How to do Assessments Under the Proposed Forest Service Planning Rule – Part 4: Beginning with the End

Gunnison National Forest, Colorado

This is the last in a series of posts about assessments for Forest/Grassland plan revisions under the proposed Forest Service planning rule.  The posts are a summary of this working draft of the asssessment process.  In previous posts, Part 1 described some suggestions about how the assessment process would focus on a series of questions derived from the rule.  Part 2 talked about the analysis and deliberation steps.  Part 3 described futuring and scenario planning.

Before revising a Forest Service plan, the proposed planning rule requires an assessment – both a product (the document), and a participatory process (deliberation and analysis).  There are three important outcomes of the assessment process:

  • It can provide baseline information for looking at the effects of a Forest Plan.
  • It can provide actionable knowledge about the need to change the Forest Plan.
  • As part of a broader adaptive governance framework, it can foster collaborative learning, especially when there is no agreement on the problems or solutions.

The assessment sets the stage for the subsequent proposed plan, an Environmental Impact Statement (EIS), and the who, what, when, where, why and how for the NEPA process.  The interplay between the assessment document and the EIS is of particular interest.  As a comprehensive look at the planning rule requirements, the assessment would look at the current plan and serve as a screening process for an EIS.  This would simplify the EIS since it would only need to focus on those requirements that the current plan isn’t expected to meet.  The assessment could also essentially become the “affected environment” chapter of the EIS. 

Several points need emphasis.  First, the topics covered in an assessment are at the scale of the Forest Plan decision under NFMA and its implementing rule.  The level of detail required to develop a Forest Plan is less specific than resource planning (like fire planning or forest-wide recreation planning) or project planning.  Second, an assessment is time sensitive.  It provides information for the subsequent plan revision and EIS.  The rule assumes a more or less continuous cycle of assessment, plan revision or amendment, and monitoring.  An assessment is a time step for those issues that are ripe for discussion.

“Actionable knowledge,” as researcher Chris Argyris has written in his 1993 book, “is not only relevant to the world of practice, it is the knowledge that people use to create that world”.   A forest plan assessment needs to provide information about what needs to be changed in the forest plan, and how those changes should be made.  An assessment shouldn’t merely be a compilation of “descriptive” facts about a forest.  The descriptive facts should be connected together in the context of the assessment questions and the experience and judgment of the participants.  We might know that there are 10,000 acres of dead trees in a forest.  But just knowing that there are dead trees doesn’t compel us to act.  However, if we have Forest Service employees, scientists, local residents, or others with experience about disease agents and how they might spread, within the context of a specific assessment question about wildlife habitat or timber salvage markets, we now have actionable knowledge that can inform how the forest plan might be changed. 

Argyris has said that actionable knowledge includes a deliberate, intentional search for error, understood as a mismatch between either intentions or assumptions and outcomes.  In a sense, these errors are surprises that we didn’t know about or think about when we wrote the original plan.  The whole idea of actionable knowledge is about having a reasonable process that facilitates timely recognition of likely, yet unpredictable surprises so that less costy actions are possible in response.  Actionable knowledge is about looking to learn, instead of assuming that what we think we know during a planning process will always be the case as we move forward.  The context in which we manage these public lands is just too dynamic for such assumptions.

An important theme of the planning process in the proposed rule is learning:

This new framework is science-based and would provide a blueprint for the land management process, creating a structure within which land managers and partners could work together to understand what is happening on the land, revise management plans to respond to existing and predicted conditions and needs, and monitor changing conditions and the effectiveness of management actions to provide a continuous feedback loop for adaptive management.” Federal Register p. 8487

Ideally, for adaptive management to work, learning objectives should be explicitly stated and incorporated into the objectives of the forest plan, with monitoring questions and indicators all tied to those objectives.  The proposed rule requires the identification of monitoring questions and indicators as part of the assessment process.  So it beomes important that participants use the assessment process by formally asking what they want to learn and why.

Elsewhere on this blog, we’ve discussed the need for the Forest Service to establish an adaptive governance framework, and some of the basic principles.  As part of that broader framework, the forest plan assessment process can be used to engage stakeholders and allow participants to invest in the planning process.  Without such an investment, we will not reach that basic standard of collaboration—are stakeholders, including the Forest Service, willing to live with the proposed changes?  Failing to reach that basic standard reduces the willingness to help get the job done and increases the willingness to challenge the decision administratively, legally, or through civil disobedience, such as ignoring new management rules. 

The assessment process will require a capacity to collaborate.  Based on a study of forest plan revision efforts, Sam Burns and Tony Cheng have developed six essential prerequisites for utilizing a collaborative process:

Is the Forest Service staff aware of collaboration ideas and principles?

