adaptive management

When Policy Trends Toward Bullshit

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Much government policy and some law resides in a realm philosopher Henry Frankfurt labels “bullshit”—in earlier times called humbug or balderdash. Much US Forest Service policy falls here too: regulation, manual and handbook directives. At least that’s the way I’ve seen it for a very long time.

Early in my Forest Service career, a colleague and I were conscripted into a week-long Forest Service Manual/Handbook writing exercise, specifically focused on the Forest Planning sections. A quick survey of the materials led us to conclude that our week had to be spent making sure that there was nothing in the FS planning manual that could possibly harm anyone. We knew that we could not ‘fix’ the manual, so we spent our week in a second-best endeavor.

A few years later a FS Planning Director asked a group of us for policy ideas at an economists conference. I suggested a bold move: Throw the Forest Service Manual and Handbook in the Potomac. I made the recommendation in the main because both the FS Planning and Economics Manual/Handbook materials were pretty much bullshit. Note that I immediately added that people should be able to swim out and retrieve portions of the policy manuals they deemed useful, and then upgrade them as necessary to help advise program development, project design and work generally. The point was to decommission the whole mess, and free the agency of both the manuals/handbooks and the mini-bureaucracy that oversaw them. Of course I didn’t believe that the FS would act on my suggestion, at least not then. But one can always hope. [Note: I wish there were electronic copies of earlier FS Manual/Handbook materials to point to for historical (hysterical?) purposes. ]

I suggested “tossing” the FS manual and handbook to both Chief Dombeck (via Chris Wood) and Chief Bosworth. Both were somewhat warm to the idea, but nothing happened. I’ve once again raised that issue with FS top brass, suggesting that collaborative adaptive governance can’t work if everybody shows up with several yards worth of “holy writ” that must be followed.

Later I called bullshit on the Forest Service’s initiative to tie planning (and pretty much all else) to environmental management systems—chronicled in my Forest Environmental Management Systems blog (Oct. 2005 – April 2007). That particular mess went away, with EMS rightfully retreating to a minor place (facilities and fleet management) in Forest Service administration. I’m sure my blogging did not influence the outcome. But at least I left a record, so that we might learn from the mistake.

Common wisdom says, “When you find yourself in a hole, stop digging.” Let’s pause a moment and explore special characteristics of what we are digging through.

What is ‘bullshit’?
Before anyone gets too upset with my BS terminology, maybe we ought to delve into Frankfurt’s little book On Bullshit—an essay really, which you can read online. Frankfurt’s little book adorned a special shelf in my FS office bookshelves, accompanied by Joseph Heller’s Catch-22 and Something Happened, Lewis Carroll’s Alice in Wonderland, and some other classics. Frankfurt begins On Bullshit with,

One of the most salient features of our culture is that there is so much bullshit. Everyone knows this. Each of us contributes his share. But we tend to take the situation for granted. … In consequence we have no clear understanding of what bullshit is, why there is so much of it, or what functions it serves.

Frankfurt attempts to tease out a ‘theory of bullshit’ for us. I’ll not bore you with all Frankfurt’s building blocks, but I at least we need to know that he distinguishes bullshit from lying, in part as follows:

The essence of bullshit is not that it is false, but that it is phony. … The bullshitter is faking things. But this does not mean that he necessarily gets them wrong. [But it does mean that they don’t quite ring true.]

How much FS policy falls in this realm? Politicians tend to create bullshit to pander—to curry favor. Bureaucrats create bullshit for very different reasons. Frankfurt says,

Bullshit is unavoidable when circumstances require someone to talk without knowing what he is talking about. … [This is] common in public life, where people are frequently impelled—whether by their own propensities or by the demands of others—to speak extensively about matters of which they are to some degree ignorant.

Think about how Forest Service teams are put together, often without asking for volunteers and without too much regard for seeking out the most knowledgeable team members. It always seemed to my jaundiced eye that team members were selected to construct manual and handbook materials in the main because they were ‘good soldiers’, and particularly not ‘radicals’ who might rock the boat too much.

Why I’ve tried to stop the BS

I know that it is pretty much a fool’s quest, but I’ve always tried to get the Forest Service bureaucracy to ‘swing for the fences’ and pull itself up from the morass of its own policy, manuals and handbooks. But, like many American institutions the Forest Service will not take a hard look at itself. Maybe it’s due of fear. Maybe it is due to ennui—stuckness, lack of hope. Maybe it is something else. Maybe it is just because they don’t realize that bullshit might be outright harmful, even toxic to the organization.

This proves especially true when bullshit policy is brought into court, “for the record,” when people challenge federal actions, which must be based on federal policy. At the point federal policy bullshit makes an appearance in court, federal judges are not pleased to have to wade through it—so we too often get strongly-worded federal decisions against the Forest Service.

In any case, meaningful links between process and outcome in the Forest Service often simply don’t exist in any practical sense. They are too encumbered by bullshit. For example, we often hear that if the Forest Service can’t fix the Forest Planning process (for example) in ‘rulemaking’ then we’ll fix it in forest plan implementation—as if that can happen. Isn’t such talk just administrative governance denial?

