Assuming that we couldn't yet rid ourselves of the National Forest Management Act (NFMA) Planning Rule, my first hope was for a one simple sentence Rule that went something like, “Every ten to fifteen years revise your forest plan.” That way people would focus on the RPA/NFMA law (badly in need of reform since the world no longer believes in the type comprehensive, rational planning it once did), and other law and policy that guides the management of the national forests.
One might have added a sentence a la Jack Ward Thomas’ admonition, “Tell the truth, obey the law, and practice ecosystem management.” But ecosystem management is now pretty much the expectation – what we all know we ought to be about. And having to tell folks to tell the truth and obey the law is at best a bit embarrassing. This is the same kind of embarrassment that stems from phrases like, “The responsible official must take into account the best available science.” What else would a “responsible official” do? Take into account the worst available science, mediocre science?
My one-sentence regulation didn’t happen, of course. In fact the NFMA Rule embeds language that kicks directive down to manuals and handbooks, just like the now-archaic NFMA law contains language directing the Forest Service to develop planning regulations.
So here we are. In critiquing the NFMA Rule Directives, my proposal is that we pay most of our attention to the FS Manual, part 1920 and elsewhere, and limit what is there to the bare minimum. We ought to devolve all Handbook materials to technical guidance and use the Handbook “placeholder” only to point to technical guidance repositories.
Risking much rent seeking by specialists who love to “direct,” we must remember that if there is one right way to do things, and our wish it to “direct” such, then it ought to be in the Handbook.
My advice still stands: No Handbook for planning!
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