Accountability

From Forest Planning to Adaptive Governance

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“If planning is everything, maybe it’s nothing.” Aaron Wildavsky

[Author’s note: This is a lengthy (for a blog), partisan, historical view rant on the road from NFMA “forest planning” to “adaptive governance.”]

Let’s face it, the “forest land and resource management plan” is an anachronism—an artifact of a bygone era. That era was in its heyday when the Office of Management and Budget (OMB) reigned supreme after President Richard M. Nixon consolidated rule-making and other powers in the OMB via executive order in 1970. Economics-based, comprehensive rational planning was the rage. It is no surprise that The Renewable Resources Planning Act was passed in 1974, just after Nixon consolidated power under the banner of rationally planned and carefully audited governmental process. Twenty years later Henry Mintzberg penned The Rise and Fall of Strategic Planning (1994). Mintzerberg’s classic pretty much laid a tombstone atop rational planning exercises. Or at least it should have.

The Forest Planning Era
Following passage of the National Forest Management Act of 1976 as an amendment to the Renewable Resources Planning Act of 1974, it was thought that forest program management decisions could be adequately fit into a forest plan “decision container”—that somehow each forest could develop a forest-wide plan that would integrate programs now and into the future in a such a way as to allow disclosure of environmental consequences that might flow from said decisions. Project level National Environmental Policy Act (NEPA) disclosure would disappear with proper forest planning and environmental disclosure at the forest level.

Allowance was made for FS administrative region plans, and for a national RPA Program plan. Given the upper two tiers, it was believed that decisions would be integrated vertically, and cumulative effects—according to NEPA standards—could be adequately disclosed.

It was a relatively innocent era, when viewed through the “green-eyeshaded accounting lenses” of OMB over-see-ers. The innocence collapsed relative soon in the forest arena as litigation proved that the three-level administratively-bounded review was not going to pass muster in the courts. Not only were projects not going to be shielded from NEPA review by a forest plan, there was increasing evidence that at least one level of planning/disclosure might be needed between project and forest.

An initial remedy to the seemingly endless process gridlock brought about by too many levels of planning was to eliminate regional plans. I referred to this then as the Texas two-step solution (forests/projects), since at that time the Forest Service’s National Planning Director was from Texas. But that was a solution looking for a problem, or better still a “non solution” not looking for anything but an easy way out. The problem between forest and project remained. Another problem was to be found elsewhere, framed larger than forest plans but not fitting into regional plan containers.

Spotted Owls, Roadless, and more
Much time and effort was now spent in the 1970s, 80s, 90s on above-forest policy making, brought about by actors and actions taken either against the Forest Service or from within the Forest Service responding to the Endangered Species Act of 1973. They were, “Spotted Owl Management Plans,” “The Roadless Rule,” “The Northwest Forest Plan,” and more. These decision containers were bounded as regions, not FS administrative regions but geographical regions more appropriately suited to the issues and the actors petitioning for problem resolution. Note that the policy-level decision making was largely about curtailing timbering and roading, but the Forest Service chose to name the efforts after the initiating issues, not the federal actions being considered.

Forest Planning Proves Resilient, if not useful
The forest planning paradigm still captured much attention, but the three-level planning process swirling around the forest plan—projects/mid-scale/forest—was felt by forest planners and the Forest Service generally to be too cumbersome. Something else needed to be done. While the rest of the world was waking up to complex systems, wicked problems, and adaptive management, as was part of the Forest Service via the Northwest Forest Plan, the Forest Service via the NFMA rule was still stuck in the wonderful, if overly complex and somewhat bizarre world of capital P “Planning.” And the Forest Service was always trying to force-fit things into forest-level and project-level decision containers. But times were changing by 1990 and at least for a time, the Forest Service seemed to be ready to catch up to the rest of the world.

Adaptive Governance: Emergence in the Clinton Era
Adaptive management seems to be evolving in name to Adaptive Governance, following a path laid down early on by Kai Lee in Compass and Gyroscope: Integrating Science and Politics for the Environment (1993). For a time the Forest Service seemed inclined to follow. [Note: Today, the “adaptive governance” path seems already well-discussed, if not well traveled. That is if my “adaptive governance” Google search is an indication. But my Wikipedia search didn’t give me much. Recognizing that the only viable adaptive management for dealing with public lands management has to deal with both Kai Lee’s Adaptive management compass and his civic-engagement gyroscope. I’ll go ahead and use the term “adaptive governance” hereafter.]

In what we might call Clinton era management, Chief Michael Dombeck sought to bring about a Leopoldian awakening (see, e.g. here, here) to Forest Service thinking. That “awakening,” as per Leopold’s earlier thinking, was about adaptive governance. But the largely Republican-dominated Forest Service resisted. Chief Dombeck was never accepted by Forest Service managers since he was from the BLM and appointed by an environmentally left-leaning Clinton administration. Things didn’t get better under Chief Jack Ward Thomas, himself a huge fan of Leopold. The road from Pinchot to Leopold was not going to be an easy one. Adaptive governance thinking was soon on the chopping block along with pretty much all else from “new forestry” to “new perspectives,” etc. following the election of George W. Bush as a new Administration came to Washington.

Adaptive Governance: Bush/Cheney Backlash
The Bush/Cheney public lands legacy can be viewed as a legacy of war—war on the environment and war on anything the previous Clinton Administration had built under the rubric of “ecosystem management” (See generally Bob Keiter’s Breaking Faith with Nature: The Bush Administration and Public Land Policy). Under Mark Rey as Undersecretary of Agriculture, the Forest Service moved into its “Healthy Forests Initiative,” followed soon thereafter by the “Healthy Forest Restoration Act of 2003.” As Bob Keiter notes, the names could be viewed as cynical, as part of a well-orchestrated backlash against Clinton era reforms. To Keiter:

By using the Healthy Forests Initiative to expand the scope of NEPA categorical exclusions and to alter the ESA consultation process, the Forest Service has further enhanced its authority and reduced the potential for judicial review of its decisions, which is also what the [Aquatic Conservation Strategy] and species inventory revisions to the Northwest Forest Plan would have done. Congress has abetted this de-legalization effort by including NEPA provisions in the HFRA and the Energy Policy Act that either eliminate or reduce environmental analysis requirements for timber thinning and energy exploration projects.279 Add to this the Bush administration’s approach to its ESA responsibilities—which include an overt hostility to new listings, a rush to delist species, and contemplated revisions to the section 7 consultation process and critical habitat designation and critical habitat designation criteria—and the land management agencies could well be relieved from meaningful regulatory oversight. Related efforts to eliminate administrative appeal opportunities are plainly designed to further insulate management decisions from review. The net effect is to minimize opportunities to enforce environmental standards and procedures, and thus shield criteria—and the land management agencies could well be relieved from meaningful regulatory oversight. Related efforts to eliminate administrative appeal opportunities are plainly designed to further insulate management decisions from review. The net effect is to minimize opportunities to enforce environmental standards and procedures, and thus shield the agencies from any meaningful accountability. It is a return to an era when discretion reigned supreme. [Footnote in original]

All good things come to an end. So do all bad things. The Bush/Cheney regime and its war on the environment ended in January 2009, although effects (and federal judges) linger. [Personal aside: My friend from the early “planning days,” Dale Bosworth served as Forest Service Chief early in the Bush/Cheney Administration. I believe Dale did what he could to curb the worst of the what might have been done to the Forest Service during that era, but didn’t take my advice the be take a firm stand and be the first Chief since Gifford Pinchot to be fired for standing up against the powers that be. Had I been in his shoes I might not have taken that advice either. Who knows? But it wasn’t in Dale’s nature to work that way. I don’t find fault with Bosworth’s leadership/management during that era.]

