Planning Rule Development Process

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

Missoulian Story on Planning Rule Public Meeting

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Somehow I missed this one earlier.

Here’s the introduction:

It’s a little like changing the shape of the strike zone in baseball, or the allowable deductions on your income tax form. A proposed planning rule for all U.S. Forest Service activity is both deeply wonky and game-changing.

The draft rule spreads fine print from page 8,480 to page 8,528 in the Federal Register. In there is something that may affect every trail walker, tree cutter, mushroom picker, snowmobile rider, hunter, angler, small-plane pilot, outfitter, gold miner, folf player and who-knows-what other national forest user.

About 80 such interested parties gathered on Tuesday in Missoula to hear Forest Service planning specialist Regis Terney answer questions about the draft rule. For all its complexity, the rule is the simplest part of a process that guides the writing of huge plans for 125 national forests and grasslands across the nation. The Missoula audience was ready to scrutinize it down to individual word choices

Public Meetings on Planning Rule: What Did You Hear?

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Photo of bear at Golden Colorado forum on planning rule by Kirk Siegler

I didn’t see too much in the press about the meetings so far. There is this one from Oregon Public Broadcasting.

Forest Service Updating Framework For Long-Term Planning

Rob Manning | March 25, 2011 | Portland, OR

Top federal forest officials visited Portland Friday. And a new constitution for the country’s national forests was on the table, as Rob Manning reports.

The Forest Service is updating a federal framework that local forest managers have to use to draft long-term plans, whether for grasslands in the Southeast or the Mount Hood National Forest.

Assistant director, Ric Rine is on a national tour explaining the draft rule – and why it should change.

Ric Rine: “The 1982 regulation reflected the science and the planning processes of the ’70s, when timber management was a dominant use. The science has changed, public values have changed, the rule hasn’t changed.”

Environmentalists, loggers, and snowmobilers asked Rine skeptical questions – mostly asking for details. They wanted to know how science would be used.

Several people suggested that a proposal for a narrow-window to file objections would marginalize the public.

Rine said the intent is to rely on a more collaborative process to better include the public, and avoid objections in the first place.

And this one from KUNC, Greeley Colorado.

Like any bureaucratic planning document, the proposed rule isn’t exactly bedtime reading. But there are several clear themes; such as directives that the Forest Service consider the best possible peer-reviewed science before issuing local management decisions and a push for more forest restoration and habitat protection jobs.

“The proposed forest rule has some promising ambitions,” says Caitlin Balch-Burnett, Colorado outreach representative for Defenders of Wildlife. “However, we feel like these ambitions really do not translate into meaningful and binding standards.”

Defenders of Wildlife is one of the groups that sued the Bush Administration during its attempt to revise the 1982 planning rule. Courts threw that out twice in 2005 and 2008. Balch-Burnett says the Obama Administration’s plan gives too much discretion to the Forest Service and its local forest managers when making decisions on watershed or wildlife habitat protection.

“Our concern is with so much flexibility and not enough guidance given, that’s when you know, critters can fall through the cracks in terms of management and protection,” she says.

But by giving more flexibility to local forest managers in its proposed rule, the Forest Service also seems to be trying to address complaints from critics of litigious-minded conservation groups who argue current planning gets too bogged down in administrative appeals.

Tom Troxel, executive director of the Intermountain Forest Association which represents timber companies in Colorado, Wyoming and South Dakota, says in this era of budget deficits, the planning process is too long and costly.

“I live in Rapid City,” Troxel says. “The Black Hills National Forest I think has the world record for forest plan revision, it took them 16 years to finish a 10-15 year plan.”

In other words, Troxel says, forest plans are supposed to get updated every 10-15 years. On average, local forests take about six years just to revise a plan.

That was about how long it took Colorado’s most visited forest, the White River N.F., to issue its latest version in 2002, according to a forest spokesman. And much has changed there since then. Just think about all those beetle-killed trees dotting the hillsides of Summit County, for instance.

