Forest Planning Directives

Chapter 43: Ecological Sustainability

Page 11:  Introduction, par 1, sentence 2

If this sentence is going to cite the CFR, it should do so completely; otherwise, confusion will result.  The CFR says that the goal is “to contribute to sustaining native ecological systems by providing conditions to support diversity of native plant and animal species in the plan area.”  The focus on “native” is absent from the introduction.  The aspect of “sustainability” is absent from the introduction.  The limitation of “within their ranges” is absent from the rule.  If this introductory section does not reflect what is in the rule, the field will have difficult when it comes to implementing. 

o     Suggest that the second sentence of the introduction be replaced with the following ”The primary focus is at the scale of the ecosystem, in developing plan components to provide a framework to contribute to sustaining native ecological systems by providing conditions to support diversity of native plant and animal species in the plan area (36 CFR 219.109(b)).” 

Page 11:  Introduction, par 1, last sentence

This sentence states that a species-specific approach “may be necessary”; however, FSM 1921.7 states that for the federally listed species, species-of-concern, and species-of-interest, existing information “should be assessed. . . .”  Which is it?

o     Suggest the terminology match. 

43.1 – Ecosystem Diversity

FSH 1909.12, Chapter 40 Science and Management

Chapter 41-Scence [Reserved]:  It does not help with review that the Science chapter is still missing.  This was a major piece of the 2000 version of the rule that was removed from the 2004 version.  How this is handled via directives will be important.

FSM 1900: 1905-Definitions

Page 9:  Benefit (Outcome)

This is confusing, given that there is a definition of outcome provided later.

o     Suggest deleting the entry.

o     If there’s a desire to keep the entry, delete the definition and add the parenthetical “see Outcome” (see my comments on the definition for “Outcome,” below)

Page 9:  Characteristics of Ecosystem Diversity

The current wording of the parenthetical in the first phrase connotes rarity as attributable only to vegetation, and the list then seems to leaves out those elements that are neither major nor rare.  It is also problematic to use “system” as a composition parameter for ecosystems.  The parenthetical also lists composition elements that are of different scales for example, “riparian systems” that can include different vegetation types.

o       For a little more equivalency of scale, suggest the parenthetical of the first phrase reads, “(such as vegetation types, hydrologic cataloguing units, and soil types)” 

In the second phrase, “water quality” is not an element of “structure.” 

o       Suggest omitting “water quality.”

The last phrase is not very helpful – all ecosystems (at least on Forest Service lands as opposed to hydroponic farms) have soil, water, and air.

o       Suggest omitting “soil, water, and air resources.” 

o       If there is a need to include something about soil, suggest addressing it with an example under the “ecological processes” phrase, for example, “nutrient cycling.”

The last phrase inserts the word “principal,” which is not found in the definition on page 11 for “ecosystem diversity.”

o       Suggest omitting “principal.”

Page 10:  Conservation

The “without impairing” phrase set ups the human uses as being more important than species goals.  The intent may be to ensure we look at species and human uses, but the balancing act and give-and-take is a decision to be made, not the foundation of conservation.

o       If the intent was to ensure inclusion of human uses as that which we wish to conserve, suggest replacing “without impairing” with “and to provide”

General Comments

Comments on directives for 2004 planning rule
Submitted by: Gina Lampman, Regional Aquatic Ecologist, R4
April 8, 2005

GENERAL COMMENTS:

1.In several locations, direction appears in the ecological sustainability discussion that should appear anywhere else there is discussion about analysis, evaluation, and plan component development. Not to do so creates a higher standard for ecological sustainability analysis (which seems counter to the accusations about past ecological analysis causing process gridlock) and does nothing to bring equality of importance among ecological and social and economic sustainability. Examples of these are discussions about the following: a. The Responsible Official needing to consider the limits of agency authorities and the capability of the plan area b. Uncertainty c. Valid and existing information d. Documentation

2. The continued attempt to describe the 3-part format of the plan “model,” for example FSH 1909.12, only serves to create additional pages of explanation and confusion about terms. The model served its purposes, setting forth the relationships between vision, strategy, and design criteria, a la the model format. Those who worked on the model should be acknowledged for their accomplishment and for providing an overall schematic, but the purpose has been served and there has since been identified the need for a few additional components and adjustments to others. The references to the 3-part model are akin to the proverbial square peg in the round hole and should be removed. The more useful step would be to adjust the “model” to fit the final requirements of the 2004 planning rule.

3. For a set of directives that is taking a hierarchical approach to diversity with the ecosystem-level approach first, it would have been helpful if there were more to review under the sections on integration, e.g. FSH 1909.12, Chapter 14, Resource Integration (page 50 ff). In the cited section, where there are “considerations” provided, it is difficult to see where the concept of “integration” comes into play. There is reference to “integrating these resource decisions into the plan,” which sounds like no integration of the resources themselves occurs. If “integration” refers only to using the information, the term should be changed from “resource integration” to “use of individual resource information.”

1921.04a

Seems to me there are many things for which the WO EMC staff is responsible, the most relevant of which is #2 here -- supporting the planning efforts of Forests, etc. 

#1 is also true, but if we feel the need to detail EMS in this way, do we not also need to detail other areas -- analysis, evaluation, monitoring, data management, plan implementation, collaboration, and so on?

1921.03d

This section starts by pinpointing "plans developed or revised prior to Nov 9, 2000..." Should this read "plans developed or revised using the planning regulations in effect prior to Nov 9, 2000..."?  If not, what happens to plans developed or revised between Nov 9, 2000 and the new rule?

Iten 3 in this policy section starts by saying that a plan amendment process from either the 1982 rule or the 2004 rule can be used to change plan monitoring requirements, then goes on to give an example that cannot by used.  Either the 'cannot' is a typo, or this example should be dropped.

1921.02b

This section is on Objectives of Land Management Plans, specifically special area designations.  Item 3 states that the objective of special area designations is "3. Recognize that congressionally designated areas are nationally significant and ensure the plan contains components for them." (emphasis added)  This is a confusing use of the word 'component' since the rule defines the components of a plan as desired conditions, objectives, guidelines, suitability of areas, and special areas.  A better word here may be guidance, strategies, consideration.  Or even better, drop the second clause so that the objective is to "Recognize that congressionally designated areas are nationally significant." since obj 2 is to provide guidance for the area.

1921

It is unclear why the first paragraph of this section is about EMS.  I believe that the reference to EMS as a "framework for planning and management of every National Forest" is from an earlier draft of the rule -- it is certainly not in the published 36 CFR 219.5.  EMS may establish a framework for continuous improvement of selected environmental conditions, it does not establish a framework for planning.  This entire paragraph should be deleted.

1920.3

"When Responsible Official sprepare plans or plan revisions, they must: 1.  ... Selection of the area included in these evaluations shall be guided by the issues being addressed, the extent of relevant ecosystems and their composition, structure and function, the ranges and habitats of individual species, or key social and economic patterns and processes." 

The phrase 'the ranges and habitats of individual species' needs a qualifier similar to 'relevant ecosystems' and 'key social' or it could be interpreted as all species, which would be impossible to implement.

1905 EMS definitions

Definitions for EMS details such as EMS auditing, Communication, and so on to EMS Training should be moved to FSM 1330, FSH 1909.12 Chapter 20, or better than those options, to a new technical guide on EMS.