Adaptive Governance: Obama’s ‘Audacity of Hope’
Unfortunately for Leopoldian dreamers, incoming President Barrack Obama’s audacious plans have not yet been focused on matters environmental, other than green energy. Nor will they likely anytime soon, even if Obama or anyone in his Administration were prone to do so—which itself is in question. Obama is too distracted with two wars, emergent unrest in the Mideast and Middle America following Tea Party elections in statehouses and the US Congress. Not to mention continued after-shocks from the near-disaster of the financial meltdown that arrived coincidentally (or not) right as Obama was entering the White House.

Obama cut his political teeth on community organizing, and that is in a sense Kai Lee’s gyroscope to accompany his adaptive management compass. So we can at least hope for endorsement from Obama if planning is replaced with adaptive governance. Whether or not it will be a good thing depends largely on whether or not untoward devolution happens—or is perceived to likely happen—under adaptive governance schemes. Time will tell. But I get ahead of our story. The Forest Service hasn’t yet embraced adaptive governance, although I hear they are flirting with it. Instead they are still wedded to capital P “Planning.” As Andy Stahl noted, the recent Draft NFMA “planning rule” (pdf) (as the Forest Service likes to call it), stages up a rational planning exercise. The difference is that this time it is driven by ecological rationality instead of the earlier economic rationality from the OMB era.

Adaptive Governance: Absent in the NFMA Draft Planning Rule
I suspect it was because the Bush/Cheney era NFMA rule was thrown away by the courts, but for whatever reason the Obama Administration chose to rewrite the “NFMA rule.” There has been a flurry of commentary on this blog and elsewhere about the rule and associated planning. But does anyone really care about this type planning anymore? What decisions are really contained by a forest-level plan? Despite the language of the draft rule, I find no “ecological resilience” decisions, neither “ecological or social sustainability” decisions, nor any “species viability” decisions, nor … that can be contained in a forest-level plan. All such considerations will well-up at scales different from forest boundaries.

As I’ve argued before, these are wicked problems. Wicked problems are not amenable to rational planning resolutions. Part of the “wicked problem” problem is that they are shape-shifters, they vary in problem identification and resolution across both time and space. They just won’t stand still, and will not be force-fit into predetermined “decision containers.”

In addressing wicked problems, I believe that scale-dependent futuring, and/or puzzle solving, is in order alongside scale-dependent assessments and monitoring. We ought to add in scale-dependent standard setting. They all fit under a header “puzzle solving.” Where scale-dependent is really the stuff of framing decisions/actions according to a “Garbage Can Model” wherein issues, actors, and arenas self-organize across the landscape into various and sundry decision containers. We all need to think hard about wicked problems and, e.g. Cohen, March, and Olsen’s garbage can decision model. Here’s a pdf of CMO’s 1972 article: “A Garbage Can Theory of Organizational Choice.”

See too Pritchard and Sanderson’s chapter in Panarchy: Understanding Transformations in Human and Natural Systems (2002), “The Dynamics of Political Discourse in Seeking Sustainability.” After setting stage for adaptive governance, complete with “wicked problem identification” and “garbage can” resolution mechanisms, Pritchard and Sanderson conclude:

[Testing hypotheses and applying lessons learned] to the thorny puzzles of environmental management and governance are [noble] goals. The greatest promise lies in addressing political issues directly, rather than in avoiding or submerging them. The fondest hope might be that individuals, communities, and formal organizations engage the spirit of adaptation and experimentation, by allowing a set of contingent ideas to shape “the gamble” of democratic resource management, and citizen experts to report on the results. Of course, for such a profoundly disorganized and multiscale approach to thrive, government, market, and citizen must share a common vision—that all must address these puzzles in order that they might be engaged and worked on—not solved forever; that “expertise,” popular voice, and power are separable, and none holds the dice [from a “floating crap game” model of politics] for more than a pass.

A Few Questions Linger
Is an ecologically framed rational planning rule what we need to resolve controversy?
Or is it time to embrace adaptive management, even adaptive governance in an attempt to tame wicked problems? Yes, I know that the preamble to the Draft NFMA rule claims that forest planning will be driven by adaptive management. But, really? Read the rule and explain to me how the draft rule stages for more than rational planning.

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Related:
The Forest Service as a Learning Challenged Organization, Iverson, 1999
US Forest Service Deeply Flawed Planning Culture, Iverson, 2004

Standards in Planning

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The question of standards in forest planning has emerged as a central issue in the proposed NFMA regulations.  It seems that a common narrative by the press in covering the story thus far is the amount of discretion afforded in the proposed rule versus its lack of “musts and shalls.”

Here is the definition of standards in the proposed regulations: “A standard is a mandatory constraint on project and activity decisionmaking, established to help achieve or maintain the desired condition or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal requirements.” (76 Fed. Reg. 8517).

I have made my pro-standards case in various places, hitting on the usual theme of accountability, while others like Professor Mark Squillace have thoughtfully criticized their use at the forest plan level.  I hear similar complaints about standards from others participating in the draft regulations as well. 

This is an important debate.  But my sense is that we might not all be that clear about the variety of ways in which standards are used in planning.  Maybe we all have different conceptions based on our interactions with forest planning in various parts of the country.  So before making an argument for standards, allow me to first explain what I mean by the term.

Types of Standards Used in Forest Planning 

Different types of standards are used in forest planning.  They can differ in scale, specificity, and complexity.  Some administrative regions of the USFS, for example, use standards cutting across multiple National Forests (this being very relevant to Melissa’s point about standards and scale–many of us agreeing that some standards might best be applied at larger spatial scales).

National Forest plans have also used forest-wide standards that vary in detail and complexity.  Take, for example, the forest-wide range standard in the 1986 Lolo National Forest Plan:

Conflicts between livestock and big game will be resolved so big game are allocated the forage required to meet their needs.  Domestic livestock will be allowed to utilize any forage surplus not conflicting with the planned expansion of big-game populations.  Reductions in livestock numbers will be avoided if possible, but will be acceptable to meet management goals. (II.9). 

