Why the Forest Service Can’t Get Plans Done

Perhaps the greatest challenge in the development of a new Forest Service planning rule is the need to reduce the length and cost of forest planning processes.  The salary costs of an interdisciplinary planning team can easily run $100,000 per month, or over $1 million per year.  Planning processes can easily run five, six, seven or more years, so total salary costs can approach $10 million. 

Except for the Beaverhead-Deerlodge plan in Montana, and the smaller National Forests in the east, no plan revisions have been completed in the last four years.  The problem occured even with new planning rules in 2005 and 2008 which were intended to simplify the planning process.  There are currently 70 forest and grassland plan revisions nationwide that are overdue.

The need for a new planning rule to reduce complexity has been discussed previously on this blog.  The Notice of Intent for a new rule last December described the problems that lengthy planning processes can create for the public:

“One challenge the Agency has faced with regard to public participation is that plans can at times take 8–10 years to revise, a timeframe that is too long to sustain a true collaborative effort and use the most up-to-date science and management thinking.”

Perhaps the root of what’s going on is the “wicked problem” posed by the National Forest Management Act (NFMA), as earlier discussed on this blog and in the excellent review by George Mason University of the process for the Sierra Nevada plan amendments.  The wicked problem is evident through the lack of consensus about multiple use management.  Shortly after NFMA was passed, commentors saw that it was an impossible task and should be repealed.  Unfortunately, NFMA isn’t going away, which led to a proposal earlier on this blog to at least limit any new regulatory requirements to the minimum required by the Act.   As early as a 1990 Critique of Forest Planning, there have been calls to simplify the planning regulations.  This was noted in the December NOI for a new rule:

“The Critique found that the 1982 planning rule process was very complex; had significant costs, was lengthy, and was cumbersome for public input. The recommendations in the Critique and the Agency’s experiences with planning led to the Agency issuing an advance notice of proposed rulemaking for new regulations in 1991, and two proposed rules, in 1995 and 1999. After working with a committee of scientists, the Department issued the 2000 rule to revise the 1982 regulations. The 2000 revision of the planning rule described a new framework for NFS planning; made sustainability the foundation for NFS planning and management; required the consideration of the best available science during the planning process, and set forth requirements for implementation, monitoring, evaluation, amendment, and revision of land and resource management plans. However, a review in the spring of 2001 found that the 2000 rule was costly, complex, and procedurally burdensome. The results of the review led the Department to issue a new planning rule in 2005, and a revised version again in 2008…”

Meanwhile, planners are forging ahead.  There are 21 forest plan revisions continuing using the existing regulations. 

To understand why plans are expensive and time consuming, it is helpful to look at the process.  There are five major cost centers in a Forest Planning process:  assessments, collaboration, environmental documentation, reviews, and objection/appeals.  (Often, the actual writing of a plan is a relatively small task compared to these other five.)  Any one of these five cost centers can create delays in the timeline and additional costs. 

The unfortunate problem with delays is that it extends the window in which a planning effort may be subject to new policies, directives, requirements, or political considerations.  Thus, the process itself can spiral, and a three month delay can become a one year delay to meet a new initative.  Recent examples of delays to forest plans include emerging climate change considerations, new guidance on restoration, and changes to energy policies.

The need to simplify the planning process was discussed last week at a meeting of Forest Service planners in Salt Lake City.  The planners recognized that management of the five cost centers is critical.  One planner said that it takes “wisdom and courage” which is not often rewarded.  Is there a point where more collaboration will no longer be effective?  Do we have the courage to make a decision without certain information?  It requires line officer engagement, to let future Regional Office and Washington Office reviewers know what is going on before the reviews.  It may require saying “no” to 11th hour changes to the plan.  It requires a set timeline, notifying the public, and sticking to the timeline.  It requires internal and external communication across all levels of the organization, to let people know ahead of time when they will be needed.  Regional and Washington Office reviewers need to be efficient, and give Forest planners more leeway.  There needs to be transparency with the public so they can see what is going on and how and when they can have input.  The Forest Service Manual and Handbook can cause confusion, and must be streamlined.   Instead, it’s important to follow the concepts of “organizational learning” discussed earlier on this blog.

Unfortunately, most or all of these managerial solutions have been tried in the past with mixed results.  Perhaps we are expecting too much from forest planning.  For instance, effective stakeholder collaboration can take years to build.  It might be easier to work on partnerships on specific projects, and build collaborative capacity prior to beginning any forest planning process. 

Until we recognize the true limitations of planning, it cannot become what it truly needs to be.  At it’s best planning can clarify goals, set priorities, empower organizational learning, and establish relationships.  But those things can’t happen if plans never get done.