Is there an understanding of the social and historical context for collaboration in the planning locale, including community understanding of collaboration and related collaborative capacities?

Is there internal capacity to do collaboration?

Are there clear collaborative expectations?

Are there ways to monitor and adapt the planning process?

Is there a design for how the collaborative process will work?

A collaborative learning process is essential because forest planning often behaves as a classic example of a wicked problem, where there is no definitive statement of the problem, and hence there can be no definitive solution.  (See for instance Salwasser’s description of the Sierra Forest Plan amendments).  The forest planning process will involve fragmented stakeholders, high-uncertainty, disagreement about the role of science, political engagement, and an ebbing and flowing of Forest Supervisor control.  As the assessment process goes through the iterations of deliberation and analysis, The Forest Supervisor should determine if it still helping define the problem, or still building relationships and capacity for subsequent planning and project work.  There will be no easy rules of thumb for when the end the assessment process.  There are no “right” answers for many of the assessment questions.  The proposed planning rule gives some flexibility by allowing the assessment process to overlap with the revision and NEPA process.  It also gives the Forest Supervisor the discretion on when to end the process.  Hopefully, the Forest Supervisor has communicated early in the process how she/he will decide when to end the process, participants shouldn’t be surprised when management intervention is taken.

The design and implementation of the assessment process needs to have its end in mind.  It’s about convening, exploring and learning, in order to act and move ahead.  Ultimately it’s not about a plan, it’s about implementing a plan.  But you can’t implement until you know what you’re doing.  You also can’t implement a plan without support of those affected it.  A well designed assessment process can improve the final plan document, provide a fair process for the participants, and foster relationships with people that can later help implement the plan.   So let’s begin.

How to do Assessments Under the Proposed Forest Service Planning Rule – Part 3: Scenario Planning

Mendocino National Forest, Bear Creek Campground, photo by Tiffany Flanagan


What is the future of our National Forests?  How do we fulfill NFMA’s challenge to plan for sustained yield of products and services into the future?   

In the messy world of forest planning, there are demands for certainty and assurances about the future, so subsequent project work can be done.  Planners have responded with deterministic linear programming models, reasonably foreseeable development forecasts, ranges of historic variation, or simply promises.  If uncertainty remains, there is a promise to monitor, and to eventually adapt.  Sometimes these approaches have worked, often they haven’t.  

The challenge of the proposed planning rule is to assess present and potential future conditions in order to plan for them.  In previous posts, I offered suggestions to review assessment questions derived from the rule through an interactive process using analysis and deliberation.  If Forest Plans are to be strategic and guide projects from one decade to the next, they must be able to address an uncertain world.  However, the appearance of certainty comes at a price, both in the cost of the plan’s preparation, and its reliability.  One thing becomes clear: forest planning should not try to reduce uncertainty – instead, it should embrace uncertainty.

One approach to addressing uncertainty is to set up adaptive management.  You establish a hypothesis, then test it through monitoring and evaluation.  But adaptive management only works when the Forest Service is in control of the forces affecting the forest.  For uncertainty that can’t be controlled, a better approach is to develop a plan that is robust and flexible to respond to the unexpected problems that “walk into the District Ranger’s door”, or to address the uncertain events that the proposed planning rule calls “drivers, stressors, and disturbances” or “risks”.

Nimble, flexible planning requires some awareness of blind spots and assumptions about the future.  It requires a look at alternative futures.  In order to break out of people’s comfort zones, it’s important to offer stories with impact, that create a future shock.   These are the elements of scenario planning, or what is sometimes referred to as scenario thinking.  Scenario planning is a structured framework to identify actions that will be most effective across a range of potential futures to promote desired outcomes. Peterson, et. al. has described how scenario planning is useful in natural resource planning where there is high uncertainty and minimal control.  The Park Service is applying scenario planning for addressing climate change in park planning.

Applied to the Forest Plan assessment process, scenario planning would include the following steps:

  • In answering the assessment questions, find out what scientists know, think they know, and don’t know.
  • For the things that we don’t know, find out what are the most critical forces that affect the answers to the assessment questions.
  • Combine the most critical forces into different stories about how the future will play out.
  • Think about what should be in the forest plan to respond to the various scenarios.
  • Determine what important monitoring questions and indicators are important to see what scenarios may unfold.

