2012 Planning Rule

Swan View Coalition Shares Perspective on Collaboration

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Snapshot of the Flathead National Forest (MT) Plan Revision field tour on the Tally Lake Ranger District, August 2013. That's New Century of Forest Planning commenter Dave Skinner with the camera, green hat and snazzy shirt. Photo by Keith Hammer.
Snapshot of the Flathead National Forest (MT) Plan Revision field tour on the Tally Lake Ranger District, August 2013. That’s New Century of Forest Planning commenter Dave Skinner with the camera, green hat and snazzy shirt. Photo by Keith Hammer.

(The following two columns are guest posts from Keith Hammer with the Swan View Coalition in Kalispell, Montana. Feel free to make comments below, but if you have any specific questions regarding the Swan View Coalition’s perspective on collaboration, please contact Swan View Coalition directly. Thank you. – mk)

Swan View Coalition on Collaboration
By Keith Hammer

Swan View Coalition will always follow the legally required National Environmental Policy Act (NEPA) public involvement process and will participate in optional collaborative processes as time and funds allow. We appreciate both as avenues to better understand all interests and issues.

But we have seen the collaborative process abused by federal agencies and key “stakeholders.” In 1997, national “conservation” groups joined industry in insisting its Flathead Common Ground logging plan be called “ecologically-driven vegetation treatments,” even though the scientific panel they asked to review their proposal disagreed and concluded “The desire to harvest timber products should be explicitly recognized here as the driving force.” This oft-repeated collaborative myth allows industry to argue old logging roads are ecologically necessary to log the forest back to health!

In 2012, the SW Crown Collaborative down-played opportunities for road decommissioning to benefit fish and wildlife in the Swan Valley, based on a mistaken report by the Flathead Forest Supervisor that “the Swan RD has already decommissioned 800 miles of roads . . .” We had to correct the record by providing the Supervisor’s own spreadsheet indicating less than 10 miles of road have been decommissioned in the Swan Valley! Who’s on watch here?

Forest-based collaboratives are skewed toward logging as “forest restoration,” rather than including a robust consideration of road decommissioning and other time-proven means to restore over-logged and over-roaded forests. Indeed, National Forest Foundation’s “A Roadmap for Collaboration Before, During and After the NEPA Process” helps institutionalize the assumption that trees must be removed to restore forest ecosystems. It offers the following tip: “It can be helpful when in the field to ask stakeholders what they would do to improve the condition of the project area. In the case of forest restoration, it can be as simple as asking stakeholders which trees they would leave on the landscape and why.”

We will continue to provide the Forest Service with the scientific research – most of it its own – indicating most forests suffer from too many roads and motorized vehicles, not too many trees. We’ll always do so through the NEPA process and will via the collaborative process when able. But we’ll continue to file lawsuits when necessary to prevent the Forest Service from continuing to create a landscape “pocked with clearcuts and criss-crossed by roads” (see the comments of Former USFS Chief Jack Ward Thomas below) and we’ll refuse to be marginalized simply because we dare speak up and advocate for fish and wildlife.

Why Collaboration and What’s the Fuss?
by Keith Hammer

Definitions of collaboration include “working together” and “traitorous cooperation with an enemy.” Over the past several decades, the Forest Service has increased its use of collaboration to forge consensus among key “stakeholders.”

This has allowed it to marginalize those of lesser means or not in agreement with social compromises that again “cut the baby in half” and perhaps violate laws protecting fish, wildlife, and water quality. Indeed, the National Forest Foundation’s “A Roadmap for Collaboration Before, During and After the NEPA Process” warns of the significant expenditures of “time, effort, funds and social capital necessary for an ongoing collaborative process.”

Current Forest Planning regulations urge that an optional collaborative process precede then parallel the National Environmental Policy Act’s (NEPA) public involvement process. And therein lie two aspects of the rub: 1) collaborators get to front-load the process with their proposals while, 2) many folks who can’t afford to do both must choose whether to collaborate or follow the legally required NEPA process.

