adaptive management

Monitoring Paper from Lindemayer and Likens- Practitioner Stamp of Approval

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When I read an academic paper that describes the world as we practitioners know it and propose practical situations, it’s an award-worthy thing.

Here is a great (in my opinion) review paper Lindenmayer&Likens2010.Science&ApplicationEcologicalMonitoring that resonates with some of my simplistic comments about how we approach viability in the post below.

Here’s some of my favorite quotes from the paper- what are yours?

5.4. Squabbles about what to monitor
An alternative response by some workers to the ‘‘laundry-list” approach has been to argue that ‘‘indicator species” or ‘‘indicator groups” should be the targets of monitoring programs (Andersen and Majer, 2004; Cantarello and Newton, 2008; Dung and Webb, 2008; McLaren et al., 1998; Sparrow et al., 1994; Spellerberg, 1994; Woodward et al., 1999). Many would argue that the group of organisms they study is special and any valid monitoring program cannot proceed without including them. We have found that over 55 major taxonomic groups have been proposed as indicators for monitoring programs, ranging from viruses and fungi and bryophytes to invertebrates and virtually all major vertebrate groups.
We found that only very rarely was it explicitly stated: (1) what these species or groups were actually indicative of, particularly at the ecosystem level and (2) the circumstances where these species or groups were or were not appropriate indicators. We believe that the problems of ‘‘laundry lists” and indicator species can be avoided by carefully crafting questions at the onset of a monitoring program, using a well-conceived model to help conceptualize a particular ecosystem and make predictions about ecosystem behaviour and response (see below). These key steps will help identify those entities most appropriate for monitoring.

I have sat through some very painful laundry list and “you should monitor them because I who have studied them for thirty years say that they are critical to the ecosystem” kinds of discussions. Here’s to clarity about why you want to monitor things, and why you think they are more important than other things you could be monitoring!

True collaborative partnerships are also essential because policy-makers and resource managers will often not know how to
frame questions in ways that can be resolved by well-executed monitoring, or may initially pose too many questions without prioritizing them. They also may have unreasonable expectations about what questions or problems can and cannot be solved by scientific projects and how much effective monitoring can cost. Thus, policy-makers need to understand better the scientific approach and the importance of posing the right questions in the correct way. Conversely, scientists need to articulate better what kinds of questions they can and cannot answer. They also need to understand
better the complexity of the policy process (Clark, 2002;Pielke, 2007). Scientists will often not fully comprehend the kinds
of key problems faced by policy-makers and resource managers that need to be addressed by long-term monitoring (Russell-Smith et al., 2003). Nor will scientists necessarily be fully aware of the policy options and the range of on-ground, management interventions available for testing and monitoring in a particular ecosystem (Walters, 1986).

And, eerily similar to the earmark idea:

Access to funding is an obvious factor influencing the success of monitoring programs. Many aspects of funding are not well suited to the establishment and maintenance of such programs. Monitoring programs are often seen as a luxury and not core for many resource management organizations. They are therefore usually the last initiatives to be funded and the first ones to be cut during budget shortfalls. In addition, budget cycles emphasize short-term projects
with rapid achievement of milestones. Funding initiatives of 1–3 years are rarely congruent with the timeframes appropriate
for effective monitoring. Thus, there often is a fundamental mismatch between long-term environmental management aspirations and short-term financial realities. We believe funding models based on endowments may be useful to circumvent problems associated with short-term funding problems. An outstanding example is the 175-year research program at Rothamsted in England (Rothamsted Research, 2006).

Fixing the “Rule”

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As we have been discussing in previous posts/comments, one possible resolution to the forest planning dilemma — as part of NFMA rule development — is to deal with what has been called forest planning under the broad umbrella of adaptive governance, or adaptive co-management.

A part of the process would be to require an “every five years review/evaluation” of ALL decisions related to or interrelated with an administrative unit of the national forest system. This was recommended by the Clinton era Committee of Scientists as I recall. The evaluation, along with a database of all decisions relating to the FS unit would be all that a new rule would require. Specifics required by the law could be packed into the review/evaluation requirements or allowed in other decisions fitting into “ALL decisions” above. Note that most decisions would be appropriately framed (scale and scope) and dealt with as wicked problems (Wikipedia, EcoWatch) at levels above or below the forest administrative unit—on rare occasions “at” the level of the administrative unit.