To me, this seems more like a nudge than a clear unequivocal standard, but it still provides some direction. 

Forest-wide standards can also be more complicated, such as the Lolo’s forest-wide “snag standard.” This standard requires sufficient snags and dead material to be provided in order to maintain 80 percent of the population of snag-using species.  More detailed prescriptions are provided in this forest-wide standard, such as specifying the number of big snags needed per acre on different forest types on the Lolo.  (I get the sense that critics of standards are thinking about this sort of example). 

Standards are also used for particular management areas or zones as identified in a forest plan.  These sorts of standards can be very straightforward and basically state what is allowed to happen in a particular area. They specify allowed uses, prohibitions, and constraints.  The Lolo Plan, for example, divides the forest into 28 management areas, each with a different set of standards.  Consider the following examples:

Standards used for a municipal watershed area state that “livestock grazing permits will not be issued” and that “chemical herbicides and pesticides will not be used within the Ashley Creek Watershed.” 

A management area including significant historical, archeological, paleontological, and cultural sites uses a timber standard stating that “timber removal will be limited to that necessary to enhance historic values and provide for public safety” and that “timber removal will be under administrative use rather than commercial sale authority.”

A management area consisting of large roadless blocks of land contains standards that disallow most types of motorized access, the construction of developed recreation facilities, and commercial logging. 

These are straightforward, meaningful standards playing an important role in forest planning.  They are not hyper-complex nor do they require super-human analytical abilities to write and implement them.  Nor is there any evidence, that I’m aware of at least, showing that the writing of such standards is what bogs down the forest planning process. 

Why Standards?

The use of standards in a forest plan should be required under the NFMA regulations for several reasons.  We have discussed a few of these already on the blog, often in the context of what is required by NFMA and the importance of accountability.  I’d like to discuss a few issues that have not received as much attention but are very relevant to the proposed rule:

1.  Standards help differentiate one management (planning/zone) area from another.  The above example from the Lolo demonstrates the important relationship between standards and the designation of management areas/zones.  The former gives meaning to the latter.  Why would the Lolo National Forest designate a management area if that area had no different allowed uses or prohibitions than some other area? Or why would the proposed rule require the identification of priority watersheds for maintenance or restoration if those areas had no meaningful prohibitions?  If the agency is going to draw lines on a map, then those lines should mean something. 

2.  Standards facilitate the effective use of adaptive management—one of the principles of the proposed rule.  Standards help define the purpose and boundaries of adaptive management and planning.  After all, adaptive management is a means to an end, and that end needs to be clearly articulated.  Without standards, adaptive management is too susceptible to political exploitation and the dodging of tough political choices. 

A commonalty found in most adaptive management literature is the need for a structured decision making process and the identification of clear and measurable management objectives.  The Interior Department’s Technical Guide (as discussed at the Science Panel) emphasizes both as crucial to the success of adaptive management:

If the objectives are not clear and measurable, the adaptive framework is undermined…Objectives need to be measurable for two purposes: first, so progress toward their achievement can be assessed; second, so performance that deviates from objectives may trigger a change in management direction.  Explicit articulation of measurable objectives helps to separate adaptive management from trial and error, because the exploration of management options over time is directed and justified by the use of objectives.  U.S. Department of the Interior, Adaptive Management: The U.S. Department of the Interior Technical Guide (2009), at 11. 

Standards can be used to help define these objectives while providing a relevant metric in determining their achievement.  More basic is the fact that adaptive management projects will take place in particular management areas of a National Forest, as identified in a forest plan, and these zones/standards will guide the questions and purpose of any adaptive management project. 

3. Standards can help the USFS, and other federal agencies, meet the goals and mandates of other environmental laws. There are important interconnections between NFMA and other laws like NEPA and the ESA and CWA.  NFMA regulations should thus be considered as part of a larger regulatory framework.  And these environmental laws and regulations should be viewed as goals, not constraints. 

Consider, for example, the role standards play vis-à-vis the ESA.  The proposed planning regulations properly emphasize the agency’s obligation to conserve endangered and threatened species.  The proposed rule “would require the responsible official to explicitly recognize the recovery of T&E species as an important part of land management plans…” (76 Fed. Reg. 8494). 

Standards can play an important role in this regard.  Consider, for example, the unsuccessful delisting of grizzly bears in the Greater Yellowstone region.  At issue in this case was the Grizzly Bear’s Conservation Strategy, which included the amending of multiple national forest plans.  The Court found the Conservation Strategy short of being an “adequate regulatory mechanism,” as required by the ESA, partly because the forest plan amendments included few meaningful standards and too many discretionary and unenforceable guidelines.  Cases like these demonstrate how meaningful standards can help the USFS meet all of its legal obligations, not just NFMA.(see Greater Yellowstone Coalition v. Servheen, 672 F. Supp. 2d. 1105, (D. Mont. 2009).

Stop Killing Messengers

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There is really little chance that we will, anytime soon, stop “killing the messenger” in the natural resources arena. But we might do it first in another important arena: banking and finance. Later, perhaps the many sad tales of public lands whistleblowers losing all trying to stand up for truth and justice will finally come to an end. Or maybe I was just dreaming today, at Economic Dreams-Nightmares in Stop Killing Messengers: Banking and Finance Edition.

Killing the messenger has been around for a very long time. In our day, we mostly don’t shoot them (at least not in so-called “civilized countries”), but “it is still worth a man’s neck to disturb an emperor’s image. Nowadays the axe falls more subtly and the execution may be postponed, but sooner or later it comes.” (citation in Wiki link above.)

Why not reward whistleblowers instead? If we were to reward whistleblowers, rather than killing them—figuratively, if not literally—we would have to reward them handsomely. Why? Because in most cases whistle blowing is a career-ending if not a job-ending move. Over at Macroeconomic Resilience Ashwin Parameswaran champions whistleblowing:,

Compared to other whistleblowers, employees have the best access to the information required to uncover fraud. They also possess the knowledge to analyse and parse the information for any signs of fraud. This is especially important in a field such as banking where outsiders rarely possess the knowledge to uncover fraud even when they possess the raw information….

[M]onetary incentives have an even stronger role to play in uncovering fraud in banking. The extremely high lifetime pay expected in the course of a banking career combined with the almost certainly career-ending implications of becoming a whistleblower means that any employee will think twice before pulling the trigger. Moreover, the extremely specialised nature of the industry means that many senior bankers have very few alternative industries to move to. …

The focus must be not to keep whistleblowers from losing their jobs but to compensate them sufficiently so that they never have to work again. As it happens, the scale of fraud in financial institutions means that this may even be achieved without spending taxpayer money. The whistleblower may be allowed to claim a small percentage of the monetary value of the fraud prevented from the institution itself, which should be more than sufficient for the purpose.