The process of seeking consensus through collaboration remains contentious, especially when the Forest Service and industry use it to enlist enough folks to agree with them so they can marginalize those who disagree. Consider these quotes:

“Between private lands and public lands the world that was once covered with a sea of green was now pocked with clearcuts and criss-crossed by roads. But we still continued until we were faced with a segment of the public that had a differing view of what their national forests should be.”
– Former USFS Chief Jack Ward Thomas (Chronicle of Community Vol. 3, No. 1, 1998)

“[W]hen local environmental groups and timber representatives learn to reach consensus . . . that will marginalize extremists.”
– Former USFS Chief Jack Ward Thomas (Daily Inter Lake 6/8/97)

“We need to find common ground so the people who want to litigate are marginalized.”
– Former Assistant Secretary of Interior Rebecca Watson (Missoulian 11/28/02)

“The Collaborative Forest Landscape Restoration Act . . . is largely being used to circumvent existing environmental laws and give control of the management of our National Forests to local special interests.”
– Al Espinosa and Harry Jageman, retired USFS fisheries and wildlife biologists (Letter to Senate Subcommittee on Public Lands and Forests 8/21/10)

“I believe that we . . . have public lands that belong to all people . . . I fear that localized decisions are usually based on ‘How much can I get now?’”
– Former Lewis and Clark National Forest Supervisor Gloria Flora (Chronicle of Community Vol. 3, No. 1, 1998)

“There’s something unreasonably comfortable about focusing primarily on alternative structures for decision making instead of the issues that lie at the heart of the debate.”
– Economist Tom Power (Chronicle of Community Vol. 3, No. 1, 1998)

“Consensus is the process of abandoning all beliefs, principles, values and policies in search of something in which no one believes; but to which no one objects; the process of avoiding the very issues that have to be solved, merely because you cannot get agreement on the way ahead. What great cause would have been fought and won under the banner, ‘I stand for consensus’?”
– Former UK Primer Minister Margaret Thatcher

Planning Rule Committee Meeting- August 2013

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Sounds like all will be able to participate via conference call or webinar. Here’s the link to the story.

The National Advisory Committee for Implementation of the National Forest System Land Management Planning Rule has scheduled a three-day meeting for late August. The U.S. Forest Service announced the meeting on Thursday, Aug. 1. You can read the agenda at http://www.gpo.gov/fdsys/pkg/FR-2013-08-01/html/2013-18469.htm.

The meeting, the committee’s fifth, takes place between 8 a.m. Tuesday, Aug. 27 and 11:30 a.m. Thursday, Aug. 29 Mountain Time at the Embassy Suites Salt Lake/West Valley City, 3524 South Market St., West Valley City, Utah, 84119. The public may attend. If you can’t make it to Utah, you may listen in or participate by conference call or webinar.

You can also send written comments.

In addition to discussing standard administrative matters, the committee will discuss its working group findings and develop advice on the Proposed Land Management Planning Directives.
The committee last met in June. It first met in Washington, DC last June. You can find background at http://www.fs.usda.gov/main/planningrule/committee.

True Nature: Revising Ideas On What is Pristine and Wild

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disneyland-timeshare
I thought this was interesting, as it came across my screen right after our discussions of “ecological integrity” in the new planning rule. My hypothesis is that every twenty years or so the same “truths” are rediscovered..because the shifting and fragmenting nature of disciplines leaves scientists unfamiliar with previous thought on the same topic.

So here’s an article in Yale Environment 360. It fascinates me that this is reported as if Dan Botkin (yes, the same who spent time at Yale Forestry School) said much the same in his book Discordant Harmonies in 1992 (over 20 years ago). The use of the idea of “museum exhibit” reminded me of this paper by Connie Millar and Bill Libby in Fremontia in 1989, when they used the more colorful term “Disneyland”. Due to my disciplinary loyalty, the photo above is of Disneyland and not a museum.

Given the discussion we’ve just had about “ecological integrity,” here’s an interesting excerpt:

For instance, it calls into question the conventional view that ecosystems such as rainforests are complex machines, or super-organisms, that have emerged through a long process of co-evolution of species to fill ecological niches. But, if that is so, asks ecologist James Rosindell of Imperial College London, how come alien species are so good at invading other ecosystems, frequently becoming fully integrated neighbors?

