Thinking about the ecological integrity and NRV reminded me of my comments on the 2000 (yes!) planning rule. (Aren’t computer searches grand!)
Caveat: at this time of my career, I had not worked in planning or NEPA. Also I was working at OSTP at the White House when the 2000 rule was clearing, and OMB folks had some real concerns about the costs of doing the 2000 (I might have spoken with them to help clarify their concerns, but ultimately they were clearly told to stop being concerned).
Some have argued that this one (2012) has even more requirements for analysis and will hence be more expensive and time-consuming (despite intentions) than the 2000. I thought I had said that the pursuit of HRV seemed to be a “full employment program for historic vegetation ecologists”, but maybe not in this set of comments.
Here is a link to my comments.
Below are a couple of paragraphs..
4. Clear Conceptual Foundation
One of the basic concepts of land management is that while doing an activity anywhere (building a campground, using a road, fishing, cutting firewood, harvesting mushrooms) has some impact on the environment, there is a point at which the resource is being damaged, and at that level, the activity is not sustainable. Better scientific information tells us the many impacts of each activity and possible negative consequences. But somehow, someone has to draw the line between the social good of recreating, mushrooms or firewood, and potential damage to the resource that might result. Whether you call this sustainability, or something else, this is the same concept as what has been in place throughout the history of the FS. Our knowledge of effects is more sophisticated today, and the political climate is different than the heyday of timber management, but the concepts are the same. Balancing (a moving target, as conditions change) can occur through decisions at the national level (no OHV’s on national forests, for example) but in most cases, the actual effects of what people do vary by site, by elevation, by soil and by a host of other factors that cannot be summarized on a national level. That is why the local people and communities have an important role in determining that balance. If, on the other hand, like the FS’s sister agency the Park Service, the presumption is that people’s activities are generally negative and are to be kept to a minimum, then local knowledge and input is not as important. If Congress chooses the resource management philosophy, then special attention needs to be given to ensuring that local people’s balances are not overridden by outsiders, however well-intentioned, who are not familiar with the local situation. This is Congress’s prerogative, however, and not the FS’s choice to make. The tension between local and national interests is another real-life situation that must be considered in the design of the process. Like the role of an expert in a democracy, these are ongoing tensions in governance of this country, and natural resource management should acknowledge and reflect the legitimacy of these tensions.
One can read the whole history of “ecological sustainability”, “ecological integrity” and “range of historic variation” as a target, to reframe the debate so that scientists become the experts on what should be done. This gets away from the messy conflicts over policies, such as who wins and who loses. This does not build trust. “I don’t like OHV’s because they disrupt a species of wildlife on this watershed” is meaningful. “Roads disrupt ecological integrity” does not pack informational content and in effect obfuscates the terms of the tradeoffs or balancing of interests.
If “ecological sustainability” and pre-European North America are the targets, then the planning questions are “how quickly can we afford to shut down existing roads and campgrounds, and can we afford the law enforcement to lock people out of the NF’s? “ We will ignore fire threats and fuel buildup close to adjacent landowners because there were lots of massive fires prior to European settlement (although there were not enclaves of million dollar homes). Clearly then, there are parameters within which pre-European will guide FS thinking and others where it will not. No where is it clear in exactly what kinds of decisions the authors of the document think that this criterion will be relevant.
If the FS is to reestablish trust, I think a few things need to be in the regs and the regs are an important place to carry this out. First, the concepts, steps in the process, and decision space itself need to be so clear that any FS employee can explain them to any member of the public. Anyplace where ecological science expressions such as “functioning of ecosystems” occurs in the text, it needs to be translated so that the non-technical public can understand it. Everyone knows we’re not reintroducing grizzlies to the central Sierra, or closing ski areas, or replacing all exotic grasses with natives, so clearly there are distinctions and priorities. There is no reason they can’t be clearly stated, e.g. “water quality and quantity is #1 priority and while there were massive fires and sediment flows within the range of historic variation, we acknowledge that these levels of sediment are not desirable today.”