in the Old Rule that have led to the collapse of the planning process. The defects, as seen by the courts, lie the National Forest Management Act (NFMA) implementing regulations, i.e. 36 C.F.R. 219.

    Every significant NFMA lawsuit probes the meaning and wording of the 219 regulations. It is those regulations that litigants and the courts have used for years to subvert the planning process.

    If the Forest Service is to truly repair the planning process, they need to do so by revising the 219 regulations in a manner consistent and compliant with the National Forest Management Act (16 USC Secs. 1600-1614).

    The fix is not to insert new words like “stressors” or “climate change” into the 219 regulations, words which are not found in the NFMA or in other enabling Acts of Congress. The Forest Service has already inserted a passel of new words into the 219 regulations which are not found in the Law. Such words as “sustainability” befuddle the regulations. That word was derived from the Multiple Use Sustained Yield Act (MUSYA) which mandated sustained yield of timber and nothing more. But Forest Service planners, following the latest planning fads, morphed the MUSYA mandate into sustainability of who-knows-what.

    Key words like sustainability, diversity, ecosystem management, ISO, etc. are not found in the NFMA although they now appear in the 219 regulations (“diversity” is found in one place in the NFMA and is conditioned by “based on the suitability and capability of the specific land area… where appropriate… to the degree practicable… “).

    Therein lies the problem. The NFMA was not meant to be a blank slate for whatever current fads forest planners chose to follow. The 219 regulations must adhere to the original enabling Act of Congress, the NFMA.

    Provision of water quality and water production is found in the NFMA. So is provision of wildlife, fish, soils, food, fiber, timber, recreation, and esthetic values. Through the NFMA, Congress directed the Forest Service to “adequately protect forest and rangeland resources from fire, erosion, insects, disease, and the introduction or spread of noxious weeds, insects, and animals.”

    Those are statutory mandates, straight from Congress. The Healthy Forest Restoration Act (16 USC 6501–6591) and the Forest Landscape Restoration Act (PL 111-11) are also statutory mandates, Acts of Congress that the Forest Service must obey.

    The Forest Service must make the 219 regulations (36 C.F.R. 219) consistent and compliant with the Law. Nothing more, nothing less. Until the Forest Service complies with the Law, and only with the Law, the entire planning system will be a bottomless morass, and forest planning and management activities will continue to be paralyzed.

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  12. Lockjaw says:

    M Armstrong’s comment from July 14, 4:50 pm are right on. Please carefully consider the remarks.

    Thank you

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  13. Steve Graham says:

    The terms “stressors”, “need for change”, give me a sinking feeling. This document gives me no faith that this proposed process will be any less muddled and difficult than the system that is currently in place.

    Anyone who expects a “shared vision”, especially after “collaborating” with all “stakeholders” has never been to a meeting regarding public lands.

    I predict the NFS will solve this problem by simply allowing “Watershed Health” issues to trump all others-resource, recreation, or otherwise. Can another term have such wide ranging jurisdiction and ramifications?

    A rising population brings increased demands on the land whether it be energy, mineral, timber, recreation, or otherwise. More rules, fewer roads, and more conservation makes me say Goodbye to the Great American West, the culture, and way of life that utilized the natural resource wealth of our nation to drive the U.S. economy.

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  14. treelady says:

    In one of the national forums the word “elegant” was used as a potential goal for the language in the planning rule. I believe the three-part framework is a great start. I was happy to see the framework wasn’t loaded up with a bunch of buzzwords and didn’t stray into unknown territory as the 2005 rule did with the EMS debacle. Of course the word “collaboration” is a buzzword and it is certainly overused these days. Many of us recall that one definition is “working with the enemy,” circa WWII. But in the context of national forest planning it CAN mean learning together about our natural resources and their uses, identifying common ground where it may exist, and developing plan language acceptable to most prosess participants, even if with reservation given the diversity of passions that people bring to the table, and given the sideboards of law, regulation, and policy.

    Three suggestions to the rule writing team:

    1. As you fill in the details under each part of the framework, continue down the road of simple and straightforward and using words that are clearly understood..

    2. If you use examples in the future, INCLUDE RECREATION EXAMPLES!!! Every forum I watched/participated in noted the downplaying of recreation and uses of the forest in the NOI. The forest service folks responded, “We here you! We hear you!” Let’s start to see real evidence of that.

    3. Beware of making the amendment process so onerous that managers shy away from amending their plans.

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  15. Fotoware says:

    This comment was imported from the old blog so that the full conversation on the framework could be viewed in one place.