Scenario planning focuses on multiple, reasonably plausible futures.  While these multiple futures can be thought of as analogous to multiple forecasts, true scenario planning seeks to describe multiple plausible futures.  Scenario planning does not seek to establish probabilities associated with those futures.  The emphasis on plausibility instead of probability is overlooked by some disciplines that have embraced the terminology of scenarios without understanding the origins of scenario planning.  Emphasis on probabilities reinforces a problematic search for a single best answer (see for instance, Mitroff and Lindstrom or Van der Heijden), a problem the founders of scenario planning sought to address (wikepedia link).

This difference between emphasizing plausibility and emphasizing probability creates a need to develop new Forest Service skills, because those trained in natural resource sciences are taught about probabilistic methods.  Some of the new skills needed require rethinking fundamental training, which is especially challenging.

The main goal of scenario thinking is to question basic assumptions about how the world works and to open people’s minds about possible futures that would otherwise be unimaginable.  Participants can break out of their standard worldview, exposing blind spots that would otherwise be overlooked in the generally accepted forecast.  It’s then easier to recognize a scenario in its earliest stages, should it actually be the one that unfolds.  The Forest Supervisor is also better able to understand the source of disagreement that often occurs when different people are envisioning different scenarios without realizing it.

Collaboration is central to scenario planning – engagement that includes but is not limited to that of technical experts and scientists.  This engagement is a scientifically valid method of bringing biases and assumptions to the surface and then using those to construct plausible alternative futures.  In contrast, traditional approaches to forest planning typically pit competing perspectives against each other in search for a single best forecast or scenario, occasionally looking for multiple single-point forecasts.  Chermack and Lynham explain that the search for a single best forecast makes traditional methods fundamentally adversarial, and therefore at odds with more collaborative, learning-oriented approaches to planning and decision-making.

Like most planning methods, there are some cautions with scenarios.  We’ve talked about Mintzberg’s classic book on this blog, and Mintzberg (p. 248) mentions the balancing act between developing enough scenarios and hitting the manager’s mental capacity.  He says that “hedging or remaining flexible has its own costs, primarily in the lack of commitment to a clear strategy.”  Plus, even when the planners are quite sure that one of their scenarios is on the right track, there remains the problem of convincing management to do something about it.   Still, despite Mintzberg’s and other commentors’ concerns, scenario planning is useful to begin a dialogue, to blend the “hard” analysis with a manger’s “soft” intuition, and engage the public.

Properly done, an assessment under the proposed planning rule should challenge the conventional wisdom and contribute to the learning of all participants.   That might be the greatest benefit of NFMA planning.


How to do Assessments Under the Proposed Forest Service Planning Rule – Part 2: The Process

In an earlier post I offered some ideas for doing an assessment under the proposed Forest Service planning rule.  The essential purpose of the assessment would be to review assessment questions derived from the rule to determine what in the Forest Plan needs to change for the Revision.

In order to assess the relevant conditions of a forest, or the risks to a forest, two activities are often described in the planning literature: deliberation and analysis.  (See for instance the National Research Council’s guide to risk assessment.)  These two activities can be thought of as complementary approaches to gaining knowledge about the world.  Analysis uses rigorous, replicable methods to arrive at answers to factual questions.  Deliberation is any formal or informal process for communication and collective consideration of issues.  Together, the combination of deliberation and analysis serves as the synthesis process, required for assessments in the proposed planning rule (see definition at 219.19).

The Deliberative Democracy Consortium defines deliberation as an approach to decision-making in which citizens consider relevant facts from multiple points of view, converse with one another to think critically about options before them and enlarge their perspectives, opinions, and understandings.  Deliberative democracy strengthens citizen voices in governance by including people of all races, classes, ages and geographies in deliberations that directly affect public decisions.  As a result, a citizen influences – and can see the results of that influence on – the policy and resource decisions that affect their daily lives and their future.

The assessment process would contain analysis and deliberation steps, but the process itself must be designed collaboratively by the participants.  The principal reason is that the participants should have sufficient ownership in the process.  If participants have ownership in the process, they will see it as fair, and therefore willing to live with the eventual outcomes.  The steps and the sequence should be agreed upon by the participants at the beginning of the process.  The Forest Supervisor needs to be fully engaged, explaining to the participants the sideboards for the process, and that she/he will retain the discretion to determine the scope, scale and timing of the assessment (proposed planning rule at 219.6)

David Straus has described in his book How to Make Collaboration Work (amazon link) that a flowchart of the steps of a collaboration process might look like an “accordion”.  For a plan assessment, here’s what it might look like.

There are cycles between deliberation activities and analysis activities.  There are also cycles between large group activities and small group activities.  Each cycle refines the answers to the assessment questions, and may bring in new participants and new sources of knowledge.  The flow chart expands with concurrent activities, then contracts into deliberative meetings, then expands again, hence the description as an “accordion process.”