Ecosystems begin to look a lot more accidental, random, and transient than niche theory would suggest. They are constantly being remade by fire and flood, disease, and the arrival of new species. They are a hodgepodge of native and alien species. This fits a rival model for how ecosystems work called “ecological fitting,” first articulated by the legendary U.S. ecologist Daniel Janzen of the University of Pennsylvania. He said that co-evolution is a bit-part player in ecosystems; most of the time, species muddle along and fit in as best they can.

Far from reaching some equilibrium state with niches filled, ecosystems have always been in a constant state of flux, says Stephen Jackson, of the Southwest Climate Science Center in Arizona, in Novel Ecosystems. “Change, including rapid and disruptive change, is a natural feature of the world.” Humans may have dramatically speeded that up, but novelty is the norm.

In that light, we need to look afresh at conservation priorities. Novel ecosystems cannot be dismissed as degraded versions of proper ecosystems, nor can alien species be demonized simply for not belonging. If novelty and change is the norm, Hobbs and colleagues ask, does it make sense for the growing business of ecosystem restoration to try and recreate static historic ecosystems? By doing that, you are not creating a functioning ecosystem; you are creating a museum exhibit that will require constant attention if it is to survive.

Gee, I said the same thing.. 😉 But of course those folks and I did not redefine “restoration.” Also, Pearce keeps using “virgin” inappropriately, in my view, as per my post in HCN here.

“Sustainable Recreation”: USDA /Forest Service Bites the Hand that Feeds Them?

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road_closed_wide470

First, let’s go back to the Mike Dombeck quote I cited previously from this article in Forest History:

The most enduring and powerful maxim of business is that “money flows to things people want.” People want their cultural heritage protected, clean air and water, healthy forests and rangelands, good hunting and fishing, sustainable supplies of timber and forage, etc.

Actually, Mike’s only listing of recreation was hunting and fishing on this list, but recreation is clearly the #1 use of the national forests by people of the U.S. (and other countries).

Friday, I reviewed the history of the sustainability concept in various planning rules. In the 2012, a new concept hit the street. This is “sustainable recreation”. I know all of you who are specific and careful about words are wondering “what’s up with that?” doesn’t everything have to be sustainable? Why single out recreation to be called “sustainable recreation” every time?

Well, it’s not really clear but I guess it’s because there is an internal strategy/framework about “sustainable recreation.” Here is a link to a document about the strategy from 2010. The strategy is an easy read, and makes a great deal of sense. I thought it was well done, even though I’m not usually a fan of “strategies.” I didn’t find anything particularly novel, although I’d be interested in what readers of this blog think.

However, I wonder about the “sustainability” (ink, paper, electrons) of adding an extra word (sustainable) every time you write about one of the multiple uses in a regulation when it’s already required to be sustainable.

So let’s see how it is talked about in the 2012 Rule.

The final rule provides direction for sustainable recreation throughout the planning process. The final rule retains the term ‘‘sustainable recreation’’ to recognize that planning should identify, evaluate, and provide a set of recreational settings, opportunities and access for a range of uses, recognizing the need for that set to be sustainable over time.

Again, everything has to be sustainable so…??

Ah so now we encounter the Directives, let’s look at BRC’s comments:

E. The draft Handbook at 23.22b – “Sustainable Recreation Resources” and “Opportunities to Connect People with Nature” Does Not Properly Track the Rule

The draft Handbook inappropriately modifies the definition of Sustainable Recreation. Again, the Handbook contradicts the Rule, and whether intentionally or otherwise sets up the agency to fail the newly-configured duty to provide “sustainable recreation.” The Rule states: Sustainable recreation. The set of recreation settings and opportunities on the National Forest System that is ecologically, economically, and socially sustainable for present and future generations.
(36 CFR 219.19)

The draft Handbook modifies this definition here:
Plan components must provide for sustainable recreational settings, opportunities, and access. Sustainable recreation opportunities and settings are those that are economically, socially, and ecologically sustainable for the future. To be sustainable, the set of recreational settings and opportunities must be within the fiscal capability of the planning unit, be designed to address potential user conflicts among recreationists, and be compatible with other plan components including those components that provide for ecological sustainability.
(Chapter 20 at 23.22b Page 80 underline emphasis added) I

Ironically, the Rule’s definition of “sustainable” recreation troubled agency recreation staff, who proposed changes to the definition that they feared would “set the bar too high.” See email correspondence dated Oct. 13, 2011 (AR 0125036-0125039). The draft Handbook not only ignores but builds on these fears, again with the effect of creating an unnecessarily high burden.