19 thoughts on “Why the Forest Service Can’t Get Plans Done”

  1. Well said, John. Also looming on the horizon are mandates to make forest plans understandable to the public (actually to make judges be able to understand them, as they think forestry and natural resource management should be easy, compared to their years of law school!). The ever-changing landscape of public land management is seemingly tied to the constant litigation of everything the Forest service wants to do. It’s no wonder that forest planning is floundering when the “goalposts keep getting moved”, over and over and over again. Without litigation reform, we’ll continue to be hamstrung in actually implementing important time-sensitive projects.
    Maybe an “emergency situation” needs to be enabled, to exempt certain contentious issues from the courts? Litigants consistently ignore such damaging facts, using loopholes to “monkeywrench” any project that cuts merchantable trees. We NEED to accept the fact that groups like the Sierra Club have promised litigation on any and all timber sales/fuels reduction projects. Once our government, mainly the Congress, accepts that now-established fact, maybe litigation can be hemmed in. Collaboration and consensus simply CANNOT be achieved in today’s litigious society. We need to move on and exclude those who don’t want consensus.

    It seems that the new-age battle is pitting conservationists against preservationists, a la Tester’s Bill.

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  2. John, this is a great post IMHO. I think it is also important to consider that length of planning is not entirely an NFMA planning problem, it can happen to some extent on projects, too. Some of the reasons may be the same, some different.

    I saw this story this week in the Porterville CA news:

    An effort to move forward with a fuels reduction project which the Forest Service initiated about 17 years ago is underway.

    The public has about two more weeks to submit comments pertaining to the controversial project.

    The commenting session on the Revised Ice Timber Sale and Fuels Reduction Project began June 3 and ends July 6.

    The Forest Service’s evaluation of a fuels-reduction project in the Ice analysis area — located in the Alta Sierra tract in the Greenhorn Mountains, an area in the southern portion of Sequoia National Forest, began in 1993 as a result of concerns expressed by homeowners regarding the fire danger posed by high fuel loadings and dense forest stands.
    The Forest Service’s evaluation of a fuels-reduction project in the Ice analysis area — located in the Alta Sierra tract in the Greenhorn Mountains, an area in the southern portion of Sequoia National Forest, began in 1993 as a result of concerns expressed by homeowners regarding the fire danger posed by high fuel loadings and dense forest stands.

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  3. It’s not just forest planning that is dysfunctional. The FS website is down again (for the last 2 days), as it is regularly. I spent 3 hours on hold this week when I called the help (sic) desk at the Albuquerque Service (sic) Center to let the custodians of the FS directory know that Tom Tidwell is no longer regional forester in Missoula (who knew?).

    The Forest Service’s chief financial officer fabricates his duty station, embezzles government travel and is a chronic credit card scofflaw. Leadership covers it up while the CFO’s deputy tries to shoot the whistleblower (a good move, apparently, as she was promoted to CFO after her boss was forced to retire). The Chief, who approved the fraudulent duty station in the first instance, recommends the CFO for a $13,000 performance bonus (which he received, plus a 4% raise that sweetened his retirement nest egg) even as USDA was trying to force him out over his financial shenanigans.

    So you would think the FS would have washed its hands of the disgraced former CFO. Not so. The FS continues to employ him as a “consultant.” Is it any wonder that FS employees are cynical, disgusted, and fed up?

    Petty corruption and cronyism at the top will rot any organization to its core. People think the Mineral Management Service is bad, but its #111 ranking on the “best places to work” in the federal government is a far sight better from the FS’s almost last-placed 206th score.

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  4. Good article John. I agree with photowares comments. The constantly changing planning rules have not been any help, but the FS interpretation of the rules likely further compounded the situation. Line officers need to be involved in the planning process and NEPA as well to keep the projects under control. Often it seems like the goal is the process itself rather the outcome.

    Andy your way off topic…

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  5. Michael D — The best planning rules in the world won’t save the FS from inept or corrupt leadership.

    Fotoware — Breaking the law is a bad thing. Enforcing the law is a good thing. What’s so complicated about that?

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  6. Andy, Instead of going way off topic and attempting to change the subject matter maybe you whould do your own post on the corrupt and inept FS leadership.

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  7. Self-interpreting the law and finding like-minded corrupt “activist” judges is bad when either side does it, marginalizing the few objective scientists we have left, is never a good thing, either. I say that following the Clean Air Act, the Clean Water Act, The Antiquities Act and the Endangered Species Act are all good things that “unstewardship” doesn’t support.

    BTW, Andy, do you speed on the Interstate?? That puts other drivers at-risk but, surely you justify and marginalize it, eh??

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  8. AND, some laws just aren’t good laws. An example from Oregon:

    A door on a car may not be left open longer than is necessary.

    Yes, I was only proposing that we change the bad laws that conflict and inhibit the scientific management of forest ecosystems and public lands to actually follow those landmark environmnetal laws (listed above) we all cherish.

