Wilderness Society on Planning Rule- Science in the Front Seat?

What I found most interesting about this pieces by Cecilia Clavet of The Wilderness Society, given the lecture by Toddi Steelman here, is asking “who is saying that science should determine policy?” and “in what context do they say it?”.

Here we have an example of the perceived need for science to “take a front seat” in the planning rule, in the context of public comment on the rule. So we are perhaps expecting that those of us not familiar with the issues would simply write a letter calling for 1) more rules about collaboration, and 2) science taking a “front seat.”

I’m beginning to think that their are two problems:a) the discussion isn’t really as nuanced as it could be about what is a “foundation” compared to “scientists should determine what happens”- a mildly (at least) undemocratic idea. And perhaps some policy folks, lawyers and editors have never been exposed to the true messiness of scientists, scientific agendas, and political agendas all duking it out in some controversy. Or they have seem it (in the climate world, it’s hard to avoid) and chosen to look away.

Time to speak up on rules governing how our forests are managed
Photo

By Cecilia Clavet on March 17, 2011 – 2:28pm

The Obama administration and the Forest Service last week hosted what they call a national roundtable. It was an effort to summarize and explain in detail the various components of the draft forest planning rule, which was published last month. When final, this rule will guide the Forest Service on how to manage 193 million acres of America’s national forests. The roundtable, held in Washington D.C., was the beginning of a series of public forums that will take place throughout the country.

The components covered a range from climate change to timber production and from recreation to water resource management. However, much of the day’s emphasis was on the role of collaboration. The draft rule requires collaboration to take place when individual forest plans are developed. This in theory means that the Forest Service will reach out to a wide variety of people interested in contributing to plans for managing forests. These stakeholders include scientists, conservationists, local land owners, foresters and other concerned citizens.

While this sounds like a very inclusive process, a couple of concerns come to mind:

First the planning rule does not provide guidelines to ensure good collaboration, leaving all discretion to the forest manager. The excuse against collaboration guidelines is that no collaborative will be the same across the landscapes. However, I would argue that you can follow some basic rules on collaboration by adopting similar guidelines to the Collaborative Forest Landscape Restoration Program, which would ensure some consistency across all the collaborative efforts and ensure all the right stakeholders are invited to the tables. This will in turn provide the appropriate check on the agency as it developed new forest plans.

The second concern is that the emphasis on collaboration that could minimize, and thus weaken, the role of science in decision-making. The administration appears to view collaboration as having equal footing with science. While collaboration is a complementary component of the forest planning process, the agency must require that the best available science is the foundation. A New York Times editorial also raised some questions the Forest Service needs to answer about science and protecting wildlife.

These are the concerns about collaboration, and there are others. In last week’s roundtable, the administration and agency staff spoke a lot about the intent of the rule, stressing the importance of water, wildlife and sustainable recreations and addressing new challenges like climate change. We wholeheartedly agree. The problem we find is that the language of the draft rule doesn’t match the intent. However, the agency is able to make some changes that could have very meaningful impact to sound forest management.

Now that the draft of the forest planning rule is out, it’s up to everyone who cares about our national forests to make our voices heard. We can start by attending the roundtables taking place across the country. More importantly, we can visit the Forest Service’s forest planning rule site and make official comments about what we would like the agency to do as it revises the draft. We should start by calling for more clarity on collaboration and by demanding science take a front seat in the process.

Note that the NY Times editorial mentioned is the same one I critiqued in my blog entry “NY Times Editors Need New Nemesis” which included the quote “The net result is to give too much discretion to individual forest managers and not nearly enough say to scientists. This is dangerous because, over the years, forest managers have been easily influenced by timber companies and local politicians whose main interest is to increase the timber harvest. ”

Scorecard- Scientists /science as drivers..
NY Times 1
Wilderness Society 1

Congressional Roadless Hubbub Plus CRS Report

Here’s the Greenwire story.. and a link to the Congressional Research Service pub.

FORESTS: Report suggests Congress resolve roadless rule before case reaches Supreme Court (04/21/2011)
Phil Taylor, E&E reporter
A decade-long, litigious battle over how to manage the nation’s remaining roadless forests may have to be decided by Congress, according to a report issued this week by the nonpartisan Congressional Research Service.

The 19-page report suggests the ongoing legal battle over the Clinton administration’s controversial 2001 roadless rule could also be solved if the Obama administration promulgates its own rule for managing the nation’s remaining unspoiled forests.

The Obama administration could also follow the lead of the George W. Bush administration, which allowed states to petition for their own roadless plans rather than follow the national model, the report suggests. The Bush plan was panned by conservation groups and found to be unlawful by the 9th U.S. Circuit Court.