Most, if not all, USFS Programs are not adequately funded. Indeed, the shortfall in the roads maintenance budget, and the trail maintenance backlog for trails in designated Wilderness, is well documented. The language here raises the concern that the agency may attempt to rely on lack of funding as an excuse for lack of effort and creativity in comprehensive recreational planning and motorized recreational travel planning specifically.

That’s the BRC point of view.. my point of view is … let’s call things as they are and not redefine commonly used expressions like sustainable, (or restoration, for that matter) to mean something different. It seems like you are trying to put something over on the public rather than clarifying your intentions and being transparent.

If the FS means ” there’s a great many multiple uses, but only recreation will be subject to the “fiscal capacity” test. I wouldn’t call that “sustainable” because it doesn’t have the same meaning as other uses of the term. I would call it “fiscally prudent” recreation approach. Other proposed terms are welcome in the comments. In English, are they thinking:

We fully recognize that recreation is the most popular to the citizens of the US who provide this funding. We also value our partnerships, volunteers and other ways (outlined in the Sustainable Recreation Framework).

But we are holding recreation to a higher standard than any other use, because ______.

I’m trying to understand how they would fill in the blank.

It seems to send a message “we’re not so sure we want you recreationists out there, despite all the partnerships and volunteering” which could ultimately be a funding death spiral. Not enough money, we’ll kick you out, you won’t want to fund the FS, therefore fewer people and shoddier facilities, so more will be kicked out..

As Mike Dombeck said above, “money flows to things people want.”

Or perhaps recreationists aren’t organized enough across the motorized and non-motorized spectra to resist, as oil and gas, timber or ranching might be, so they are an easy target for integrity- promotion? Or maybe it just sounded like a good idea to someone and was stuck in the directives randomly?

Maybe someone can shed some light on this.

The Incredible World of Sustainability Definitions in Planning Rules

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2000 rule 2

I want to talk about “Sustainable Recreation” in the planning directives. But first we need to lay the groundwork, so we need to go back to the Rule. Clearly everything has to be (plans must promote) sustainable, as in every rule since the 2000.

Sustainability is defined in the 2012 Rule as:

Sustainability. The capability to meet the needs of the present generation without compromising the ability of future generations to meet their needs. For purposes of this part, ‘‘ecological sustainability’’ refers to the capability of ecosystems to maintain ecological integrity; ‘‘economic sustainability’’ refers to the capability of society to produce and consume or otherwise benefit from goods and services including contributions to jobs and market and nonmarket benefits; and ‘‘social sustainability’’ refers to the capability of society to support the network of relationships, traditions, culture, and activities that connect people to the land and to one another, and support vibrant communities.

One might wonder.. gosh, the concept of sustainability has been around for a long time (since the Brundtland report).. how did EI get into the definition?

So you might ask, how did they define ecological sustainability in 2005?

(b) Sustaining ecological systems. The overall goal of the ecological element of sustainability is to provide a framework to contribute to sustaining native ecological systems by providing ecological conditions to support diversity of native plant and animal species in the plan area. This will satisfy the statutory requirement to provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives (16 U.S.C. 1604(g)(3)(B)).

So we went from diversity of native plants and animals, to “its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity).” I have called it “everything” before, because I can’t think of anything that isn’t covered, being within NRV AND resilient.

I use the ticks standard.. could lawyers argue that a project changes the compositions of species of ticks on elk (or the genetic composition of species of ticks on elk, or viruses..) ? And we see “no” in 2005, and yes in 2012. Because ticks are not plants or animals.

But in 2012, you would have to know what the species composition was during the reference period. Except like so many things, you never could know. Maybe we need historic tick ecologists and modelers? You may say, that’s silly. But it’s composition, which is listed as a “dominant ecological characteristic.”

