The new plan, same as the old plan

It has been a busy week in the arena of federal forest policy. One of the most significant announcements was the release of the final environmental impact statement for a new National Forest System land management planning rule.

This is the most recent action in a process that started in 2009 to promulgate a new rule under the National Forest Management Act, replacing the 1982 rule. The planning rule guides land and resource management planning on National Forest System lands. As threats to our nation's forests grow, a sound planning rule is crucial to the restoration of federal forest lands and the rural communities that rely upon sustainable outputs from management activities.

Numerous attempts to revise the 1982 planning rule spans over 12 years and three administrations. As expected from previous rewrites, this one has also met with criticism and concern.

Response from conservationists support "strengthening protections for watersheds that supply drinking water for millions of Americans but expressed concern that the planning rule will allow some species to fall by the wayside," as reported in a recent press article.

Others "warned the plan will make it harder for the Forest Service to permit multiple uses such as timber, mining and grazing without falling prey to burdensome paperwork or lawsuits." Sounds like the current status quo.

Analysis of the new rule is long and complex; however, a flash point always have been and continues to be species protection (or viability) versus allowing for multiple uses such has timber harvest, motorized access and recreation. The National Forest Management Act requires the agency to manage for a diversity of plants and animals within the context of its multiple-use mandate.

Diversity of plant and animal communities in the new planning rule (Section 219.9) suggests an ecosystem and species-specific approach to maintaining the diversity in a plan area. Compliance with requirements in paragraph (a) and (b) maintains diversity and additional ecological conditions. Plan components in paragraph (a) must include "standards" and guidelines to maintain or restore the ecological integrity of terrestrial and aquatic ecosystems. Again, sounds like the current status quo.

The 1982 rule is a set of "standards" and guidelines. Guidelines do provide the technical guidance for designing on-the-ground projects and activities; however, "standards" (by default) end up defining what land managers cannot do instead of offering "objectives" or a vision of what land managers can do.

Even though the new planning rule mentions "objectives" more than 20 times, it does not do so in the context of restoring and maintaining diversity of plant and animal communities. This is unfortunate and will likely perpetuate the debate between species viability and a multiple-use mandate.

The new planning rule reverts back to a "species" or "standards" approach to conservation, instead of coarse and file filter analyses (or a "system" approach) focused at the community level, assuming that by maintaining a set of ecological communities of sufficient size, composition, structure, and distribution, viability for the majority of all species is maintained.

A coarse filter analysis considers changes over time in vegetative composition, including human-caused impacts and disturbances. The purpose of this filter is to provide findings that are a basis for the development of plan "objectives" that maintain or restore ecological communities such that the viability for the majority of all species is maintained.

The purpose of a fine filter analysis is to identify threats to species at-risk not covered by the coarse filter analysis. However, a significant challenge in the 1982 planning rule is the requirement to provide for a well-distributed habitat (36 CFR219.19) based on a set of "standards" instead of plan "objectives" that would measure progress toward achieving or maintaining a desired future condition.

The nature of land management planning should be a strategic guide for designing specific projects. Plan components should consist of "desired conditions" where the social, economic and ecological attributes guide land management and resource allocations and "objectives," where concise, time-specific intended outcomes are measured, and "guidelines" offer technical information for project and activity design at the decision-making level.

The overall goal of managing public lands should be to sustain, in perpetuity, the productivity of the land and the multiple uses of its renewable resources, within a framework that is flexible, and can adapt to a dynamic and changing ecosystem.

Julia Altemus is the executive vice president of the Montana Wood Products Association.