U.S. DEPARTMENT OF THE INTERIORBUREAU OF LAND MANAGEMENT
UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
May 20, 200
In Reply Refer To:
1610 (210) P
EMS TRANSMISSION 05/26/2009
Instruction Memorandum No. 2009-127
To: All Washington Office and Field Office Officials
From: Assistant Director, Renewable Resources and Planning
Subject: Development and Approval of Preparation Plans for New Planning Starts
Program Area: Renewable Resources and Planning
Purpose: As outlined in IM 2001-038, prior to receiving funding for new planning starts (including new plans and any major amendments) the BLM State Offices will submit a preparation plan (approved by the State Director) through Washington Office State Liaisons to the Assistant Director (WO-200) for approval. Guidance concerning preparation plans is available in the BLM Land Use Planning Handbook (Appendix F). This IM provides additional guidance for the development and approval of preparation plans and supplements the outline provided in Appendix F-1: Recommended Format for Preparation Plans.
Policy/Action: As stated above, all planning efforts for Resource Management Plans and Amendments must have an approved preparation plan in order to receive funding. Preparation plans should follow the outline found in Appendix F of the Land Use Planning Handbook and answer the questions found in Attachment 1 of this IM.
The purpose of a preparation plan is to outline the statement of upcoming work for a land use planning effort in a way that identifies the important issues to be addressed, the skills needed to address those issues, a schedule and budget, planning criteria and the available and/or needed data and metadata. The preparation plan is created by the Field Office in conjunction with the State Office and reviewed by WO-210. The preparation plan is considered a contract between the State Office and the Washington Office holding the State and Field Offices to the defined timetables and budgets.
The preparation plan should clearly and concisely describe the project budget, schedule, community-based collaboration process, Cooperating Agency participation, and anticipated planning issues based on the Plan Evaluation and internal scoping. The preparation plan must include an analysis on which parts of the planning process will be done internally and which parts will be done externally through contractors, Cooperators or other parties. The preparation plan should also identify and budget for mandatory consultation and coordination activities such as the economic workshop (IM No. 2003-169), cultural landscapes overviews, and Endangered Species Act information dissemination.
Preparation plans should be sent by the State Office to the appropriate Washington Office (WO) State Liaison after approval by the State Director. The WO State Liaison reviews the preparation plan to ensure that all potential impediments associated with planning issues, management concerns, planning criteria, data management, staffing, contracting, GIS, and time schedules are addressed in order to eliminate any delays in the preparation of the document.
Final approval of preparation plans rests with the Assistant Director for Renewable Resources and Planning. Upon approval, a concurrence memo is sent to the State Office which serves as a contract agreement between the State Office and WO-200 and secures the plan schedule and budget.
The schedule identified in the preparation plan should outline the completion of all the required plan components (see Land Use Planning Handbook). Each action should be associated with a target completion date. Dates should be specific enough to track milestones. The overall time schedule for plan completion should be approximately 3-5 years. Critical paths such as the comment period on a Draft EIS (90 days), the Governor’s Consistency Review (60 days) and the protests period (30 days) must be correctly incorporated into the schedule. Schedules should include adequate time for review by the State Office, Washington Office and the Solicitors. Washington Office review, including WO-210, program leads and the Solicitor’s office, should be approximately 3 weeks (45 working days) for both the Draft and Final EIS. The schedule should also include necessary training such as ePlanning.
The schedule identified in the preparation plan also serves to set targets for the planning Projected Target Allocation. These targets should be kept up to date should the schedule change. A schedule extension request should be submitted should the completion of the Record of Decision (ROD) need to be moved to the following fiscal year.
Combined, the schedule and budget create transparency and therefore, accountability. The budget identified in the preparation plan should match the budget request submissions for each year. The budget should identify, among other things, the costs associated with data collection, any contracts identified, staff work months, and associated travel costs. Each expense should be broken down into project level actions and have identified funding sources.
The overall cost of plan completion should be reasonable for the type of plan. A study of plans completed since 2000 has shown that average plan cost has stayed well within the range identified in the 2005 Group A Report, Attachment B. On average, plans with a higher level of controversy due to energy issues or high BLM acreage have ranged from $3-5.5 million for plan development. Plans with lower levels of controversy have stayed within the $2-4 million range. The approval of a preparation plan acts as a contract between the State Office and Washington office for how funds will be allocated through the planning process, therefore, the costs associated with items in the budget must be reasonable.
The preparation plan should be utilized in the development of a Statement of Work (SOW) for any possible contracts. The schedule and budget should identify which actions will be performed by a contractor and which shall be done in-house. A general trend away from all-inclusive contracts and towards contracts with increased oversight has shown to be successful in recent plan development. While some plan development actions can be successfully and effectively performed by contractors, others are more appropriately accomplished by BLM staff. Aspects of the planning process such as development of the Analysis of the Management Situation (AMS), alternative development and protest response work should not be included in a contract. Aspects of the planning process that have shown success in contracts include facilitation duties, writer/editor duties, comment analysis, and various data needs. See IB-2005-138 for a Contracting Decision Making Tree and further suggestions on the appropriate use of contractor support. The preparation plan should also consider how contractors might be involved in ePlanning.
Data Needs and Management
The Data Needs section of the preparation plan should identify the information or data needed to resolve or address identified issues, management concerns, planning criteria or to perform the requisite analysis. Data needs should be presented in the format shown in Attachment 2 and include responses to the fields identified. Beyond this table, the Data Needs section should also address the reasons for data gaps and the prioritization of data needs in order to create a data inventory and collection activity plan.
Preparation plans should consider the use of Priority Planning for Species and Vegetation tools (PPSV) for data management and alternative development. The PPSV is a data management tool that helps to identify priority species existing condition, potential effects from other resources and potential alternatives for management. Classes on PPSV are available to create the framework and develop the information needed for the AMS. Preparation plans should identify use of PPSV and any scheduled classes.
The Data Needs section should also show how the goals of the Assessment, Inventory and Monitoring (AIM) strategy and E-GIS will be addressed in the planning effort. The AIM strategy should be useful in determining the types of data sets and scales being used and the preparation plan should note whether any regional assessments have been completed in the planning area and how these will be used and interpreted in the planning analysis. The data management section should identify if E-GIS data standards are met and how they will be addressed.
For an example of a successful preparation plan, please refer to the Rio Puerco RMP Preparation Plan located online at: http://www.blm.gov/nm/st/en/fo/Rio_Puerco_Field_Office/rpfo_rmp_revision.html.
Timeframe: This IM is effective upon issuance. Preparation plans for FY2010 planning efforts should be prepared as soon as possible.
Budget Impact: This IM provides instructions on the process for the release of funding relating to new plan starts. Funding will not be released until a planning effort has an approved preparation plan.
Background: Since FY2001, the Washington Office has been requiring preparation plans prior to the release of funding.
Manual/Handbook Sections Affected: The guidance in this IM supplements guidance provided in the BLM Land Use Planning Handbook H-1610-1. Washington Office IM No. 2001-038, 2003-134 and Washington Office IB 2005-138.
Coordination: Renewable Resources and Planning (WO-200)
Contact: Questions should be referred to Sandra Meyers, Planning and NEPA, Branch Chief, at 202-557-3373
Signed by: Authenticated by:
Robert T. Ratcliff Robert M. Williams
Acting, Assistant Director Division of IRM Governance,WO-560
Renewable Resources and Planning