At issue is the fate of 58 million acres of relatively pristine forests — roughly a third of the national forest system — where the Clinton administration banned most road construction and timber harvesting.

The rule could face conflicting legal opinions from the 9th and 10th circuit courts, setting the stage for a possible Supreme Court case, the report warns.

“The ultimate decision of which roadless rule applies may not be in the courts, unless it is brought before the Supreme Court, but by Congress,” the report said. “The contradictory court decisions may indicate a statutory fix is needed.”

The report notes that the Clinton rule was upheld in 2009 by the 9th Circuit but that the 10th U.S. Circuit Court of Appeals is still considering a Wyoming court’s decision overturning the rule on the grounds that it violated the National Environmental Policy Act and created de facto wilderness, which only Congress can declare.

“This could lead to a conflict between the two circuits with one saying the nationwide rule is valid nationwide, and another saying the contrary,” the report says.

However, the report cites language in both the Multiple Use Sustained Yield Act and National Forest Management Act that gives the Forest Service authority to manage areas as wilderness and assure the protection of watersheds, wildlife and recreational opportunities. The report did not say whether the Clinton rule restrictions violate a separate mandate to maintain productive forests.

Rep. Jay Inslee (D-Wash.) and Sen. Maria Cantwell (D-Wash.) last Congress introduced a pair of bills to make the Clinton rule protections permanent and resolve the ongoing legal battle (E&ENews PM, Oct. 1, 2009).

The bills would allow for continued forest management to promote forest health, preserve public access to existing roaded areas and ensure continued opportunities for hunting, fishing, hiking and other forms of outdoor recreation, according to the lawmakers.

“Numerous lawsuits have tracked the roadless rule’s course, both in favor and opposed,” Inslee said on the House floor at the time. “This legislation will permanently protect our nation’s roadless areas and remove all ambiguity concerning their conservation and protection.”

Staff for both Inslee and Cantwell this morning did not immediately say whether the lawmakers planned to reintroduce the proposals in this Congress.

While Inslee’s bill carried several Republican co-sponsors, such a measure would likely face heavy resistance in the current Republican-led House, where some members have pledged to roll back Obama administration policies they say have locked up federal lands.

Greenwire obtained the CRS report from the office of Rep. Kevin McCarthy (R-Calif.), who last week introduced a bill to release the majority of inventoried roadless lands into multiple-use management, which could include timber, oil and gas development or other road-dependent uses ( E&ENews PM, April 15).

McCarthy’s bill, H.R. 1581, calls for the reversal of the 2001 roadless rule and would open up roughly 49 million acres to logging, road building and extractive uses, according to critics.

The bill has 22 Republican co-sponsors including National Parks, Forests and Public Lands Subcommittee Chairman Rob Bishop (R-Utah), and Western Caucus Chairman Steve Pearce (R-N.M.).

Conservation groups have slammed the proposal, calling it a threat to the “last refuge” of many of the nation’s wildlife species.

“This bill threatens to kill off wide-ranging species that just cannot survive in the developed landscape,” said Earthjustice attorney Tim Preso, in a statement. “We are talking about grizzly bears, wolves, elk, and bighorn sheep. The bill would also remove protections for some of our last, best fisheries, including blue-ribbon trout streams and some of the last available spawning habitat for imperiled wild salmon.”

In the meantime, Agriculture Secretary Tom Vilsack said he will decide which timber or road building proposals are allowed to go forward in roadless areas on a case-by-case basis.

Last May, he authorized 14 road construction projects to honor pre-existing mining claims and to allow the construction of methane vents in Colorado coal mines located underneath roadless areas (Greenwire, May 13, 2010).

Three Pathways to Adaptive Governance

Adaptive governance—an adaptive management approach to public lands management—is well underway, and will replace planning, the Forest Service’s chosen management strategy for the 20th century. This may be seen as a bold assertion. But the ideas and actions embedded in adaptive governance have been emerging for quite some time as more and more people realize that 20th century notions cannot guide the Forest Service or any other government agency into the 21st century. Adaptive Governance framing is very different from scientific management/planning framing.

Gifford Pinchot’s “planned forests” guided Forest Service thought, policy, and action for the 20th century. (See, e.g.: here, here (pdf)). It was a model where humans sought to recreate and control Nature’s forests for utilitarian purposes. This model no longer serves. For the 21st century, we are better served with Aldo Leopold’s notion that humans humbly serve as plain members of a broader ecological community, and are not masters of the community. Still, humans must derive sustenance from the land and also re-create the human spirit via interrelationship with the land. To facilitate this transformation, a broad educational campaign in ecological literacy is needed. Part of that educational process can be effected via deliberative democracy in development of adaptive management strategies and actions, with its emphasis on learning not only to incrementally design and implement ever-better management actions, but also to design and implement ever-better management and science theory.