    My assessment is that we have 22 million acres of dead trees, we have legal
    gridlock in the courts, and we have assurances from the preservationist
    industry that they will litigate until the Forest Service timber sale program
    has ended.

    I’m just not seeing any of this being “planned” for, other than
    letting it all burn.

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  16. Jim Gerber says:

    This comment was imported from the old blog so that the full conversation on the framework could be viewed in one place.

    It sounds like you listened and heard what the public said fairly well. I
    commend you for that.

    I do have a few comments however. I do not see anything about developing a
    desired future condition (DFC) for the forest, or for that matter, formulating
    goals, objectives and standards and guidelines.

    I do not understand how a Forest can prepare a forest plan without first
    determining what people want the forest to look like, and be like, in 40 or 50
    years. If a Forest does not a compass pointing it in the right direction (the
    DFC) it is like a ship at sea without a rudder; goes in whichever direction the
    wind is blowing. A Forest will never reach its destination (future desired
    condition) except by coincidence. Management by coincidence is not a great way
    to manage a Forest!

    I would expect the DFC would come at the end of the 1st step in the framework;
    the assessment. At that point the Forest should have developed a collaborative
    relationship with the various user groups so that a shared vision for the
    forest in the future could be developed.

    Next step would be to develop goals, objectives and standards and guidelines
    for the Forest (I also did not see these steps identified in the framework).
    Goals are established to meet the DFC and quantifiable objectives are produced
    to meet the goals. Standards and guidelines are needed to achieve management
    practices that accomplish results on the ground in the most environmentally
    sound manner. I see these steps being accomplished in the Revise/Amend portion
    of the framework.

    Quantifiable objectives are very important so a person can track the goals and
    know the goals are actually being met. If a Forest is not meeting the
    objectives it is not likely meeting the goals, and if the goals are not being
    met it is likely the DFC is not being met (except for that coincidence thing).

    Tracking objectives occurs in the monitoring phase. It is extremely important
    that someone actually sit down and see if the objectives are being met and if
    not, is the condition of the forest diverging from the DFC and if so, should
    the Forest try harder to accomplish the objectives or does it change the DFC
    because it is not realistic? These questions can only be asked if someone is
    monitoring the objectives.

    It has been my observation that the whole planning process falls apart in the
    monitoring phase because everyone is so focused on meeting the standards and
    guidelines of individual projects they forget to look and see if the objectives
    are being met, and what the implication for the DFC is if the objectives are
    not being met. I believe the whole DFC through monitoring objectives thing is
    critical for planning, and should be specifically identified in the framework.

    I am not clear where alternatives fit in this framework. I assume alternatives
    would be in the revise/amend phase, but that is not clear from your outline.
    Alternatives could be a 4th phase of the framework.

    Where do concepts like ecosystem resiliency, forest and grassland health (and
    how to achieve it), adaptive management, biological diversity, the roadless
    rule, best science, and allowing the public to have some say in selection of
    the final plan alternative fit it?

    I would also think the idea that a forest plan is a programmatic document that
    provides overall guidance, and not a site specific document that addresses what
    is happening on the ground, should be discussed in the framework. I know a few
    federal judges that are confused by this one.

    Those are my initial thoughts. You may have a better idea how this all fits
    together than I do, but at this point I have more questions than answers.

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  17. Anna says:

    This comment was imported from the old blog so that the full conversation on the framework could be viewed in one place.

    I really liked the post here; I would try my best to implement it in-house.

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  18. Candace McCarthy says:

    This comment was imported from the old blog so that the full conversation on the framework could be viewed in one place.

    It is well and good that you want to revisit the existing plan and upgrade it to accommodate the new needs, but I have yet to see how you have addressed the elderly and ADA folks.

    Most 60+ year olds can not hike the needed 3miles to get
    into a park and need use of an ATV for going into any park. This also goes for the Disabled… How are we to have a family member in a wheelchair join in our outings as a participant. ATV’s, Pack Mules and Horses all provide these two groups access that would have been denied if some of your non-recreational suggestions are adopted.

    What is a stressor in your definintions….I know what I mean, but…Just wanted to get a clarification. It probably means that
    anything entering the forest is a problem? candace

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  19. Andy Stahl says:

    This comment was imported from the old blog so that the full conversation on the framework could be viewed in one place.

    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.