I keep the pressure on, hoping against fate that a miracle will occur, as it did with General Electric not too long ago, just before GE was to fall in to a bureaucratic quagmire from which it would not, could not escape. Make no mistake, the GE rebirth was brutal. But the company is arguably much better today than before—now that fierce conversations are standard practice innovation is center stage, and people are required to challenge each other to do better, and to be better. Maybe someday the same will happen in a government agency, even perchance to the Forest Service. But I’m not holding my breath.

New study challenges forest restoration and fire management in western dry forests

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(Below is a press release from the researchers. A copy of the study is available here. – mk)

New research shows that western dry forests were not uniform, open forests, as commonly thought, before widespread logging and grazing, but included both dense and open forests, as well as large high-intensity fires previously considered rare in these forests. The study used detailed analysis of records from land surveys, conducted in the late-1800s, to reconstruct forest structure over very large dry-forest landscapes, often dominated by ponderosa pine forests. The area analyzed included about 4.1 million acres on the Mogollon Plateau and Black Mesa in northern Arizona, in the Blue Mountains in northeastern Oregon, and in the Colorado Front Range.

The reconstructions, which are based on about 13,000 first-hand descriptions of forests from early land surveyors along section-lines, supplemented by data for about 28,000 trees, do not support the common idea that dry forests historically consisted of uniform park-like stands of large, old trees. Previous studies that found this were hampered by the limitations inherent in tree-ring reconstructions from small, isolated field plots that may be unrepresentative of larger landscapes.

“The land surveys provide us with an unprecedented spatially extensive and detailed view of these dry-forest landscapes before widespread alteration” said Dr. William Baker, a co-author of the study and a professor in the Program in Ecology at the University of Wyoming. “And, what we see from this is that these forests were highly variable, with dense areas, open areas, recently burned areas, young forests, and areas of old-growth forests, often in a complex mosaic.”

The study also does not support the idea that frequent low-intensity fires historically prevented high-intensity fires in dry forests.

“Moderate- and high-severity fires were much more common in ponderosa pine and other dry forests than previously believed ” said Mark Williams, senior author of the study and recent PhD graduate of the University of Wyoming’s Program in Ecology.

“While higher-severity fires have been documented in at least parts of the Front Range of Colorado, they were not believed to play a major role in the historical dynamics of southwestern dry forests .”

Some large modern wildfires, such as Arizona’s Rodeo-Chediski fire of 2002 and the Wallow fire of 2011 that have been commonly perceived as unnatural or catastrophic fires actually were similar to fires that occurred historically in these dry forests.

The findings suggest that national programs that seek to uniformly reduce the density of these forests and lower the intensity of fires will not restore these forests, but instead alter them further, with negative consequences for wildlife. Special-concern species whose habitat includes dense forest patches, such as spotted owls, or whose habitat includes recently burned forests, such as black-backed woodpeckers, are likely to be adversely affected by current fuel-reduction programs.

The findings of the study suggest that if the goal is to perpetuate native fish and wildlife in western dry forests, it is appropriate to restore and manage for variability in forest density and fire intensity, including areas of dense forests and high-intensity fire.

Key findings:

•  Only 23-40% of the study areas fit the common idea that dry forests were open, park-like and composed of large trees.

•  Frequent low-intensity fires did not prevent high-intensity fires, as 38-97% of the study landscapes had evidence of intense fires that killed trees over large areas of dry forests.

•  The rate of higher-severity fires in dry forests over the past few decades is lower than that which occurred historically, regardless of fire suppression impacts.

The study was published online last week in the international scientific journal, Global Ecology and Biogeography. The published article can be accessed online here. The title is: Spatially extensive reconstructions show variable-severity fire and heterogeneous structure in historical western United States dry forests.

The authors are Dr. Mark A. Williams and Dr. William L. Baker, who are scientists in the Program in Ecology and Department of Geography at the University of Wyoming.  Dr. Mark A. Williams is a 2010 PhD graduate, and Dr. William L. Baker is a professor, both in the Program in Ecology and Department of Geography. In Dr. Williams’s PhD, he developed and applied new scientific methods for reconstructing historical structure and fire across large land areas in dry western forests. Dr. Baker teaches and researches fire ecology and landscape ecology at the University of Wyoming and is author of a 2009 book on “Fire Ecology in Rocky Mountain Landscapes.”

Contact Information:
Dr. Mark A. Williams, Program in Ecology and Department of Geography, Dept. 3371, 1000 E. University Ave., University of Wyoming, Laramie, WY 82071. Email: [email protected].

Dr. William L. Baker, Program in Ecology and Department of Geography, Dept. 3371, 1000 E. University Ave., University of Wyoming, Laramie, WY 82071. Phone: 307-766- 2925, Email: [email protected].

Fishers ‘n’ Fire

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In keeping with this weeks California wildlife theme, this was in E&E news the 22nd of December.

Thinning forests in the southern Sierra Nevada mountains may cause some harm to key habitat for an isolated population of fishers, but such fuel reduction treatments likely will benefit the weasel-like mammals over the long run by reducing the risk of severe wildfire, a recent study concludes.

Forest managers have targeted dense stands in the Sierra National Forest and other public lands in the region for thinning in recent years, but they’re also required to help protect the fisher, which is a candidate for protection under the Endangered Species Act.

