Timber Wars Over.. Role of Forest Planning Process??

U.S. Secretary of Agriculture Tom Vilsack (center) expresses his appreciation for being given the opportunity to tour and learn more about Arizona’s groundbreaking effort to restore forest health and protect fire-threatened communities. Congresswoman Ann Kirkpatrick (left) and various local and forest officials accompanied Vilsack on the tour.

Please see story on Four Forests Initiative in Arizona.

It would seem to support the ideas of landscape scale decisions and collaboration, and the forest plan as a compilation of decisions made, rather than the instrument of decision making. Also, as Andy maintains, if NFMA is about timber, and if timber wars are over, then should forest plans be simply a large loose-leaf notebook of decisions made at different scales? Is there any “there” there?

Also it brings up Martin’s question of large scale NEPA- will ask around how they are handling it and report back.

6 thoughts on “Timber Wars Over.. Role of Forest Planning Process??”

  1. I’m currently the team leader for the 4 Forest Restoration Initiative (4FRI) and would be happy to talk about how we’re thinking about planning. Without a doubt, if you’re interested in how to tackle large-scale, collaborative planning, and monitoring, how landscape-scale planning intersects with forest planning, and how to make plans adaptable over time, northern Arizona is the place (or one place) to be right now.

    4FRI is largely in the conceptual stages at the moment, but we’re looking at how to do project-level planning at the ~750,000-acre scale. Why that scale? Well, we’re really looking at a restoration program that will cover ~2.4 million acres of ponderosa pine forest across the Mogollon Rim of northern Arizona. That area includes parts of four National Forests, one of which is the Apache-Sitgreaves, the site of the White Mountain Stewardship Contract, which is closely linked to this initiative. At present, one of our primary tasks is to figure out what kind of assessment or strategic document to tackle for the entire 2.4 million-acre area. The forest supervisors decided a programmatic EIS to cover that entire area was not appropriate, for numerous reasons, just two of which were the complications of doing a programmatic EIS at that scale while concurrently revising up to four forest plans and the unclear utility and amount of time associated with doing a programmatic EIS followed by subsequent project-level EISs.

    At the same time, given that we’re considering treating an additional 30,000 acres/year through mechanical thinning and prescribed burning, and potentially entering into a 10-year contract to offer 300,000 acres of treatment, there are great reasons to do project-level planning at a scale at least somewhat commensurate with the scale of contracting under consideration. Even doing NEPA at 300,000 acres for a project would be innovative, so why not go to ~750,000 acres, a scale that would match a ten-year contract? We’re engaged in a collaborative planning exercise, with representation from industry, conservation NGOs, county representatives, and other state and federal agencies. We will never succeed with restoration at meaningful scales without support from this stakeholder group, and we also can’t do it without reengaging an appropriately-scaled industry. If we could successfully take forward a collaboratively-designed proposed action at the right scale for a contract, that might be out best chance for success–success being the achievement of landscape-scale restoration.

    Analysis at this scale will require approaching our assessment of current conditions and effects analyses in new ways. One reason we have a good chance of success here is the presence of science providers, including the Ecological Restoration Institute and ForestERA at NAU, who have new kinds of data that will allow us to approach NEPA analysis in innovative ways. Conducting stand exams and surveys or approaching effects analyses in traditional ways will never work at this scale. We’ll have to figure out what level of detail we need to understand current conditions and prioritize areas for treatment. What information is necessary in this document that will allow us to go straight to implementation? When we started conceptualizing this, I asked, “How do we do a meaningful effects analysis at that scale?” And, someone countered, “What is a meaningful effects analysis and does the FS do that now?” A good question and one we’ll be wrestling with. Certainly we’ve all seen effects analyses that were less than informative. This project presents an opportunity to approach our analyses in ways that may ultimately be the future of landscape-scale planning.

    The questions that loom largest for me right now: What are the respective roles of a 2.4 million acre strategy that is not a decision document, forest plans, and a project-level analysis that will cover parts of two forests and lay out 10 years of work? How do we make a project-level analysis at that scale adaptable? How will we tackled monitoring at this scale and feedback information into a document that surely will become stale if not somehow adapted and updated? How do we engage in truly collaborative planning with a highly involved stakeholder group and still do what we are required to do by law? How will we fund an initiative of this scope, even if industry can be engaged in a way that drastically reduces costs to the agency for service work provided?

    We have the opportunity here in northern Arizona to wrestle with some of the most fascinating challenges and questions in U.S. forest policy: how to do landscape-level planning, how to make it adaptive, how it relates to forest planning (and what is the role of forest planning), how to plan collaboratively and capitalize on unprecedented levels of social agreement, how to strike a balance between management and the reintroduction of natural processes, and on and on. Have I convinced anyone to come work with us? There’s plenty of excitement to be had around this effort and plenty of nay-saying. Surely it’s extremely complex and daunting, but the opportunities to accomplish something new and different are incredibly exciting.