There is little doubt that if Brooksley Born had been listened to by Robert Rubin, Alan Greenspan, and Larry Summers during the Clinton era, the 2007-8 US financial meltdown might have happened sooner, but would arguably have been milder.

Rewarding whistleblowers can serve as a compliment to an idea The Epicurean Dealmaker, put on the table to attract some highly-talented people into government service. To TED:

Staff the SEC, or whatever “Super Regulator” the government decides to deputize to oversee this mess, with a bunch of highly-paid, tough-as-nails, sonofabitch investment bankers. You will have to pay them millions, just like regular bankers. (You can tie their incentive pay to improvements in the value of securities held under TARP and TALF, if you like.) Pay them well, and investment bankers won’t be able to treat them like second-class citizens at the negotiating table. Pay them like bankers, and your regulators won’t hesitate to read Jamie Dimon or Lloyd Blankfein the riot act, because they won’t give a shit about getting a job from them later.

Trust me, these are the kind of people you will need on your team: highly educated, financially sophisticated, psychotically hard-working, experienced professionals who know or can figure out CDOs, SIVs, balance sheet leverage, and credit default derivatives just as easily as the idiots who created and trade this shit. …

If these two measures were used to compliment other reform measures, we would go a long ways toward preventing future financial catastrophes.

[Personal Disclosure: I serve on the board for a little organization (FSEEE) set up to protect whistleblowers as a part of a three-part mission. What I’ve learned over 20 years is that there is little protection for whistleblowers. Despite high-sounding rhetoric in several Acts of Congress, whistleblowers usually lose most everything: jobs, families, property, etc. FSEEE, PEER, and GAP (three organizations I know that attempt to protect whistleblowers) all advise prospective whistleblowers not to blow the whistle, at least not publicly. Even though all three organizations know well the value of whistleblowers, they advise against the practice because the personal price to be paid is too high. Only crazy people blow the whistle, but FSEEE, PEER, and GAP (among others) stand ready to help by getting the message out (either anonymously or with what meager protection that can be offered by “going public in a big way”).]

Forest Wars: From Multiple Use to Sustained Conflict

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When we sometimes tire of our “word wars” here, we need to remember that they are just one manifestation of broader holy wars being waged in and around our public lands.

Long Road to War

Utilitarian ideology has been a mainstay in forest policy development since the early 1900s when Gifford Pinchot and Bernhard Fernow introduced forestry into American government. Samuel Hays’ Conservation and the Gospel of Efficiency, alongside David Clary’s Timber and the Forest Service both build on self-righteousness to the point of religious fervor among many who chose to work on the land, notably foresters and engineers, and their evangelists (pundits, professors, etc). Similar books could be written — likely have been — talking about the religious-like fervor of the environmental community. [See, e.g. Environmentalism as Religion, Wall Street Journal, 4/22/2010.]

For many years, what later emerged as forest wars were never more than disagreements between mainstream forestry practitioners and malcontents like John Muir, Aldo Leopold and Bob Marshall. Such “disagreements” were deep-seated ideological splits, but contrarians of that era didn’t have the political/legal muscle to make for war. Later, however, the very same disagreements intensified into ideological war with the dawn of the environmental movement.

Environmentalists gained traction in forest debates, appeals, litigation, etc. after people began to wake up to environmental concerns in the late 1960s. The first of a series of Wilderness Acts became law in 1964. The Endangered Species Preservation Act of 1966 predated and set a stage for the Endangered Species Act of 1973. Earth Day began in 1970. In 1969 the National Environmental Policy Act (NEPA) became law. In 1976 The National Forest Management Act (NFMA) and the Federal Lands Policy Management Act added to the mix. The environmental battles gained legal footing. But it is not clear that the legal footing was ever recognized, or at least accepted by the US Forest Service. At least if actions speak louder than words, we must question whether the Forest Service and its USDA overlords ever accepted these legislative mandates.

Disdain for legislative mandates runs deep, but there is an alternative path — a road not taken. Sally Fairfax set a stage for continued disgust for NEPA among forest practitioners with her 1978 Science article titled A Disaster in the Environmental Movement. Countrast Fairfax’s view with that from Jim Kennedy’s NEPA note: Legislative Confrontation of Groupthink.

Environmental Wars

Beginning in the 1970s, environmentalists waged war on timbering, grazing, road building, mining and oil & gas development, developed recreation, and more. Warriors on the “enviro” side typically vilify corporations, else government “lackeys” for the corporations. Warriors on the practitioner side vilify the enviros. In war there is little room for thoughtful discussion or dialogue. The rift between the two camps will likely remain very deep for a long time.

It is not clear that the Forest Service ever gave much heed to the “legislative confrontation of groupthink” ideas in NEPA. It seems that the Forest Service has been evading/avoiding NEPA responsibilities from the get-go. They continued “go-go timbering” up to the point of shutdown following the Monongahela and Bitterroot controversies. After things were sort-of opened up again via NFMA, the Forest Service wanted “once and for all NEPA”, i.e. the forest plan would be a catch-all NEPA container, allowing all projects to flow without any further NEPA review. When that didn’t work, the Forest Service played various shell-games pointing either upward (e.g. forest plans, regional plans) for NEPA compliance, else downward toward projects depending on what was being challenged. Finally, during the Bush/Cheney period, they sought to “categorically exclude” as much as possible from NEPA review.

In 1999 I wrote up a little thing titled Use of the National Forests. I noted four distinct periods of Forest Service history: Conservation and “Wise Use” — 1900-1950, Multiple Use — 1950-1970, Sustained Conflict — 1970-2000, and Collaborative Stewardship — 2000+. Although we might quibble over the dates as well as the categories, I now realize that I was over-optimistic as to the dawn of the Collaborative Stewardship era. At minimum there was a dramatic backlash — not necessarly against collabortion but clearly against environmetalism — commencing with Bush/Cheney Administration and their ABC (“anything but Clinton”) campaigns. The Bush/Cheney war on the environment was a reenactment of an earlier war waged by the Ronald Reagan Administration.

Bob Keiter (Univ. of Utah Law School) chronicled the emergence of both ecological awareness and collaborative stewardship in Keeping Faith with Nature. Keiter later chronicled the Bush/Cheney reactionary footnote in a 2007 article, Breaking Faith with Nature. Taken together, the two trace certain aspects of emergent gospels that were part of the ideological wars. The former traces what I’ll call the “ecosystem awareness” movement in the Clinton era of government, and the second the Healthy Forests Initiative and the Healthy Forests Restoration Act reactions during the Bush/Cheney era.