The study, published in the most recent issue of the journal Landscape Ecology, used computer models to simulate how different fuel reduction scenarios, including a no-treatment scenario, would affect fisher habitat over 60 years, compared with the potential effects of a major wildfire on the same habitat area. The authors concluded that while thinning could cause some damage to the fisher’s habitat, a high-intensity fire is a greater threat.

Description: Pacific fisher

Rare Pacific fishers rely on downed trees for denning, prompting questions about the effects of forest thinning on the animals’ habitat. But a recent study suggests that reducing the risk of destructive forest fires through fuel treatments will benefit the animals over the long run. Photo courtesy of Fish and Wildlife Service.

“Our simulations suggest that the direct, negative effects of fuel treatments on fisher population size are generally smaller than the indirect, positive effects of fuel treatments, because fuels treatments reduced the probability of large wildfires that can damage and fragment habitat over larger areas,” the study concludes.

Fuel treatments typically involve removing dead wood, which fishers use for denning, from the forest floor, said Robert Scheller, an assistant professor of environmental sciences and management at Portland State University in Oregon and the lead author of the study.

“It’s pretty important for them to have a safe place to raise a litter,” he said.

But a major fire would also damage the population’s habitat, “potentially over much broader areas than the treatments intended to reduce wildfire risks,” the study states. A large, super-hot fire would likely kill larger trees, shrink the forest canopy and burn up dead wood, all of which could adversely affect fishers.

“The long, relatively narrow arrangement of suitable habitat means that one or more large fires could burn across it and isolate fishers on either side of the burn,” the study states. “Because both fuels treatments and wildfires can negatively impact fisher habitat, this system exemplifies a probabilistic, risk-minimizing balancing act for forest and wildlife managers.”
Small, isolated population

Biologists estimate the southern Sierra Nevada fisher population at about 300 adults, most of which live in a narrow, isolated band across the western slope of the Sierras, south from Yosemite National Park to the mountain range’s southern tip.

Scheller added that while the study found that the overall benefits of fuel treatments probably outweigh the risks, such treatments are still something of a gamble: If no fire ever scorches the area, then the damage to the habitat from the fuel treatments would be for naught.

“The question is, ‘What are the odds of a fire coming through those areas that have been treated?'” he said.

The study is part of a broader effort from the Forest Service to figure out how to protect fishers while allowing for timber harvesting and fuel treatments in Sierra National Forest. Under the National Forest Management Act and Sierra Nevada Forest Plan, the Forest Service is to help maintain viable, well-distributed fisher populations.

The fisher once roamed from British Columbia to the southern Sierra, but historic fur trapping and logging reduced its range to three native populations — the southern Sierra Nevada, Northern California and southwestern Oregon — as well as a reintroduced population in Washington’s Olympic National Park.

Environmental groups say that logging continues to threaten the remaining fisher populations. Several groups have filed a lawsuit to try to force the Fish and Wildlife Service to add the West Coast population of the fisher to the endangered species list.

“Without protection from continued logging on private and federal lands, the fisher will go extinct,” said Craig Thomas, executive director of Sierra Forest Legacy.

Here’s a link to the study. I was looking around on the web for other information and ran across this look at the impacts of fuel treatments with some potential mitigation of their impacts by Truex and Zielinksi….

Also this one from May:

Kings River Fisher Project — Progress Report

Researchers Craig Thompson, Kathryn Purcell, James Garner and Rebecca Green from the Sierra Nevada Research Center of the U.S. Forest Service have just released a progess report on 72 radio-collared fisher which they have been studying since 2007. The project area is located in the Kings River area, west of Shaver Lake in the High Sierra Ranger District of the Sierra National Forest.

The purpose of this study is to learn more about fisher ecology including their habitat requirements, and to increase understanding about the effects of timber harvest and fuels treatments on select response variables of interest, including fishers and their habitat.

The report is too large to post here (30 MB) but it can be downloaded from this website until June 22. Here’s an excerpt from the summary:

“Using a combination of telemetry and scat dog data, we generated a preliminary density estimate of 13.4 fishers per 100 km². We observed reproductive activity for 79% of the adult females monitored during two breeding seasons, with 45 kits observed at 31 natal dens. We located an additional 64 maternal dens in a variety of structures. Survival rates ranged from 0.61 for subadult males to 1.0 for juvenile females, and predation accounted for 81% of all mortality. Genetically confirmed predators include mountain lion (40%), bobcat (40%), and coyote (20%).

We generated 95% kernel home range estimates of 1,113 ha for females and 4,522 ha for males. In agreement with most published literature, fishers were found in areas of higher canopy cover. However they were also found more often in areas with higher number of small (<20” dbh) trees, indicating that these trees may provide requisite structure and canopy. Fishers avoided edges, particularly with respect to resting sites, and were found on the lower portions of north facing slopes more often than any other topographic position. Fishers used a variety of tree species and structures for resting, with the most common choices being cavities in black oak and white fir. Diet was dominated by mammalian remains, though we documented a large diversity in food consumed including plants, birds, reptiles, and insects."

I wonder if fishers and Sierra red foxes (also in consideration as endangered species here) might be in competition for the same prey species?

Very interesting to me was the structure of the Sierra Nevada Adaptive Management Team here. With the public involved and the public discussion forum here. It is an intriguing approach and may be a good deal for $12 million over 7 years.