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  9. So here’s my view, I agree that Andy has some important points that are worthy of a separate post.

    I’d like to go deeper and possibly become more specific with this discussion on the topic.. does anyone have any ideas of how to reduce the time spent on planning other than the ones that John has suggested and the one Andy suggested in his KISS posts? How about some specific examples? We had one forest that was court ordered to get ‘er done and they did it. Region 9 got a bunch out, each in three years (I think). These were done under the 82 rule. What are lessons from some things that went right or wrong?

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  10. Here’s an idea! Why can’t we take the ESA and use it as a club to make sure that habitat isn’t lost in catastrophic wildfires, mandating scientific management as part of the recovery plan that all Agencies MUST follow??? Seems so easy to me!

    What good is an “owl circle” that doesn’t have any live trees left?

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  11. Foto- it is not clear to me that more litigation will streamline any processes. It could lead to more surreal, complex and time-consuming situations like roadless; follow the Rule and do not follow the Rule at the same time to satisfy courts. I would be against anything that takes time away from on-the ground activities like permit administration, OHV compliance or abandoned mine cleanup for more brief-preparing and record-copying.

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  12. Ahhhh… I see a new strategy. Let’s LET those endangered species lose their habitat through catastrophic wildfires, especially their nesting habitat so that they “naturally” won’t block future plans anymore. The conversion of unhealthy and currently “protected” ESA lands to plantations should surely lift restrictions, returning those lands to “the matrix”, eh? “Progress”(???) marches on?!?! Forest plantation “planning” is surely much easier than dealing with “controlled areas”.

    The litigious community will resist any and all efforts to streamline ANYTHING that cuts a merchantable tree! They also have decided that collaboration is not what they want, and that ANY consensus and compromise is not desirable.

    Clearly, the Forest Service is already in violation of the ESA by letting habitat burn. The Act requires a management plan to get those species OFF the list.

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  13. I think that Forest plan revision needs well defined goals and objects that tie to the ground before they start revising. Often it seems like the goal is the revision itself. They need to look at the old plan and see what is working and what is not, some call it monitoring. The input needs to be from the ground on whats working and whats not.

    It seems like the more folks involved in plan the more complicated it becomes, especially when politics becomes mixed with science. Consultation, collaboration, and public involvement all bring politics into the process, as well as rule making and national strategic plans. The political input is probably needed, however trying justifying it with science complicates things.

    Attempting to micro manage a Forest by using extremely specific and stringent standards and guidelines is a mistake. The Forest plan should provide guidance and a general picture of how the Forest should be managed.

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  14. The FS takes a long time to write forest plans because it can. In those rare instances, e.g., the Northwest Forest Plan, where issuing the plan is a prerequisite for doing what the FS wants on the ground, the plans issue promptly.

    Speeding up the planning process is one reason the KISS rules recommend that forest plans make real-life timber harvest/vegetation management decisions. So long as forest plans remain broadly aspirational, visionary documents that make no real-world decisions, forest planning will continue to be an endless exercise.

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  15. Going back to Sharon’s request for examples… During the Southern Region Roundtable (Planning Rule), Land Between the Lakes was cited as a model for completing plans in under two years. The NOI was published in June 2003 and the final plan completed in December 2004. Of course, LBL is a National Recreation Area, so perhaps that simplified the process. Other R8 examples included the Ouachita and Ozark-St. Francis NFs, which completed their plans via a coordinated effort (and using a regional assessment to inform their need for change) in just over three years (NOIs published in May 2002, final plans in September 2005). All under ’82 regs.

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  16. Many people don’t realize the amount of fieldwork that goes on in support of new plans. They also don’t realize the level of expertise required in some areas. Many years ago, I had an assignment on the Sumter NF, doing stand exams. (I also did stand exams on the Ouachita, as well.) With over 40 different trees species and 20 different oaks, I had to dredge up a lot of old dendrology stuff, especially in the bottomland areas.

    As more and more of our population despises forest management, less and less of our youth are studying forestry. How can we accomplish future plans without the experienced manpower needed to collect the required data? Obviously, old data cannot fill the bill for long, if at all.

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  17. I am trying to find information on the 2001- 2005 “New Century of Service for Lookouts” that was part of a program, partnered with the Forest Fire Lookout Association, a private non-profit advocacy group. There was to be an agreement in
    force providing funding by both the USFS and the FFLA to achieve certain goals for this New Century of Service theme. I can find very little information if any of that funding happened or what happened to the agreement’s objectives. Is there anywhere I can search for this?
    Thank you

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  18. Robert- I’ve send this request to the right channels in DC to answer your question but if anyone knows out there in the blogosphere, you can answer here. Perhaps we need a section for “questions asked and answered”?

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