2012 Planning Rule

So what is this “ecosystem integrity” that we are now requiring in the 2012 Planning Rule?

Just looking at it, we see the word “ecosystem” with a value word “integrity”. Could this be an expression of what Bob Lackey calls “normative science”? Sure enough, several papers have been written critiquing the concept. You can do the experiment yourself, just go to Google Scholar and search on ( “ecosystem integrity” critique) . Note: I am going to equate “ecological” and “ecosystem” integrity since they seem to be the same to most authors.

One paper I found is DeLeo and Levin (italics mine) 1997. Here’s the link

Pressure for adequate answers creates a need to devise conceptual tools, such as ecological integrity, to help scientists and resource mangers grasp the complexity of biological systems (Bernstein and Goldfarb 1995). The concept of integrity is far from a panacea for any management problem. Its definition simply reflects the capability of ecosystems, however defined, to support services, including pure aesthetics, that humans value. Ecosystem integrity is not an absolute, monolithic concept, but a multidimensional, scale- dependent abstraction; there is no unequivocal way to apply it in decision making. Measures of integrity must recognize the importance of maintaining processes that support those critical services.

What are the practical implications of these discussions? How should a manager implement notions of ecosystem integrity? The first step is to recognize that this is not the domain of the manager or of the scientist alone. Integrity reflects the ability of ecosystems to sustain services to humans, and the identification of those services can best emerge from multisector partnerships, in which all stakeholders seek agreement on the uses to which an ecosystem will be put, recognizing the linkages with other ecosystems. From such agreement on uses can come the identification of a set of measures that represent the status and trends of those services. A basic research question then arises: how to characterize the relationship between structural features of ecosystems (such as biodiversity or trophic linkages) and measures of functioning? This is an inchoate and nascent area of investigation, but one that holds tremendous potential for advancing the science of management (Daily 1997, Levin 1997, Levin and Ehrlich 1997).

Hmm. The people studying it say “there’s no unequivocal way to apply it”. Should we intentionally put it into a regulation? Isn’t this handing a court a can of worms? If it’s too difficult for us resource folks to figure out, do we just give our “inchoate” ideas to judges? I wonder whom this approach empowers and whom it disempowers.

Someone who has published often on natural resource disputes and science, Bob Lackey, has this to say in his “Seven Pillars of Ecosystem Management” here .

The terms ecological health and ecological integrity are widely used in scientific and political lexicon (Rapport, 1989; Costanza, et al., 1992; Norton, 1992; Grumbine, 1994). Politicians and many political advocates widely argue for managing ecosystems to achieve a “healthy” state or to maintain ecological “integrity.” By implication their opponents are relegated to managing for “sick” ecosystems.
Scientists often speak and write about monitoring the health of ecosystems, or perhaps the integrity of the ecosystem. There is usually the assumption that there is an intrinsic state of health or integrity and other, lesser states of health or integrity for any given ecosystem (Norton, 1992). Some scientists explicitly advocate ” . . . that maintaining ecosystem integrity should take precedence over any other management goal” (Grumbine, 1994).

Much of the general public seems to accept that there must be a technically defined healthy state similar to their personal human health. After all, people know how they feel when they are sick, and so, by extension, ecosystem sickness must be a similar condition, which should be avoided. “Health” is a powerful metaphor in the world of competing policy alternatives.

For example, society may wish to manage a watershed to maximize opportunities for viewing the greatest possible diversity of birds, for the greatest sustained yield of timber, or for the greatest sustained yield of agricultural products. Achieving each goal would almost assuredly result in ecosystems that were very different, but equally “healthy.”
The debate is really over defining the “desired” state of the ecosystem, and secondarily, managing the ecosystem to achieve the desired state. Phrased another way: What kind of garden does society want (Regier, 1993)? There is no intrinsic definition of health without a benchmark of the desired condition. In ecosystem management, scientists should avoid value-laden terms such as “degradation, sick, destroy, safe, exploitation, collapse, and crisis” unless they are accompanied with an explicit definition of what the desired condition of the ecosystem is as defined by society. The word “society,” as used here, includes only humans.
In philosophical terms, the problem with “health” is how one links “is” and “ought.” For example, an ecosystem has certain characteristics — these are facts on which all analysts who study the ecosystem should be able to agree. Characteristics such as species diversity, productivity, and carbon cycling are examples. If the same definitions and the same methods are used, all analysts should come to the same answer within the range of system and analytical variability. The “ought” must involve human judgement — it cannot be determined by scientific or technical analysis (Shrader-Frechette and McCoy, 1993). The concept of “health” has a compelling appeal, but it has no operational meaning unless it is defined in terms of the desired state of the ecosystem.