The “review” might be accompanied by some simple scenario planning (Wikipedia) — which is more the stuff of futuring than of planning — to deal with emergent, but unknown, even unknowable futures. Note that scenario planning specifically avoids the “desired future” trap.

My vision of the every-five-years-evaluation would also allow for “niche” statements to be developed for a forest unit (perhaps for appropriate subunits as well). As with “scenario planning”, the Forest Service/USDA might or might not require niche statements in the NFMA Rule. My preference would be to include both, but with a strong caution not to over-complicate “requirements”, in the rule, in manuals, in handbooks.

I would be pleased to see the Forest Service adopt such a resolution or to at least explain how such is inappropriate framing (Wikipedia) for RPA/NFMA forest planning/management, or inferior to alternate proposals. Maybe some who frequent this blog can step up and explain any inappropriateness in advance of what will likely be yet-another nonresponse from the Forest Service. Or maybe you will like it, and will offer up suggestions for improvement. I am very concerned that the forthcoming “show and tell” NFMA Rule meetings will yield no useful results. So any suggestions coming from us here may be the Forest Service’s best hope to avoid another wasted 30 years.

Related:
The Frame Game
A Simpler Way (Forest Policy-Practice, 2006)
Interrelated Ecosystems and Adaptive Management, (EcoWatch, 1992)

Lessons from the Northwest about Commitment to Adaptive Management

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Diagram from Dept of Interior Adaptive Management Technical Guide

Adaptive management could be a component of a new planning rule.  In previous posts we’ve discussed the need for adaptive governance.  We’ve discussed the legal challenges.   In a previous discussion thread, Martin points out what some consider a flaw in the 2005/2008 planning rule, where we “simultaneously deep six NEPA (at plan level) while forwarding some ill-defined adaptive management/EMS framework.”   But is it possible to make the commitment to adaptive management?  Does the Forest Service have the management and science capacity? 

It’s worth considering the experiences in the Pacific Northwest.  In a previous thread, Andy provided a link to a paper by Forrest Fleischman.  Here’s part of Fleischman’s analysis:

“Examination of existing literature on the implementation of adaptive management by the USDA Forest Service in the Pacific Northwest offers a few key lessons, however it also raises many interesting questions that cannot be answered with existing data. All of the literature indicates that the designation of areas devoted to adaptive management was not a successful strategy for promoting adaptive management. It appears that only one adaptive management area actually implemented anything that could be called adaptive management, and in that one case, the administrative designation does not appear to have been an important causal factor – instead, it appears that the designation occurred because of innovative research that was already occurring at the site.” p. 17

Here is a presentation from a 2005 conference from Forest Service research scientist Bernard Bormann on adaptive management in the Northwest Forest Plan.  Here and here are some additional publications.

In his presentation, Bormann says that adaptive management is harder than they first thought because adaptive management was never considered a “core business”, and most adaptive management areas are now idle. There are institutional barriers including lack of leadership, low budgets, and lack of learning structures. One idea he has is that the next generation of plans might contain “learning objectives.”  

There are many compelling reasons for the Forest Service to move from an “event driven” planning model (where large plan revision efforts occur every 15 years) to a more “continuous” planning model.  NFMA itself says that the planning rule should “insure research on and (based on continous monitoring and assessment in the field) evaluation of the effects of each management system to the end that it will not produce substantial and permanent impairment of the productivity of the land.” 16 USC 1604(g)(3)(C)    What will it take to successfully implement this requirement?

 

What Have We Learned Since the COS Report?

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Thanks to the generosity of the Society of American Foresters, we can post articles from the Journal of Forestry May 99 edition on this blog. This edition of the journal focused on the COS Report. Today I’ll post the Norm Johnson article here.

Since 1999, we have tried many of the ideas that the COS brought forward. I would be interested in how you all think these ideas have worked.

I will post later this week on my experience with trying out some of these concepts.