Three Pathways to Adaptive Governance

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Adaptive governance—an adaptive management approach to public lands management—is well underway, and will replace planning, the Forest Service’s chosen management strategy for the 20th century. This may be seen as a bold assertion. But the ideas and actions embedded in adaptive governance have been emerging for quite some time as more and more people realize that 20th century notions cannot guide the Forest Service or any other government agency into the 21st century. Adaptive Governance framing is very different from scientific management/planning framing.

Gifford Pinchot’s “planned forests” guided Forest Service thought, policy, and action for the 20th century. (See, e.g.: here, here (pdf)). It was a model where humans sought to recreate and control Nature’s forests for utilitarian purposes. This model no longer serves. For the 21st century, we are better served with Aldo Leopold’s notion that humans humbly serve as plain members of a broader ecological community, and are not masters of the community. Still, humans must derive sustenance from the land and also re-create the human spirit via interrelationship with the land. To facilitate this transformation, a broad educational campaign in ecological literacy is needed. Part of that educational process can be effected via deliberative democracy in development of adaptive management strategies and actions, with its emphasis on learning not only to incrementally design and implement ever-better management actions, but also to design and implement ever-better management and science theory.

My assertion that adaptive governance is well underway stems from many conversations with planners, NEPA coordinators, and planning directors. It also stems from extensive reading in adaptive governance. [See, e.g. Adaptive Governance: Integrating Science, Policy, Decision Making (Brunner et al, 2005), Finding Common Ground: Governance and Natural Resources in the American West (Brunner et al, 2002), The Politics of Ecosystem Management (Cortner and Moote, 1999)]

At this time when we are discussing the recent Draft NFMA rule, I see three paths forward for the Forest Service: Leave the NFMA rule anchored in by-gone-era planning, while continuing to move toward adaptive governance in all other aspects of forest service thought/action. Develop a very simple NFMA rule that frees the Forest Service of much of the baggage of past NFMA rules, thereby allowing the agency to move forward into the adaptive governance era. Embrace adaptive governance in the NFMA rule.

If as expected the Forest Service chooses to embrace a slightly tweaked Final NFMA rule, which it now calls a “planning rule,” the major problem is that it will further erode trust—a much-discussed casualty of the highly controlled central planning methodology with its “jack in the box” public involvement strategies. [Yes, I’m aware that the Draft rule champions collaborative engagement, but we all know that the Forest Service has little intention to alter its current behavior of giving little more than lip-service to collaboration in forest planning, let alone in higher policy arenas. Besides, if as I’ve argued forest-level planning has little to offer re: adaptive governance, even extensive well-intentioned collaboration in that arena will yield little more than frustration and discontent.]

If the Forest Service chooses to develop a very simple NFMA rule, public interest groups may go along, recognizing that the US Congress is not likely to repeal, amend, or revise RPA/NFMA anytime soon, and that the Forest Service is already engaging stakeholders in adaptive governance discussions/policy actions. On the other hand public interest groups may not go along, if only beause the wicked problems surrounding “species viability” will not be quickly tamed. If the species viability questions can be addressed in (or around) a “simple rule,” public interest groups may move their attention to other arenas. There is a long-standing tradition in American government of leaving laws on the books long after enforcement of these laws makes sense. Think about how long city governments kept laws like “a hitching post will be provided every X feet along Main Street” on their books.

Finally, if the Forest Service chooses to embed adaptive governance in the NFMA rule, it can serve at once as a wake-up call to the Congress to revise RPA/NFMA and simultaneously relieve forest-level burdens now imposed by an anachronistic planning rule—currently the 1982 planning rule. It can also serve as a means to rebuild trust!

I’m betting on a simple tweak of the Draft rule, but hoping for one of the other two paths.

Mark Squillace in New West on Proposed Planning Rule

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Here’s the link .

Here are a couple of quotes:

Decades of land use litigation have crippled the Forest Service’s planning process, causing the agency to become over-cautious and vague, according to environmental lawyer and scholar Mark Squillace. A proposed national planning rule, for which public comments close on May 16, is too complex, time-consuming, and fraught with unnecessary choices that invite litigation, says Squillace, director of the Natural Resources Law Center at the University of Colorado School of Law in Boulder.

“I really think the forest planning process is broken, and one of the reasons is they spend so much time revising the plan and they don’t really improve it, because it becomes static over time.” he says. “It’s really about monitoring, not assessment. What you want is a monitoring program that’s constantly looking at what’s happening in the forest.”

Squillace, who has worked in the Department of the Interior and was director of litigation for the Environmental Policy Institute in Washington, D.C., says monitoring of many conditions, such as the population status of species, soil moisture, and pathogens, should all feed back into the assessment reports of national forests that are compiled every two years, which in turn would be used to alter the national plan. “If it’s done right, you’ll virtually never have to do another plan at all, because it’s constantly changing.”

Squillace applauds the public input. “I think the process they’ve used has been exemplary. They’ve really tried to involve people in a meaningful way.”

But at the national forum, he asked a Forest Service panel if they had considered options to make the plan development process simpler, such as resource-use plans at the level of the individual forest that would avoid the complicated standards and guidelines built into the national plan. “I think right now the public often loses the forest for the trees because of the detail, the complexity, of the plan,” he said.