Troxel says the current national proposal does little to address the costs and complexity embedded in the existing rule which he says has made it difficult for timber businesses to operate under.

“Whatever your interest in the national forest is, it’s better to have them managing forests and maintaining trails and improving wildlife habitat than it is in this endless planning process,” Troxel says.

At a public meeting earlier this month in Golden, Forest Service officials fielded criticisms similar to those of Troxel and conservationists. The agency’s Ric Rine says that’s why the proposed national rule is a draft, not a done deal.

I attended four public meetings, and one with state government folks and elected officials. As with the story above, “best available science” and objections were also topics in our area. I plan to post more on those later this week. What did you all hear? Did you hear anything that surprised you? If so, what?

From Forest Planning to Adaptive Governance

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Standards in Planning

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

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

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

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

Types of Standards Used in Forest Planning 

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

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

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

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

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

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

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

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

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

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

Why Standards?

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

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

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

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

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

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

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

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

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

Time for a Bold Statement?

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It’s starting to look like “A New Century of Forest Planning” may ultimately come to refer to the hundred years or so it takes to get a new planning rule implemented. Will the “Hundred Years War” come to signify the length of the timber wars?

Way back in the 1900’s, Chief Dale Robertson was convinced that a bold policy statement was necessary to address the big concern of the day– clearcutting of national forests.  In a policy letter (not the best way to make policy, but a lot quicker than rule-making), Dale established that clearcuttting would no longer be the primary means of regeneration on national forest lands. There were howls of protest from silviculturists and tree-improvement specialists. There were exceptions for species like Jack Pine and Sand Pine.   There certainly was no end to the timber wars, but it was a start down a path towards armistice.

Getting a new planning rule implemented will take more than just agreement about the wording of the rule.  It’s going to require an environment that will insure the intent of that wording can be carried out. Perhaps now is an appropriate time for the current Chief to make some bold statements.

My suggestions are:

1.       Declare that restoration of ecosystem resiliency is not just an important part of the mission; it’s the most important part.

Management actions would be all about producing desired ecological conditions in order to restore and maintain resilient ecosystems and help protect human communities from undesirable things like intense wildfires in the wrong places or downstream impacts from deteriorating road systems.  There would be no need to calculate ASQ or argue about “lands unsuitable for timber production”. (There may still be a need to “zone” for other uses.) “Below-cost” timber sales would no longer be a meaningful calculation.  And, if the South is any indication, a lot more timber would become available for local mills.

2.       Declare that planning at all levels will be a truly open and collaborative process.

All phases of planning would be “open source” with draft documents and supporting information easily accessible on-line.  Raw data from inventories and monitoring as well as interpreted data, maps, and models would be open to all. I can’t think of any other policy change that would do more to improve the level of trust among stakeholders.  A side benefit would be a tremendous savings in responding to FOIA requests.

3.       Declare that the Forest Service will commit to a process of establishing a shared vision for the entire agency.

With the National Forest System, Research, and State and Private Forestry all working towards shared goals, using an “all lands” approach, imagine what might be accomplished at landscape scales?  This is the sort of partnership between managers and scientists that will be needed to truly ensure that “best science” is incorporated into decisions at all levels.

Are these declarations really all that bold?  Not really, The Forest Service has been moving in these directions since before Dale Robertson penned his letter.  A clear commitment to these principles might be what’s needed to finally move the National Forest System into the New Century.

Not Seeing the Forest for the Trees

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If I were a visitor from another planet, who having read some of the recent posts to this blog, wanted to understand what all the fuss about things like “viability” is about, I might look to the Forest Service homepage for guidance.  There I would learn that “The mission of the USDA Forest Service is to sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and future generations.” Pretty straightforward so far.  Looking for more of what these things called “national forests” are all about, I would learn that the agency’s “Motto” “Caring for the Land and Serving People” means, among other things, “Protecting and managing the National Forests and Grasslands so they best demonstrate the sustainable multiple-use management concept.” I would get confused though because I read that the mission also includes things like “Listening to people and responding to their diverse needs in making decisions.” And although I would agree that that is an absolutely essential thing to do, I wouldn’t be able to find anything in any law that says that is part of the agency’s mission.  You might say that I was nit-picking, but fortunately we don’t have nits on my home planet.

