National Park Service policy: precautionary principle and “best available sound science”

If you’re weary of debating USFS policy, here’s a look at National Park Service policy, in a document released yesterday:

DIRECTOR’S ORDER #100: RESOURCE STEWARDSHIP FOR THE 21ST CENTURY

The document states that “To achieve the stewardship goal, the NPS will adopt the precautionary principle and adaptive management as guiding strategies for resource management subject to all existing authorities. These strategies will promote science-based decisions, help deal with uncertainty, and promote a culture of learning. Management decisions based on the precautionary principle may often require adaptive management.”

Also, it adds “sound” to “best available science”:

“To fulfill the stewardship goal, the NPS will use a decision-making framework that is explicitly based upon three criteria: (1) best available sound science and scholarship, (2) accurate fidelity to the law, and (3) long-term public interest.”

Does adding “sound” — “best available sound science and scholarship” — make it easier for managers to disregard science that doesn’t support agency goals?

13 Comments

  1. Personally, I think of “sound science” as being methodologically rigorous with reproducible results and high confidence in the findings. These concepts, along with adherence to the precautionary principle, are more important than ever in an era when policymakers are increasingly comfortable citing uncertainty and bias as justifications for discounting or dismissing the scientific consensus.

  2. Steve, a very interesting question that surfaces with the addition of “sound”. Who determines what is sound? What criteria will be used to determine what is “sound”and what is “not sound”. Wow!!

    • My definition is that “sound” is whatever a group of people think is “sound”- each discipline has its own opinion (or subgroups have their own opinions), plus that changes over time. It’s also interesting that an agency can decide something like being “precautionary”. My favorite example is introducing the legal marijuana industry to states.. that’s certainly not precautionary about either the environment or public health. Maybe it has to do with statutes vs. regs. But if you’re not precautionary about statutes (the big picture), what good will it do to be precautionary about the regs to implement the statutes? So confusing.

  3. Steve

    I don’t think that ambiguities like “sound” and “best” are helpful in an operational directive unless some supporting document defines at least the established and universally applicable fundamental science that applies in all decision making.

    I would say that “best” is defined as conformance with the intentions of law and state best management practices.

    I would say that “sound” requires adherence, at a minimum, to recognizing the inviolate laws of science that are universally applicable in all forests regardless of their location. By using the word “recognizing” we are allowing the option to go against such principles by not maintaining healthy stand density or fuels levels or whatever. What we are requiring is that the reasons for ignoring such science must be specifically enumerated in any plan.

    In recognition of the last paragraph, I would greatly appreciate your feedback on the discussion thread titled “In Search of Common Ground”. That thread is an attempt to define the Bare Minimum of Sound, Fundamental, Established, Universally Applicable Forest Science.

    • Gil,

      I read your original “In Search Of Common Ground” post in the with interest, and although I haven’t had time to follow the discussion closely, I’ve flagged it for later reading. In short, you’ve made an excellent start. One aspect to consider adding is the social aspect for forests and forestry, from recreation to spiritual values. There is science to inform us on this. Like it or not, forest managers do not work in a vacuum. Others may have addressed this already….

  4. The Park Service has admitted that their decisions regarding wildfires in Yosemite were not good. Indeed, just WHERE is the science in conducting burns during the middle of summer?!? Their prescriptions aren’t inclusive of all actual conditions. If they used fuel moisture in considering safety issues, I think we’d all be better off.

    • Larry

      That error is incredible. Down here in the south you have to pull all of the site pertinent fire weather info predictions together, decide that the conditions are within the state requirements and then submit it to the state for their approval before you can do anything. If the state says no, then its no go.

      What causes deficiencies like this? Is it too broad of an education without sufficient depth? Is it federal diversity mandates that force unqualified people into jobs that they aren’t qualified for? Is it laziness where people don’t bother to review the literature before they act on something that they don’t do regularly? As they say: “One Ah! Shucks! wipes out a million “attaboys””.

      • Well, the Park Service has differing goals and rules. Written into their prescriptions is the desire to kill a certain percentage of trees in overstocked areas (since they cannot thin and sell trees). For Yosemite, they decided to burn 75 acres, in a dry August, in the old A-Rock fire area, near Foresta. Within 30 minutes after ignition, the winds changed from the morning downslope winds into the up-canyon winds and the near-record temperatures. 17,000 acres and over 16 million dollars later, the fire was finally put out. The re-burn within the old fire’s footprint were particularly devastating, killing off the natural conifer regeneration and sterilizing the soils with long-burning old growth logs, laying on the ground. Even the common and dominating brush are having trouble growing in the soils devoid of organic material and with a severely-reduced water holding capacity.

        Letting fires burn wherever they go is a poor policy when you rigidly enforce it, regardless of conditions and situations. ‘Active fire management’ should include steering or stopping the fire’s direction. One example in Yosemite of a bad decision is to let a fire run downhill, into a major highway into Yosemite Valley. The dead trees along the highway had to be cut, in a 4 mile stretch.

  5. Here’s the NPS definition: “Best available sound science and scholarship is up-to-date and rigorous in method, mindful of limitations, peer-reviewed when appropriate and required, and delivered at the appropriate time in the decision-making process in ways that allow NPS managers to apply its findings. Sound science and scholarship is a body of knowledge that draws upon a broad and often interdisciplinary community of practitioners, both within and beyond the NPS.”

    As a practical matter, I think “sound” is already a component of “best,” so this shouldn’t change the outcomes. The message here may be that as a policy matter, NPS managers should be alert to science that isn’t sound. No reason this policy should be biased for or against agency goals, but it could have been identified as an issue because they have encountered unsound science being used against agency goals.

    • Jon

      The NPS definitions are totally meaningless imho since the pertinent words in the definition are totally ambiguous. Not even worth the paper that they are written on.

      It sure would be nice if they had a list of “universally applicable established forest science” as a checklist that they had to adhere to or explain why they chose to ignore them in the plan or in the authorization for an unanticipated activity before its execution. i.e. see “In search of common ground”.

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