Again, the 2012 Planning Rule says that “plans should promote ecological integrity”, yet we learn from the literature that “ecological integrity” is a flawed concept.

So,we might ask, how does the planning rule define ecological integrity?
We find it in 219.19

“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.”

I couldn’t find “natural range of variation” in the rule, which seems odd because plans need to promote integrity, you tell if something has integrity because it’s within NRV.. so NRV becomes pretty crucial.

Conveniently, it is now defined in the Directives, in the Zero code chapter.

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.

OK, so let’s get the logic here.
Plans are required to “promote” ecosystem integrity in a regulation.
Ecosystem integrity is defined in the regulation as equal to (dominant characteristics within NRV) AND (resilient to disturbance)
Yet, being with NRV is “not a target”. But based on these definitions you can’t have EI without being within NRV. And EI is a target. If I (integrity) is a target and I= (NRV) AND (Resilience) then isn’t NRV also a target implicitly?

If I want cookies that have nuts AND chocolate chips, then aren’t I saying that they need to have nuts?

It makes my few remaining (after trying to read the directives) neurons melt. But as during the COS debate on whether ecological sustainability should be “primary”, I still don’t understand what it means in practice. During the selected historic period, you may not have had roads on the Angeles NF; you didn’t have jet aircraft flying over Weminuche Wilderness. So we just start deleting activities until we get to those of some chosen “historic period?” Is this what the public wants from its public lands?

Plus now we have climate change, so in many cases returning to HRV with any distribution of any species may be impossible. Why would we want to put into regulation impossible implicit or explicit targets?

It’s interesting that in procrastinating on working on reviewing the Planning Directives, I found and posted MUSYA. Let me quote it again here:

‘‘Multiple use’’ means: The management of all the various renewable surface resources of the national forests so that they are utilized in the combination that will best meet the needs of the American people; making the most judicious use of the land for some or all of these resources or related services over areas large enough to provide sufficient latitude for periodic adjustments in use to conform to changing needs and conditions; that some land will be used for less than all of the resources; and harmonious and coordinated management of the various resources, each with the other, without impairment of the productivity of the land, with consideration being given to the relative values of the various resources, and not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output.
(b) ‘‘Sustained yield of the several products and services’’means the achievement and maintenance in perpetuity of a high-level annual or regular periodic output of the various renewable resources of the national forests without impairment of the productivity of the land.

This seems to be what Congress intended the purpose of the national forests to be. So far, they seem to have added other environmental laws (which as Andy says, are not in conflict) so we would think that the primary purpose still stands.

Well, in the 2012 planning regulations, section 219.1 b states that it is consistent with MUSYA, and then 219.1 c says that “the purpose of this part is to “guide the …land management plans that promote the ecological integrity of national forests and grasslands.” It goes on to say that lands will be managed to be “ecologically sustainable” and “contribute to” social and economic sustainability.

So it seems like we have made a regulation for implementing NFMA, that at first, seems contrary to MUSYA.

Here’s MUSYA “harmonious and coordinated management of the various resources, each with the
other, without impairment of the productivity of the land”

whereas in the new NFMA regulation the goal is to “promote the ecological integrity” and “ecological sustainability” is first and no “harmonious coordination” seems to be required.

So, for those of you who didn’t follow the Committee of Scientist dynamics.. remember Roger Sedjo, of Resources for the Future said this..in his dissent from the COS report in 1998 (15 years ago and the discussion seems to be .. rather .. stuck). Here’s the link.. worth taking a look at.

I believe that the Report recommends measures, specifically the preeminence of an ecological sustainability focus together with the stringent viability regulations, that would have the effect of having the National Forest System operating primarily as a biological reserve. These recommendations go well beyond the Secretary’s charge to the Committee, which “is to provide scientific and technical advice to the Secretary of Agriculture and to the Chief of the Forest Service on improvements that can be made in the National Forest System Land and Resource Management planning process” and that this be done “within the established framework of environmental laws and within the statutory mission of the Forest Service.” The Report, however, recommends what is clearly a new mission for the FS that is in conflict with much of the statutory mission of the FS.

