Mark Squillace on the New Planning Rule: About Science

I ran across this on the Red Lodge Clearing House newsletter…

Here’s a link to his comments.

Here’s what he said about science:

Use of science in planning.36 CFR §219.3.The proposed rules required the Forest Service to“take into account the best available scientific information throughout the planning process…”
Many,including me,suggested that it was not enough merely to take the best science into account,as if it were only one factor to be considered. The Forest Service apparently agreed and the final rules require the agency to “use” the best available science.

It’s discouraging to me that anyone could believe that “scientific information” is somehow hardwired to any decision. That’s the linear model of science in policy that no one in the science policy science community sees as accurate. I have noticed that lawyers often seem to believe in the linear model. The problem will be when a judge decides what “using” the “best scientific information” means. It won’t be a requirement, I don’t think, that the judges familiarize themselves with the science policy literature before making a judgment on the Forest Service’s adherence to this new regulatory standard.

As I’ve said before, it seems contradictory to write a regulation that requires the use of ” the best current scientific information,” but not to use the best scientific information from the science policy or science and technology studies literature in development of the regulatory standard for the use of science.

Scientific information, in reality, is only one factor to be considered in making decisions, as stated by Sir Peter Gluckman, Science Advisor to the Prime Minister of New Zealand here (I became aware of this due to a post from Roger Pielke, Jr., here.

We live in a democracy, and governments have the responsibility to integrate dimensions beyond that covered in this paper into policy formation, including societal values, public opinion, affordability and diplomatic considerations while accommodating political processes.

Here’s a longer quote from the paper.

It is important to separate as far as possible the role of expert knowledge generation and evaluation from the role of those charged with policy formation. Equally, it is important to distinguish clearly between the application of scientific advice for policy formation (‘science for policy’) and the formation of policy for the operation of the Crown’s science and innovation system, including funding allocation (‘policy for science’). This paper is concerned with the former. A purely technocratic model of policy formation is not appropriate in that knowledge is not, and cannot be, the sole determinant of how policy is developed. We live in a democracy, and governments have the responsibility to integrate dimensions beyond that covered in this paper into policy formation, including societal values, public opinion, affordability and diplomatic considerations while accommodating political processes.

Science in its classic linear model can offer direct guidance on many matters, but increasingly the nature of science itself is changing and it has to address issues of growing complexity and uncertainty in an environment where there is a plurality of legitimate social perspectives. In such situations, the interface between science and policy formation becomes more complex. Further, many decisions must be made in the absence of quality information, and research findings on matters of complexity can still leave large areas of uncertainty. In spite of this uncertainty, governments still must act. Many policy decisions can have uncertain downstream effects and on-going evaluation is needed to gauge whether such policies and initiatives should be sustained or revised. But, irrespective of these limitations, policy formed without consideration of the most relevant knowledge available is far less likely to serve the nation well.

Note that Sir Peter also uses the term “consideration.”

6 thoughts on “Mark Squillace on the New Planning Rule: About Science”

  1. Sharon says,

    [I]t seems contradictory to write a regulation that requires the use of ”the best current scientific information,” but not to use the best scientific information from the science policy or science and technology studies literature in development of the regulatory standard for the use of science.

    I couldn’t have said it better. But I’ll add “art” to the mix. I have harped on this topic for many years. See, The Art and Promise of Adaptive Governance:

    As mentioned earlier, critical review authors cite the fact that adaptive management in its public form is too technical, too much centered in technocratic rationality. But adaptive governance need not be so burdened. Adaptive governance can operate in policy-development spaces far apart from those where “adaptive management experiments” are structured, tested, and rationalized. But it can embrace those too, where they make most sense. This is the direction some of us tried to take the Forest Service in the early 1990s, under the banner “A Shared Approach to Ecosystem Management,” outlined in part here. It lives today under the banner “adaptive governance.” …

    I believe that the time is right to more-fully embrace adaptive governance —to replace what has been forest planning. But a big barrier is that the Forest Service remains a technocracy, a big-believer in science and management, with little or no formal emphasis on the art of “forestry,” the art of “political decision-making,” etc. I remember all too well the many Forest Service social science meetings where I complained that two words (and practices) were forbidden in both voice and action: politics and psychology.

    See also: From Forest Planning to Adaptive Governance, and Fixing the Rule: An Adaptive Management Roadmap.