Again, the focus of deliberation and analysis would be answering the assessment questions.  One of the first questions on the list relate to the values that participants place on a National Forest, and what roles and contributions they see the forest providing now and into the future. 

One approach that can be applied is David Cooperrider’s appreciative inquiry methodology.  This process moves from (1) discovering what works well in the current forest management situation; (2) envisioning what might work well in the future; (3) designing, planning and prioritizing what would work well; and (4) executing the proposed design.

Another key step is looking into the future.  The next post describes the potential role of scenario planning in the assessment process.

How to do Assessments Under the Proposed Forest Service Planning Rule – Part 1

Lynx and coyote tracks, Superior National Forest, Minnesota, photo by Larry Weber

An assessment is the gathering and integrating of information relevant to the planning area from many sources and the analysis of that information to identify a need to change a plan or to inform how a new plan should be proposed. – section 219.5(a)(1) of the proposed Forest Service planning rule

It is a synthesis of information in support of land management planning to determine whether a change to the plan is needed.  Assessments are not decisionmaking documents but provide current information on select issue. – section 219.19 of the proposed Forest Service planning rule


This is the first of a series of posts about possible approaches to preparing an assessment for a National Forest/Grassland Plan revision under the proposed Forest Service planning rule.  (It is based on some informal conversations that Peter Williams and I have had with folks inside and outside the Forest Service, but nothing here reflects official Forest Service policy or the deliberations of the team working on the planning rule.)

The proposed rule expects a process that integrates both science and collaboration: “the objective of this part is to guide the collaborative and science-based development, amendment, and revision of land management plans.” (219.1(c)).  Under the rule, an assessment must be collaborative and science-based, just as the overall plan revision process, because it brings together many sources of information, including social, economic, and ecological, whether qualitative or quantitative.  Moreover, the subsequent process must rely on information from an assessment if the process is to be collaborative and science-based.

Although one immediate purpose of an assessment is to identify whether a need for change exists, the second, equally important purpose of an assessment is to inform design of the subsequent forest planning process that will propose specific changes to the plan if a determination is made that a need for change does exist.

Under this definition, an assessment is both a product and a process

The product is a report similar to an “Analysis of the Management Situation” or other scoping documents under the 1982 planning rule.   It documents “existing and potential future conditions and stressors” that subsequently will be the foundation for the revision’s Environmental Impact Statement.  It describes the Forest in the context of the broader ecosystem, and what’s going on in the States and counties within and surrounding the Forest.

The process involves convening multiple parties at multiple scales to determine if the current Forest Plan is working by answering a set of assessment questions derived from the rule

This rather long list of questions has the potential to be quite lengthy, so they need to first be screened to determine if they are relevant to the particular forest.  Screening questions would include:

Assessment Goal

Coarse Screening Question

Need for change in plan components or monitoring program

Is the information needed to inform and develop plan components (i.e., Is this a Forest Plan issue, not a program planning issue or a project issue)?  219.6(b)(1)
Is the resource present?  219.7(b)(2)(ii)
Is the resource important?  219.7(b)(2)(ii)
Is addressing the resource within the authority of the Forest Service?  219.8, 219.9, 219.10, 219.11
Is addressing the resource within the capability of the plan area?  219.8, 219.9, 219.10, 219.11
Is addressing the resource within the fiscal capability of the unit?  219.10
Is there an emerging public issue that needs be addressed?  219.6

Design of process for revising a plan or monitoring program

Is the information needed to understand the discrete roles, jurisdictions, responsibilities, and skills of interested and affected parties?  219.4(a)
Is the information needed to understand the expectations regarding the accessibility of the process, opportunities, and information?  219.4(a)
Is the information needed to determine the scope, methods, forum, and timing of public participation opportunities?  219.4(a)(1)
Is the information needed to develop required plan components (219.6(b)(1)), including information needed to inform design of the public notification and participation process?  219.7(c)(1)

In answering the questions, technical information is essential, but an assessment under the rule should not merely be a technical process – it is fundamentally participatory, drawing on information and knowledge from multiple sources and multiple participants.  During an assessment, the most accurate, reliable, and relevant scientific information is synthesized from governmental and non-governmental sources. But the process is also about clarifying values, because an important step is to identify why a particular National Forest/Grassland is important to the participants.  One reason for clarifying values is that the knowledge being sought includes how a new plan should be proposed.  That is a process-oriented goal.  To meet such a goal in a way that is appropriate for the local situation, the assessment must seek to understand procedural preferences—values—of stakeholders, including but not limited to those of Forest Service personnel. The second specific assessment purpose is worth highlighting again: the goal of an assessment under the proposed planning rule is to gather and integrate information that informs design of a participatory and collaborative process should one be needed to change the plan.