An era of “collaborative stewardship” may yet be emerging, albeit slowly and as already seen, with pushbacks. Enviros are still quite leery of “collaborations” and high-sounding agency rhetoric. They are warriors, after all. So the wars are not yet over, and may not be for a very long time. Timbering continues, albeit a a much lower volume than in the go-go days, and reframed as “ecological restoration” or “forest restoration”. New forest evangelists appear on the stage. Now we have both Wally Covington and Jerry Franklin preaching the gospel of forest restoration. I’ll leave it for further discussion as to how the two brands compare, and as to who buys into one, the other, both, or neither.

Other Wars

Even if wars between environmentalists and industrial and government practitioners were to ever end, these are just the tip of an iceberg of forest wars. We must add in the budget and staffing wars (hereafter budget wars) that have been ongoing in the Forest Service for a long time. Timber and Engineering reigned supreme in budget wars for many years, particularly after World War Two and the housing boom that fed rapid increases in timbering and associated road-building after WWII. Recreation, Wildlife, Soil and Water, even Fire, Personnel (later, “Human Resources”), Planning, Budget, Fiscal, State and Private Forestry, etc. were always struggling for funds. After go-go timbering days were a thing of the past — i.e. Environmentalists effectively shut down “go-go timbering”, Recreation and Fire gained an upper hand in budget wars. Somehow Engineering always seemed to keep its share of the money. [Note: Someday, maybe I’ll get these budget categories approximately right. For now, they are “good enough for government work”]

Finally — not trivially — Public Lands Wars have raged more of less continuously for many years. Remember the “Sagebrush Rebellion” and the so-called “County Supremacy Movement”? Now those have transformed into more of a “States’ Rights” movement. In all cases, part of the action has been an assault on federal lands.

I’ve probably missed some of the “wars” here. But if I’ve captured any of this even partially correctly, the landscapes, biophysical and political, have been transformed in the process. Some argue, as did Fairfax way back when, that the legal-administrative gridlock that has been a reality in federal lands management during the last 30-40 years, has done significant harm to the environment, and only resulted in wasted paper (EISs and dollars/time spent on forest planning, project planning, related NEPA work, appeals and litigation). Others like me argue that sometimes it is necessary to grapple with vexing social issues, even wicked problems in a very public way. Such “civic discovery” is a necessary part of a working democracy. Would that we could move from “war talk” to “fierce conversations“.

Related:
NEPA is Not the Problem, Forest Policy – Forest Practice, Oct 2007
The Blame Game

Planning Rules, Manuals and Handbooks – a flashback

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Here is a post from a short-lived blog I ran in 2005, Forest Planning Directives, about Forest Service planning Manual/Handbook rewriting. I think it may shed light on our planning rule critique as well. And it can serve as a guidepost, for the inevitable Manual/Handbook rewriting that will ensue just after the Draft Planning Rule moves to “Final.” Here it is, lightly edited:

Any role at all for NFMA Directives?

I have struggled for the last few days to better understand management and planning systems and ask myself whether we ought to keep any parts of the "interim directives." As usual I answer, No! You may find my thoughts amusing. You may find them bemusing. There is an odd chance you may find my thoughts enlightening. Here they are:

Land Management Planning as an Embedded Process

We have many processes (or systems) to help us manage the national forests and other public lands. Problem is these systems are often fractured and fragmented, and sometimes work at cross-purposes. We have tried to run our systems as pieces of a well-oiled machine. But it can’t work that way. The world is too complex for that, and sometimes politically wicked as well. A better management model is one that mimics nature, one comprised of self-organized complex adaptive systems. See Margaret Wheatley and Mryon Kellner-Rogers A Simpler Way for more.

Looking at things hierarchically, in a complex systems frame, we can see land management planning systems embedded in planning systems, embedded as part of "management systems."

Forest Service Management Systems
It proves helpful to see the map of interrelated systems that aid in adaptive management/organizational learning. Commonly recognized systems include:

  • Assessment Systems
  • Evaluation Systems
  • Inventory Systems
  • Monitoring Systems
  • Planning Systems

Add to these supporting systems, like:

  • Education and Training Systems
  • Personnel Recruitment and Support Systems
  • Budgeting and Finance Systems
  • Information Technology Systems
  • And so on

Now overlay all these with various "functions," like:

  • Vegetation management (timber, range, etc.)
  • Bio-physical resource management (soil and water, wildlife, plants, etc.)
  • Fire management (suppression, pre-suppression, etc.)
  • Facilities management systems
  • Recreation management systems
  • And so on

Finally overlay all with what we refer to as "Line Management," with about:

  • 900 District Rangers, who report to
  • 120 Forest Supervisors, who report to
  • 9 Regional Foresters, who report to
  • 1 Chief Forester

Now we can begin to get a glimpse of the complex nature of the management systems that we attempt organization with. The trick to all this is to make sure that the systems are not only complex, but adaptive and purposefully interrelated as well. No small order. And there are traps along the path we need to be aware of.

Decision Traps
Identifying systems and subsystems can either empower us or disable us. There are two traps that people commonly fall into here. First, we do not want to overly-reduce the complexity that enfolds us or we may develop overly complex systems or components in any one area, and at the same time neglect other important areas. This trap has been called "Abstracted Empiricism" or "Methodism."

Second, we may simply trap ourselves in the identification of the complex systems themselves. This trap is called "Grand Theory," where the trapped are paralyzed by their own overly-generalized identification and specification of complexity in the universe. In extreme form, this trap paralyzes people to the extent that they do not attempt any organization at all.

Interconnectivity, Dynamics, and Relationships
Traditionally we like to think of our organization as decentralized. But given law, policy, and Manual and Handbooks, etc. it is hardly decentralized.

We also traditionally think of our organization as working according to the dictates of "directives" that guide much of the action. Problem is, the directives tend not to be able to guide the workings of this (or any other) complex, adaptive, system. So what we have is a mess. We pretend to be decentralized, but that cannot be. We pretend to be directed in much of what we do, but the direction seems at best archaic, at worst unworkable from the get-go.

All the management systems are highly inter-connected. For now we will simply recognize them without pigeonholing them into some rigid structure like "plan-do-check- replan." This is not to say that we won’t keep that model in mind. Instead we don’t want to get trapped into thinking that is all we have to do. Our general approach should be mindful of our over-complexification dark side, our penchant to narrow our focus to the inner reaches of whatever box we find ourselves in and begin crafting ever-more- complex regulation, rules, technical guides, etc.

Take planning, for example. We have to plan before we develop any system or subsystem. But we can over-plan any system and ruin it. See, e.g. Henry Mintzberg, The Rise and Fall of Strategic Planning, 1994. In the Forest Service we have many over- planned and under-used systems. A lesson we continue to fail to learn, is that we need to design systems that can grow and develop as "users" continuously critique them and improve them. That means we have to start small, and let systems grow and develop as they are used. It also means that we have to weed out components, subsystems, and even whole systems that have outlived their usefulness. Pruning and tending are important, if unglamorous tasks in managing systems.