On science,

In terms of the role science would play in resource management, Squillace worries that the language of the draft plan requires only that officials “take into account the best scientific information throughout the planning process.” Such weak wording could turn the rule’s scientific standards into a paper tiger, he claims.

He cites a comment made by a member of the public during the national forum that there is no “best science,” only competing views. He disagrees vehemently. There may be a level of uncertainty, as with climate science, he says, but the agency cannot avoid a preponderance of scientific opinion simply by noting that scientists may take different views.

“The Forest Service is increasingly careful about not setting standards that will tie their hands,” he says. “To me, that’s the essence of planning: making choices.”

Even so, Squillace says the Forest Service has trouble making such site-specific analyses, because the resources required for the national planning process detract from resources needed for project-level studies. “I can say with confidence that this kind of thing has happened in many forests.”

One of his answers to the problem is to use more maps, to help visualize resource questions or threats. From the many meetings he has attended over the years, he says his sense is that the public mainly wants to know what uses of national forests will and will not be allowed. Maps that show such uses, or zonings, already are made by the Forest Service, he says. This should be extended to maps that designate the suitability of tracts of land for particular uses. Other maps could display watersheds, wildlife habitats, ecosystems, and ecological conditions. They could be designed as overlays, so the public could see how such resources interplay with the suitability of a given tract of land for various uses.

“Maps provide a really transparent way, I think, to engage the agency in what the public would like to see,” he says. This would help everyone to analyze use options. “We fight it out, if you will, in the decision-making phase.”

I agree with most of his points, especially about the public’s interest in lines on maps.

However, it is interesting that his views of science seem to be different than Toddi’s below. Maybe we are talking past each other, but I have noticed that people in the law profession (this is my current hypothesis) seem to have the idea that decisions can be hardwired to some “science.” Following Toddi’s post, it will be interesting for us to note who makes these claims about science and see if those claimants fall into any kind of pattern. In the past, I’ve noticed this coming from NGO’s with many lawyers on their boards and staffs. Scientists themselves tend to be more cautious. And of course, people who study this kind of thing academically (STS or science policy studies) sound like Toddi’s lecture.

Also, Squillace said:

“They make it impossible to challenge monitoring,” Squillace charges, “because monitoring reports every two years are not decisional documents, so they’re not reviewable.”

I don’t know the utility of legal challenges of monitoring per se… I’m sure something got missed in the interview here. Based on other conversations, I think he means challenging legally decisions made or not made on the basis of that monitoring.. but the NEPA of the decisions themselves could be challenged..??

And finally..

Squillace thinks the agency should look to legal precedents that argue in favor of analysis of individual ecosystems rather than concentrating on the “bird’s eye view.” He points to a 1987 case in Wyoming concerning oil and gas leases on more than 10,000 acres of the Shoshone National Forest. In dismissing a suit brought by the Park County Resource Council that contended the Environmental Impact Statement was inadequate, a court of appeals ruled that a comprehensive EIS is not required at the leasing stage. Nine out of ten leases do not result in exploratory drilling, the court noted, concluding that site-specific environmental assessments should be made before a particular drilling project actually occurs.

This finding was strengthened the following year, when another court of appeals ruled that federal agencies did not violate law in selling oil and gas leases on 1.3 million acres of the Flathead and Gallatin National Forests in Montana without preparing an EIS.

Is he arguing that forest plan EIS’s are not particularly useful? I seem to remember others who thought this…during the 2005 (Mark would probably call it the “Bush” ;)) Rule.

Fixing the Rule: An Adaptive Governance Roadmap

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If adaptive governance, i.e. adaptive management applied to public lands, might help move beyond ongoing forest wars, how might the Draft NFMA Rule (pdf) be improved toward adaptive governance? This post outlines my ideas for improving the rule. Ultimately, I’d like to see us vet this proposal when more fully developed, against the Forest Service’s Draft Planning Rule, Andy Stahl’s KISS Rule, and any other proposals that may be floating about. But before I put pen to paper, I’d like to get feedback on my ideas. Here is how I propose to “fix” the rule:

Background Notions

  • No matter what NFMA rule is put in play, it needs to be written by lawyers. Court challenges will not cease no matter what rule is in force.

  • I like the idea of adaptive governance, but also believe that adaptive management as applied to public problems is the same thing. I do not have a strong preference for which words, “adaptive governance” or “adaptive management” are used to described the process. I will use “adaptive management” here. There are many pathways that might be taken to adopt an adaptive governance approach to management. It may be that embedding adaptive governance into the NFMA rule is not the best path forward. I’m willing to listen to other possible pathways, and even alternatives to any adaptive governance pathway. But I still believe that the Draft Planning rule fails as adaptive management, and can not provide a useful path forward.

Reframing/Rewriting the NFMA Rule

  • Rewrite the “Purpose and Applicability” (219.1) (and also the “Summary” and “Overview” in the Federal Register run-up to the rule) to include reasons for a move away from narrowly framed forest planning and toward broader public engagement to address forest management’s wicked problems. Include a discussion of decision containers [See, this note] and how the public needs to help natural resource managers frame discussions/resolutions, including scope and scale. Allow wicked problem discussions/resolutions to well-up to appropriately sized containers so that people don’t have to grapple with policy at local scales, where such does not makes sense. Include “all lands” decision-making where and when appropriate, allowing for responsible officials to include but not be limited to Forest Service officials.