Part 2 will describe how an assessment might be conducted.

In Search of Our Desired Forest

Jumbo Peak, Gifford Pinchot National Forest, photo by Tom Kogut

“What we leave on the land is more important than what we take away.” – Forest Service Chief Dale Bosworth, 2002

“Narrowly defined desired future ecosystem conditions, particularly if they are historical conditions poorly aligned with the unprecedented future, will seldom provide useful targets for management intervention.” – Stephenson, Millar, and Cole In Beyond Naturalness, 2010

What’s the true value of a Forest Plan?  Over the history of Forest Service planning, the answer has changed. Now it’s changing again – plans in the future will not be measured by the accuracy of their detailed descriptions of fixed “desired conditions”, but how robust and flexible the plans will be when dealing with uncertainty.

Of course, maybe the true value of planning was never what we thought. It may have simply been about drawing a map of the areas where activities could occur, and creating a certain level of accountability with the public about how the activities would be conducted. But the idea persists today that the central purpose of plans is to describe detailed “pictures” of our desired conditions, and the specific structure, composition and function of the necessary ecosystem elements.

What a history we’ve had! NFMA plans were originally conceived as essentially one big timber sale. During the Senate floor debate in 1976, Hubert Humphrey said that no project level NEPA documents would be required after a plan was completed. All the parts of the plan were equally important. That changed in 1990, when former Chief Dale Robertson began to assert that standards and guidelines were more important than objectives. Throughout the 1990s, we shifted our focus from the uses of the forest to the condition of the forest itself. While changing the NFMA planning rule, the 1999 Committee of Scientists described the purpose of forest planning as “outward looking, built upon assessments; grounded in current scientific understanding; collaborative in nature; and focused on desired future conditions.” Planners were told to concentrate on “what we leave on the land.”

Meanwhile, planning was requiring huge investments of time, and plans were being written with a few pages of goals and objectives followed by 100 or more pages of forest-wide or management-area-specific standards and guidelines. Good standards were difficult to write, because they required inventories of current conditions that weren’t available, understanding of changing technology, and the need for difficult projections about the level and intensity of likely future activities in the face of changing management priorities and changing conditions on-the-ground. It was difficult to set standards for things like old growth or riparian areas when we didn’t even know how many acres were out there.

So the 2005 and 2008 planning rules were written to make plans more strategic and vision oriented, like county comprehensive master plans, and less dependent upon prescriptive standards. The preamble to the 2008 planning rule explained that “plans are more effective if they include more detailed descriptions of desired conditions, rather than long lists of prohibitive standards or guidelines developed in an attempt to anticipate and address every possible future project or activity and the potential effects such projects could cause.”

But a funny thing happened when we started writing plans under the 2008 rule. Instead of 100 pages of standards and guidelines, we now had 100 pages of desired conditions. Rather than broad, strategic goals, descriptions of desired conditions were becoming specific, detailed, highly-parameterized descriptions of vegetation conditions: percent species composition, numbers of trees per acre, desired ranges of basal area, numbers of snags, etc. The idea was that detailed desired conditions could ease the burden on project planners in developing the “purpose and need” for projects. At the same time, these desired conditions writeups were suggested as a tool for “accountability”.

Meanwhile, we probably lost the idea that forest plans should be readily understood by the lay reader who treasures a forest.  For many people, a forest is a place.  It’s not a list of attributes.

But here’s the fundamental question about planning:  Do National Forests change because of Forest Plans or in spite of Forest Plans? Can we really control nature? Is intensive end-oriented management possible everywhere? In the Rocky Mountain west, we work in fire-dominated ecosystems with very long fire-return intervals. We have seen huge swaths of trees dying of insects or disease. The rates of change are enormous, and for some forests, current FIA data doesn’t represent the current conditions on the ground. We are heavily influenced by severe storm events – intense snowstorms, rain on snow events, patterns of drought, summer floods, even tornadoes. There is no equilibrium condition. Our Forest Plan modeling shows dynamic, ever-changing forests.  We have become focused on the types and rates of forest disturbances.  At the scales we’re dealing with, it may not be possible to map a single desired condition, or even a reasonably understood “range of conditions”.

The dynamics of climate change create uncertainties at the scales we are working at.  Connie Millar has said that “although DC statements may be written broadly (“habitat for species x exists in adequate amounts to maintain current populations”), equally often they emphasize limited views of the future, or very narrow ranges of conditions (“4-6 snags per acre”). This suggests that the possibility of multiple ecosystem pathways, unexpected events, major interactions among elements, and threshold events are not really accepted by managers or the public. DC statements that recognize ranges of outcomes and not just singular states as acceptable are more realistic.”

