Policy Statements » Letters from the President:
NFMA Planning Rule Comments
March 20, 2003
USDA FS Planning Rule
Content Analysis Team
P.O. Box 8359
Missoula, MT 59807
Dear Sir or Madam:
As President of the Ecological Society of America (ESA), the nation's premier Society of professional ecologists, I write to offer comments on the Forest Service's 2002 Proposed Rule: National Forest System Land and Resource Management Planning. The Proposed Rule would replace the existing rule promulgated in 2000. When the 2000 rule was proposed, ESA commended its emphasis on ecological integrity and the role of science and scientists in planning. The revision proposed in 2002 seeks to address concerns about the implementability of the 2000 rule, providing greater discretion to the local mangers in the level of detail required in analyses of ecological integrity and in the involvement of scientists in the planning process.
ESA appreciates the Forest Service's concerns about the challenges of implementing the 2000 rule, the potential for inconsistent implementation, and the desire to provide managers an opportunity to match the level of analytical detail to local needs and circumstances. However, in providing greater flexibility in the details of forest planning, the Forest Service should continue to strive for the high standards of scientific credibility established by the 2000 rule. These standards include detailed analyses of ecological sustainability in management plans and a requirement to include scientists in the design and evaluation of monitoring strategies. Scientific credibility is key to management plans in which all concerned parties have confidence and to consistent implementation of the rule without the sacrifice of local flexibility. Therefore we recommend the continued and consistent use of scientific peer reviews of monitoring strategies and data, as exemplified in the 2000 rule.
We also would like to encourage you to consider the numerous, and typically unquantified, benefits provided by intact ecological systems. These ecological services may have monetary values equal to or exceeding the commodity values of forest ecosystems, and it is critical that they be considered in any discussion of the costs of analysis and monitoring and in management decisions.
Finally, we acknowledge the budget constraints faced by many federal agencies, including the Forest Service, that may limit the agency's ability to perform the requisite analysis and monitoring. We are willing to work with federal agencies to ensure adequate support for the science needed to make effective management decisions.
I hope that the above comments are useful. ESA's 8,000 members are experts in a host of areas relevant to the development of the proposed rule, and we have invited them to provide your agency with comments. If ESA can be of service or if you would like us to provide you with the contact information of members with expertise in this area, please contact our Director of Public Affairs, Nadine Lymn (202.833.8773, extension 205; firstname.lastname@example.org).
Ann M. Bartuska