Science and the Planning Rule Redux

See this story in the Sacramento Bee:

Critics say Obama abandons science in forest rules

GRANTS PASS, Ore. — The Obama administration’s proposed new rules for protecting clean water and wildlife on the United States’ nearly 200 million acres of national forests goes against the president’s pledge to let science be the guide, conservation groups and two former Clinton administration officials said Monday.

The administration made a “clear commitment” to make conservation policy based on sound science when it took office, said Jane Danowitz of the Pew Environment Group.

“One of the things we are asking for today is simple: Use science to set clear standards,” Danowitz said. “Make sure water and wildlife are protected for generations to come.”

The comments came in a teleconference from Washington, D.C., marking the end of a 90-day public comment period on new rules governing administration of the National Forest Management Act. The U.S. Forest Service expects to come out with final rules by the end of the year.

Also participating was Jamie Rappaport Clark, a Defenders of Wildlife executive and former U.S. Fish and Wildlife Service director. Clark said forest supervisors being given unprecedented discretion under the new rules need strong standards and guidelines to resist the political pressure they regularly face in making decisions on managing their lands.

Jim Furnish, a former deputy chief of the Forest Service, said the proposed rules tell local forest supervisors to consider science but leave them room to ignore science when making decisions on protecting clean water resources, fish and wildlife habitat, and endangered species.

The proposed rules represent another shift to the right on environmental issues for the Obama administration, which recently stood aside as Congress lifted Endangered Species Act protections for wolves in the Rocky Mountains and took steps to ramp up domestic oil production by extending drilling leases in the Gulf of Mexico and off the coast of Alaska.

The 155 national forests and grasslands managed by the Forest Service cover 193 million acres in 42 states and Puerto Rico. They provide about 40 percent of the nation’s clean water and threatened and endangered species habitat.

Balance between industry and conservation in those areas has been tough to find since the existing rules took effect in 1982. The existing rules were the basis for lawsuits that cut logging by more than 80 percent to protect salmon, the northern spotted owl and other fish and wildlife.

Tony Tooke is overseeing development of the rules as Forest Service director of ecosystem management coordination. He said the agency is trying to write rules that will guide a collaborative process based on science and other information sources. It looks forward to improving the rules after reviewing more than 100,000 public comments received, he added.

“There are other important sources of information as well, used in the planning process,” Tooke said. “For example, local indigenous knowledge, public input, agency policies, the results of the monitoring process and the experience of land managers on the ground.”

On national forest policy, the Obama administration came into office supporting protection of undeveloped areas known as roadless areas and payments to rural counties hurt by the loss of logging revenues.

Earlier this year Agriculture Secretary Tom Vilsack said he wanted to break through the logjam of political conflict over forest management by using science to do what is best for the forests.

More than 400 scientists and a bipartisan group of congressmen wrote letters urging Vilsack to also include more specific protections for clean water and wildlife habitat in the rules.

“This policy is probably one of the most important conservation measures I think this administration will ever undertake,” said U.S. Rep. Martin Heinrich, D-N.M.

I have a couple of thoughts on this article:
1) Does it unnecessarily politicize the debate? People like or don’t like the proposed rule across a wide political spectrum. For example, Jim Furnish seems to be called a “Clinton Administration Official”; yet as far as I know he was a career employee in a career position when he retired. Also, “The proposed rules represent another shift to the right on environmental issues for the Obama administration.” What if this article said they represent a faithful response to public comment, or a “shift to the center.” You know what I think about unnecessarily partisanizing public lands debates: it’s a bad idea.

2) I don’t think any of the cited people are scientists, nor students of science and technology studies. The idea that it is more “scientific” to have a policy with one standard from forests in Puerto Rico to Alaska, from New Hampshire to San Diego doesn’t reflect my experience in science.

3) It’s interesting to think about a thought experiment with the same quotes and considering energy policy (another natural resource policy) instead of the planning rule.

For example “One of the things we are asking for today is simple: Use science to determine which sources of energy we use” or

“Governors can consider science but national policies leave them room to ignore science when making decisions on regulating different energy sources in their state.”

and I don’t know if Vilsack really said this:

Earlier this year Agriculture Secretary Tom Vilsack said he wanted to break through the logjam of political conflict over forest management by using science to do what is best for the forests.