CEQ Guidance Comment Period

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Since we spend some quality time on this blog talking about NEPA, you might be interested in commenting on this draft CEQ guidance. the climate change and mitigation and monitoring might be particularly relevant to our discussion, since the draft guidance seems to extend the NEPA regs to past implementation of the decision. Here are some questions relevant to federal land management, and the bolded ones seem to have to do with LMPs:

CEQ also requests comment on land and resource management issues, including:
1. How should NEPA documents regarding long-range energy and resource management programs assess GHG emissions and climate change impacts?2. What should be included in specific NEPA guidance for projects applicable to the federal land management agencies?
3. What should be included in specific NEPA guidance for land management planning applicable to the federal land management agencies?4. Should CEQ recommend any particular protocols for assessing land management practices and their effect on carbon release and sequestration?
5. How should uncertainties associated with climate change projections and species and ecosystem responses be addressed in protocols for assessing land management practices?
6. How should NEPA analyses be tailored to address the beneficial effects on GHG emissions of Federal land and resource management actions?
7. Should CEQ provide guidance to agencies on determining whether GHG emissions are “significant” for NEPA purposes. At what level should GHG emissions be considered to have significant cumulative effects. In this context, commenters may wish to consider the Supreme Court decision in Massachusetts v. EPA, 549 U.S. 497, 524 (2007).

Here’s the link.

New CEQ NEPA Guidance In conjunction with NEPA’s 40th Anniversary Celebration, CEQ is publishing three draft NEPA guidance documents for review and comment. Below are links to the draft guidance documents and instructions for submitting comments:

– ESTABLISHING AND APPLYING CATEGORICAL EXCLUSIONS

Comments are due 45 days after publication of the Federal Register notice.

Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa

– MITIGATION AND MONITORING

Comments are due 90 days after publication of the Federal Register notice.

Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa

– CONSIDERING GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE

Comments are due 90 days after publication of the Federal Register notice.

Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa

Additional information is available at www.whitehouse.gov/administration/eop/ceq/initiatives

The Frame Game

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There is power in “framing” political discourse and policy development: Those who control the frame, control the content, the context, and more. In short, “He Who Sets the Frame Controls the Game”.

What just happened in the NFMA Rule Development game? The comment period closed yesterday. The frame was set by rehashing experience in planning, then constructing five “Substantive Principles for a New Rule” and three “Process Principles” (each with a battery of related questions). How many people, do you suppose, chose to respond outside that frame? How powerful was the frame?

In my formal comment I said that I wish the Forest Service had simply established a blog, and begun with a simple question, like: “Given the noble ideas embedded in RPA/NFMA (Wikipedia link) and other principal laws related to the Forest Service, how might the planning/management process of the USDA Forest Service be improved?” Then I said that I hoped someday the FS would indeed engage the public in meaningful inquiry as to its operations and the management of the national forests. Not yet, though. I added:

Unfortunately but not unexpectedly given the RPA context, these regulations have been dubbed a “planning rule.” If one looks at RPA/NFMA through the lens of adaptive management, the process outlined in Section 6 looks much different than if one views it through the lens of comprehensive rational planning. Unfortunately, all previous “NFMA rules” (and associated forest plans) have been developed under the “comprehensive rational planning” frame.

We must remember that the Clinton era Committee of Scientists recommended that a forest plan be viewed through an adaptive management lens — viewed, figuratively, as a loose-leaf compendium of all assessments, decisions, monitoring and evaluation efforts, etc. that affect an administrative unit of the national forest system. …

If so-called “planning rule” development is viewed, once again, as yet-another comprehensive, rational planning exercise, the agency will be mired again in analysis paralysis and process gridlock. If viewed as a mandate for adaptive management with a heavy dose of collaborative engagement on the part of other agencies, other governments, and citizens, then a whole new world of opportunity and challenge opens up to the Forest Service.

Please do not fall into the ‘planning trap’ again.

Now we wait for “next steps” and for a “Draft Rule.” And we hope that we — all of us, both the Forest Service and the public — won’t be trapped in an inappropriate “frame.” It is not that I believe that the Forest Service deliberately manipulated the “frame” in this case. Just the opposite. I believe the Forest Service fell into common decision traps: “frame blindness”, “lack of frame control”, “plunging in”, others?

Related:
Adaptive Forest Management blog
Earth to FS Planning: Get a Blog!
The Forest Service as a ‘Learning Challenged’ Organization, (1999)

Adaptive Governance and Forest Planning

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Army Officer at Nine Mile Camp, Mt. Baker National Forest, 1933, photo by W.L. Baker

The more we look at the literature, the more evidence we find that our current NFMA management system doesn’t align with the current thinking about land use management.  We gravitate toward adaptive management, but we don’t quite grasp it yet.