In selecting the new mission the Report uses definitions of sustainability that are considerably more narrow than those commonly used, and indeed more narrow than those used by the US Government in its international negotiations on sustainable forestry in the Montreal Process and Santiago Declaration. Furthermore, the Report justifies the new sustainability mission for the FS with assertions to the effect that the NFS is in jeopardy, but these assertions are not supported by evidence. In fact, evidence available strongly supports the view that forest sustainability is not in jeopardy, generally, although area specific problems do exist.

Additionally, most fundamental defects in the forest planning process cannot be corrected by the changes recommended in this Report. The Report recognizes the difficulties of meaningful implementation of planning without a basic reform to allow the budget and planning processes to operate in concert. Additionally, under the current planning system problems are exacerbated by frequent disruptions of planning via administrative orders from above, which often render the process meaningless. Also, the Report acknowledges, but does little to address, the problem of endless appeals that has plagued the forest plans and the planning process. Without these and other fundamental reforms, the changes recommended in the planning process are unlikely to alleviate most of the more serious problems experienced with forest planning.

Well, I’ve run out of room. Tomorrow we’ll discuss the “ecological integrity” definition in the rule and how it’s carried forward into the directives.

Thanks to a nice Forest Service person, I found out about this meeting in a few weeks. Is anyone from this blog planning to attend, and possibly do some reporting on what happens?

Here’s the agenda>.

Here’s the Federal Register notice.

One thing that I’ve noticed since I retired is that when I got paid (even though I did most reading in the evenings and did not mark “Free Time” on my timesheet.. True Confessions!) to do certain things, I didn’t mind donating my time to write about them on a blog.

I have to admit that the idea of “reviewing the planning directives” was not something I would have done, were it not for another volunteer responsibility (other than this blog). I don’t know what I could possibly have done in a past life that the karmic payback was to have to have read three sets of NFMA planning directives in my life (and sets of regulations, but they are shorter).

So my next step was to figure out “is there anything specific that they want comments on?” Calling and emailing the Forest Service, I got the answer “look at all of it.” Which seemed odd because for the objections rule, there were specific questions that helped focus our comments, and that rule was much shorter. I even asked Ray Vaughan, the chair of the FACA Committee, and he said “look at all of it.”

So my next idea was “some people get paid to read them, let’s look through their comments for pages and ideas of particular interest.” The problem with this approach is that people tend to wait until the last minute to turn theirs in.

So it looks like I will have to read the whole thing.. I’m asking people on this blog to take a look and comment with any feedback.

Here are my principles.. I’d be interested to know what you think about those:

1) Do you really need directives? Right now forests are working using the new planning rule. I would like to hear from them, where and why they think directives will help them.

2) Shorter is better. If you have a list of 10 things to do versus 200, you are more likely to accomplish the 10, it seems to me. Plus the environmental impact of potentially printing the extra pages.

3) There shouldn’t be concepts that are “normative science” like ecosystem health or integrity or…
Now this might be a problem because those were put in the Rule. So it’s like tilting at windmills. However, some windmills really deserve to be tilted at.

4) People can get carried away with assessing to the point of silliness, given the few things that can actually be manipulated on a forest. What’s in the directives to prevent this from happening?

What do you think of these? What others would you add?

We have discussed making public discussion about projects amenable to people who have other jobs.. not so sure reviewing the planning directives fits in with this..

Also for those of us who don’t remember what the old ones said, it’s hard to figure out how to comment on important changes to the old ones. Some have estimated there are 600 pages.. I guess I’ll find out. Any help would be greatly appreciated!

Here’s the link.

The Planning Rule FACA Committee meets next week in Albuquerque and is open to the public. You’ll remember that the need for a committee was discussed years ago during the development of the rule here.

Here’s a link. It would be interesting if someone who is going to be there would post their impressions here.

Here’s a news story that says anyone is allowed to submit their comments in writing.

Here’s a link to the page, and here’s the agenda.

It would be nice (in my opinion) if the meetings were webcast, and when they take public comment, they could take it from outside the area where they are meeting through Skype or even the telephone.