  • Define adaptive management, then do a near “global replace” of “planning” with “adaptive management.” A beginning point for a definition of adaptive management might be:

    [Adaptive Management]: linking a broad range of actors at multiple scales to deal with the interrelated dynamics of resources and ecosystems, management systems and social systems, as well as uncertainty, unpredictability, and surprise. Adaptive governance focuses on experimentation and learning, and it brings together research on institutions and organizations for collaboration, collective action, and conflict resolution in relation to natural resource and ecosystem management. The essential role of individuals needs to be recognized in this context (e.g., leadership, trust building, vision, and meaning); their social relations (e.g., actor groups, knowledge systems, social memory) and social networks serve as the web that tie together the adaptive governance system. It has cross-level and cross-scale activities and includes governmental policies that frame creativity.

    From “Adaptive Governance of Social-Ecological Systems”, Carl Folke, Thomas Hahn, Per Olsson, and Jon Norberg, Annu. Rev. Environ. Resour. 2005. 30:441-473 (pdf)

  • Keep “forest plan,” but define as suggested by the Clinton era Committee of Scientists: “A loose-leaf notebook that contains all of the policy directions, strategies, and implementation proposals from decisions that have been made at all levels of the planning process. It is the official repository of decisions big and small that have been made and reviewed in the strategic and landscape-level planning processes.”

  • Keep the tie to the FS Strategic Plan, but add more responsibility at the Chief’s office to make sure that adaptive management is real—a cultural change, more than just words—and something that “the Forest Service does”, not something delegated to a single staff group like “planning” or “ecosystem management.” In short, position most responsibility for RPA/NFMA to the Chief and/or Secretary of Agriculture.

  • Replace “three levels of planning” (219.2) with “multiple levels of adaptive management assessment, monitoring, and decision-making.” Make sure that “all lands” assessment, monitoring, and decision-making, done in concert with appropriate collaborators is the logical choice when such makes sense. [See, Why Three Planning Levels?]

  • Keep the idea of “standards and guidelines” (219.7) but make the development and revision of both “situational” at appropriate scope and scale. The idea is that most would be developed at levels other than a “national forest.” Still, forest supervisors would be charged to show how such standards apply to decisions they make. Similarly for assessment and monitoring information, as well as for policy decisions and legal authorities.

  • Add the idea of a “forest niche,” that would be reviewed publicly at, say, five-year intervals. [See, A Forest Service for the 21st Century Who Are We? to better understand niche idea for the Forest Service as a whole.]

  • Abandon the idea of “desired conditions,” instead allow for simple “scenario planning” that would embrace the idea of emergent unfolding future as opposed to managing toward a desired future. Note that this idea interfaces with the idea of “niches” above and does not preclude working toward betterment. It just moves the “betterment” debate into the policy arena and away form the land planning arena. [See: Whose Desire? What Future? Why?]

  • For specific requirements of NFMA law, craft wording to require the WO (and it’s bevy of legal counselors) to find means to comply with said requirements as expeditiously as possible at scale and scope as close to “national” as possible. For example, the requirement for an Allowable Sale Quantity might be set nationally at zero, with provision that all timber volume flowing from the national forests be determined via adaptive management and in the context of, say “ecosystem stewardship contracting,” or equivalent internal process.

Followup

I still intend to work up a complete rewrite of what I’ll call a “Draft NFMA Rule” soon. But I would like your feedback on these ideas now.

I have been chatting with a friend about the “Pre-Decisional Administrative Review Process” (219.50-59). We believe that if collaboration were much improved and allowed for multi-scale adaptive governance, the whole idea of “pre-decisional review” makes no sense, and perchance neither does any “appeal process.”

Finally, I may probably won’t include language relative to the “species diversity” provisions from NFMA. That will no doubt be the most fought-over part of the rule. Still, I maintain that the adaptive management fight is equally important. In my framing, species diversity is one of the items that the WO and its bevy of legal counselors ought to deal with. In all such “dealing” I believe that such policy review/policy revision ought to begin early, even perchance predating the adoption of a NFMA rule. Why the Forest Service runs so much of its policy development through “NFMA forest planning” remains a mystery to me.

It’s Complicated: Forest Management’s Wicked Problems

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Most people view the problems of forest management from the narrow perspective of their own interests. They understand that there are “many great interests on the National Forests which sometimes conflict a little,” as Gifford Pinchot described the situation a century ago. While we must honor specific interests, the Forest Service’s charge under Organic Act of 1897 stewardship framing, then broadened and altered by subsequent law is more complex. It is never as easy as getting folks together to sit across a table and working out a “forest plan.”

The Forest Service came into being at the end of a very rapacious period in American history. Hence the emphasis on “reserves” in the Organic Act , and later in the Weeks Act of 1911. The public lands had been attacked by many as the so-called settlement of the American West proceeded after the Civil War. It was perceived and used as a “commons” and plundered and burned in too many places. That caused the public outrage that led to the forest reserves.