My assertion that adaptive governance is well underway stems from many conversations with planners, NEPA coordinators, and planning directors. It also stems from extensive reading in adaptive governance. [See, e.g. Adaptive Governance: Integrating Science, Policy, Decision Making (Brunner et al, 2005), Finding Common Ground: Governance and Natural Resources in the American West (Brunner et al, 2002), The Politics of Ecosystem Management (Cortner and Moote, 1999)]

At this time when we are discussing the recent Draft NFMA rule, I see three paths forward for the Forest Service: Leave the NFMA rule anchored in by-gone-era planning, while continuing to move toward adaptive governance in all other aspects of forest service thought/action. Develop a very simple NFMA rule that frees the Forest Service of much of the baggage of past NFMA rules, thereby allowing the agency to move forward into the adaptive governance era. Embrace adaptive governance in the NFMA rule.

If as expected the Forest Service chooses to embrace a slightly tweaked Final NFMA rule, which it now calls a “planning rule,” the major problem is that it will further erode trust—a much-discussed casualty of the highly controlled central planning methodology with its “jack in the box” public involvement strategies. [Yes, I’m aware that the Draft rule champions collaborative engagement, but we all know that the Forest Service has little intention to alter its current behavior of giving little more than lip-service to collaboration in forest planning, let alone in higher policy arenas. Besides, if as I’ve argued forest-level planning has little to offer re: adaptive governance, even extensive well-intentioned collaboration in that arena will yield little more than frustration and discontent.]

If the Forest Service chooses to develop a very simple NFMA rule, public interest groups may go along, recognizing that the US Congress is not likely to repeal, amend, or revise RPA/NFMA anytime soon, and that the Forest Service is already engaging stakeholders in adaptive governance discussions/policy actions. On the other hand public interest groups may not go along, if only beause the wicked problems surrounding “species viability” will not be quickly tamed. If the species viability questions can be addressed in (or around) a “simple rule,” public interest groups may move their attention to other arenas. There is a long-standing tradition in American government of leaving laws on the books long after enforcement of these laws makes sense. Think about how long city governments kept laws like “a hitching post will be provided every X feet along Main Street” on their books.

Finally, if the Forest Service chooses to embed adaptive governance in the NFMA rule, it can serve at once as a wake-up call to the Congress to revise RPA/NFMA and simultaneously relieve forest-level burdens now imposed by an anachronistic planning rule—currently the 1982 planning rule. It can also serve as a means to rebuild trust!

I’m betting on a simple tweak of the Draft rule, but hoping for one of the other two paths.

Climate Shift – Nisbet’s Report

Certainly public land managers need to be climate aware; and that also means being climate-debate aware. Here is a recent report- “Climate Shift A Clear Vision for the Next Decade of Public Debate.” Many of the findings may be of interest to NCFP readers.

This is from the summary..

Just as public opinion needs to be considered in the context of the economy and the message strategy of prominent political figures, belief in the reality and risks of climate change are also linked to the proposed policy solutions. Polling experts assert it is wrong to assume that questions asking about the causes and impacts of climate change are in fact measuring knowledge. Instead, answers to these questions are much more likely to be indirect opinions about cap and trade policy and an international agreement, explaining why even highly educated Republicans appear in polling to doubt human caused climate change. Academic studies reach a similar conclusion. In these studies, perceptions of scientific consensus vary by an individual’s underlying ideological values and in relation to the inferred course of policy action.

Research is less clear about the wider impact on public opinion of conservative outlets such as Fox News or for Climategate. These studies show that conservative-leaning individuals who already hold stronger doubts about climate change are more likely to view Fox News, and this viewing reinforces these doubts. Research shows that the same factors related to selective attention and interpretation apply to understanding the impact of Climategate on public opinion.

Just as ideology shapes the public’s judgments about climate change, ideology also guides the political interpretations of scientists and environmentalists. To understand this process, I analyzed a recent survey of members of the American Association for the Advancement of Science (AAAS). To be clear, the survey of AAAS members is by no means representative of scientists who are actively engaged in climate change research. On the reality and causes of climate change, there is no debate among specialists. Respondents to the AAAS survey are instead representative of the organization’s interdisciplinary and professional composition, with 44 percent of members working in the biological, medical or agricultural sciences

As the data show, AAAS members are strongly ideological, partisan and like-minded in outlook. With “moderate” and “independent” the mid-points in a continuum of political identity, more than a majority of AAAS members declare themselves to the left of these outlooks. To add context to this finding, I compared the political composition of AAAS members with 10 other politically-active groups and commonly-referenced media audiences. AAAS members are as ideologically like-minded as evangelical church members and substantially more partisan. Only black church members exhibit a stronger partisan lean than AAAS members and only Fox News viewers, Mormon Church members and Tea Party members exhibit a stronger ideological lean.

