Do we need another COS?

This letter from Center for Biological Diversity and more than 100 groups:

Forest Planning Rulemaking to Vilsack 16Dec2009

can serve to initiate our discussion on what is the appropriate role of science and scientists in the development of a planning rule.

NFMA (1976) says ” the Secretary of Agriculture shall appoint a committee of scientists who are not officers or employees of the Forest Service. The committee shall provide scientific and technical advice and counsel on proposed guidelines and procedures to assure that an effective interdisciplinary approach is proposed and adopted. The committee shall terminate upon promulgation of the regulations. The views of the committees shall be included in the public information supplied when the regulations are proposed for adoption.”

Since NFMA was passed in 1976, which was 34 years ago, we can imagine that our knowledge of best how to use science in policy has improved along with other scientific fields of study.

So one could reasonably ask, if we were to design something today, would we use current thinking, for example, use a perspective based committee such as the RACNAC was for roadless? This would provide also provide an independent view.  See for example, Brown’s piece “Fairly Balanced”.

Does external advice need to stop at the promulgation of the regulations? I would argue that it should not, rather the development of directives and implementation could also benefit from the advice of an independent group.

Due to the recent interest in “Climategate” there have been some  examples of  current thinking on the role of science in developing policy.  For example, see Hulme’s and Sarewitz and Thernstrom’s recent op-eds.

As a scientist, and having been involved with the 05 Rule, I think we have to be very careful about what we determine is a “science” issue; which disciplines of science we choose to get involved; whether the development of consensus via arbitration of disagreements among individuals from different fields on an interdisciplinary science advisory panel can be claimed to be “science.”

I think that we can learn from the substantial literature on using science in developing policy and advisory panels that has accumulated since 1976.

This letter also highlights one of the tensions about developing  NFMA planning regulation.  Some see it as a process to arrive at a forest plan, where the substance occurs at the forest plan level. Others see it as an opportunity to hardwire policy choices at the national level through these regulations

So the discussion,  if you are a process proponent,  is simply  how to use science in forest planning; if you are a “national policy content” proponent, it may be about specific science to be used in determining national policy choices. Where you are in this “process to content” or “decide in a forest plan or decide in the Rule”  continuum may determine how you see the utility of science in the development of a rule.

Thank you to CBD and to the the other groups for articulating their perspective.

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