K.I.S.S.

Contributed by Andy Stahl

Forest planning has been hijacked by a generation of planners who turned what should have been a narrowly-focused effort to constrain an out-of-control Forest Service logging program and turned it into a wasteful, endless, bureaucratic exercise with little merit.  Let’s review what the National Forest Management Act actually requires of plans and the planning regulations.  The reader can follow along here:

http://www.law.cornell.edu/uscode/16/usc_sec_16_00001604—-000-.html

Here’s what a NFMA plan must contain:

1) the “planned timber sale program” including the “proportion of probable methods of timber harvest.”

That’s it.  There is no second item.

Now look at what NFMA requires of the planning regulations.  First, there must be guidelines

1) to identify the suitability of land for resource management;

2) for obtaining inventory data; and,

3) for identifying special conditions or situations involving hazards.

Second, the planning rules must

1) insure that economic and environmental matters are considered in the forest plan;

2) insure that plans provide for diversity of plant and animal communities;

3) insure plans address research and evaluation of management systems to prevent substantial and permanent impairment of land productivity;

4) permit increases in harvest levels based on growing trees faster;

5) ensure that timber will be harvested only where soil, slope or watershed conditions will not be irreversibly damaged, land is restocked within 5 years, protection is provided to water from detrimental changes, and harvest methods are not chosen based on greatest dollar return or unit output; and, finally,

6) ensure that even-aged cutting is used only where it is appropriate, natural appearing, not too big, and protective of other resources.

That’s it.  When read in the context of the times, i.e., the clearcutting scandals of the mid-1970s, it makes perfect sense that what Congress sought were timber sale programs for each national forest that ensured logging levels and methods were light-on-the-land and protected other resources.

In the 1980s, with national forest logging beyond 10 billion and up 12 billion board feet annually, that was no mean feat.  Today, with logging at or below 3 billion board feet, forest planning ought to be a snap.  But only if the Forest Service sets its cross-hairs only on the target Congress demanded.  Otherwise, it will continue to take 15 or more years to write 15-year plans that will make no decisions and be irrelevant in the real world the day they are signed.

Andy Stahl is the Executive Director of the Forest Service Employees for Environmental Ethics

5 Comments

  1. Andy- thanks much for this contribution. While I’m not enough of a NFManiac to know exactly how simple we could be and meet the intent of NFMA (although I’m sure there are many out there who have opinions), I think it’s important to have a legally sufficient minimalist alternative that we can carry through to the point in the EIS for the Rule where we calculate the costs. That way, we could all see and talk about whether the extra bang was worth the extra bucks.

  2. Great post. I think many Forest Service planners would agree that the K.I.S.S. approach should be used in developing a planning rule (and don’t forget the associated planning directives in the Forest Service manual and handbook.)

    While it’s a great idea to maybe try to focus plans on the specific limits for timber cutting discussed in NFMA, my understanding of the Act is that it requires plans to address all the multiple uses. NFMA requires plans to “include” the planned timber sale program and proportion of probable methods, but not exclusively address timber. 16 USC 1604, or section 6 of NFMA, starts out in section e with a requirement that plans provide for multiple use and sustained yield of products and services, and a requirement that “forest management systems, harvesting levels, and procedures” be determined in light of all the multiple uses in the Multiple-Use Sustained Yield Act. That introduction along with the requirement to form “one integrated plan” seems to imply some sort of umbrella document that guides all the activity in a forest. Later on, the Act requires consideration of “various systems of renewable resource management” while explaining that silviculture is related to the protection of forest resources to provide for outdoor recreation (including wilderness) range, timber, watershed, wildlife, and fish.

  3. Another key point to NFMA is that it did not replace the Forest and Rangeland Renewable Resources Planning Act of 1974 – it amended it. This amendment redesignated the sections of FRRRPA and added additional language on many of the sections – quite often this language deals with timber harvest activities and program; however it did not replace the language of FRRRPA. Additionally federal lands are subject to the Federal Lands Policy and Management Act of 1976 which speaks directly to land use planning and land use plans.

    Now I’ll admit the agency (FS) has probably done a disservice by calling their land use planning NFMA planning and referring to project level planning as NEPA planning. Both processes are subject to NEPA – thus they are NEPA planning. Land use management planning is more of a strategic planning effort that uses a systematic interdisciplinary approach to establish multiple use objectives and wieghs long term benefits to the public against short term benefits. Project level planning is a more tactical planning effort that depending upon the complexity and uncertainity of an action should consider different approaches to accomplish the planning effort (rational planning paradigm, post-rational planning paradigm, post-post-rational planning paradigms).

    Part of this disservice reflects a lack of “professionalization” in planning within the agency. This has lead to mental models about what “planning” is and what “NEPA’ is which may not be as accurate as needed to understand the system in which it truly operates. This doesn’t mean the employees are not professional about how they approach the business they do – instead it represents the fact that they do not share a common language or ethos with other planning communities.

  4. Pingback: K.I.S.S. in Rule Form, Part I « A New Century of Forest Planning

  5. Pingback: KISS Planning » The Antiplanner

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