Bitterroot, Flathead and Lolo National Forests

Working Under the New Planning Rule

Why We Chose To Switch

The new planning rule includes a transition option for forests whose revision processes were already well underway when the rule was adopted. We had a choice of continuing to work under the old planning rule, or switching to the new rule. The following points were major considerations in our decision to switch to the new rule:

(1) Past experience has shown that it is not realistic for us to predict specific project impacts in a Forest Plan Environmental Impact Statement, when future environmental, social, and economic conditions cannot be accurately known. Therefore, it is very often necessary to also prepare an Environmental Impact Statement for each individual project. Transitioning to the new rule allows us to avoid the expenditures of time and money formally done at both the forest plan level and the project level because, under most circumstances, forest plans will be Categorically Excluded from the requirement to prepare an Environmental Impact Statement.

(2) Experience has also shown that rigid environmental protection Standards that cannot be modified without a Forest Plan amendment, are often not well matched with actual field conditions at the project level. The use of Guideline, under the new planning rule, allows us to make appropriate project level adaptations as long as we demonstrate that our adaptations are made for good reasons, and maintain a level of environmental protection comparable to that afforded by the original Guideline.

(3) Developing a full range of alternative plans for public review and comment tends to reinforce polarization among public constituencies by putting the Forest Service in the position of having to choose from among several alternatives that each have strong and often contradicting constituencies. The new rule allows us to present one preliminary option to the public and then engage in collaborative dialogue with all interested parties, with the goal of iteratively revising that option to arrive at a plan that different constituencies have worked together to create. This can both save the agency time and money, and increase the likelihood that the final plan will enjoy broad public support.

Several Important Differences

Here are several important consequences of operating under the new planning rule:

1. The Responsible Official will be the Forest Supervisor.
2. Each National Forest will establish an Environmental Management System prior to completion of its revised forest plan.
3. We expect the planning and decision process to be Categorically Excluded from the need to prepare an Environmental Impact Statement.
4. “Appeals” will be resolved following a 30-day Objection period, before the decision is signed. Objection reviews will be at the Regional level rather than at the Washington Office level, as before.
5. The emphasis on public involvement will shift from public comment on a range of alternative plans, to an iterative public-Forest Service collaboration intended to meld a single option into a broadly supported plan.

Procedural Details

Environmental Management System (EMS): In compliance with a Presidential Executive Order, and provisions of the new planning rule, each Forest will establish an Environmental Management System (EMS), using the ISO 14001 model, before the revised forest plans are implemented. Information as to what an EMS is and what the ISO 14001 model is may be found on the web site: http://www.ISO.org/ (link opens new window). Each EMS will focus on selected important aspects of a Forest’s environmental management, as a means of tracking how efficient and effective that Forest is in making improvements in the areas being tracked. We will be asking for public review and comment on our proposed monitoring of the Environmental Aspects each Forest has chosen for initial tracking through its Environmental Management System.

Planning Elements Completed Before Transition to the New Rule: Forests such as ours, that have already done a great deal of plan revision work before transitioning to the new regulations are instructed, by 36 CFR 219.14(e)(1), that we are not required to halt the process and start over, but may continue as appropriate to complete the plan revision process. Following is a summary of the important plan revision elements that we have already completed before publication of this Notice of Adjustment.

Summary of Conditions and Trends: Our Analysis of the Management Situation (AMS), completed in the fall of 2003 and available on our web site, constitutes our management review of Forest conditions and trends that led to six environmental aspects in which we saw significant needs for change.

Public Collaboration: Our Proposed Action, released in January 2004, presented our preliminary thoughts as to how we might respond to major needs for change. It became the focal point for public engagement through, open houses, invited presentations, community-based collaborative groups, and many written comments. Our Content Analysis Report, also on the web site, summarizes our learnings from information received during a 90-day public comment period.

Preliminary Alternatives: Based on information in the Content Analysis Report, things we learned through full-day meetings with every Ranger District in the Zone, on-going community-based collaborations, and face-to-face deliberations among the leadership teams of our three Forests, we identified six preliminary alternative themes. These themes, which were designed to reflect six different management philosophies that we thought were reflected in dialogue with members of the public, other agencies and governments, and our own employees are summarized in our Fall 2004 Newsletter, which is also posted on our web site.

Suitability of Areas: The alternative themes were further developed by asking each Ranger District to map areas they would designate as suitable for various forest management purposes, under each of the six alternative themes. This met six sets of maps, each of which displayed tentative suitability of areas under one of the six management philosophies.

Preferred Option: Finally, we again met with the assembled Forest leadership teams to consider the six preliminary alternatives and arrive at a single option that reflected the best and most feasible features of all six. Following some additional integration and mapping adjustments, this became the option that we used to launch our next round of collaborative dialogue.

Public Involvement: In late spring of 2005, we began public collaboration on our preferred option, with each Forest using some combination of the following methods: (1) posting draft desired conditions and supporting maps on our web site, (2) open houses, (3) invited presentations, (4) newsletters, and (5) on-going collaborative dialogue in community-based working groups. The major focal points of the collaborative process were: (1) desired future conditions, (2) suitability of land areas for various purposes, (3) management objectives for helping us moved toward the desired conditions, and (4) monitoring and adaptive management strategies.

More Information

You can find detailed information about the "2005 Final NFMA Planning Rule"on the national FS web site (link opens a new window)

USDA Forest Service - Bitterroot, Lolo, Flathead National Forests
Last Modified: Friday, 05 January 2007 at 12:54:57 EST