So what does the 2000 Rule say (remember the COS gave input on that rule, and thus the Sedjo discussion and point of view, we described previously here)?

So I looked at 2000

Similarly, the Forest Service and scientific community have developed the concepts of ecosystem management and adaptive management. Scientific advances and improved ecological understanding support an approach under which forests and rasslands are managed as ecosystems rather than focusing solely on single species or commodity output. Indeed, ecosystem management places greater emphasis on assessing and managing broad landscapes and sustaining ecological processes. Ecosystem management
focuses on the cumulative effects of activities over time and over larger parts of the landscape. Planning and management under ecosystem management also acknowledge the dynamic nature of ecological systems, the significance of natural processes, and the uncertainty and inherent variability of natural systems.
Ecosystem management calls for more effective monitoring of management actions and their effects to facilitate adaptive management, which encourages changes in management emphasis and direction as new, scientific information is developed. In accord with ecosystem management, regional ecosystem assessments have become the foundation for more comprehensive planning, sometimes involving multiple forests and other public land management units. The Northwest Forest Plan, for example, affects 17 national forests and 6 BLM districts in a three-state region. The Interior Columbia Basin Ecosystem Project encompasses 25 percent of the entire National Forest System and ten percent of the public lands administered by the BLM nationwide.

(As an aside, our appetite for these giant projects seems to have dissipated in the last 13 years. Does this have to do with the apparent lack of capacity to do any adaptation? Why is that? Would like to hear opinions of folks experiences with NW Forest Plan and ICBEP).

And what was ecological sustainability then?

Ecological sustainability: The maintenance or restoration of the composition, structure, and processes of ecosystems including the diversity of plant and animal communities and the productive capacity of ecological systems.

Hmm.
2001
Maintenance OR restoration of composition, structure and processes.

2012
Capability of ecosystems to maintain ecological integrity

Which is, again:
The quality or condition of an ecosystem when its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity) occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

So if we use my ticks example, under the 2000 Rule, we would be able to argue that our project was not changing (maintaining) the same tick species as on the current elk.

According to 2012, though, we would have to figure out what the reference period was and see if our project “promoted” the species composition which occurred during the “reference period.” Unless I’m missing something?

What on Earth have we gotten ourselves into?

For those who claim that this is all “science” take a gander at SY_CallicottMumford1997paper (which you can get for free through this link, but not from Wiley..)

Ideas that scientists and philosophers exchange about the world and how things should be are not “science” in the sense of hypotheses that can be verified. This paper also brings up another normative science idea, health, but lends an interesting view of how the different disciplines see what’s important (I’ll give you a hint, it’s what they spend their time studying ;))

I tried to copy out the salient paragraphs but it doesn’t let me, nor could I extract the page. Check out the left hand column on page 37. Note that this discussion is clearly normative, and argues that “ecosystem health” is good for managed landscapes(sustainable) and “ecosystem integrity” for preserves. Just to be clear, I think it’s fine for academic philosophers and scientists of all stripes to talk about concepts…but putting vague normative science ones into regulation is quite questionable. Indeed, then stating that it is “science” to value the “reference period” is pretty clearly.. well.. not “science”, despite the fact that some scientists espouse it.

Potential for Collapse of Forest Ecosystems

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A guest post from Kevin Matthews:

A substantial body of science shows a general pattern, that when the ecological integrity of a natural ecosystem is degraded, its response curve is non-linear. The state that occurs when the response curve becomes non-linear, such that small additional impacts result in large losses of ecosystem integrity, is sometimes referred to as ecosystem collapse.

One of the scientific bases for why ecosystem collapse tends to catch humans by surprise is pretty interesting with regard to the O&C checkerboard forest lands of western Oregon.

Natural ecosystems tend to be very resilient, accommodating heavy damage and still recovering, up to typically somewhere between 50% and 90% damage. This lulls humans into complacency, to the sense that they can keep taking, and the ecosystem will keep recovering.

Then, somewhere in the range of substantial alteration of from 50% and 90% of habitat area, ecosystem resiliency breaks down. A threshold gets crossed, where things fall apart fast and hard. And in a relatively short time frame, the habitat is changed (loss of soil, hydrology, key species, whatever) so the ecosystem no longer has a viable path to recovery.