After successfully bringing the reserves into the national forest system, Gifford Pinchot wanted to regulate all forest practices in the US. Pinchot could not achieve his dream, and the private lands were over-cut for a long time. Even Weyerhauser, where I worked for a summer in the late 1970s—and deemed the “Best of the SOBs” by Forbes magazine, knew but were reluctant to admit in public that their “fee lands” were being cut faster than their “High Yield Forestry” tree farms could replace the volume being cut and milled during that late period of the US housing boom. There would be a “gap.” And sure enough, just as soon as their and other private land owners “gaps” appeared the pressure mounted to cut the national forests. And cut they did, until the environmentalists, working public attitudes/pressures/law shut it down, amid great angst for locals particularly in the Northwest.

As the timber wars raged, more people with new-found affluence were using the national forests and more conflicts emerged between recreationists and cattle and sheep grazers on the national forests. And there were two emergent back-country recreationist movements that were destined to clash one with another: the “primitive back-packers” and the “ATV/OHV users”. In addition, primitive canoe, kayak, float boat enthusiasts were clashing ever-more with commercial outfitters and motorboat enthusiasts, not to mention personal watercraft. And then there were Wilderness advocates clashing against motorheads of all ilks. The wars were on.

Amid this upwelling of controversy, the US Congress penned the Renewable Resources Planning Act of 1974. But before the ink dried on that law, timber cutting on the national forests, clearcutting to be precise slammed to an immediate legal halt via a lawsuit on the Izaak Walton League. Then under a panic to reopen clearcutting on the national forests, the National Forest Management Act of 1976 was born, and so was forest-level planning. But there was little in either the RPA nor its amendment the NFMA that was destined to settle the controversies. The controversies were the stuff of wicked problems in public forests as noted first by Allen and Gould in 1986.

So here we are more than 30 years after NFMA, with the same controversies raging, overlaid by more people wanting more (and different) things from the national forests, more people living much closer to the national forests, global climate change controversy, species loss controversies that stem from more people (and roads/dams/power lines/energy corridors/etc.) across the landscape and from more stress on both “sources” (resources) and “sinks” (particularly air and water sheds where pollution is dumped)added in, etc..

And all the while the Forest Service continues to pretend that forest planning, pretty much as designed in the late 1970s, but having dropped economic rationality in favor of ecological rationality, will somehow save the day. Or at least that’s how I read the Draft Planning Rule (pdf)

It is my feeling that the only path forward that will afford any chance to allow forest users to sit across tables and talk seriously about prudent use of individual forests, watersheds, or mountain ranges, is for their to be some means to continue to discuss, debate, and develop policy for “broader scale” issues that will set boundaries on discussions of use and conservation at “local scales,” including but not limited to the national forest-scale.

That is why I continually suggest that an Adaptive Governance approach be developed in the NFMA rule. It could as well be developed apart from the NFMA rulemaking process. But until and unless it is developed, there is little or no chance that national interest groups will allow for the type across-the-table “use discussions” that more local interest groups advocate. This conclusion is not mine alone. Consider this from 1999, subtitled Making Sense of Wicked Problems:

What is the answer then, to these complex (wicked) problems? How do we organize ourselves to deal with diverse values and expectations about sustainable forest management? Shannon (1992) asserted that the answer lies in the notion of informed governance. That is, we need places where people can learn, question, debate, and come to an informed judgment of what choices are best (FEMAT 1993). In Coming to Public Judgment , Yankelovich (1991) determined that the most critical barrier to making effective and informed choices in a complex world is the lack of forums in which the process of “working through” value differences and preferences can occur. There is growing support among natural resource professionals that a public dialogue must be an integral part of achieving social and political acceptance of forest practices (e.g., Bengston 1994, Clark and Stankey 1991, Shepard 1992). Regardless of value differences, if people are to come to an understanding of, if not agreement on, the problems and choices that confront public lands management, it is likely to be in public forums where open and honest discussion can occur. Unfortunately, from their research on adaptive approaches to forest management, Stankey and Shindler (1997) conclude that such forums are most notable by their scarcity. (emphasis added)

Anybody want to explain to me where I (we) have got it wrong?
[Note this post was precipitated by this comment. Thanks Brian]

The Art and Promise of Adaptive Governance

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Adaptive Governance is art and science, blended with management and politics. It is art since political decision-making is an art. One face of adaptive governance is a dance wherein public land managers engage with particularly ecological and social scientists in learning from experience about transformations in ecosystems and institutions. The dance is broadened further, since both managers and scientists dance with the public, both as interested individuals and communities of interest alongside communities of place.

The promise of adaptive governance for the US Forest Service and other public lands agencies is that it might heal the wounds from many of the forest and rangeland wars that have only festered during thirty years of failed rational planning games. The promise too is that if properly framed and practiced, adaptive governance could free up talent at the national forest level to do the many worthwhile jobs that need attending to at that level, like road, trail, and campground and other recreation-related maintenance, like permit administration, and program and project management (fire, timber, recreation, minerals, grazing, etc.), like attending to trespass and encroachment problems, fragmentation of land ownership patterns/problems, and so on. Forest-level people would not have to attend to many tasks now burdening them under the current “planning” frame—framed as rational planning with public input.

One problem I’ve been harping about for years is that “wicked problems” can not be tamed via rational planning. They have to be attended to through the art of political decision-making. Take a look at the Fishlake National Forest in central Utah, for example. It is widely known for its ATV experiences, jamborees, etc. It is also a relatively easily-accessible place for big game hunting, via various sorts of Off Highway Vehicles. [In younger years I used to wander the roads there, and wander off the roads, looking for big mule deer.] The decisions, or political/social happenstance, that took the Fishlake in this direction, are the stuff of politics, not science.

