Sharon’s All Time Favorite Post: Andy Stahl’s KISS Planning Rule

Brian Hawthorne raised the point here that the Forest Service spends too much time on planning, and not enough time on doing or implementing.  The Forest Service has tried to address this problem several times- I think the EADM process was initiated partially to make planning and NEPA more efficient.  During my time in DC on the NEPA staff, the problem was framed as “Process Predicament.” Various approaches have been tried to do this, both for “NEPA” projects and for “NFMA” plans.

What I like about Andy’s KISS rule is that it starts at the beginning, “What does NFMA call for?”  Here is KISS I from December 31, 2009 (remember NCFP was started to discuss and follow along with the development of the 2012 Rule). Check out the comments from thoughtful John and David.  I linked the various other KISSs in this post. It’s my favorite because it is radical (goes to the root of NFMA) and it is still relevant as per discussions of  forest plans, collaboration and the 1982 Rule Colville Plan.  As forests spend more time on planning, and being litigated, under the 2012 Rule (aka developing case law for the 2012), perhaps Andy’s post is even more relevant.

KISS Planning Rule

Contributed by Andy Stahl

Forest planning has been hijacked by a generation of planners who turned what should have been a narrowly-focused effort to constrain an out-of-control Forest Service logging program and turned it into a wasteful, endless, bureaucratic exercise with little merit.  Let’s review what the National Forest Management Act actually requires of plans and the planning regulations.  The reader can follow along here:—-000-.html

Here’s what a NFMA plan must contain:

1) the “planned timber sale program” including the “proportion of probable methods of timber harvest.”

That’s it.  There is no second item.

Now look at what NFMA requires of the planning regulations.  First, there must be guidelines

1) to identify the suitability of land for resource management;

2) for obtaining inventory data; and,

3) for identifying special conditions or situations involving hazards.

Second, the planning rules must

1) insure that economic and environmental matters are considered in the forest plan;

2) insure that plans provide for diversity of plant and animal communities;

3) insure plans address research and evaluation of management systems to prevent substantial and permanent impairment of land productivity;

4) permit increases in harvest levels based on growing trees faster;

5) ensure that timber will be harvested only where soil, slope or watershed conditions will not be irreversibly damaged, land is restocked within 5 years, protection is provided to water from detrimental changes, and harvest methods are not chosen based on greatest dollar return or unit output; and, finally,

6) ensure that even-aged cutting is used only where it is appropriate, natural appearing, not too big, and protective of other resources.

That’s it.  When read in the context of the times, i.e., the clearcutting scandals of the mid-1970s, it makes perfect sense that what Congress sought were timber sale programs for each national forest that ensured logging levels and methods were light-on-the-land and protected other resources.

In the 1980s, with national forest logging beyond 10 billion and up 12 billion board feet annually, that was no mean feat.  Today, with logging at or below 3 billion board feet, forest planning ought to be a snap.  But only if the Forest Service sets its cross-hairs only on the target Congress demanded.  Otherwise, it will continue to take 15 or more years to write 15-year plans that will make no decisions and be irrelevant in the real world the day they are signed.

Andy Stahl is the Executive Director of the Forest Service Employees for Environmental Ethics


6 thoughts on “Sharon’s All Time Favorite Post: Andy Stahl’s KISS Planning Rule”

  1. In 2009 I was no doubt making similar arguments on the inside for more meaningful planning.

    However, I agree with my old colleague John Rupe that it’s not that simple: “16 USC 1604, or section 6 of NFMA, starts out in section e with a requirement that plans provide for multiple use and sustained yield of products and services, and a requirement that “forest management systems, harvesting levels, and procedures” be determined in light of all the multiple uses in the Multiple-Use Sustained Yield Act. That introduction along with the requirement to form “one integrated plan” seems to imply some sort of umbrella document that guides all the activity in a forest.”

    That said, I think it could have been simplified to only those multiple-uses that could affect the timber program, and in particular it could have focused on those having substantive requirements in NFMA, primarily “provide for diversity of plant and animal communities” and “protection is provided to water from detrimental changes.”

    As for relevancy, I don’t know if you are looking to extend the debate about an old decision versus looking at how it is playing out in plan revisions (or just creating a “greatest hits” gallery). One possibility is that the Forest Service is oversimplifying the parts they should be paying attention to (and wasting time and space on other things).

    • I’d be interested in a separate post along the lines of your last sentence if you have thought about it. My intention is not to restart the debate on the Planning Rule, but just so that newer readers know that the Forest Service was not ineluctably led to the complexities of the 2012 Rule. There were other choices on the table. I’d think if you were in the middle of such a process you would want to know that the complexities were intentional. That’s why it’s a greatest hit to me. Also the fact that Andy and I have agreed on (I think) three things in 10 years and that was the only one of them that deals specifically with the Forest Service. Which is a pretty big thing, really. I think- the utility of forest planning as currently practiced.

    • Just to clarify, I was on the inside too at the time. Including public meetings, DC meetings and all that. I never really felt that a serious look was taken at simplifying- more about what could be added.

  2. Kudos for bringing this up for a fresh look; I too spent a lot of time doing “planning” and being frustrated. Andy refers to the “why” of NFMA: Timber! — recall that Congress, led by Hubert Humphrey (D -MN) threw the FS a lifeline because the entire timber program was threatened. The resulting FS regulation was very timber-centric (appropriate, given the focus of NFMA on timber), but heavily skewed toward logging. Witha dose of other resource for consideration for good measure. As time elapsed, efforts became ever more comprehensive and holistic. I heard many planners and line officers lament that plans were supposed to “resolve problems, not create them”. Can you blame aggrieved parties for latching onto plans as a means to pick bones?

    There remains an opportunity to reclaim the high ground of plans as generally strategic documents with enough timber specifics to respond to NFMA req’s. FS lawyers have tried for decades to make the case that plans make few real decisions. Maybe it’s time to re-imagine a 20 page glossy coffee table forest plan that guides subsequent decisions.

    • I agree Jim, I don’t think that before the 2001, 2005, nor 2012 Rules did people ever go back and ask “what have we learned from planning? what works, what doesn’t? what’s necessary and what isn’t?” let alone “what parts of this foster collaborative work and which provides opportunity for reopening old wounds?” Does the sheer size and number of decisions involve heighten the stakes? How can we keep them from being so complex that “the people” can’t really participate?

      I think the FS did a great process for the 2012, but in my opinion the need to successfully “get the Rule done”, and the need to satisfy people who wanted more complexity/legal hooks (so the Rule wouldn’t be litigated by them), kept us from examining a “full range” of rule alternatives.

  3. Those questions have always been asked, starting with –
    But there is never the follow-through that checks back to see if identified problems have been corrected (or the discipline to say “no” to those who want to add “their” piece).

    I would phrase the most important question that NFMA wanted an answer to is “can the level of timber harvest on a national forest be sustained in light of the need for sustaining ecological systems?” I think they would still rather answer the question of “how can we keep timber levels up and not limit our options for how to get them?”


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