    • Courtney,

      Thanks for thinking of us, this is great. I have no satisfying answers. But the purpose of NEPA comes to mind, as I too consider some issues related to large-scale restoration planning up here. One critique I find compelling is that the USFS often does NEPA too late in the game to be of help in setting program goals and objectives.

      Professor Oliver Houck, an expert on all things NEPA, makes such a case in his excellent and provocative analysis: “How’d We Get Divorced?: The Curious Case of NEPA and Planning,” Environmental Law Reporter, 39 (2009): 10645 (can’t find online and not sure if I can post or not). He analyzes this divorce, focusing on USFS and Federal Highway Administration, and reviews key case law and agency postures along the way.

      His argument is that NEPA has essentially “been relegated to the latest, smallest, and most foreordained step in the process.” Too much piecemealing he argues, with NEPA coming in too late in the 4th quarter. The challenge, as he puts it, is to “make NEPA work for legislative proposals and for programs that all but conclusively determine what the subsequent projects will be.”

      I’m sympathetic to this argument, though also understand the problems evident within it—how to do meaningful effects analysis at this large-scale. But as a citizen, I want the opportunity to weigh in on these large-scale programs that place the agency on a trajectory that is hard to stop once begun.

      All of this also makes me even more curious about Andy Stahl’s KISS approach to planning. Perhaps if the forest planning process were simplified, the agency could spend more time on this big-picture landscape-level stuff (using NEPA at the program level). Something to think about.

      Good luck.

  2. Courtney- thank you for this very thoughtful comment.
    We had many of the same conversations around the analysis for forest plan EISs as we worked on the 05 rule- how to keep it real, or not have one. Although unpopular, you can see how we arrived at that solution.

    If I were doing it, I would keep the assessment and monitoring a living document in terms of feedback and updating (maybe online with public comments and annual meetings with the public).
    But it’s possible to conceive of a programmatic to which each project could be tiered – but you would want to do public involvement on each project, so in reality how much less work would it be to just do an EA?
    The problem with using a NEPA-free assessment and updating process would be that I think there is some case law around a Port Orford Cedar strategy, that strategies in and of themselves can’t be incorporated in NEPA documents. I am probably missing some very important legal nuances though.
    Anyway, my view of the best analysis of environmental effects is just before you do something because 1) external kinds of information gets better in general (more science, more monitoring results) , and 2) effects are a function of what you are going to do, where, how you’re going to do it, and what other things have happened and might happen in the future. So in my view, “just-in-time” disclosure of environmental effects is the best approach.

  3. As Martin said, NEPA needs to not be the last thing done on the checklist. Instead, NEPA can and should be more organic and it can fit each step in a long process. Detailed site-specific impacts analysis is not usually needed in a landscape decision, like a plan. But that does not mean there needs to be no analysis. NEPA analysis needs to fit the level of decision. A forest plan looks at a whole forest over a time frame of 15 years. NEPA analysis for that should look at the perimeters of the possible impacts from each alternative over that time. What are the range of impacts reasonably expected? What can be done generally (and specifically, if known) to mitigate those and limit the impacts to the center of the range? What sets of tools and actions can be available for individual projects that will provide for mitigation and limiting impacts then? What types of monitoring will be needed to assess those impacts and make sure they are as limited and as much within the center of the range of impacts as possible?

    Then, each project tiers to that broad analysis with the site-specific stuff. “Within the range of impacts foreseen by the plan, this project alternative will likely cause impacts A, B, C and F. Tools for mitigation appropriate for this proposal are 1, 5, and 17. Applying those tools to these expected impacts will likely result in the impacts being of this extent in this project area. That will cause the following impacts to these known resources and values in the area. The monitoring needed to cover this is M1, M4 and M88. Etc.”

    Putting it in terms of a budget, for example: The plan is your family’s budget for the next decade. This much is likely needed for housing. This much for college at these dates. Etc. Here is how much I need to save overall to meet the long-term college needs and how much must be saved each year, on average. What you set up as the detailed budget for Junior’s first year in college is then a “project” tiered to the plan. You do budget analysis for both the broad, long-term view and for each “project” within it, but the specifics of the analysis change. The need for the analysis and the need for it to work together across the projects and the overall plan stay the same. If you do not do the analysis for the long-term plan but instead just say “I will save enough for Junior’s college,” without general ideas of how you might do that, then when it comes time to do what needs to be done for Junior’s first year, you will be in a world of trouble. No amount of project-specific analysis then will make up for the lack of general analysis earlier.


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