Do we need another COS?

This letter from Center for Biological Diversity and more than 100 groups:

Forest Planning Rulemaking to Vilsack 16Dec2009

can serve to initiate our discussion on what is the appropriate role of science and scientists in the development of a planning rule.

NFMA (1976) says ” the Secretary of Agriculture shall appoint a committee of scientists who are not officers or employees of the Forest Service. The committee shall provide scientific and technical advice and counsel on proposed guidelines and procedures to assure that an effective interdisciplinary approach is proposed and adopted. The committee shall terminate upon promulgation of the regulations. The views of the committees shall be included in the public information supplied when the regulations are proposed for adoption.”

Since NFMA was passed in 1976, which was 34 years ago, we can imagine that our knowledge of best how to use science in policy has improved along with other scientific fields of study.

So one could reasonably ask, if we were to design something today, would we use current thinking, for example, use a perspective based committee such as the RACNAC was for roadless? This would provide also provide an independent view.  See for example, Brown’s piece “Fairly Balanced”.

Does external advice need to stop at the promulgation of the regulations? I would argue that it should not, rather the development of directives and implementation could also benefit from the advice of an independent group.

Due to the recent interest in “Climategate” there have been some  examples of  current thinking on the role of science in developing policy.  For example, see Hulme’s and Sarewitz and Thernstrom’s recent op-eds.

As a scientist, and having been involved with the 05 Rule, I think we have to be very careful about what we determine is a “science” issue; which disciplines of science we choose to get involved; whether the development of consensus via arbitration of disagreements among individuals from different fields on an interdisciplinary science advisory panel can be claimed to be “science.”

I think that we can learn from the substantial literature on using science in developing policy and advisory panels that has accumulated since 1976.

This letter also highlights one of the tensions about developing  NFMA planning regulation.  Some see it as a process to arrive at a forest plan, where the substance occurs at the forest plan level. Others see it as an opportunity to hardwire policy choices at the national level through these regulations

So the discussion,  if you are a process proponent,  is simply  how to use science in forest planning; if you are a “national policy content” proponent, it may be about specific science to be used in determining national policy choices. Where you are in this “process to content” or “decide in a forest plan or decide in the Rule”  continuum may determine how you see the utility of science in the development of a rule.

Thank you to CBD and to the the other groups for articulating their perspective.

biological diversity press release on new rule

Forest Service Embarks on Fourth Drafting of
National Planning Rules That Could Have Major Impact on Wildlife
More Than 100 Groups Urge Independent Scientific Input
WASHINGTON—
The U.S. Forest Service today announced its intent to develop new
regulations to implement the National Forest Management Act of 1976, a
rule that will govern all regional forest plans and site-specific
projects – such as timber sales, livestock grazing, and road
construction – throughout the entire 193-million-acre national forest
system. Federal courts ruled against the agency’s attempts in 2000, 2005, and 2008 to revise its original 1982 rule. (more)

http://www.biologicaldiversity.org/news/press_releases/2009/nfma-12-17-2009.html

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The Journey Begins- NOI December 18 for new rule

Here’s the press release and the website..
also the FS website for the new rule is in the blogroll in the right column
Release No. 0620.09
Contact:
Forest Service Press Office (202) 205-1134

USDA FOREST SERVICE LAUNCHES COLLABORATIVE PROCESS FOR NEW PLANNING RULE

WASHINGTON, Dec. 17, 2009-Agriculture Secretary Tom Vilsack today
announced that the USDA Forest Service is beginning an open,
collaborative process to create and implement a modern planning rule to
address current and future needs of the National Forest System,
including restoring forests, protecting watersheds, addressing climate
change, sustaining local economies, improving collaboration, and
working across landscapes. The Forest Service will publish a notice of
intent (NOI) in the Federal Register tomorrow, December 18, to prepare
an environmental impact statement (EIS) to develop a new planning rule
that will provide a framework for management of national forests and
grasslands.
“Our National Forests and Grasslands are great natural treasures
that we must conserve and restore for the benefit of future
generations,” said Secretary Vilsack. “Developing a new planning rule
provides the opportunity to manage national forests and grasslands for
the benefit of water resources, the climate and local communities.”
The Forest Service is seeking public involvement in developing a
new direction for local land managers. A 60-day comment period on the
NOI will begin upon publication in the Federal Register on Friday,
December 18, 2009. Comments will be used to shape the focus of the
collaborative dialogue and creation of a proposed rule.
To begin the conversation, the Forest Service has included in the
NOI a set of potential principles that could guide development of a new
planning rule. The potential principles include an emphasis on
restoration, conservation, and the improved resilience of ecosystems;
watershed health; climate change response; species diversity and
wildlife habitat; sustainable National Forest System lands; proactive
collaboration; and working across landscapes.
The Forest Service will use state-of-the-art new media tools in
conjunction with face-to-face interaction to facilitate wide public
participation throughout the nation. Please visit
www.fs.usda.gov/planningrule to participate in our web-based planning
rule blog, and to learn more.
The 2000 planning rule, which allows the Forest Service to use
provisions of the 1982 planning rule, is currently the rule that is
legally in effect. As an interim measure, the Department will republish
in the Federal Register the 2000 planning rule as amended in order to
make it available to the public in the Code of Federal Regulations.
This action will facilitate its use by forests and grasslands in the
National Forest System to revise and amend plans while a new rule is
being developed.
The mission of the USDA Forest Service is to sustain the health,
diversity, and productivity of the nation’s forests and grasslands to
meet the needs of present and future generations. The agency manages
the 193 million acres of National Forest System land, provides
stewardship assistance to non-federal forest landowners, and maintains
the largest forestry research organization in the world.
#
USDA is an equal opportunity provider, employer and lender. To file a
complaint of discrimination, write: USDA, Director, Office of Civil
Rights, 1400 Independence Avenue, SW, Washington, DC 20250-9410 or call
(800) 795-3272 (voice), or (202) 720-6382 (TDD).

http://www.usda.gov/wps/portal/!ut/p/_s.7_0_A/7_0_1RD?printable=true&contentidonly=true&contentid=2009/12/0620.xml