    But alas, parroting songwriter Don McLean, “They never listen. They’re not listening still. Perhaps they never will”

    Reply
  2. Hmm, so what’s with the whining tone to this post? It seems obvious to me from the context i the rule (and you wish, taking ito account courts’ interpretation of agency discretion), that all “use” means is “to judiciously apply, to not ignore.” That’s all Squillace and Gluckman are actually advocating, isn’t it? I don’t see anywhere where these writers are overtly advocating that relevant science be discarded or dismissed. As far as I can tell the rule doesn’t really call for any more than NEPA ad APA already require. Nor do I see anywhere the rule implies that “science” trumps other values and considerations–quite the contrary.

    Reply
    • Chris- A short note on our blog norms… commenters and posters have a variety of tones on this site. We usually don’t critique them unless they seem disrespectful of others. It’s part of “soft on people, hard on ideas.”

      If by “use” you mean “judiciously apply, not ignore”, I don’t know why “consider” wouldn’t be more accurate. In the previous rule version, you needed to consider the best scientific information and document how you used it. We actually don’t know how the courts will interpret the term “use” and my opinion is that that is not the best place to decide things. After all, courts are using their interpretations of the regs and NFMA, and nowhere in their deliberation would be the “best available science” on the use of science in managment.

      Finally the statement “Many,including me,suggested that it was not enough merely to take the best science into account,as if it were only one factor to be considered.” was from Squillace, and that’s what I was questioning, not the Rule.

      Reply
  3. This is an excellent addition to the whole discussion of “a new century of forest planning.”

    Thanks to Sharon for bringing it up, Mark for the original thinking found on Redlodge, and Dave for weighing in.

    One of the fundamental tensions for forest planning, at least for my 2c, is between traditional rational planning and more contemporary thinking along the lines of what Sharon mentions as policy sciences and Dave mentions as art. Traditional planning still searches for the one-best-solution. Those who disagree about which solution is best are still often in violent agreement that there is a single best solution and that the planning problem is to agree on the solution, as opposed to building capacity to implement a decision. Seems like the pain of reaching agreement can lead to less capacity or less willingness to help get the job done, whatever that job might be.

    While a search for a single-best-solution may work for technical problems that have a tractable definition and probable answer, planning seems more about dealing with problems where there’s often little agreement about the details, only agreement that a problem exists. In addition, because we don’t share an understanding of the problem, there’s often no stopping rule, meaning science can’t tell us when we have a “solution.” Much of what science–the body of knowledge–can’t do, human beings do daily–make choices based on limited information and then adjust to a dynamic environment instead of assuming away “externalities” as nasty inconveniences beyond our control.

    What-if? What if we understood that some of the best available science is from the policy sciences, the decision sciences, post-normal science, human dimensions, and other non-traditional disciplines? Would that change how we think about or discuss “best available science” and its use? Would that change the arguments placed before lawyers and argued in courtrooms? My sense is this could be quite consistent with what Mark Squillace is suggesting, but I’m not sure.

    And, what if we were to think about planning differently in light of the full body of science? Would we approach the process differently? I’m thinking that a more collaborative process–which I mean as a scientifically valid approach to collaboration–is more consistent with contemporary thinking about planning, although I realize that some folks participating in these discussion may disagree. Perhaps some of that disagreement stems from unfortunate experiences with less scientifically valid approaches to collaboration, by which I mean approaches that are called collaboration yet characterized by more traditional models of planning where content expertise matters more than process expertise. .

    Just trying to stir the pot without pushing buttons…

    Reply
    • “… only agreement that a problem exists.” There ARE some who don’t agree with that. They would like you to believe that “free-range” wildfires are “natural and beneficial”, requiring no response, outside of their tiny version of the SUI (snagland urban interface *smirks* )

      I’m with you, AO, wanting science to guide our human impacts on the world. Cutting excess trees here should mean that others cut fewer elsewhere, always in places where restrictions are few or none. Sadly, forests will continue to suffer, until society figures it out.

      Reply
      • A good point, Larry/Foto. I worried about being too general even as I wrote my little piece.

        What you’re point out–which is really important–is that there are some “problems” that are not recognized or not accepted by some who are involved. Your example is a good one. Another might be the situation that can occur with motorized and non-motorized recreation. Sound of motors can be a “problem” for those trying to enjoy non-motorized recreation and “not-a-problem” for those enjoying motorized recreation.

        When faced with trying to work through a situation like that, it can help to listen for a way to frame the problem differently. Maybe it isn’t “sound” or “free-range wildfires, as in our examples, but something else, like something that could bring those folks together (shared interests perhaps?) instead of forcing them apart (divisive positions).

        What do you think? Anything valuable here?

        Reply

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