FSM 1921.03g (p. 25): Replace “Monitoring and data collection…should…” to “Monitoring and data collection shall.” I understand we’re trying to avoid unnecessary ‘shalls,’ but looking at the direction contained in this part, I can think of no reason why a Forest could be justified in not observing it.
FSM 1921.08 (p. 29): Delete #8 (“Follow the plan model…”). The Plan Model is a useful reference and may be helpful in guiding preparation of Plan Documents, but it requires a great deal of interpretation and adaptation to the specifics of an individual Forest’s circumstances. In any case, the true ‘model’ of a Forest Plan is continually evolving, especially in these first few years. Requiring Plan Documents to follow the Model in its current stage of development will limit the creativity and flexibility needed as we all learn to implement the new Rule. Also, this requirement is unnecessary for establishing consistency across Plans, since the required 5 Plan Components and other parts of the Plan Set of Documents are indicating in many other parts of the Directives.
FSM 1921.12 (p. 30): Modify #2 to read: “The statement of desired conditions is the plan component that describes the attributes of ecological, economic, and social sustainability that characterize or exemplify the outcome of land management.” This strengthens and clarifies the need to link desired conditions to elements of sustainability that are considered most important for the Forest.
FSM 1921.17d (p. 37): The fact that “land where timber harvest could occur” includes both lands suitable for timber harvest and lands suitable for timber production (as defined in #1 of this section) probably ought to be clarified.
FSM 1921.17g (p. 39): The requirement that “[timber management projections] describe forest management systems, harvesting levels and procedures… and must reflect proposed and possible actions, including the planned timber sale program and the proportion of probable methods of timber harvest” seems to be a fundamental contradiction of the principle that Forest Plans do not authorize on-the-ground activities. The argument will be made that if we can make such specific assumptions about timber harvesting activities, then we should be able to estimate the environmental effects (EIS) of such activities. The premise behind the proposed CE is that Plans do not have specific environmental effects. Either that premise needs to change, or the proposed CE must be dropped, or we must be more clearly instructed about how to make NFMA-required timber projections without making specific assumptions about on-the-ground activities.
FSM 1921.21 (p. 42): The statement that “the Responsible Official has full discretion on deciding how and when to involve the public in providing input for management review” leaves open the possibility that there will be no public involvement in management review. Assuming this is not what the directive intends, something to the effect of ‘the public must have meaningful involvement in the management review, but the Responsible Official has full discretion on how and when it will be solicited’ would be more appropriate. If the directive does intend to leave open the possibility of no public involvement, then the cynicism of the entire body of regulatory direction will quickly become apparent and the public trust will suffer severely.
General comments about FSM 1921.3 (p. 43) and related direction:
- There are semi-redundant logics throughout the planning directives, including Plan Vision/Strategy/Design Criteria v.v. 5 Plan components, EMS v.v. monitoring, Management Review v.v. Comprehensive Evaluation, Performance Measures v.v. Objectives, etc. These conceptual models must be streamlined or better integrated with one another throughout the directives; currently they serve primarily to confuse the planning process.
- The 5-year comprehensive evaluation may identify need for change relative to one or more Plan Components. When would such a change constitute a Revision, as opposed to an Amendment or an Administrative Correction? I have found nothing in the Directives to clarify this.
FSM 1921.52 (p. 50): In #1, change “should” to “shall.” There is no good reason why a Plan should not be required to identify monitoring questions.
FSM 1921.7 (p. 54): Add after first sentence of last paragraph: “Desired Conditions shall reflect those elements of sustainability to which the Forest should make the most meaningful contributions.”
FSM 1921.71 (p. 55): In first paragraph change to, “the evaluation must integrate the relevant elements of sustainability…”
FSM 1921.71 – Exhibit 1 (p. 56): The social and economic elements of sustainability should be organized based on the RPA Assessment Criteria (National Sustainability Criteria/MPCI), in the same way that the ecological elements are.
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