A slight twist on the adaptive management idea is the concept of “adaptive governance.” The word “governance” instead of “management” recognizes the collaborative aspects. It’s similar to the idea of “adaptive co-management”  that Dave Iverson has described in his post here and here on this blog, citing the summary from the Resilience Alliance.

The concepts of adaptive governance are worth considering in the forest planning and management system for a couple of reasons. First, it includes the idea of learning-oriented planning similar to what Jim Burchfield proposes in his earlier post on this blog. Second, the role of science is different. Instead of relying on scientific management as the foundation for policy development, adaptive governance integrates various types of knowledge in a contextual manner.  This is similar to what Sharon describes here and here about analyzing specific questions posed by land managers and the public .

In the book Adaptive Governance: Integrating Science, Policy, and Decision Making by Ronald Brunner, Toddi Steelman, Lindy Coe-Juell, Christina Cromley, et. al., the authors use five case studies across the West.  amazon.com oxford journal review

The authors make the following points about adaptive governance:

  • Planning sets goals. You try alternatives. The burden of decision making shifts to monitoring and evaluation and terminating policy alternatives that fail.
  • No policy is permanent because interests, knowledge, and other significant details of the context are subject to change.
  • There is an understanding that politics are unavoidable. Participants assume responsibility and accountability for the policy because they must live with the consequences of implementing it.
  • Best available science is integrated with other kinds of knowledge, including local knowledge.
  • Science must be contextual, necessitating interpretations and judgments that integrate what is known about the context.

These guidelines appear to converge with other ideas that we’ve noted on this blog.  There seems to be evidence that this works.  Although NFMA and the previous forest planning rules are grounded in the scientific management process, the 2000, 2005, and 2008 rules introduced the concept of collaboration in all aspects of planning, monitoring, and evaluation, and required the consideration of uncertainty and risk. But what is missing in those rules is the idea that we are committed to using dynamic monitoring and a collaborative evaluation process in order to change policy.  For those that think that the NFMA planning rule is just about writing a Forest Plan, this would be a huge surprise and some would argue, a wake-up call.  Are the concepts of adaptive governance the next step?

Weaving Discussion Threads Together

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Once a week or so, I will try to weave some of the discussion threads from the past week together. There are many interesting ideas in posts that any of us may not have time to respond to in real time, but may be working in the back of our minds somewhere.

Here’s an attempt for the past couple of weeks:

There is the minimalist, timber-only, view of planning – Andy’s KISS approach, which keeps us legal with NFMA. This seems pretty well developed.

Then we have some consensus around something like an “adaptive governance” .
ADAPTIVE GOVERNANCE
On some timeframe, at some appropriate spatial scale (a forest or subsection of forest or Forest/BLM combination ?), a collaborative group (FACA committee?) would involve the public in discussions of “what’s working now and what needs to change”, determine some ideas for change and learning questions, prioritize some activities to learn about and test ideas for change, monitor, and have a formal, transparent, public process (annually?) for checking on goals and adaptive changes. Climate change would be incorporated as included in scenarios this group would consider. It’s more about public deliberation, and learning from the land in real time, than analysis. As Dave said here

“You can only hope to accomplish anything when you are able to define the scope the problem (time, space, issues, etc.) into “decision containers” that people (stakeholders, administrators, etc) can get their minds around. It seems that traditional “forest plan” containers are hopelessly over-filled when land management zoning, land management goals and objectives, program goals and objectives, and related “standards and guidelines” are all in play — and “in play” in a spatial container that isn’t really relevant to many of the objectives at hand.”

So this idea is adaptive governance for a spatial scale appropriate to the problem at hand, which would make decisions within decision space bounded by environmental law.

ENVIRONMENTAL LAWS: In addition, there is a fundamental legal framework of environmental laws that translate into standards (BMPs, species-wide standards such as grizzly) and serve as restrictions on activities, as well as ideas for improvements to help species recovery (sometimes it is about doing things, in addition to “not doing” things) that can both feed into Adaptive Governance (AG).

MONITORING: There should also be some fundamental framework of monitoring for key elements of environmental quality, such air, water and some, but not all. species, that crosses ownership boundaries and also provides some useful information to the regulatory processes. In addition to this basic monitoring, AG groups could add other monitoring related to their questions and learning objectives at hand.

