Pursuant to the Sikes Act, INRMPs must be reviewed on a regular basis, but no less often than every five years, by DoD, FWS, NOAA Fisheries Service, and State fish and wildlife agencies. This review must be documented and signed by these parties. At a minimum, reviews shall assess conservation goals and objectives and the status of the natural resources conservation metrics described in DoDI 4715.03 (2011). According to DoDI 4715.03, “the requirement to review the INRMPs on a regular basis, but no less often than every 5 years, does not mean that every INRMP must be revised when it is reviewed. The Sikes Act specifically directs that the INRMPs be reviewed “as to operation and effect,” emphasizing that the review is intended to determine whether existing INRMPs are being managed to meet the requirements of the Sikes Act and contribute to the conservation and restoration of natural resources on military installations in accordance with the Sikes Act.”
A 2013 MOU between the DoD, FWS and AFWA regarding INRMP cooperation speaks to reviewing, revising, updating and implementing INRMPs for military installations. Related DoD Memorandum guidance in 2015 provides guidelines for INRMP review. The “Guidelines for Streamlined INRMP Review” do not apply to newly developed INRMPs or to INRMPs undergoing major changes (i.e., revisions). The processes established in the 2013 MOU and refined by the 2015 guidelines:
- Facilitate faster review and approval of INRMPs requiring updates;
- Reduce the number of non-compliant INRMPs; and
- Improve coordination and collaboration among installation personnel and FWS regional reviewers.
The 2015 Memorandum contains some key definitions to ensure consistency in discussions and procedures that generally agree with the 2013 MOU and FWS guidance:
Compliant INRMP: An INRMP that has been both approved in writing, and reviewed, within the past five years, as to operation and effect by authorized officials of DoD, FWS, and each appropriate State fish and wildlife agency.
INRMP Revision: Any new natural resources management actions necessitated by changes to the military mission, the condition of the land, or the status of the species present and not previously considered by the parties to the existing INRMP when the plan was last approved and/or reviewed as to operation and effect. All such revisions require approval by all parties to the INRMP and will usually call for a new or supplemental National Environmental Policy Act (NEPA) analysis, most commonly an Environmental Assessment.
INRMP Transmittal Letter: A cover letter to an INRMP update that summarizes changes to the compliant or operational INRMP.
NRMP Update: Any change to an INRMP that, if implemented, is not expected to result in consequences materially different from those in the existing INRMP and analyzed in an existing NEPA document. Such changes will not result in a significant environmental impact, and installations are not required to invite the public to review or to comment on the decision to continue implementing the updated INRMP. Updates do not change the management prescriptions set forth in the INRMP, and do not require analysis under the NEPA. The use of updates is intended to reduce the workload for all involved agencies while maintaining both INRMP currency and mission flexibility.
Operational INRMP: The most recent version of an installation’s INRMP that was reviewed for operation and effect. The FWS will consider the INRMP currently being used to guide natural resource management on a given installation, irrespective of signature date, to be the operational equivalent of a compliant INRMP.
Nominal changes to activities would generally not trigger the need for a revision. Both the scope of the change in an activity and the scale of the change may inform the decision. There is no hard and fast rule on this decision; most commonly natural resources military service leads or their designees are involved in reviewing the INRMPs prior to signature, and would provide guidance to installations. Things that might trigger the need for a revision include changes to the mission, changes in the environment, and/or changes in management approaches or activities. More specific examples include the listing or new arrival of federally-listed plants or animals, the designation of critical habitat on the installation, addition or modification of ESA consultation requirements, significant changes to multiple-use management activities (e.g., grazing, timber, recreational, and agricultural programs), new arrival or changes in management activities for invasive plant and animal species, or any other significant change to the management prescriptions in the INRMP.
Once finalized, an updated or revised INRMP is considered reviewed for operation and effect and will restart the five-year window for compliance.
Next Page: Monitoring INRMP implementation and effectiveness
Author
David S. Jones, RA IV, Ecologist/Project Manager
Center for Environmental Management of Military Lands
Warner College of Natural Resources
Colorado State University