Send Benchmarks to the Bench


From Andy Stahl

It’s Friday before a three-day weekend, so here’s a short one. Twenty-eight years ago, while serving on the National Forest Products Association’s federal land planning task force, I suggested a way to use the FORPLAN model to calculate the timber opportunity cost from environmental protection. First, have FORPLAN calculate the maximum sustained yield of timber assuming no discretionary environmental protection. Second, sequentially impose environmental protections – the timber volume difference between the two is the opportunity cost of protecting the environment. Forest Planning published my article (thanks Randal) and Doug MacCleery took it with him when he made his move from NFPA to USDA as Deputy Assistant Secretary of Agriculture in the Reagan Administration. In 1982, Doug re-wrote the Carter Administration’s 1979 NFMA rules and added benchmark analysis as a planning requirement.

Benchmark analysis had only one purpose – to highlight the cost of protecting wildlife habitat, ensuring clean water, and keeping the forest pretty for people to enjoy. The thought being that if people, and decisionmakers (like OMB), only knew the dollars they were giving up, they would rally around increased national forest logging. But it was not to be. When it comes to public forests, no opportunity cost appears too high to pay for their protection.

I’m delighted to add my nail to the benchmark analysis coffin. Forest planning is challenging enough without adding gratuitous and divisive analysis that provides no information of real use to national forest managers or the public.

5 thoughts on “Send Benchmarks to the Bench”

  1. Andy, so we can blame all this on you?? Back in the 1980s, the Washington Office was sending plans back to forest planning teams for more benchmark analysis, taking up to a year to redo. As late as 2005, some forest teams were trying to make benchmarks more realistic by imposing an experienced budget constraint on the max timber benchmarks, but ending up going back to the unconstrained projection based on a plain reading of the rule.

    Actually, when planning today under the 1982 rule (technically the 2000 rule transition provisions that allow us to continue to use for revisions or amendments the “procedures” of the rule that existed before November 9, 2000, but I digress ….. ), benchmark analysis is really just a minor annoyance. We either use a “brute force” method of analysis where we just work our way through the analysis steps, so we can get to more pressing issues. (See for example the plans completed in the last five years in the Eastern Region.) The information is available for people to see, in case they might find value in it.
    http://www.fs.fed.us/r9/chippewa/plan/revision/analyses/dftfacts_benchmark.pdf

    Or, based on a need-for-change planning approach to plan revision, we do a review of the previous plan to confirm that the old analysis is still adequate for addressing the requirement.
    http://www.fs.fed.us/r3/coronado/plan-revision/documents/Coronado-CER-SuplementaryDocument.pdf

    Reply
    • The corollary to benching benchmarks is eliminating the “allowable sale quantity.” A good start to demonstrate that the FS is no longer motivated by maximizing timber production is to stop calculating and advertising the maximum timber output.

      Reply
  2. The challenge for all of us as we think about a new planning rule is how to reflect today’s understanding about sustainable forest management while being faithful with NFMA which says:
    16 USC 1611(a): The Secretary of Agriculture shall limit the sale of timber from each National Forest to a quantity equal to or less than a quantity which can be removed from such forest annually in perpetuity on a sustained-yield basis: provided that in order to meet overall multiple-use objectives, the Secretary may establish an allowable sale quantity for any decade which departs from the projected long-term average sale quantity that would otherwise be established.
    Here’s one description of the forestry business, by Jane Lister at the University of British Columbia:
    http://www.allbusiness.com/sector-55-management-companies-enterprises/430251-1.html

    “The bottom line is that to be sustainable, forest management must be adaptive. It must evolve in response to changing social preferences, advances in scientific understanding, fluctuating market conditions and unpredictable ecological disturbance. There is no generic formula for achieving sustainable forest management. Rather, the effective management of the forest resource and ecosystem requires a consistently flexible and responsive process that is based on open social dialogue, ongoing forest research and education, and integrated consideration of ecological, economic and social criteria.”

    She goes on to describe “myths” and “realities”:
    “Myth: Forests can be stable if managed correctly.
    Reality: Healthy, productive forests are dynamic and dependent upon natural disturbance not controlled management.

    Myth: A non-declining, even flow harvest ensures forest industry jobs and local economic prosperity.
    Reality: Local employment and prosperity are determined by technological change, global markets and regional economic diversity and not by a constant timber supply.”

    Reply
    • John,

      It would seem a trivial exercise in today’s < 3 billion board feet world for the FS to demonstrate that each national forest's sale quantity is less than the maximum non-declining even flow level. Note that this section of the law (16 USC 1611) is not even a part of NFMA planning (16 USC 1604) per se. It is a stand-alone requirement that is best met on an annual basis by writing a one-page memo-to-the-files that compares the volume sold for each national forest to that forest's potential NDEF level. Mission accomplished.

      Reply
  3. I like your idea of simplifying the NFMA requirements. We may even be revisiting what long-term sustained yield means given today’s understanding of unpredictable ecological disturbance, and the unknown changes resulting from potential climate change.

    I have one other thought – and I’d like to hear from any timber industry folks out there. Instead of theoretical maximum benchmarks, it seems that the more relevant questions about projected timber supply is “what’s changing?” I know it’s important to have as much information as possible about the wood supply in order to make investment decisions on things like mill capacity, modernization, or decisions about consolidations or closures. In some places, we may actually need new capacity to use material created by desired thinning or other vegetation treatments.

    It seems to me that we need to take an adaptive approach on economic goals just like ecological goals. We need to ask what’s working now, what needs to change, and whether we have the capacity to change. We need input from community leaders, industry representatives, environmental groups, and technology experts. Maybe a probable sale quantity is based on what we’re currently doing and what changes we think are feasible given what types of wood products we want, what’s environmentally sound, and socially acceptable. We need to monitor these factors and make adjustment to sale quantity just like other objectives.

    Reply

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