Among AAAS members, given that very few specialize in earth science, perceptions of climate change also vary considerably by ideology, just as they do among the public. Less than a majority of conservative AAAS members think the Earth is warming and that humans are a cause, compared with more than 80 percent of moderates and more than 95 percent of liberals. There are even stronger differences in the perceived seriousness of the issue.

Ideology also strongly influences the political events that AAAS members follow and their interpretation. Among strong liberals, 74 percent reported hearing a lot about claims the Bush administration had interfered with the work of government scientists, compared with 27 percent of conservative AAAS members. In comparison, just 10 percent of the public had heard a lot about the debate. Ideology additionally shaped how the claims were interpreted. On this matter, of those hearing about the debate, 57 percent of conservative AAAS members said the claims were true, compared with 87 percent of moderates and 97 percent of liberals.

To the extent that AAAS membership is consistent with the political identity of the environmental movement and scientific community at large, the findings suggest several important themes to consider. First, given their political identity and outlook, it is likely very difficult for many scientists and environmentalists to understand why so many Americans have reservations about complex policies such as cap and trade that impose costs on consumers without offering clearly defined benefits.

Second, as a natural human tendency, the political preferences of scientists and environmentalists likely lead them to seek out congenial sources in the media and to overlook the polarizing qualities of admired leaders such as Gore. These same factors also likely shape a view of the world that is inherently hostile even when objective indicators of financial resources, media coverage and public opinion suggest otherwise.

As a result, in discussion of communication initiatives and political strategy, scientists and environmentalists tend to overlook how economic trends and their own actions might diminish public concern, and instead focus on presumed flaws in media coverage or the activities of conservatives. Moreover, as organizations such as the AAAS train and encourage their members to engage in public outreach, most participants are likely to view politics very differently from the audiences with which they are trying to engage, a challenge that merits greater focus as part of these trainings.

These observations will probably raise most heat..

Designs to Win: Engineering Social Change
In Chapter 2, I examine the conventional belief that conservative philanthropists like the Koch brothers are more effective than their centrist counterparts because they funnel their funding into a coordinated set of causes, think tanks and groups aimed at achieving specific policy ends. Yet as I review, far from being passive supporters, over the past decade, foundations supporting action on climate change have strongly shaped—if not defined—the environmental movement’s agenda, engaging in many of the same policy-focused strategies as conservatives.

In 2006, several of the country’s wealthiest foundations hired a consulting firm to comprehensively survey the available scientific literature and to consult more than 150 leading climate change and energy experts. The result of this intensive undertaking was the 2007 report Design to Win: Philanthropy’s Role in the Fight Against Global Warming.

Leading the report was the recommendation that “tempering climate change” required a strong cap and trade policy in the United States and the European Union, and a binding international agreement on greenhouse gas emissions. The report predicted that passage of cap and trade legislation would “prompt a sea change that washes over the entire global economy.” The report included little to no discussion of the role of government in directly sponsoring the creation of new energy technologies. The report is additionally notable for the absence of any meaningful discussion of social, political or cultural dimensions of the challenge.

To understand how this planning document shaped the investment strategies of major foundations, I analyzed available records as of January 2011 for 1,246 climate change and energy-related grants distributed by nine aligned foundations between 2008 and 2010. These aligned foundations are among the wealthiest in the country, include several of the top funders of environment-related programs, and were either sponsors of the Design to Win report or describe themselves as following its recommendations. The foundations analyzed were the David and Lucile Packard Foundation (#1 in environmental funding for 2009), the Sea Change Foundation (#4), the William and Flora Hewlett Foundation (#5), the Kresge Foundation (#13), the Doris Duke Charitable Foundation (#24), the McKnight Foundation (#39), the Oak Foundation (#41), the Energy Foundation and ClimateWorks.

Approximately $368 million was distributed across the 1,246 individual grants. However, given that not all foundation records are publicly available for this period, the total of $368 million likely underestimates the actual amount distributed between 2008 and 2010. If an average based on a foundation’s previous year giving is used as a stand-in for missing years, these nine foundations would have distributed more than $560 million between 2008 and 2010.