The point of collapse is hard to predict because the system responses go rapidly non-linear. Past rates of recovery, however well-researched, become almost instantly irrelevant.

A rough, understated estimate would be that the overall O&C checkerboard is already at 75-80% substantial impact, based on close to 100% impact to the industrial part, and optimistically 60% impact to the BLM part. (Looking just at old growth remnants, 90% or more impacted would be defensible.)

Add in the ongoing impacts due to climate change, and there’s a strong basis to believe the checkerboard forests are hanging on the edge of serious collapse.

Interestingly, much same thing is true for ecosystems overall, viewed at the global scale:
http://arch.designcommunity.com/viewtopic.php?f=22&t=37314

Habitats incorporating giant trees were endemic across the well-watered areas of what is now the U.S., from the Appalachians to the Great Plains, from the Carolinas to Maine to Minnesota. After a few centuries of western expansion, all that remains of those great tree forests is a thin fringe along the western edge of the continent. And this thin fringe is critically endangered.

Time to change our ways.

If we were ecologically realistic, given the heavy impacts on western Oregon forests to date, in order to avoid collapse we might want to plan for significant disturbance to not more than 25% of the checkerboard lands, and that, only in lands heavily disturbed already.

Key questions then would be, how could we make a sustainable level of harvest, contained by that threshold, work for the economics of rural communities? Could we continue needed building construction with the resulting output of sawlogs? Could we maintain a timber culture that we would all be proud of?

Recent calls by Senators and other politicians to increase logging, without addressing these broader and deeper issues, are fundamentally misinformed.
http://www.tester.senate.gov/?p=press_release&id=2883

I’d like to see all sides work together in seeking a true balance, based on clear evidence, for forest policy in this new century.

Warning: Fuzzy Concept in Regulation- “Ecological Integrity”- IV- After the “AND”

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times arrow

Fortunately for everyone this will be my last post on the concept of “Ecological Integrity”as described in the NFMA Rule. Perhaps unfortunately, not my last post on the planning directives. Other guest posts on the directives are welcome. Wading through the directives was a lonely business, and thanks much to the others on this blog who suffered and shared.

So let’s return to the definition in the regulation of “ecological integrity”:

“The quality or condition of an ecosystem when its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity) occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

We have discussed the first part in previous posts, here, here and here… now let’s look at after the “and”:
“can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

Well, that sounds like a good idea. But what “can withstand and recover”? It appears to be the “dominant ecological characteristics” composition, structure and function, species composition and diversity”. That sounds like “everything you can possibly think of.” So everything would have to go back to being the same as it was prior to “most” perturbations. And how is that?

Natural range of variation (NRV). Spatial and temporal variation in ecosystem characteristics under historic disturbance regimes during a reference period. The reference period considered should be sufficiently long to include the full range of variation produced by dominant natural disturbance regimes, often several centuries, for such disturbances as fire and flooding and should also include short-term variation and cycles in climate. “Natural range of variation” (NRV) is a term used synonymously with historic range of variation or range of natural variation. The NRV is a tool for assessing ecological integrity, and does not necessarily constitute a management target or desired condition. The NRV can help identify key structural, functional, compositional, and connectivity characteristics, for which plan components may be important for either maintenance or restoration of such ecological conditions.

But how do we know if something (er.. everything) will “withstand and recover from “most” perturbations?” Who gets to decide what “most” is?

While I thought that the 2000 rule was a full employment program for fire ecologists and historic vegetation ecologists.. this sounds like a full employment program for lawyers and modelers, as well as the fire ecologists and historic vegetation ecologists. I wonder who was sitting around the table or on the phone when this rule was developed, and if there is some correlation between the disciplines of those folks and the disciplines advantaged by this language ;)?

If we agree that climate change is unprecedented, then with climate change, the past cannot be a predictor of the future.. so we don’t really have any information, not do we have any predictive capability other than modeling. Of course, our climate models are not particularly accurate at the scales we are interested in, and humans are constantly not doing what we assumed they would do when we ran the scenarios in the models.