We need fewer teams of people to design work for other people, and more teams that design their own work and do it in ways that both improve and simplify the systems they work with. W. Edwards Deming champions such organization in his The New Economics: For Industry Government Education. Margaret Wheatley and Myron Kellner-Rogers lay out fundamental ideas and concepts on organization, information, and relationships in A Simpler Way. I recommend reading the books beginning with A Simpler Way, then moving to The New Economics, and finally for the devoted (and particularly for planning cheer-leaders) reading The Rise and Fall of Strategic Planning. But there is no way to practice adaptive management if we are unwilling to think about and read about ways to make it happen.

What does this mean for Manuals and Handbooks?
It means only that we had better do something very different from 18-30 feet of shelf space filled with cumbersome Manuals and Handbooks. We had better cut it all to the bare minimum. We had better take advantage of what’s out there in professional practice, and only add what must be added to help professionals work in our environment. It means The End of Bureaucracy & the Rise of the Intelligent Organization, which is also a very informative book written by Gifford and Elizabeth Pinchot. {Note Gifford is the grandson of the Forest Service’s founder.}

In this spirit, the Forest Service economists recently reduced about 100 pages of Manual and Handbook materials (FSM 1970, FSH 1909.17) to about 2 ¼ pages each for Manual and Handbook. The manual says, in essence, address social and economic context in various ways and places to help set a stage for managerial decision making. And highlight the social and economic consequence of proposed (and actual) action to the extent practical and foreseeable.

What does this mean for the Land Management Planning Manual & Handbook?
For Land Management Planning it means that we need to design and work with a subsystem that contributes to the whole rather than being parasitic on the whole. It means we need to quit thinking about controlling other systems. We need instead to think about contributing our small part to a broader whole.

First lets look at broad management systems. What might such a systems look like? What directives might guide it? The system is a complex web of multiply interrelated systems, all sharing some information with other systems while holding some information within any given system since it only adds "noise" to other systems. All systems are interrelated as well by the relationships between them, and by the relationships between those who take care of each system, and by the relationships of these people with those whose focus is broader, covering several or all systems.

Sustainability
The system is purpose driven, wandering down a path toward what many call sustainability. We know that the path is long, winding, and indeterminate. Sustainability is a vision quest. Sustainability is something that shape-shifts as we move down the path. But sustainability is also something that we are ever-mindful of. It is a goal that hovers in front of us, guiding us. Ecosystem constraints bound the path – some associated with natural and biological systems, some associated with human systems.

Long term, we are rewarded when we stay on the path toward sustainability, and punished when we stray beyond the bounds. Short term, we often blow the boundaries, sometimes by political design and sometimes by human error. Such deviations are punished, but the punishment may be felt by "contemporaneous others" or "future others." There are lags, often very long ones, in the feedback loops.

Surrounding our complex of managerial systems, and connected to them are broader-framed social systems with names like science, ethics, politics, beliefs, participation, that are part of the social/cultural environment. These systems interrelate with natural systems in the physical and biological realms.

Now let’s look at land management planning systems, embedded in ever-larger adaptive management frames.

Land Management Planning
What questions might guide our inquiry? (Similar questions might be framed for any planning)

  • What is planning?
  • How does it fit into adaptive management?
  • What do we expect from planning?
    • What if desired deliverables do not include a plan? Remember that Scenario Planning advocates and many others do not believe that the goal of planning be the production of a plan. Instead, they stress the importance of planning to rehash the past and rehearse the future.
  • If we expect a plan, along with other deliverables, what do we want it to do?
    • If we only want a plan to be a vision document, perchance highlighting vision over a variety of landscapes, but not making any how-to decisions, then we will answer this question much differently than if we expect a much more comprehensive, detailed plan.

Why bother with any Manual or Handbook? Why isn’t the NFMA Rule enough directive? Perchance the NFMA Rule is already too much directive, but that is a question for another time.

——————————–

2011 Update: Closely Related Posts
Why Three Planning Levels?
New Planning Rules Fails as Adaptive Management
The Frame Game

Voice in Democracy: When Anonymity Helps

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As we are seeing these days in the Middle East and Africa, even Wisconsin, democracy is never easy—whether to initiate or to keep. What we know is that we cannot maintain a democratic form of government without “voice.” After all, democracies are “temples of talk.” Yet, many times it proves too threatening to express opinions, or even to interject facts, into public discussions. Discussions sometimes threaten work, family, or community relations, yet without discussions, none of these institutions can long survive. In many situations, only the few dare voice opposition to either the status quo or to proposed change. But these days it is getting easier to be heard without some of the threat that has traditionally attached to voice. We are seeing an upwelling of “anonymity” as a form of voice.

I follow a bunch of blogs in the economics and finance arena. Believe me, there are a bunch of these. As you might guess, given recent financial shenanigans events, there are very active conversations in these blogs, and also in mainstream periodicals—that themselves now embed blogs. Some who comment and some who blog remain anonymous. Why? Because of perceived threats, sometimes very real threats. Anonymity allows a particular voice that would be disallowed if people were to “post” or comment under their real names.

Here are two examples. One noted financial blogger, The Epicurean Dealmaker, posts as TED (an acronym). TED is widely viewed as a sage in the arena of Wall Street financial deal-making. TED claims to be a mid- to higher-level employee of a Wall Street firm. He (or she? Not likely!) has been very critical of the culture wherein he makes a fine living. And his posts, and guarded/shielded interviews, have helped to unravel some of the mysteries of this arcane world. TED is unabashed. He even challenges people to find out who he is. He is so sure of himself that he believes that he will not be “outed.”

Then there is Maxine Udall (girl economist), who spent a few years blogging and attracted a following. Turns out that “Maxine” was not her real name. Unfortunately, the real author passed away suddenly a few weeks ago. She was “outed” after her untimely passing. Most everybody had previously thought Maxine was a savvy graduate student. Turns out that she was a professor. Had she been blogging under her real name, her voice would have been less edgy.

If you want to comment with anonymity, here’s what you can do. First create a fictitious name/email address, then begin commenting. Or, particularly if you want to carry conversation “off line” set up a real email, like TED did, with a “handle”, not your real name. If you feel you have more to say, start an anonymous blog—it is very easy.

We need more “voice” in the public lands arena. I don’t understand why there are not more blogs on matters we discuss here. Is it just timidity? Is it that there is so little passion among employees and public lands watchers? Really? Likely not. So what else is going on?

The Forest Service’s Fatal Flaw?

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Road removal in Redwood State Park (CA). Adam Switalski 2004c.

