RE: CPEO-MEF Sustainable Range Management Directive

[marianne.thaeler@sfsierra.sierraclub.org]

Although the new directives specifically defines "sustainable range management"
for the purposes of these directives, this is not always the case when this
these words are used.

How the word "sustainable" is interpreted by the those that must implement
policy, is an issue of accountability, and should be coupled with
mechanisms for
feedback and monitoring.

The environmentally community has learned from experience over the last 8 years
that some offices of Department of Interior agencies and the US Forest Service,
particularly at the local levels, have interpreted this word to mean
continuation of the status quo without change even when directives were
meant to
imply otherwise. (Sadly, litigation too often followed.) 
 
The intent of those formulating policy is clear to this reader, but those that
interpret it into action may find "sustainable" to be a confirmation of
maintaining the status quo and the directive is leading to charges of
un-neccessary government paper work. 
Unless there is monitoring and feed back, it is difficult to imagine how
misinterpretations may be avoided and corrected.

Alternative words should be used for planning puruposes. The concept is to
insure that there are adequate training and testing ranges to meet readiness
needs. The challenge is to mold and meld  training and testing needs to
available range capacity, and to mold and meld capacity to training and testing
needs. In some cases, it may be necessary to add new capacity (Atlantic fleet
training needs, is an example.)  
Marianne Thaeler


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