NEPA : NEPA would be done for each project or at the appropriate scale for larger scale issues (power lines, oil and gas leasing, travel management, species protection). Cumulative effects would be done “just in time” as what is “reasonably foreseeable” one year may be substantially different in three to five (for example, industry is interested/is not/is in certain energy deposits, species are reintroduced or move in on their own or become threatened, bark beetles, big fires and their aftermath, roadless rules, etc.) This is the NEPA equivalent of what Dave articulates here .

“Peter Drucker used to write about the “futurity of current decisions”, that is to look at that will emanate from each decision, as it relates to all other decisions. But to act in as close to “real time” as possible, and adjust policy and program and all else to accommodate emergent realities. I call this “just in time decision-making” or “once and forever decision-making.”

(Dave, did you mean “in contrast to” “once and forever decision-making?”)

There does seem to be some dichotomy among us on the utility of predictions at the “forest plan level.” And differences in the view that somehow broader scale- say, landscape scale- NEPA will both be better and remain fresh while the projects are carried out. This may be where Martin is with his contingency/adaptive NEPA, or maybe that’s just for long term projects such as grazing.

Ray Vaughan expresses a need for something strategic at a broader level in this post, but whether it needs to be NEPA or not is another question, in my view. The idea being that we think ahead strategically so that we don’t end up in some kind of corner by focusing on a project at a time. But to me, that’s a discussion with the public about strategy about what “might could” happen under a variety of scenarios, and not an explicit NEPA analysis of alternatives.

I liked Ray Vaughan’s analogy that he discusses in the same post, but the family in the analogy doesn’t have to spend a significant part of this year’s budget on a formalized, legally defensible, construct of different alternatives to reach its goal, given that perhaps it doesn’t know a)how many children will arrive, b) their family income, nor c) costs of education, that far in the future.

So does my weaving resemble yours? Tell us about what yours looks like.

Earth to FS Planning: Get a Blog!

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Yes I know that the FS thinks it has a Planning Rule blog. But it doesn’t. Not a real blog anyway. All it has, so far, is a poor excuse for a comment aggregator. The other day I decided to leave a comment on Peter Williams’ recent post on the “official blog”. Guess what? The so-called blog won’t accept comments that include paragraph breaks. No HTML is allowed. And, best I can tell, even simple “http” references are not converted to active links. So I decided that until and unless the FS is willing to at least fix the paragraph breaks problem—or tell folks how to use the blog so that it will include “breaks”—I will just use real blogs outside the “official” smokescreen. Here is the comment I intended to post as a response to Peter, slightly edited:

Here is my “take” on Peter Williams’ final two questions, restated a wee bit:

How might the planning rule provide for an all lands approach and address the contribution of NFS lands to local communities?

  • How can the new planning rule, by itself or as a road map for developing forest plans, reflect the interdependency of social, economic, and ecological systems in a way that supports sustainable management of national forests and grasslands?
  • How can it help provide or ensure opportunities for goods and services to support vibrant rural, regional, and national economies?

My guess is that any planning rule that is developed in the long tradition of “rules” dating back to 1979 will not be helpful in achieving the goals embedded in the questions. Why? Because the focus of each “rule” has always been on developing a “Forest Plan” as if there were wide discretion in that process and “as if” the forest administrative unit made sense as an overall “catchall” for decision-making. Neither is the case.

One problem is that there can not be wide discretion in forest-level decision-making if only because the ecosystems embedded in each administrative unit of the national forest system are themselves part of broader ecosystem wholes, e.g. larger watersheds, larger “basin and range” systems, both, and more. This means that what works for sustainability (instead of against) re: “forest subsystem contributions” to ecosystems must be informed by the needs of broader wholes. So too with social systems. An “all lands approach” must be scaled, hierarchically, to guide development of plans at subscales. Maybe a NFMA “rule” can address such, but we haven’t seen one yet. Only with such an adaptive management assessment information system could forest-level decision-making begin to make any sense. And the ecosystems/social systems scale problem is but one of many problems that impede wide discretion in decision-making. Another is what I call the “wicked problem” problem.