Much like their conservative counterparts, the funding provided by these nine foundations reflects a pattern of support focused on achieving a clear set of policy objectives. Funding included $39 million associated with activities in support of cap and trade policies; $32 million associated with efforts at reaching an international agreement or influencing the policies of a specific country; and $18.7 million associated with efforts at limiting or opposing coal-fired power plants.

Funding patterns also reflect the Design to Win report’s framing of climate change as a physical threat that requires primarily scientific and economic expertise to solve. More than $48 million in grants were associated with policy analysis or economic impact analysis; $17 million with environmental impact analysis; and $13 million given directly to support university-based programs.

In addition, funding was concentrated on just a few national organizations. Though 1,246 grants were allocated, 25 organizations combined to receive $182 million, nearly half the $368 million total distributed. Of the 25 organizations, 14 were leaders in the push for cap and trade legislation. Recipients included the Environmental Defense Fund, the Natural Resources Defense Council, the Union of Concerned Scientists, the Sierra Club, the League of Conservation Voters and the Alliance for Climate Protection.

As the top recipient of funding, nearly one out of every 10 dollars ($34.6 million) went to the Bipartisan Policy Center, exceeding the $31.3 million distributed by Koch-affiliated foundations to all conservative organizations between 2005 and 2009.

The analysis of the Design to Win alliance shows that contrary to conventional wisdom, these nine foundations have been as strategic in targeting specific policy outcomes as even the Koch brothers, applying more than 10 times the amount of money in pursuit of their goals. Yet focus and strategy are only as effective as the premises upon which they are based. As described in the chapter, the Design to Win report appeared to define climate change in conventional terms, as an environmental problem that required only the mobilization of market incentives and public will. With this definition, comparatively limited funding focused on the role of government in promoting new technology and innovation. Nor was there equivalent investment in important human dimensions of the issue, such as adaptation, health, equity, justice or economic development.

I italicized the last sentence because within our own world of climate and public lands we are certainly free to, and I believe, should frame climate change from a more holistic perspective.

Mark Squillace in New West on Proposed Planning Rule

Here’s the link .

Here are a couple of quotes:

Decades of land use litigation have crippled the Forest Service’s planning process, causing the agency to become over-cautious and vague, according to environmental lawyer and scholar Mark Squillace. A proposed national planning rule, for which public comments close on May 16, is too complex, time-consuming, and fraught with unnecessary choices that invite litigation, says Squillace, director of the Natural Resources Law Center at the University of Colorado School of Law in Boulder.

“I really think the forest planning process is broken, and one of the reasons is they spend so much time revising the plan and they don’t really improve it, because it becomes static over time.” he says. “It’s really about monitoring, not assessment. What you want is a monitoring program that’s constantly looking at what’s happening in the forest.”

Squillace, who has worked in the Department of the Interior and was director of litigation for the Environmental Policy Institute in Washington, D.C., says monitoring of many conditions, such as the population status of species, soil moisture, and pathogens, should all feed back into the assessment reports of national forests that are compiled every two years, which in turn would be used to alter the national plan. “If it’s done right, you’ll virtually never have to do another plan at all, because it’s constantly changing.”

Squillace applauds the public input. “I think the process they’ve used has been exemplary. They’ve really tried to involve people in a meaningful way.”

But at the national forum, he asked a Forest Service panel if they had considered options to make the plan development process simpler, such as resource-use plans at the level of the individual forest that would avoid the complicated standards and guidelines built into the national plan. “I think right now the public often loses the forest for the trees because of the detail, the complexity, of the plan,” he said.

On science,

In terms of the role science would play in resource management, Squillace worries that the language of the draft plan requires only that officials “take into account the best scientific information throughout the planning process.” Such weak wording could turn the rule’s scientific standards into a paper tiger, he claims.

He cites a comment made by a member of the public during the national forum that there is no “best science,” only competing views. He disagrees vehemently. There may be a level of uncertainty, as with climate science, he says, but the agency cannot avoid a preponderance of scientific opinion simply by noting that scientists may take different views.

“The Forest Service is increasingly careful about not setting standards that will tie their hands,” he says. “To me, that’s the essence of planning: making choices.”

Even so, Squillace says the Forest Service has trouble making such site-specific analyses, because the resources required for the national planning process detract from resources needed for project-level studies. “I can say with confidence that this kind of thing has happened in many forests.”

One of his answers to the problem is to use more maps, to help visualize resource questions or threats. From the many meetings he has attended over the years, he says his sense is that the public mainly wants to know what uses of national forests will and will not be allowed. Maps that show such uses, or zonings, already are made by the Forest Service, he says. This should be extended to maps that designate the suitability of tracts of land for particular uses. Other maps could display watersheds, wildlife habitats, ecosystems, and ecological conditions. They could be designed as overlays, so the public could see how such resources interplay with the suitability of a given tract of land for various uses.