Florida State Law professor Robin Kundis Craig has argued for new types of plans and regulations because “Stationarity is Dead“:  “we are moving into an era where ecological change might not be predictable and when external factors, positive feedbacks, or nonlinear instabilities in a system will cause changes to propagate in a domino-like fashion that is potentially irreversible. As land, air, and water temperatures generally increase, patterns of precipitation alter in terms of both amount and timing, and species shift as best they can to cope, “restoration” and even “sustainability” have the potential to become close to meaningless concepts. We are moving along an at least somewhat unpredictable path to an as yet unpredictable final destination.”

The planning problem is not just about natural forces – it’s also about societal changes. We are seeing new uses of National Forests, and more and more projects are proposed by somebody other than the Forest Service.  For instance, how can we anticipate in advance what standards and guidelines apply to laying a new type of fiber-optic cable across a forest?

As explained in the business and public administration literature, the purpose of a strategic plan is to identify core strengths, intended roles and contributions, and a “vision” which can be a rallying point or goal to be achieved. A plan should be robust and flexible, so it can adapt to changing conditions, changing knowledge, and changing politics, while being consistent with the organization’s core strengths and vision. A highly detailed plan will detract from the day to day sensing necessary to manage the unexpected. As Karl Weick and Kathleen Sutcliffe state in their book Managing the Unexpected:

A heavy investment in plans restricts sensing to expectations built into the plans and restricts responding to actions built into the existing repertoire. The result is a system that is less able to sense discrepancies, less able to update understanding and learn, and less able to recombine actions into new ways to handle the unexpected.”

Park Service scientists Robert Bennetts and Bruce Bingham have pointed out the reasons that it is highly difficult, if not impossible, for managers to achieve desired conditions, because of lack of information, lack of management control, unavoidable circumstances, and trade-offs based on societal values. They talk about the “punitive paradox”: managers aren’t going to report impaired conditions if they are being judged on the difference between existing and desired conditions. They conclude that desired conditions could be a useful scientific research question, but they don’t work as a management tool.

So where does this leave us?  Actually, some of the answers have already been mentioned on this blog.  There are some exciting planning techniques being implemented in the field.  We’ve got the tools – let’s see what we can do.

CEQ Issues Final Guidance on Monitoring of Mitigation, Use of CEs

The Council on Environmental Quality (CEQ) issued two final guidance documents today, one which requires monitoring of any mitigation included in an environmental document, and the other governing the use of categorical exclusions.

It will take a few weeks to fully digest what the guidance will mean for Forest Service planning and implementation of projects.  Both guidance papers are an outcome of CEQs outreach in 2004 to “modernize” NEPA implementation, and last year’s “40th anniversary of NEPA” review.  CEQ is saying that these guidance documents are not rules or regulations, and are not legally binding requirements or legally enforceable.  Nevertheless, the guidance expresses the intent of the Administration, and will likely be used in reviews of agency procedures and NEPA documents.

The mitigation and monitoring guidance paper reemphasizes the importance of mitigation under NEPA to minimize the potential adverse environmental impacts by avoiding, minimizing, rectifying, reducing, or compensating for an impact.  Mitigation (like requiring best practices or staying out of a particular area) is often incorporated into the proposed project design or one of the alternatives.  Sometimes, mitigation might be used to reduce the impact such that a “finding of no significant impact” is made.  CEQ wants Federal agencies to ensure that mitigation commitments are actually implemented, and that monitoring is accomplished to provide feedback on those determinations.

The guidance for categorical exclusions (from NEPA documentation like an EIS or EA) places additional requirements on agencies when they establish categories or use categories already in existence.  CEQ is encouraging agencies to provide guidance on the level of documentation required when CEs are used.

Holiday Wishes for a New Planning Rule

Twelve environmental groups have started an ad campaign calling for a new Forest Service planning rule “to protect all creatures great and small.”  A press release from the Pew Environment Group and 11 other organizations mentions that 10,000 post cards and a letter to the Secretary of Agriculture will advocate that the planning rule considers strong standards for water quality and wildlife protection, and a commitment to scientific review.

The draft or proposed planning rule is in the administrative clearance process in the Department of Agriculture and the Office of Management and Budget.  The Forest Service’s planning rule blog explains that the clearance draft’s proposed treatment of species diversity has been changed from the concepts presented at the last public meeting on the rule in July.

Rethinking the Recreation Opportunity Spectrum in Forest Service Plans


Semi-primitive non-motorized.” 