The Forest Service has never (to my knowledge) addressed “wicked problems” (Wikipedia link: http://en.wikipedia.org/wiki/Wicked_problem. Such problems were first introduced to the Forest Service in 1986 by Allen and Gould (Journal of Forestry) and to the world by Rittel and Webber in 1973 (Policy Sciences). Anyone who has studied forest management problems knows that they are indeed politically wicked and cry out for approaches much different from the “comprehensive rational planning” approach that the Forest Service always gravitates toward. Even when dressed up with terms like “adaptive” or “adaptive management” the reality of the approaches used always have rational-planning at their core.

One thing is certain when dealing with wicked problems: You can only hope to accomplish anything when you are able to define the scope the problem (time, space, issues, etc.) into “decision containers” that people (stakeholders, administrators, etc) can get their minds around. It seems that traditional “forest plan” containers are hopelessly over-filled when land management zoning, land management goals and objectives, program goals and objectives, and related “standards and guidelines” are all in play — and “in play” in a spatial container that isn’t really relevant to many of the objectives at hand. I have long felt that rational planning approaches simply can’t work. Here is how I put it in my Epistle to the Clinton-era Committee of Scientists (link: http://www.fs.fed.us/eco/eco-watch/cos_greenplans.html) , written when I was an employee of the Forest Service:

… [W]e have failed to learn the lesson that there is a difference between complex problems and wicked problems (see: G.M. Allen’ and E.M. Gould. 1986. “Complexity, wickedness, and public forests.” J.For 84(4):20-23, also Henry Mintzberg. 1994. The Rise and Fall of Strategic Planning). According to Allen and Gould, politically wicked problems can not be solved by any multi-step planning process designed to “collect more data, build bigger models, and crunch more numbers … [expecting that] surely the right answer would be forthcoming.” Allen and Gould suggest that the Forest Service’s general operating norm for planning–more data, fancier analysis, more computing power, more scientists–reflects a “naive hope that science can eliminate politics.” This problem went unresolved–is still unresolved–because [Forest Service] ‘professional arrogance’ wouldn’t allow [the agency] to admit that national forest management and planning is ‘political’.

Why not try adaptive management, better still Adaptive Co-Management (Resilience Alliance Link: http://www.resalliance.org/2448.php) when thinking in terms of an “all lands approach”. Note here that the adaptive management I’m talking about is multiple-scale oriented, addresses wicked problems, and involves double loop learning (More here: http://en.wikipedia.org/wiki/Organizational_learning). Maybe such adaptive co-management can be and will be fit into the NFMA “rule” rewrite. But I doubt it. As I mentioned in an earlier post, I hope I am proven wrong.

Final thought: If adaptive co-management is to work, decision-makers will have to constantly check and “be checked” to make sure that decisions (cumulatively) aren’t afflicted with policy “decision traps.” E.g. a set of decisions might be afflicted with “policy drift” — a “tyranny of small decisions” that eventually runs counter to policy aims due to the cumulative effects of sequential or segmented decisions.

Accountability in Plans so Adaptive Management Can Work

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So we want a simplier, more adaptive management structure for forest planning and implementation?   This won’t work until we first address the questions  of public accountability and success in court.

In his law review article “Regulation by Adaptive Management – Is it Possible?”,  Florida State Law Professor J.B. Ruhl argues that environmental regulation (which can also be applied to forest planning) needs to move away from “prescriptive regulation” to adaptive management, but there are barriers.

 If we were to apply an adaptive management approach in forest planning, the Forest Service needs to consider the battles that Ruhl says will come from three fronts:  legislative, the public, and the courts.  He gives a case study of a Fish and Wildlife Service adaptive management approach to the Endangered Species Act. He observes that over time, agencies find that interest groups and the courts peck away at adaptive agency behavior, and that under conventional administrative law, agencies adopt adaptive management at their own peril.

Ruhl suggests a model of regulation (which we could embed in our forest plans) that sets boundaries that can be monitored and enforced in courts. There are two elements that we could put into plans. First, a decision shouldn’t be altered too soon after being made – what Ruhl calls “volatility.” A radical departure made quickly after the initial position suggests that the agency’s operational model is faulty, its monitoring is defective, or something else is fundamentally flawed. The other problem is the concern that an accumulation of small adjustments over time may put the agency too far from its initial position – what Ruhl calls “drift.” So a forest plan could establish the boundary of acceptable volatility (narrow at first which can broaden over time), and a broader boundary of acceptable drift.  What would such a plan look like?