Guest Post by Bethanie Walder, Wildlands CPR.  (as requested by Martin Nie)

Oedipus Rex, Macbeth, Willy Loman, Tony Soprano, and … the Forest Service? A diverse group with a common theme – tragic or fatal flaws. From ancient literature to modern times, people have written about, read about and dissected the concept of the fatal flaw. High school and college classes abound with papers about tragic heroes, fatal flaws, and what can be learned from them. While it’s been a long time since I’ve taken such a class, and my metaphorical synapses are a little rusty, it seems to me that the Forest Service may have a fatal flaw when it comes to implementing their new restoration vision: accountability.

One word may be too simplistic to describe the whole problem – which is really an issue of infrastructure-deficiency. Basically, the Forest Service has no staff, program, or office dedicated to implementing restoration at either the policy or on-the-ground levels, yet they have adopted restoration as their new vision for the 21st Century. The problem is, you can’t have a 21st Century vision without a commensurate infrastructure to enable you to implement that vision. To adapt a well known metaphor, “if all the Forest Service has is a chainsaw, then every restoration opportunity will be a tree.” The infrastructure and accountability issue is deep-seated and emblematic of how hard it is for the Forest Service to adapt to changing conditions – both politically and on-the-ground. To get a sense of whether this really is a tragic flaw, here are a few quick internet definitions of the concept (emphasis added in all definitions below):

“A tragic flaw is a literary term that refers to a personality trait of a main character that leads to his or her downfall. In other words, a character with a tragic flaw is in need of some kind of attitude adjustment.”

“The tragic hero is a longstanding literary concept, a character with a Fatal Flaw like Pride who is doomed to fail in search of their Tragic Dream despite their best efforts or good intentions.” 

While many people within the agency really do have the best of intentions when it comes to restoration, I am concerned that the Forest Service, without an “attitude adjustment,” is doomed to fail.

For more than a century, the Forest Service has operated largely as a provider of natural resources like timber, oil, gas, grazing, and even recreation. But supplying timber is what the agency is most known for. They’ve created an infrastructure that enables them to do this – though environmental accountability has long been a problem. In 2009, however, US Agriculture Secretary Tom Vilsack outlined a new vision for the Forest Service: restoration. While creative agency staff have been implementing restoration projects for years, Vilsack defined a new guiding restoration vision with an emphasis on clean water.

The new vision however, still encompasses plenty of resource extraction. The agency’s proposed Fiscal Year 2011 budget combines three major budgetary programs (timber, fisheries and wildlife, vegetation and watersheds) into one large pool to promote and hasten restoration activities on national forests. The proposed Integrated Resource Restoration Program or “IRR” (see RIPorter 15:1) would funnel nearly $700 million into a single funding bucket for “restoration.” The result is likely to be that every new timber sale will be a “restoration sale.” Again, if allyou have is a chainsaw, then every problem is most certainly a tree.

Accountability for how this funding would be spent, and whether or not it would result in real watershed restoration on-the-ground, is nowhere to be found. Similarly, the budget has no recommendations for the type of infrastructure changes (as opposed to simply changing funding mechanisms) that would enable them to implement such a program effectively and with accountability.

But this lack of accountability and capacity is not solely related to the IRR. The agency as a whole does NOT currently have the infrastructure needed to implement a robust, comprehensive, effective and viable restoration effort, yet they are asking for an enormous pot of funding to be dedicated to “restoration.” Their tragic flaw, therefore, may be their failure to create a new infrastructure to develop, promote, direct and implement their watershed restoration plans. While only the Forest Service can determine the exact infrastructure needed, we have some preliminary recommendations. For example, we think they should develop a national Watershed Restoration Program, led by a national Director of Watershed Restoration, with regional Restoration Directors, and we have proposed this to the agency. These staff should be trained in hydrology and/or aquatic/fisheries ecology, and they should be tasked with developing and implementing clear, science-based, ecoregion-specific restoration agendas for the agency that put resource needs over economic returns.

Lest this seem somewhat trivial, here’s a first-hand example of why Wildlands CPR thinks it so important for the Forest Service to create a proper structure to achieve their vision. The agency has received $180 million over the last three years to implement Legacy Roads and Trails specifically to restore and protect clean drinking water and other aquatic and fisheries resources impacted by roads. Many fisheries,  hydrology, and soils staff we’ve spoken with love this initiative, and it provides an incredible opportunity to move towards Vilsack’s vision. But because of their infrastructure, Legacy Roads and Trails, a potentially brilliant watershed restoration effort, is largely run by engineers. That’s not bad in and of itself (there are some enlightened engineers working on it), but quite frankly, most engineers love roads and have been trained to construct things. Few people like to remove their creations, yet road reclamation is a key purpose of Legacy Roads and Trails.

Initially, not recognizing their tragic flaw, we pushed the agency both to implement Legacy Roads and Trails immediately based on pressing needs, and to undertake a long-overdue national analysis of their road system to determine which roads they still need, and which they can reclaim or close. Way back in 2001, the Forest Service adopted a long-term roads policy that provided guidance for identifying a smaller, more affordable, and less ecologically damaging “minimum road system” that would meet recreational and resource management needs. Their 2001 policy envisioned the reclamation of 80-120,000 miles of system roads. To date, they have largely failed to identify that minimum system, even though doing so would provide the blueprint for how to spend Legacy Roads and Trails money.

But engineers are basically in charge of Legacy Roads and Trails, and thus in charge of implementing the minimum roads system, albeit with help from recreation and watershed staff. In March I asked some of the lead engineers in DC about their plans for this minimum road system. I was dismayed, but not surprised, to learn that they only thought they would have to get rid of about 25,000 miles to achieve it. This reflects the tragic flaw. When I asked the Chief about this and how to provide the accountability needed to ensure that a truly ecologically and fiscally sustainable minimum road system is identified, he said that it wouldn’t just be the responsibility of the engineers, they would engage other departments. But how? And who has final authority?  Where does the buck stop? Why isn’t there someone, a national Watershed Restoration Director for example, who is responsible for ensuring that the final decisions are appropriately balanced?

And this is only for identifying a minimum road system. What happens when you scale that up to $700 million a year or more with the proposed IRR? With no watershed restoration program, no Director of Restoration, and no accountability, it seems impossible for the agency to implement a new restoration vision effectively, or even at all. Unless, that is, they get an attitude adjustment – or as the case may be, an infrastructure adjustment.

Without a new watershed restoration program, the IRR, Legacy Roads and Trails, and any other new restoration efforts are likely to be mere variations on an old theme, as the resource extraction  mentality and structure of the agency butts up against their theoretical 21st Century vision. But it doesn’t have to be that way. The agency can make an attitude adjustment, they can create the necessary infrastructure and accountability, and they can implement the restoration vision that Secretary Vilsack and others have laid out. In typical tragedies, the “hero” is incapable of overcoming their flaw, and thus they fail. But this isn’t a story, it’s real life, and it doesn’t have to be a tragedy.