The fine print of most Forest Service Plans contains terms from a recreation zoning scheme that is essentially the same as when it was developed in the 1980s.  The Recreation Opportunity Spectrum (ROS) is a means to subdivide a forest by desired physical, social, and managerial features to provide a setting for compatible recreational activities.  Although the basic framework has been in place for nearly 30 years, it may be lost in the discussions about a new forest service planning rule, and the system is showing some wear.  The system was never fully integrated across resources.  Forests and Regions have developed processes independently, leading to inconsistencies within and across Regional boundaries.  Naming conventions vary, and there are differences in how wilderness areas are mapped, and how seasonal distinctions are addressed.  Now, the importance of ROS maps in Forest Plans may be even greater than previously thought, after at least one court ruling saying these maps are constraints on recreational activities.

The 1979 ROS Users Guide, the 1990 ROS Primer and Field Guide, and the 2003 National ROS inventory mapping protocol describe the six distinct settings that are mapped in a Forest Plan:  urban, rural, roaded natural, semi-primitive motorized, semi-primitive non-motorized, and primitive.  Used in conjunction with Sense of Place (SOP) mapping, the Scenery Management System (SMS), and Benefits Based Management (BBM), ROS is an approach to display human values, meanings and attachment to the landscape.

The ROS system was at the heart of a sixth circuit decision discussed here a couple of months ago which struck down the revision of the Huron-Manistee Forest Plan.  In that decision, the court addressed the concern about providing “quality recreation opportunities for hikers, backpackers, and cross-country skiiers” by upholding the ROS system as a “thoughtful methodology for matching settings and activities, among other planning purposes.”   However, the court then went further and said that the Plan should not allow activities such as gun hunting and snowmobiling that are inconsistent with ROS descriptions like semi-primitive non-motorized.  The court said: ”The [Forest] Service cannot expect us to defer to its ROS descriptions when they support its decision (which we have done above), but then to disregard those same descriptions when they conflict with its decision.” ….  “the [Forest] Service’s decision not to balance these competing uses, and to disregard its own ROS descriptions, is what fell outside the relevant standards.”

One of the esoteric debates among forest planners these days is where exactly an ROS map fits in a forest plan.  Often, ROS maps don’t match management area maps, and treatment of ROS zones varies from plan to plan.  Some plans contain ROS elements as part of an aspirational “desired condition” while other plans list the identification of an ROS class as a “standard” that all projects must meet.  Although ROS is very similar to the idea of a suitability map, like timber suitability or grazing suitability, ROS is not specific to a particular activity.  It merely describes a setting for recreation activities, and only suggests certain recreational activities that might be compatible in that setting.  Because the actual conditions of the recreation setting need to be validated on the ground, it’s difficult for a forest plan to specifically identify recreational opportunities.

Arguably the most important element of the ROS mapping process is the separation of semi-primitive non-motorized areas from other motorized or roaded settings.  Essentially, a SPNM area is a contiguous unroaded area of at least 2,500 acres. A plan should have consistent direction for ROS, scenery management, travel management, road construction, and other developments.  This part of a forest plan can be very important, because it can limit road building and other development on parcels smaller than the 5,000 acre threshold for potential wilderness areas, or areas previously mapped as roadless and controlled by roadless policies.  While a “roadless” area by definition is larger than 5,000 acres, backcountry recreation activities are certainly possible in areas as small as the 2,500 acre threshold.

ROS needs to be featured as a central part of the forest planning rule.  But it needs to be updated.  Here are some considerations:

  • The terms need to be simplified.  Many people don’t understand the concept of “semi-primitive.”  In some forest plans, management areas adopted a simpler concept known as “backcountry.”
  • New categories may be necessary, to address distinctions between summer non-motorized and winter non-motorized, variations within Wilderness areas, or roaded-natural areas that may be roaded but generally non-motorized.
  • The ROS concept should be expanded to incorporate other activities and resources.  This might best work by requiring ROS zones to be integrated into the forest plan management area process.
  • ROS classifications probably shouldn’t be treated as forest plan standards.  There are too many variables that influence what recreational activities can occur in an area.  However, the planning rule should treat the ROS idea as an important feature of forest plans and plan objectives, standards, and guidelines should be consistent with the ROS classifications.
  • The designation of ROS zones needs to be made at multiple scales.  ROS zoning is subject to the same pitfalls as general management area zoning – it can tend to fragment a forest, and doesn’t lend itself to the larger question of regional recreational experiences.  One report suggests that the inability to “think and act regionally” leads to a homogenization of recreation experiences which suboptimizes and reduces the flow of recreational experiences in the region. 