But for me, all this is a distraction from dealing with real environmental problems of today (dirt in streams, invasive species) and acknowledging that time’s arrow only goes one way. Yet this rule and its directives have us spending time digging up the past (sorry, Bob) and modeling the unmodelable. We simply have no clue about the future at the detail required in this rule.

Before climate change, we used to hear a lot the paraphrase of Haldane “ecosystems are more complex than we think, they are more complex than we can think,” with the sense that we needed to preserve species. Which is fine. But if in fact they are that complex, then what are we doing depending on models over observations today in a regulation?

It’s clear that it is not really about “science”. I like to go back to Michael O’Connell’s warning of 1999 in his testimony here (my italics).

Ecosystems are more complex than we think. There are many complexities at all levels of biological organization that cannot be measured, perceived, or even conceived of, that directly affect the viability of conservation solutions. Science can never provide all the answers to questions about conservation, so the response should be to exercise both caution and prudence when designing answers. Wise solutions don’t necessarily try to compensate for factors that cannot be defined, but at the same time they leave room for them. A good example of this is true adaptive management, where the results of ongoing monitoring are used to adjust the conservation program based on new information and changes in circumstance.

Nature is full of surprises. Ecological systems are characterized by non-linear, non-equilibrium and often seemingly random dynamics. Both unexpected events and unanticipated consequences affect the long term viability of any conservation solution. This uncertainty is a given, and its runs directly counter to the political, social and economic desire for predictability in the outcome of conservation plans. It is better to be forthright in acknowledging that the issue of “no surprises” is not a scientific question of predicting the future, but instead a social question of how to deal with those surprises.
Conservation planning is interdisciplinary, but science is the foundation. Creating a long-term solution for species and the ecosystems on which they depend is a complicated exercise in reconciling social, political, legal, economic and biological factors. But if science must be one of several competing interests in the negotiation instead of the method of evaluating how to reach specified objectives, then conservation outcomes will always be undermined. This raises the critical issue of how to integrate both scientific information and scientists themselves into the planning process.

So let’s take a real world example.. say a ski area. Does having an area suitable for skiing “promote ecological integrity” ? Well, a ski area would be outside the RNV, so that’s out, so we don’t have to go to perturbation. So are we expecting that the next White River Plan revision will be litigated for having ski area suitability and thereby not promoting integrity?

So let’s move on to resilience.. say the climate is warming and drying. You want to thin some ponderosa pine trees so they have enough water to stay healthy and do some fuel reduction. A lower basal area (than in the past historical period you picked for NRV) would be better in terms of resilience to “perturbations” . But as far as the historians tell you, that is not in NRV. So the two requirements for “ecological integrity”, NRV and resilience, could actually be in conflict. (aside: picking a reference period can’t really be “scientific” so this idea of NRV seems like “science” but isn’t really). As in you can have one or the other, but not both.

My question is “are we way overthinking this?” WTH is this doing in a regulation and thereafter in the court system?

Here’s what Mike Dombeck said: just plain English and inspiring. Have we changed so much since he said this? Here’s the link, the whole thing is worth a read.

My expectation is that everything we do—every environmental impact statement we write, every timber sale, recreation plan, mining plan, or allotment management plan we approve—will not compromise the health of the land. I want to make it very clear that no Forest Service program has dominance over another. Timber is not more important than wildlife and fisheries. Nor is wildlife and fisheries more important than timber or recreation, or cultural resources, and so on.

So what happened between Mike’s term and now? Have we really changed this intention (no one is more important than the other), or are we so wrapped around the axle of fuzzy words that we can’t even tell what we mean? Are we adrift in a sea of legal hooks?

Planning Rule Directives Comments- New 15 Day Comment Period

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I picked this up from the Teton Valley news here.

If you thought the 400 pages or more of directives were too daunting to review (and who didn’t, really?), you can now get pointed in a direction to check out certain parts, by the other comments in the reading room here...

I tried to check out Bill Imbergamo’s comments and it said that they were being checked for offensive content.. so you may not be able to see all of them. Or maybe it was just my computer?

I will also post on a few things on this blog, in addition to my ecological integrity posts, here here and here.