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  20. M Armstrong says:

    This comment was imported from the old blog so that the full conversation on the framework could be viewed in one place.

    I was very disappointed, but not surprised, that you failed to recognize and
    acknowledge the “government to government” relationship and
    responsibility that the federal government has with County government.
    “Collaboration” and including County government as a
    “stakeholder” on par with special interests and the general public
    just won’t cut it.

    County’s continue to have jurisdiction over people whether or not they are on
    federal lands. People must comply with state and local ordinances, while they
    are on federal lands. Federal lands are not isolated islands.

    Also, many rural communities and Counties continue to have fundamental social
    and economic dependencies on the continued use of federal lands. Logging,
    grazing and mining are important to the vitality of neighboring communities.

    I recently did a statistical analysis of the impact of state and federal
    regulation and management policies on the welfare of residents in my county.
    There is a direct correlation between major federal land managenet decisions
    and the official statistical increase in poverty, unemployment and the dramatic
    downward trend of the well-being of our residents during the past 20 years.
    http://users.sisqtel.net/armstrng/dam%20comments%20710.htm

    Federal Land Planning can’t just be about landscapes, trees, critters and
    watershed health. It must consider the local human context of the communities
    that surround federal land. This is required under NEPA and was highlighted as
    part of the recent Consolidated Salmon Cases (Wanger.)

    When our communities founder, the local gas station, grocery store and other
    amenities leave. Roads are no longer maintained. This makes it difficult for
    anyone to use the Forest

    When the Forest ceases to be actively managed, it burns. My district saw in
    excess of 200,000 acres burn in 2008. Now those lands are acres of dead sticks
    waiting for the next lightning strike to set them off.

    My communities live in terror of fire and smoke. The way it is being managed
    today, the Forest is not a good neighbor. In fact, our County has declared
    local Forest lands to constitute a public nuisance in the way they are being
    managed.

    I do not see that your Planning Rule takes any of this into account at all.

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  21. Michael Harper says:

    Generally a good framework; I especially support the early involvement of local governments in the assessment process. I hope the idea of using local government resources as a source of information and comment will be strongly encouraged in the new planning rule. I would suggest that under monitoring, partners in the process be invited to assist with the structure of the monitoring program. What is monitored and how it is monitored will have a significant effect on the success of the plans being developed under the general guidelines of the planning rule.

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  22. Chris Horgan says:

    At the Roundtables Recreation and Public Access were identified as the most
    important priority by a factor of more than two to one over every other issue.
    Wheeled vehicle recreation on National Forest Lands was deemed particularly
    important. Yet Recreation and Public Access are still omitted in this Framework
    document.

    What has been included specifically are environmental considerations which have
    continually been misused in the past to shut down recreation, prohibit public
    access and block active management to promote forest health.

    Even worse the framework is totally based on examining “stressors” on
    Forest Lands. Anything can be a stressor and this kind of overarching
    requirement will set the stage for litigation on any issue. The purpose of
    revising the Forest Rule was to reduce litigation and simplify the process, not
    increase litigation and complexity.
    We all care about the environment, but the time has come for human needs like
    recreation on public lands, where people can recharge and enjoy the Great
    Outdoors to be a priority in Forest Planning. Overblown or invalid
    environmental concerns should not take president for the Planning direction on
    our public lands.

    The Planning Rule needs to make Recreation a Priority and create limitations on
    Environmental criteria so they cannot be used to prohibit other forms of land
    use. The Planning Rule should clearly support all forms of land use, be simple
    and reduce litigation of Forest Plans.

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  23. Melanie Lawrence says:

    This is as close to an authentic adaptive management model that I have seen.
    Creating the collborative framework early-on and continuing through the
    monitoring phase is essential. For active adaptive management, there needs to
    be a clear declaration of experimental intent for the management actions so
    that the monitoring is directed and focused on answering hypotheses and not
    just describing what took place on the land. But I am happy to see the phrase:
    “Each NFS unit would be responsible for creating and implementing the
    unit-level monitoring plan, in conjunction with partners and scientists.”
    although this needs to be included at the front-end (in planning) as well. The
    major objective needs to be LEARNING to better inform future management
    actions.

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  24. Carol Johnson says:

    I realize the post is preliminary. However, the word “sustainable”
    does not appear anywhere. At the regional round table in ABQ, a sustainable
    approach was of major concern at all 3 tables I sat at. FYI – the facilitators
    did not seem well prepared and did not include sustainable and restoration in
    their summaries.

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