Let’s Discuss: Sam Evans’ Observations re: the 2012 Planning Rule

We’ve discussed various aspects of the Pisgah-Nantahala Forest Plan and Sam Evans’ post here and here. Also I posted specifically about the concept of “ecological integrity” and how a sample of partners talk about/use this concept.  This discussion is about “what this plan says about the 2012 Planning Rule.”  First, I’ll lift out some key observations that Sam made in his post. Then I’ll share my own views. Sam’s comments are indented.


For my part, I cannot believe that the 2012 Rule was intended to fund years-long, expensive processes that don’t produce decisions to solve problems. If we’re simply hoping that we can reach the same compromises again later at the project level, why not reflect them in the Plan now? Why did we accumulate ten years’ worth of analysis and consensus-building only to defer the decisions to the project level, where we can analyze and contest them again and again?


Agency leaders must learn that setting limits during the planning process isn’t at odds with agency discretion but is instead an efficient way to exercise agency discretion

So, if you build much analysis (a full employment program for historic vegetation ecologists, among others)  into a process, it’s going to be long and expensive. I don’t know of anyone who actually believed the Q&A around the rule that said plans would be completed more quickly.  I also don’t think more analysis will necessarily make people agree. Although that’s a great question for our social science friends, “when does more info help?”. In fact, that reminds me of an old (20 years?) NEPA discussion about some topics being more appropriate for collaboration than analysis.

My own experience was that if you build restrictions into the plan, they were still up for grabs at the project level by people of a more protective bent (these include FS employees as well as ENGOs).   Here’s what I’ve heard..”in this case it needs extra protection due to….” or “the latest scientific paper says” or “now we need to consider x about climate change, ” that wasn’t in the plan.  Again, in my experience, people will require the FS to analyze at the project level.  This actually makes sense on so many levels, as the analysis is both site-specific, and as current as possible (the best available science should get better through time, we would think.)

It sounds like what the collaborative group did is set a general direction or shared vision of what should happen where, with least disagreement.  While that doesn’t have to happen in a Plan, it does seem like a very useful exercise.  Did it need all the analysis? That would be a good question for the (hopefully there is one) team that is reviewing “Ten Years of the 2012 Rule: Lessons Learned.”

2 Sam

Identifying and ensuring progress toward restoration goals: It is possible to develop broadly supported reference conditions for ecological restoration in distinct ecological systems, even in highly altered eastern forests.

This is great news! However, there can be different views about the details of restoration as a target in the dry West, especially with regard to wildfire resilience and community protection. Also it will take quite a bit of management funds over time to develop wildfire resilience and to keep it up.  Perhaps this is a simpler issue in mesic forests. However, the need for funding to do things and how that relates to what’s in the plan is still an issue.

3 Sam

Collaboration works best, however, when agency staff are willing to work toward solutions as participants. The agency should communicate better about its own institutional needs and limitations to support consensus-building around new approaches that will work for partners and the agency alike.But it is essential that planners understand they need the public’s help to find the right answer, and they must be willing to reflect consensus in the plan itself—to share decision space.

This goes back to what Jon often says about local people not making decisions about federal land. Even FACA committees are advisory. How much should collaborative groups’ agreements influence 1) the Plan itself, 2) PPPPD (post-Plan project prioritization and design)?

4. Sam

Although the planning rule’s fiscal capability requirement is important, it should not be a straitjacket forcing planners to choose between(a) trying to justify doing the wrong things because they can pay for themselves and (b) doing nothing at all. Surmounting this problem requires a willingness to innovate beyond the planning rule’s text. Tiered objectives and adaptive management triggers offer a platform to justify additional funding, incentivize partner contributions, and get more done. But doing more is not an end in itself. A pacing mechanism is essential to ensure that the easiest or most commercially viable work does not displace higher priority work or get ahead of mitigation needs. Both of these innovations can be incorporated into traditional plan components.

It seems to me that both tiered objectives and adaptive management triggers are about PPPD, and somewhat about trust.  It sounds like folks want to help match the budget and target needs with what projects go forward.  This makes a lot of sense, perhaps via an annual input session into a proposed plan of work. I still am having trouble seeing the added value of putting something,. which seems like it should be flexible with changes in needs and conditions, into the Plan. Which, if history holds, will be outdated sooner than updated.  Here’s a very helpful comment from Sam from a previous discussion that explains how they got to these concepts (it was partially about the need to get agreement on both more intensity of management and more protection).  Still, other non-involved ENGO’s could still hold up any projects via litigation.  That seems to be one of the apples vs. kumquats of doing deals where  tradeoffs are not equivalent, nor can be made so (I could be wrong) “not doing things” and “possibly doing things if no one else objects” tradeoffs.  Think of the matrix in the NW Forest Plan.

4. Sam

Can the agency commit to work for better outcomes, build trust, and demonstrate its relevance to a public that is increasingly worried about the climate and biodiversity crises? Or will it teach the public that restoration is just another euphemism for business as usual? The next few months will tell.

I think the agency can, and does, do all that outside of the NFMA planning process. Are we laying too much responsibility on a cumbersome process for the FS to move toward those goals? Are mesic forests that fundamentally different from dry forests? I don’t think anyone has questioned the “relevance” of the FS in our neighborhood… fire suppression, recreation, and so on.

Readers: What did you expect from the 2012 Planning Rule, and the plans based on it? If you were pleased by or disappointed in aspects of a plan, please share your story here.  People who were involved in TSW (NCFP) as the 2012 Rule was being developed, feel free to link to your expectations as described at that time.

1 thought on “Let’s Discuss: Sam Evans’ Observations re: the 2012 Planning Rule”

  1. You oversimplify my argument about “local control.” I specifically reject the idea of local governments being viewed as in any way representative of the public interest in federal public lands. Groups that are designed to be more representative of that I may view differently.

    There is no question that there will be new information that has to be dealt with at the project level. That doesn’t invalidate the idea that narrowing the decision space for projects in a forest plan is likely to be more efficient than having the prior forest planning debates again for each project. A thoughtful manager should be able to determine which battles are worth fighting over over and over and which are not.


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