Warning: Fuzzy Concept in Regulation- “Ecological Integrity”- III- Deja Vu From 2000

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Thinking about the ecological integrity and NRV reminded me of my comments on the 2000 (yes!) planning rule. (Aren’t computer searches grand!)

Caveat: at this time of my career, I had not worked in planning or NEPA. Also I was working at OSTP at the White House when the 2000 rule was clearing, and OMB folks had some real concerns about the costs of doing the 2000 (I might have spoken with them to help clarify their concerns, but ultimately they were clearly told to stop being concerned).

Some have argued that this one (2012) has even more requirements for analysis and will hence be more expensive and time-consuming (despite intentions) than the 2000. I thought I had said that the pursuit of HRV seemed to be a “full employment program for historic vegetation ecologists”, but maybe not in this set of comments.

Here is a link to my comments.

Below are a couple of paragraphs..

4. Clear Conceptual Foundation

One of the basic concepts of land management is that while doing an activity anywhere (building a campground, using a road, fishing, cutting firewood, harvesting mushrooms) has some impact on the environment, there is a point at which the resource is being damaged, and at that level, the activity is not sustainable. Better scientific information tells us the many impacts of each activity and possible negative consequences. But somehow, someone has to draw the line between the social good of recreating, mushrooms or firewood, and potential damage to the resource that might result. Whether you call this sustainability, or something else, this is the same concept as what has been in place throughout the history of the FS. Our knowledge of effects is more sophisticated today, and the political climate is different than the heyday of timber management, but the concepts are the same. Balancing (a moving target, as conditions change) can occur through decisions at the national level (no OHV’s on national forests, for example) but in most cases, the actual effects of what people do vary by site, by elevation, by soil and by a host of other factors that cannot be summarized on a national level. That is why the local people and communities have an important role in determining that balance. If, on the other hand, like the FS’s sister agency the Park Service, the presumption is that people’s activities are generally negative and are to be kept to a minimum, then local knowledge and input is not as important. If Congress chooses the resource management philosophy, then special attention needs to be given to ensuring that local people’s balances are not overridden by outsiders, however well-intentioned, who are not familiar with the local situation. This is Congress’s prerogative, however, and not the FS’s choice to make. The tension between local and national interests is another real-life situation that must be considered in the design of the process. Like the role of an expert in a democracy, these are ongoing tensions in governance of this country, and natural resource management should acknowledge and reflect the legitimacy of these tensions.

One can read the whole history of “ecological sustainability”, “ecological integrity” and “range of historic variation” as a target, to reframe the debate so that scientists become the experts on what should be done. This gets away from the messy conflicts over policies, such as who wins and who loses. This does not build trust. “I don’t like OHV’s because they disrupt a species of wildlife on this watershed” is meaningful. “Roads disrupt ecological integrity” does not pack informational content and in effect obfuscates the terms of the tradeoffs or balancing of interests.

If “ecological sustainability” and pre-European North America are the targets, then the planning questions are “how quickly can we afford to shut down existing roads and campgrounds, and can we afford the law enforcement to lock people out of the NF’s? “ We will ignore fire threats and fuel buildup close to adjacent landowners because there were lots of massive fires prior to European settlement (although there were not enclaves of million dollar homes). Clearly then, there are parameters within which pre-European will guide FS thinking and others where it will not. No where is it clear in exactly what kinds of decisions the authors of the document think that this criterion will be relevant.

If the FS is to reestablish trust, I think a few things need to be in the regs and the regs are an important place to carry this out. First, the concepts, steps in the process, and decision space itself need to be so clear that any FS employee can explain them to any member of the public. Anyplace where ecological science expressions such as “functioning of ecosystems” occurs in the text, it needs to be translated so that the non-technical public can understand it. Everyone knows we’re not reintroducing grizzlies to the central Sierra, or closing ski areas, or replacing all exotic grasses with natives, so clearly there are distinctions and priorities. There is no reason they can’t be clearly stated, e.g. “water quality and quantity is #1 priority and while there were massive fires and sediment flows within the range of historic variation, we acknowledge that these levels of sediment are not desirable today.”