“Maps provide a really transparent way, I think, to engage the agency in what the public would like to see,” he says. This would help everyone to analyze use options. “We fight it out, if you will, in the decision-making phase.”

I agree with most of his points, especially about the public’s interest in lines on maps.

However, it is interesting that his views of science seem to be different than Toddi’s below. Maybe we are talking past each other, but I have noticed that people in the law profession (this is my current hypothesis) seem to have the idea that decisions can be hardwired to some “science.” Following Toddi’s post, it will be interesting for us to note who makes these claims about science and see if those claimants fall into any kind of pattern. In the past, I’ve noticed this coming from NGO’s with many lawyers on their boards and staffs. Scientists themselves tend to be more cautious. And of course, people who study this kind of thing academically (STS or science policy studies) sound like Toddi’s lecture.

Also, Squillace said:

“They make it impossible to challenge monitoring,” Squillace charges, “because monitoring reports every two years are not decisional documents, so they’re not reviewable.”

I don’t know the utility of legal challenges of monitoring per se… I’m sure something got missed in the interview here. Based on other conversations, I think he means challenging legally decisions made or not made on the basis of that monitoring.. but the NEPA of the decisions themselves could be challenged..??

And finally..

Squillace thinks the agency should look to legal precedents that argue in favor of analysis of individual ecosystems rather than concentrating on the “bird’s eye view.” He points to a 1987 case in Wyoming concerning oil and gas leases on more than 10,000 acres of the Shoshone National Forest. In dismissing a suit brought by the Park County Resource Council that contended the Environmental Impact Statement was inadequate, a court of appeals ruled that a comprehensive EIS is not required at the leasing stage. Nine out of ten leases do not result in exploratory drilling, the court noted, concluding that site-specific environmental assessments should be made before a particular drilling project actually occurs.

This finding was strengthened the following year, when another court of appeals ruled that federal agencies did not violate law in selling oil and gas leases on 1.3 million acres of the Flathead and Gallatin National Forests in Montana without preparing an EIS.

Is he arguing that forest plan EIS’s are not particularly useful? I seem to remember others who thought this…during the 2005 (Mark would probably call it the “Bush” ;)) Rule.

Toddi Steelman on Science and Politics

 

At a recent TED lecture at North Carolina State University, Professor Toddi Steeman talked about three science myths: “Science Determines Policy,” “Science is Objective,” and “More Science Leads to Consensus.” Steelman titled the talk, “My Jihad Against Scientific Fundamentalism.” Beginning about 7:50 into the presentation Steelman talks about so-called “Climategate,” as one of two case studies where misplaced emphasis on science frustrates policy development and problem solving. Here is a “snip,” [hastily transcribed from audio, beginning at 12:57]:

More, better, new science cannot provide objective answers to value-based questions. Science is actually pretty good at helping us understand problems, but is really not so good at helping us understand solutions to those problems. … Politics is the realm where we shape and share our collective values as a society. And politics requires different forms of knowledge, including local knowledge and public preferences. …

Knowledge like “public preferences” and “local knowledge” are often dismissed outright when we talk about environmental issues because they are seen as flawed in some fundamental way. They are seen as biased or not objective or not neutral. In that type of framing science is actually seen to be a more perfect form of knowledge … seen as … less biased or more objective or more neutral. … And under that type of framing [science] is a preferred or privileged form of knowledge in environmental decision-making. … The question is, Should it be that way?

Under that type of framing politics is really vilified. It is seen as a dirty, spin-filled, nasty practice full of compromise and collaboration in the absolute worst sense of those words. And because it is portrayed that way or framed that way it is easy to dismiss these other forms of knowledge….We are sort of left with having science to fill this gap. … But the question is, Should it be that way? …

Science can’t tell us what to do as individuals or as a collective society in the face of a changing climate. We have to make those hard decisions and engage in that debate collectively. And yet we continuously look to science to provide those answers for us. So the question again is, Why? Why do we do that? …

We continue to place these expectations on science—that science really cannot meet. And in doing so we really do an enormous disservice to science. …What we really need to do is to elevate the political dialogue in our society and to take the expectations on science down a little bit. …

We could continue to perpetuate the [three science myths above]. … And in doing so we do an enormous disservice to science … Or, the alternative vision is to acknowledge what those myths are and to embrace politics and the really constructive role it can potentially play for us. And in doing so what we could do is accept what science can do and what its strengths are, as well as what local knowledge can do for us, as well as what public preferences can do for us. And in leveraging all three of those knowledge types perhaps get better purchase on some of these contested claims in the environmental arena. Because the challenges we face in our environmental arena are so wide and so challenging we need all the help that we possibly can get.