Some of the tasks that now appear to be the responsibility of forest-level managers and practitioners would be handled closer to the center or the Forest Service (and at the center, the USFS Washington Office). These are the tasks of landscape and broader-scaled assessments, monitoring efforts, and related problem staging/resolution/learning as adaptive management policy-setting. In addition, the center of the organization would be held accountable to steer and monitor deeper “double-loop” learning that comes from thoughtful examination, reflection upon, and learning from “Transformations in Human and Natural systems,” the subtitle of Lance Gunderson and CS Holling’s Panarchy. Finally the center of the Forest Service would be the keeper of the Vision/Mission of the agency, reconciled appropriately with the Congress and the Administration. [Note: Mission/vision stuff should not be framed as “NFMA planning,” but still might be part of broader strategy setting and contained-in-part by a FS Strategic Plan.]

Critiquing Adaptive Governance
I have spent the last week or two trying to better understand applied adaptive governance, to see whether the time to try it formally on American public lands is at hand. I ran across several interesting investigations [which I’ll not link to today, but may detail further later], looking into the art and practice of adaptive governance or what we might call adaptive management in its public form. In almost every case the authors were reluctant to embrace adaptive governance fully since the track record is not very good, for various and sundry reasons. Once problem frequently noted was that the practice was too technical, too much engaged in “scientific rationality.” On the other extreme, some authors noted a tendency for unwarranted devolution; wherein the process was captured by too narrowly framed interests, often dominated by “locals.” In almost every case, US authors failed to investigate the influence of “political backlash” by the Bush/Cheney Administration as they waged war on the Clinton Administration’s initial strides at adaptive governance under banners of “Ecosystem Management” and “Collaborative Stewardship.” This backlash began earlier with the so-called “Gingrich Revolution”— remember the “Contract On With America”? [Want some fun? Google up: “contract with america” “public lands”] Why was the backlash missed? I don’t see how you can separate adaptive governance efforts from the politics that enfold them.

As mentioned earlier, critical review authors cite the fact that adaptive management in its public form is too technical, too much centered in technocratic rationality. But adaptive governance need not be so burdened. Adaptive governance can operate in policy-development spaces far apart from those where “adaptive management experiments” are structured, tested, and rationalized. But it can embrace those too, where they make most sense. This is the direction some of us tried to take the Forest Service in the early 1990s, under the banner “A Shared Approach to Ecosystem Management,” outlined in part here. It lives today under the banner “adaptive governance.”

Embracing Adaptive Governance
An important aspect of the emergence of adaptive governance is that it is about humans and their institutional settings—that these often fall into the same rigidity traps (problems of overly-tight coupling) and poverty traps that we talk about in so-called natural systems. This is easily seen through the lenses of Compass and Gyroscope: Integrating Science and Politics for the Environment (1993), Barriers and Bridges to the Renewal of Ecosystems and Institutions (1995), and Panarchy: Understanding Transformations in Human and Natural Systems (2002).

I believe that the time it right to more-fully embrace adaptive governance—to replace what has been forest planning. But a big barrier is that the Forest Service remains a technocracy, a big-believer in science and management, with little or no formal emphasis on the art of “forestry,” the art of “political decision-making,” etc. I remember all too well the many Forest Service social science meetings where I complained that two words (and practices) were forbidden in both voice and action: politics and psychology.

In a future post I will lay out a roadmap to begin that journey as a rewrite to the administrative “rule” that is being batted around in Draft form, improperly framed as a “planning rule.” Here, I’ll just leave one definition of adaptive governance. Maybe someone here can come up with a better one.

Adaptive Governance: linking a broad range of actors at multiple scales to deal with the interrelated dynamics of resources and ecosystems, management systems and social systems, as well as uncertainty, unpredictability, and surprise. Adaptive governance focuses on experimentation and learning, and it brings together research on institutions and organizations for collaboration, collective action, and conflict resolution in relation to natural resource and ecosystem management. The essential role of individuals needs to be recognized in this context (e.g., leadership, trust building, vision, and meaning); their social relations (e.g., actor groups, knowledge systems, social memory) and social networks serve as the web that tie together the adaptive governance system. It has cross-level and cross-scale activities and includes governmental policies that frame creativity.

From “Adaptive Governance of Social-Ecological Systems”, Carl Folke, Thomas Hahn, Per Olsson, and Jon Norberg, Annu. Rev. Environ. Resour. 2005. 30:441-473 (pdf)

Related:
Adaptive Governance and Forest Planning, John Rupe, NCFP, Feb. 2010
Book review of Adaptive Governance: Integrating Science, Policy, and Decision Making, by Ronald D. Brunner, Toddi A. Steelman, Lindy Coe-Juell, Christina M. Crowley, Christine M. Edwards, Donna W. Tucker, 2005
Collaboration Reading for Thoughtful Practitioners, Dave Iverson 2006
Taking Uncertainty Seriously: Adaptive Governance and International Trade (pdf), Rosie Cooney and Andrew T.F. Lang, The European Journal of International Law 18(3), 2007

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.

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

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.

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