This essay originally appeared at http://www.wildlandscpr.org/article/forest-services-fatal-flaw

9th Circuit, Monitoring, and Viability…Again

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Given all the talk on this blog about monitoring, NFMA diversity, and viability, etc., this recent 9th Circuit Case is another must read (file here: Native ecosystems v_ Tidwell(2)

I found it particularly interesting in light of the presentations focused on wildlife and monitoring at the planning science forum.  See e.g., presentations by Sam Cushman and Kevin McKelvey.

Here is a short summary of the case.  And here is a quote from it, sure to rabble the rousers:

“We do not share our dissenting colleague’s perception that the Forest Service can meet its obligations to the environment by naming a virtually non-existent species to serve as a proxy for critical habitat in the targeted area.  Far from usurping the agency’s role, our opinion holds the agency to its statutory responsibility to fully study the effects of the planned agency action, and ‘to maintain viable populations of existing species.’  It is unfathomable how the FS could meet its responsibility to maintain existing species by selected as a proxy a species that is virtually non-existent in the targeted area.

I also find the case interesting because it shows an unwillingness of the Court to defer to the USFS on these matters, despite all the ruckus created by Lands Council v. McNair, 2008).

Trigger Itch

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As Sharon writes, I have raised the possibility of using “triggers and thresholds” in some sort of adaptive management framework:  Here is the statement I made at last week’s science forum:

 One possible approach to this problem [how to practice adaptive management in the modern regulatory state] is to consider using some type of pre-negotiated commitments in an adaptive management framework.  These enforceable commitments would specify what actions will be taken by the agency if monitoring information shows X or Y.  In other words, some predetermined decisions, or more general courses of action, are built into the adaptive framework from the beginning (i.e., if this, then what).  Not every possible scenario can be prefigured of course, but having some thresholds or trigger mechanisms built into an adaptive framework might alleviate concerns about the amount of discretion ostensibly needed by agencies to plan and manage adaptively.

In retrospect, perhaps it’s wise to stay away from the term “threshold” because of its scientific usage and debate.  But triggers should still be considered by the agency.  I think the approach might work best in particular management situations, especially those that have an implementation monitoring program in place. 

I don’t think the approach is that uncommon actually.  Consider, for example, a report written by Chuck Quimby of USFS on using adaptive management options within a NEPA process focused on grazing (sorry, don’t have a PDF or link).  He discusses how various adaptive management options can be worked into EIS alternatives. 

Or consider various state wolf management plans whereby states commit to so many packs, and if monitoring shows they drop below some predetermined floor, a different suite of managerial requirements kick-in (more conservative wolf management). 

And to show that such an approach can cut in multiple directions consider the “adaptive timber management strategy” as used by the Tongass NF.  That strategy basically sets various triggers regarding timber harvesting and industrial development in SE Alaska.  If particular objectives are met, then additional roadless areas are opened for more harvesting.  This approach, if I recall correctly, was basically used by the Tongass as a way to more strategically open roadless lands for harvesting—rather than offering multiple sales in multiple roadless areas.  (Of course, conservationists see this as a complete bastardization of the AM approach, but it does demonstrate how adaptive management needs a purpose—it’s a means to an end—and that end needs to be defined by using NEPA). 

The approach could also be used in some restoration plan.  The USFS chooses a plan alternative (using NEPA) that emphasizes restoration.  Within that alternative are embedded a number of adaptive management options.  So, for example, if various restoration objectives are met by some date, then the agency will offer additional stewardship contracts in the following locations. 

 And one more hypothetical:  The USFS chooses a travel management alternative that connects two existing routes for OHV use.  Embedded within that alternative is an adaptive management option:  if an area adjacent to the connected route becomes illegally used and degraded, the new connected route shall be discontinued and decommissioned. 

 Sharon is right, however, because there will be lots of debate about where these trigger points are set.  (This has been a big issue in oil and gas planning and impacts to Grouse in Wyoming).  I imagine in most cases they will simply be politically negotiated, and in others scientists will be given a larger role to play (if used in the wildlife context). 

Martin Nie

Some Loose Threads Around Accountability

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Let’s take a look at this article in the Eugene Press Register Guard from this morning. Note that our fellow blogger
Andy Stahl is also quoted in this piece.

Oregon Wild, a nonprofit conservation group also has submitted written comments, said Doug Heiken, who characterized previous efforts at revision as attempts to weaken the rules and limit public engagement.
“We want to keep the agency accountable and make sure the forests are focused on clean water and biodiversity and carbon storage and recreation and all the wonderful things that come from our national forests,” he said.

This started me thinking about the concept that John Rupe originally brought up on this blog as a critical component of the Rule- accountability.

My first question was “accountability for what?” Accountability generally sounds like a good idea (we don’t want a bunch of feds running around willy-nilly getting taxpayers’ money doing whatever they feel like). Nevertheless, if you asked our colleagues in the timber industry community- they would probably also like accountability- for meeting timber objectives in plans. Do they and Mr. Heiken mean the same thing by accountability? I doubt it.

Does accountability mean to you “if the FS agrees to do something, then it should do it?”Or “when Congress funds the FS to do something, they should do it” or ??? In the context of NFMA, when people such as Mr. Heiken bring it up, I think they mean “accountability is having viability in the NFMA regulations.” But if people disagree on what they want the FS to be accountable for, how can the FS “be accountable” to meet desires that may be inherently incompatible?

The Administration has set goals for agencies for GHG reduction. Will agencies not be “accountable” for that? Congress asks the agency to do many things through the budget process. Are we “accountable” for those? Is being taken to court the only way to get the agency to do something?

While I was ruminating on the various possible meanings of accountability, our Regional Forester gave us some information from their Safety Learning Trip to Los Alamos. Note: I may not have captured this accurately.

According to what I heard, the national leadership folks were talking about how to become a learning organization in terms of safety. One thing I wrote down was something like “accountability is seen as a codeword for culpability”. I think the idea is something along the lines of “if you think you are going to get beat up for an error, you aren’t going to report it.” That does not lead to a learning organization. Safety is an important thing our agency does, we want to be a learning organization. Environmental protection is an important thing our agency does, so we want to be a learning organization in terms of this as well. In the case of environmental protection, how does accountability mesh with being a learning organization?

We assume that people want to be safe, but make mistakes through cultural habits or for other reasons. Can’t we assume that people also want to protect the environment, and examine what keeps them from doing that?

So here are three questions- 1) What does FS accountability mean to you?

2) How does this fit (if it does) with the FS becoming a learning organization, or perhaps better, the FS plus collaborators becoming a “learning community”

3) Do the above thoughts have implications for a planning rule? If so, what are they?