Sharon

“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. “ Andy Stahl (my bolding)

My memory was the that FS had identified overanalysis as a more general problem and had looked internally and externally to describe the sources and some solutions. NOTE: that this was more focused around project planning than forest planning, but one might hypothesize that some of the causes and cures would be the same.

I do remember some thinking going along the lines of : if people don’t want projects or plans to happen, and they appeal and litigate on procedural grounds (NEPA and NFMA processes), then the FS needs to develop “bullet proof ” documents.  This is a dynamic  which inexorably leads to over-analysis.

Some empirical evidence might be looking at other agencies and seeing how much they over-analyze (given that the right level of analysis is in the eye of the beholder) and attempting to correlate that with amount of litigation. I did have some experience with some APHIS NEPA that would suggest that since at the time they faced  little litigation, they did not over-analyze.

I was looking for the original FS report on gridlock, and ran across a couple of interesting things in my internet search.

One is a discussion between Neal Sampson and Andy Stahl about gridlock in 1995.

I also found the original report on Process Predicament from 2002. From the Executive Summary on page 5 :

Unfortunately, the Forest Service operates within a statutory, regulatory, and administrative framework that has kept the agency from effectively addressing rapid declines in forest health. This same framework impedes nearly every other aspect of multiple-use management as well. Three problem areas stand out:

1. Excessive analysis—confusion, delays, costs, and risk management associated with the required consultations and studies;

2. Ineffective public involvement—procedural requirements that create disincentives to collaboration in national forest management; and

3. Management inefficiencies—poor planning and decision-making, a deteriorating skills base, and inflexible funding rules, problems that are compounded by the sheer volume of the required paperwork and the associated proliferation of opportunities to misinterpret or misapply required procedures.
            These factors frequently place line officers in a costly procedural quagmire, where a single project can take years to move forward and where planning costs alone can exceed $1 million. Even noncontroversial projects often proceed at a snail’s pace

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Finally I found a news report in which both Chris Wood and Mark Rey panned the above report. Now, usually Chris Wood and Mark Rey tend not to be on the same side, at least on things that are politically charged,  so the fact that they neither thought much of the Process Predicament report is somewhat intriguing.

It sounds like we (the combination of externals and internals) never really worked through this issue, and it remains unresolved.   Re-investigating the causes and cures for this phenomenon, or at least how it applies to forest planning,  may be important to design plans with appropriate levels of analysis and planning rules to require an appropriate level.

I agree with Jack Ward Thomas when he talked about “walking around the field of battle bayoneting the wounded” in, I think,  this still relevant testimony from 2000. There are also some other relevant observations from this testimony for this planning rule discussion.

21st century planning is obviously tied to NFMA, but a challenge is to divorce ourselves from the timber -o-centric nature of the statute and the “timber wars filter” that affects the way we see and frame issues . Sometimes I wonder if those of us who remember that time have some kind of filter that we can’t see beyond- and I am speaking of both those outside and inside the agency.

My wake-up call to see my own filter was moving to the Rocky Mountain Region where day to day questions include skiing, oil and gas, travel management, grazing, fuels treatments- and the supply of wood far exceeds the demand. We have little-talked about (nationally) issues of urban forests everywhere dumping, shooting ranges, crime; we also have encroachment, trespass, the need to keep our water rights and deal with water developers, we have the important but often overlooked national grasslands with prairie dogs and energy development issues.

It is only by spending time outside the larger forest policy discussion that I came to see how the old timber filter can get in the way of seeing the future clearly, including the future of the timber industry.

One idea would be to take the Southern Cal forest plans (which are relatively timber free), and see what issues they have and how they were framed, both by the forests and the plantiffs in the lawsuit.

Another idea would be to take a group of 20-35 year olds, a combination of externals and internals  – some of our most creative  thinkers and soome  experienced with current procedures, and ask them to design a  planning rule alternative. After all, they will probably be implementing, appealing and litigating the plans while we are sitting on porches sipping iced beverages and playing with grandkids.

Finally, I think that if there were a broadly supported, surgical amendment to NFMA to get rid of requirement that were clearly outdated (or relieve low-timber production forests from dealing with them) it is within the realm of possibility to pursue it.

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:

http://www.law.cornell.edu/uscode/16/usc_sec_16_00001604—-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