But how is that working for the climate science policy – using science to “break through the logjam” (did he really use that word?) ?

How to do Assessments Under the Proposed Forest Service Planning Rule – Part 1

Lynx and coyote tracks, Superior National Forest, Minnesota, photo by Larry Weber

An assessment is the gathering and integrating of information relevant to the planning area from many sources and the analysis of that information to identify a need to change a plan or to inform how a new plan should be proposed. – section 219.5(a)(1) of the proposed Forest Service planning rule

It is a synthesis of information in support of land management planning to determine whether a change to the plan is needed.  Assessments are not decisionmaking documents but provide current information on select issue. – section 219.19 of the proposed Forest Service planning rule

 

This is the first of a series of posts about possible approaches to preparing an assessment for a National Forest/Grassland Plan revision under the proposed Forest Service planning rule.  (It is based on some informal conversations that Peter Williams and I have had with folks inside and outside the Forest Service, but nothing here reflects official Forest Service policy or the deliberations of the team working on the planning rule.)

The proposed rule expects a process that integrates both science and collaboration: “the objective of this part is to guide the collaborative and science-based development, amendment, and revision of land management plans.” (219.1(c)).  Under the rule, an assessment must be collaborative and science-based, just as the overall plan revision process, because it brings together many sources of information, including social, economic, and ecological, whether qualitative or quantitative.  Moreover, the subsequent process must rely on information from an assessment if the process is to be collaborative and science-based.

Although one immediate purpose of an assessment is to identify whether a need for change exists, the second, equally important purpose of an assessment is to inform design of the subsequent forest planning process that will propose specific changes to the plan if a determination is made that a need for change does exist.

Under this definition, an assessment is both a product and a process

The product is a report similar to an “Analysis of the Management Situation” or other scoping documents under the 1982 planning rule.   It documents “existing and potential future conditions and stressors” that subsequently will be the foundation for the revision’s Environmental Impact Statement.  It describes the Forest in the context of the broader ecosystem, and what’s going on in the States and counties within and surrounding the Forest.

The process involves convening multiple parties at multiple scales to determine if the current Forest Plan is working by answering a set of assessment questions derived from the rule

This rather long list of questions has the potential to be quite lengthy, so they need to first be screened to determine if they are relevant to the particular forest.  Screening questions would include:

Assessment Goal

Coarse Screening Question

Need for change in plan components or monitoring program

Is the information needed to inform and develop plan components (i.e., Is this a Forest Plan issue, not a program planning issue or a project issue)?  219.6(b)(1)
Is the resource present?  219.7(b)(2)(ii)
Is the resource important?  219.7(b)(2)(ii)
Is addressing the resource within the authority of the Forest Service?  219.8, 219.9, 219.10, 219.11
Is addressing the resource within the capability of the plan area?  219.8, 219.9, 219.10, 219.11
Is addressing the resource within the fiscal capability of the unit?  219.10
Is there an emerging public issue that needs be addressed?  219.6

Design of process for revising a plan or monitoring program

Is the information needed to understand the discrete roles, jurisdictions, responsibilities, and skills of interested and affected parties?  219.4(a)
Is the information needed to understand the expectations regarding the accessibility of the process, opportunities, and information?  219.4(a)
Is the information needed to determine the scope, methods, forum, and timing of public participation opportunities?  219.4(a)(1)
Is the information needed to develop required plan components (219.6(b)(1)), including information needed to inform design of the public notification and participation process?  219.7(c)(1)

In answering the questions, technical information is essential, but an assessment under the rule should not merely be a technical process – it is fundamentally participatory, drawing on information and knowledge from multiple sources and multiple participants.  During an assessment, the most accurate, reliable, and relevant scientific information is synthesized from governmental and non-governmental sources. But the process is also about clarifying values, because an important step is to identify why a particular National Forest/Grassland is important to the participants.  One reason for clarifying values is that the knowledge being sought includes how a new plan should be proposed.  That is a process-oriented goal.  To meet such a goal in a way that is appropriate for the local situation, the assessment must seek to understand procedural preferences—values—of stakeholders, including but not limited to those of Forest Service personnel. The second specific assessment purpose is worth highlighting again: the goal of an assessment under the proposed planning rule is to gather and integrate information that informs design of a participatory and collaborative process should one be needed to change the plan.

Part 2 will describe how an assessment might be conducted.