Announcing Two New NCFP Roadless Features

Conveniently for the NCFP reader, we have our own resident roadless geek (me!). A new act in Roadless Rule Theater opened last week with the beginning of a comment period on the proposed 2011 Colorado Roadless Rule. In my view, the first step of reaching mutual understanding is to jointly examine underlying facts. In this spirit, I will introduce two new features:

1) Roadless Fact Check- where I will examine claims made by various individuals and press stories.

2) A q&a opportunity called “Ask a Roadless Geek” where I will do my best to answer your questions. Send them to [email protected]. If you don’t feel comfortable using your name, you can use any pseudonym you’d like, e.g. “Perplexed by Obscure Policy” or “Somnolescent Due to Apparently Endless Wrangling”.

These two efforts are supplanting the previous “Roadless Media Watch” that showed up on the right hand column.

Stay tuned for the first edition of Roadless Fact Check…

Biomass Carbon Accounting and Other Reports of Interest from the University of Idaho Policy Analysis Group

A link to this report showed up in my inbox a while back.

#31. Accounting for Greenhouse Gas Emissions from Wood Bioenergy. Jay O’Laughlin (September 2010).

The utilization of woody biomass to produce energy is accompanied by concerns about sustainable forest management and greenhouse gas (GHG) emissions from burning biomass. The conversion, or potential conversion, of land from native forest to biofuel crops has led to reconsideration of emissions accounting practices. This report critiques and responds to the Biomass Sustainability and Carbon Policy Study commissioned by the Massachusetts Department of Energy Resources and conducted by the Manomet Center for Conservation Sciences. This report is designed to respond to a call for information by the U.S. Environmental Protection Agency as it reconsiders how GHG emissions from biomass combustion should be treated under its regulatory
responsibilities. Full report in PDF format.

Some previous posts on this blog on the Manomet study and about biomass are here and here.

But the University of Idaho Policy Analysis Group has developed a variety of interesting papers on other topics.
Check out their other studies here and here.

Fixing the Rule: An Adaptive Governance Roadmap

If adaptive governance, i.e. adaptive management applied to public lands, might help move beyond ongoing forest wars, how might the Draft NFMA Rule (pdf) be improved toward adaptive governance? This post outlines my ideas for improving the rule. Ultimately, I’d like to see us vet this proposal when more fully developed, against the Forest Service’s Draft Planning Rule, Andy Stahl’s KISS Rule, and any other proposals that may be floating about. But before I put pen to paper, I’d like to get feedback on my ideas. Here is how I propose to “fix” the rule:

Background Notions

  • No matter what NFMA rule is put in play, it needs to be written by lawyers. Court challenges will not cease no matter what rule is in force.
  • I like the idea of adaptive governance, but also believe that adaptive management as applied to public problems is the same thing. I do not have a strong preference for which words, “adaptive governance” or “adaptive management” are used to described the process. I will use “adaptive management” here. There are many pathways that might be taken to adopt an adaptive governance approach to management. It may be that embedding adaptive governance into the NFMA rule is not the best path forward. I’m willing to listen to other possible pathways, and even alternatives to any adaptive governance pathway. But I still believe that the Draft Planning rule fails as adaptive management, and can not provide a useful path forward.

Reframing/Rewriting the NFMA Rule

  • Rewrite the “Purpose and Applicability” (219.1) (and also the “Summary” and “Overview” in the Federal Register run-up to the rule) to include reasons for a move away from narrowly framed forest planning and toward broader public engagement to address forest management’s wicked problems. Include a discussion of decision containers [See, this note] and how the public needs to help natural resource managers frame discussions/resolutions, including scope and scale. Allow wicked problem discussions/resolutions to well-up to appropriately sized containers so that people don’t have to grapple with policy at local scales, where such does not makes sense. Include “all lands” decision-making where and when appropriate, allowing for responsible officials to include but not be limited to Forest Service officials.
  • Define adaptive management, then do a near “global replace” of “planning” with “adaptive management.” A beginning point for a definition of adaptive management might be:

    [Adaptive Management]: linking a broad range of actors at multiple scales to deal with the interrelated dynamics of resources and ecosystems, management systems and social systems, as well as uncertainty, unpredictability, and surprise. Adaptive governance focuses on experimentation and learning, and it brings together research on institutions and organizations for collaboration, collective action, and conflict resolution in relation to natural resource and ecosystem management. The essential role of individuals needs to be recognized in this context (e.g., leadership, trust building, vision, and meaning); their social relations (e.g., actor groups, knowledge systems, social memory) and social networks serve as the web that tie together the adaptive governance system. It has cross-level and cross-scale activities and includes governmental policies that frame creativity.

