The latest on the Pisgah and Nantahala (North Carolina) NFs plan revision (Recently discussed here). From Carolina Public Press: “Objections to proposed plan for Western NC national forests delay process.”
“U.S. Forest Service proposed land management plan for Pisgah and Nantahala forests has drawn thousands of objections, leading to extension of time to review concerns. Forest Service chief now calls plan revision process that took more than a decade unsustainable. ”
Thanks to Nick Smith’s HFHC News for the link.
All that’s missing is that “Andy Stahl was right all along with the KISS planning rule.”
“The length and complexity of the planning process are also testing the stamina of Forest Service employees, leading to widespread stress and burnout, according to a May 20 internal letter from Forest Service chief Randy Moore obtained by CPP.
Moore said the agency’s “approaches to land management plan revisions have not been sustainable” and that lengthy revisions are too costly and impacted by changes in leadership, staff and budget.
In the letter, Moore announced the creation of a centrally coordinated approach to streamline the planning process.
Moore also recognized that the intensive planning process may be a distraction from the work the Forest Service and its collaborators intend to accomplish. “
It sounds to me like he is blaming poor “approaches” to managing the planning process, which is why he adopted the new approach of central coordination. Approaches are more likely to be sustainable if the agency treats them as being important rather than a “distraction” from what they’d rather be doing, and maybe this will help.
Certainly, this outcome is a form of “Analysis paralysis”.
Instead of taking comments from so many groups and organizations, maybe if each forest had a board of directors, these plans would be approved in a more timely manner. I see it like the RAC I’m on — it has a diversity of representation and views, and with some discussion, we approve (or not) project funding requests.
Your RAC may approve funding for a project, but it does not approve the project itself. That authority remains exclusively with the U.S. Forest Service. In particular, with the line officer who, in a chain of command, derives her authority first from the Constitution’s Property Clause which grants to Congress plenary authority over public lands. Congress, in turn, in the Organic Act directed the Secretary of Agriculture to administer the forest reserves. The Secretary has administratively passed down that authority to the Chief, the regional forester, forest supervisor, and district ranger, according to the significance of the project decision.
I well aware of what RACs can and can’t do, Andy. What I’m saying is that a “board of directors” might be able to provide a more balanced approach to developing an implementing forest plans — boards usually are charged with providing strategic direction to an organization. I think of this as a beefed up collaborative group for a national forest. Diverse, local perspectives. I would give these group legal weight, but would leave the final decisionmaking to the agency. The current system doesn’t seem to be working well. Maybe a new approach is worth a look.
When was the system working well? And what characterized that system in contrast to the present time?
I don’t know that the “system” has ever been near perfect, but I think it could be made more efficient.
Hi Steve: I think it would greatly matter how the Board was formed. Look at the results we have been getting from the State Land Board and the Oregon Board of Forestry in recent years, as examples. And a lot of those problems can be traced to federal ESA regulations and processes being forced into State and private lands. The regulators, environmental activists, and their lawyers seem to hold the upper hand, and maybe that is where change is needed most. Boards are just another hurdle, from my perspective.
I hear you, Bob. FWIW, this is how RACs are formed. A board of directors might have a similar makeup, tailored to the board’s charter.
In accordance with the Act, each RAC shall be comprised of 15 members who
provide balanced and broad representation from within each of the following three
categories of interests specified in the Act:
a. Five persons who represent:
1. organized labor or non-timber forest product harvester groups;
2. developed outdoor recreation, off-highway vehicle users, or commercial
recreation activities;
3. energy and mineral development, or commercial or recreational fishing
interests;
4. commercial timber industry; or
5. Federal grazing permits or other land use permit holders or represent nonindustrial
private forest land owners within the area for which the committee
is organized.
b. Five persons who represent:
1. nationally recognized environmental organizations;
2. regionally or locally recognized environmental organizations;
3. dispersed recreational activities;
4. archaeological and historical interests; or
5. nationally or regionally recognized wild horse and burro interest groups,
wildlife or hunting organizations, or watershed associations.
c. Five persons who represent:
1. State elected office (or a designee);
2. County or local elected office;
3. Native American tribes within or adjacent to the area for which the committee
is organized;
4. area school officials or teachers; or
5. affected public-at-large.
I’ll grant that 15 members as detailed is representative of a diverse community of interest. But I can’t see how they are equal. Should they all have a voice? Absolutely
Should their voices all be equal? We all probably have different views on that, and who decides?
Maybe a BoD ought to have more than 15 members, maybe 21.
Look at it this way: For all of its imperfections, we have a representative (indirect) form of democracy. Our state and federal representatives listen to us (in theory) and take action (in theory) based on what’s best for their constituents, subject to (in theory) political negotiation with other representatives. If we had a direct form of democracy, we’d have millions of people participating in (says Wikipedia) “a form of democracy in which the electorate decides on policy initiatives without elected representatives as proxies.” NEPA set up a form of direct democracy for USFS’s forest planning and projects. A board with some legal authority would be a representative body that, while not making law (forest plans and projects), would advise each forest on what’s best for their (local/state) constituents. IOW, the board members would be representatives as proxies. Perfect system for the natural forests? No, of course not. Would it be more efficient? Maybe. Result in fewer decisions being made by courts? Quite possibly. Result in more public acceptance/social license? Maybe. Crazy? Maybe — but worth thinking about.
“NEPA set up a form of direct democracy for USFS’s forest planning and projects.” Sorry – it’s boilerplate language in NEPA processes that public comments are “not a vote,” and agency responses routinely lump form letters into essentially one comment.
Not a vote, but comments do carry weight.
I once saw an online list of official objections to a project, somewhere, along with the Agency’s official response. There were hundreds of comments, with a huge portion of them not associated with the actual project (Monsanto, etc).
Some of the comments had substance, but were not followed by the Forest.
I think it would be great if the public could view all of the public comments, and the Agency responses. It would help the public write better comments, no matter which side they are on.
I think one issue is expectations were set way too high for the time needed to develop a plan. Staff were set up for failure by the idea that they would be able to complete the process in 3-4 years simply because there was a new rule, without providing a lot more staff to work on planning. Developing a solid plan is not an easy task. There are many connected moving pieces. Plans have a significant effect on what happens on the ground. Getting it right isn’t just a formality.
I have participated in planning efforts for four 2012 Rule forest plans. During the development process, significant flaws and contradictions were observed that could not be dismissed or glossed over. Many of these issues required the planning teams to do considerable revisions. This is not a case of analysis paralysis. It is a good thing that the public was there to review the plans from a different lens. Even minor flaws and contradictions that make it into the final plan can result in a lot of confusion and debate at the project planning level and not result in the intended outcome.
I think that the 3-4 years (less time) with substantially more analysis than the 82 Rule was always more of a talking point than reality (at the time I tried to get the Powers That Were to be more honest, but to no avail). I hope staff didn’t actually believe that, or that they were in any way to blame for not being able to complete plans within that unrealistic time frame.