The ROS system is a sophisticated tool that has been adopted by other agencies and even extended to nonfederal lands.  It’s time to dust it off, and make sure it’s a key element of the new planning rule.

Forests Can Protect Humans from Disease

Here’s one more benefit of National Forests which needs to be considered in forest planning: protection from infectious human diseases.

A group of scientists published a study earlier this month in the Nature journal, citing mounting evidence that biodiversity loss frequently increases infectious disease transmission.

One of the primary authors, Felicia Keesing from Bard College, explained the general pattern to Science Daily: “biodiversity loss tends to increase pathogen transmission across a wide range of infectious disease systems.”  Keesing has been following the ecology of Lyme disease in northeastern forests for several years, and she said that evidence is mounting about biodiversity and disease.  For instance, an opossum can serve as a biological buffer between the Lyme bacterium and humans by picking and killing off ticks.  Opossums are poor hosts for ticks, but mice are good hosts.  As biodiversity is lost, opossums move away and mice remain.

The authors also cite the relationship of the mosquito-transmitted West Nile disease and low bird diversity, as well as the relationship of hantavirus and lower diversity of small mammals.  There are three reasons the loss of biodiversity can affect the transmission of infectious diseases:

  • The more diverse the number of intermediate hosts, the less likely that a specific host will be present that are dangerous to humans.
  • In a more diverse community, it’s more likely that the disease will end up in an unsuitable intermediate host.
  • Genetically diverse hosts are generally in better condition and more resistent to disease.

The authors conclude: “despite remaining questions, connections between biodiversity and disease are now sufficiently clear to increase the urgency of local, regional, and global efforts to preserve natural ecosystems and the biodiversity they contain.”

At the very least, the relationship of biodiversity and epidemiology is a very direct example of a principle the Forest Service has been using during the development of a new forest planning rule: that people and the environment are inseparable and interdependent.  The idea that forests are actually a safety net is a compelling argument for the maintenance and restoration of functioning and diverse ecosystems.

House Members Weigh In On Treatment of Recreation in Planning Rule

Is Forest Service planning becoming so complex that analysis paralysis is causing delays in decisions affecting outdoor recreation?  The importance of recreation and public access in National Forests continues to draw attention as the Forest Service attempts to move a proposed forest planning rule through the government clearance process.  Earlier this week, the planning team announced a delay in the release of a draft rule.  Throughout the rule development process, recreation interests have complained about apparent biases in draft planning material toward other multiple uses.   In some ways, the planning rule writing team hadn’t anticipated this response by initially failing to include outdoor recreation as an issue to be addressed during initial scoping.

Now Congress is entering the discussion.  In a letter sent to the Forest Service Chief last Thursday, 41 House members asked that a new planning rule “not impose new burdensome regulations or create new obstacles that could ultimately reduce recreational opportunities on these lands”.  The House members are led by Kevin McCarthy of California and Rob Bishop of Utah.  Most of the 41 are Republicans such as Denny Rehberg of Montana, mentioned earlier on this blog, but also include some Democrats like Dan Boren of Oklahoma.

The letter echoes earlier concerns about the vague generalities about ecological concepts on the planning rule website, and relates to discussions earlier on this blog about encumbering an already broken planning process.  “These are broad concepts and difficult to define.  Because stakeholders may be unable to agree on definitions, this could hamper individual forest supervisors’ ability to develop land management plans that include robust and diverse access and recreation provisions.  Other terms such as ‘ecosystem services’ and ‘stressors’ throughout the other concept drafts are also not adequately defined, which could overwhelm local land managers with the need to do exhaustive research, making the already lengthy and complicated planning process more complex and time consuming – and this impacts not just recreation proposals.  These inadequately defined terms could lead to endless litigation of the rule itself or individual USFS land management plans.  In essence, we could have analysis paralysis that denies the public access and the ability to recreate in their national forests.”

Generally, Forest Plans in the past have assumed that lands are suitable for any activity unless expressely listed as “not suitable.”  The Forest Service has also assumed that Forest Plans are generally aspirational and goal oriented and not immediately enforceable until additional site-specific NEPA documentation is completed and a travel order is issued.  However, a sixth circuit decision about the Huron-Manistee Forest Plan may indicate that courts may be changing this view, and that Forest Plans can and should restrict activities such as snowmobiling and hunting.

Forest planning under the Multiple-Use concept has never been easy, and the recreation debate is perhaps the new issue of the day.  As Martin Nie said on his earlier post on this blog: ”and so here we are, closing in on 2011, and we continue to ask about the purpose of planning, the adequacy of NFMA, and the meaning and future of multiple use.”