Forest Planning Directives

Policy statements in FSM

enclosed is a document I put together to take a comparative look at the various policy sections in FSM 1900.  It takes 1903, 1920.3, 1921.03, and 1922.03 and relates them to the regulations and the handbook, with my suggestions for deletions and/or edits, including comments.

I incorporate it here as a download to simplify the "track changes" method used.

Download id_1920-policy_rewritten.doc

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.