    From “Adaptive Governance of Social-Ecological Systems”, Carl Folke, Thomas Hahn, Per Olsson, and Jon Norberg, Annu. Rev. Environ. Resour. 2005. 30:441-473 (pdf)

  • Keep “forest plan,” but define as suggested by the Clinton era Committee of Scientists: “A loose-leaf notebook that contains all of the policy directions, strategies, and implementation proposals from decisions that have been made at all levels of the planning process. It is the official repository of decisions big and small that have been made and reviewed in the strategic and landscape-level planning processes.”
  • Keep the tie to the FS Strategic Plan, but add more responsibility at the Chief’s office to make sure that adaptive management is real—a cultural change, more than just words—and something that “the Forest Service does”, not something delegated to a single staff group like “planning” or “ecosystem management.” In short, position most responsibility for RPA/NFMA to the Chief and/or Secretary of Agriculture.
  • Replace “three levels of planning” (219.2) with “multiple levels of adaptive management assessment, monitoring, and decision-making.” Make sure that “all lands” assessment, monitoring, and decision-making, done in concert with appropriate collaborators is the logical choice when such makes sense. [See, Why Three Planning Levels?]
  • Keep the idea of “standards and guidelines” (219.7) but make the development and revision of both “situational” at appropriate scope and scale. The idea is that most would be developed at levels other than a “national forest.” Still, forest supervisors would be charged to show how such standards apply to decisions they make. Similarly for assessment and monitoring information, as well as for policy decisions and legal authorities.
  • Add the idea of a “forest niche,” that would be reviewed publicly at, say, five-year intervals. [See, A Forest Service for the 21st Century Who Are We? to better understand niche idea for the Forest Service as a whole.]
  • Abandon the idea of “desired conditions,” instead allow for simple “scenario planning” that would embrace the idea of emergent unfolding future as opposed to managing toward a desired future. Note that this idea interfaces with the idea of “niches” above and does not preclude working toward betterment. It just moves the “betterment” debate into the policy arena and away form the land planning arena. [See: Whose Desire? What Future? Why?]
  • For specific requirements of NFMA law, craft wording to require the WO (and it’s bevy of legal counselors) to find means to comply with said requirements as expeditiously as possible at scale and scope as close to “national” as possible. For example, the requirement for an Allowable Sale Quantity might be set nationally at zero, with provision that all timber volume flowing from the national forests be determined via adaptive management and in the context of, say “ecosystem stewardship contracting,” or equivalent internal process.

Followup

I still intend to work up a complete rewrite of what I’ll call a “Draft NFMA Rule” soon. But I would like your feedback on these ideas now.

I have been chatting with a friend about the “Pre-Decisional Administrative Review Process” (219.50-59). We believe that if collaboration were much improved and allowed for multi-scale adaptive governance, the whole idea of “pre-decisional review” makes no sense, and perchance neither does any “appeal process.”

Finally, I may probably won’t include language relative to the “species diversity” provisions from NFMA. That will no doubt be the most fought-over part of the rule. Still, I maintain that the adaptive management fight is equally important. In my framing, species diversity is one of the items that the WO and its bevy of legal counselors ought to deal with. In all such “dealing” I believe that such policy review/policy revision ought to begin early, even perchance predating the adoption of a NFMA rule. Why the Forest Service runs so much of its policy development through “NFMA forest planning” remains a mystery to me.

NY Times on Gas vs. Coal

Kevin Maloney for the NYT

Just when we were discussing the same topic…

here’s a link to a NY Times story

But the cleanliness of natural gas is largely based on its lower carbon dioxide emissions when burned. It emits roughly half the amount of carbon dioxide as coal and about 30 percent that of oil.

Less clear, largely because no one has bothered to look, are the emissions over its entire production life cycle — that is, from the moment a well is plumbed to the point at which the gas is used.

Methane leaks have long been a concern because while methane dissipates in the atmosphere more quickly than carbon dioxide, it is far more efficient at trapping heat. Recent evidence has suggested that the amount of leakage has been underestimated. A report in January by the nonprofit journalism organization ProPublica, for example, noted that the Environmental Protection Agency had recently doubled its estimates for the amount of methane that is vented or lost from natural gas distribution lines.

Note that the SAF scientist letter mentioned in this post did mention methane associated with natural gas and coal.