Reading on through the Forest Service “Vision” wouldn’t help either.  I might find lots of nice statements about “a caring and nurturing environment” where “employees are respected, accepted, and appreciated”, but I wouldn’t find anything about how the agency thinks the national forests should look in the future if it did a good job at carrying out its mission.

If I did a bit of Googling, I could learn that some pretty smart scientists have been thinking about new and better ways to plan and monitor and that they presented some of these ideas at the Forest Service Science Forum. [Full disclosure– I wouldn’t actually have to Google it since I was the principle author of the final report for the forum]. Some of these scientists pointed out, however, that “. . . while science can help inform decision-making processes, it is most appropriately applied first in a context of shared agreement on the agency goals that will drive management decisions.”

In the absence of shared agreement in the form of a clearly articulated and widely shared vision for the future of the national forests, even an alien can see why a number of conservation organizations insist that the proposed rule doesn’t go far enough to require actions to ensure important things like species viability.

Despite the trees, that forest is evident even to a visitor from outer space.

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

The Musts & Shalls

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Unlike his Dad, he is a big fan of discretion and dislikes one-size fits-all standards. Five years on, he's now reading Appendix N.

One of my hopes for the new planning rule was that it would require the writing of meaningful forest plans.  Here is what I wrote as part of last year’s science panel (Nie NFS planning rule science panel statement):

There is little value in writing expensive, time-consuming plans if such plans make no decisions and have no vision. 

Legally-binding and enforceable standards and guidelines should be included in the new planning rule.  NFMA was designed to reign in agency discretion by providing clearer standards and enforceable checks on the USFS.  Meeting such standards has proven difficult for the agency at times.  But the solution is not the removal of such standards, but rather to figure out ways to more effectively and efficiently meet them. 

While inherently difficult, especially at the front-end, setting standards will facilitate adaptive management and collaborative decision making over the long run.  Regarding the former, standards help define the purpose and boundaries of the process.  After all, adaptive management is a means to an end, and that end needs to be clearly articulated.  Without standards, adaptive management is too susceptible to political exploitation and the dodging of tough political choices.  As for collaboration, standards provide the necessary direction, legal sideboards, and additional certainty to those engaged in the process.

This recommendation was precipitated by the vacuous nature of the 2005/2008 planning regulations that were essentially non-decision making documents. 

So on this score, what should we make of the proposed regulations?  I think they are a more serious effort by the USFS to appropriately balance the need for planning adaptability with political accountability. 

The regulations are heavy on things the agency must consider when writing and amending forest plans.  So I don’t think the rule will streamline or expedite the planning process.  But the draft regulations require (with some wiggle room provided) plans to include some important things, like standards (AMEN! with explanation here and here), guidelines, the suitability of areas, and to situate the national forests within their larger context and landscape, among others.  Under this rule, forest plans would actually mean something and include some important decisions. 

The “Musts and Shalls:”  Here are some things the draft regulations require (not exhaustive nor includes preexisting MUSYA/NFMA requirements):

 *The responsible official shall engage the public—including Tribes and Alaska Native Corporations, other Federal agencies.

 *One or more assessments must be conducted for the development of a new plan or for a plan revision

 *The responsible official shall develop a unit monitoring program for the plan area,

 *The regional forester shall develop a broader-scale monitoring strategy for unit monitoring questions that can best be answered at a geographic scale broader than one unit.

 *Each regional forester shall ensure that the broader-scale monitoring strategy is within the financial and technical capabilities of the region and complements other ongoing monitoring efforts.

 *The responsible official shall conduct a biennial evaluation of new information gathered through the unit monitoring program and relevant information from the broader-scale strategy, and shall issue a written report of the evaluation and make it available to the public

 *While all plans must contain the required five plan components (desired conditions, objectives, standards, guidelines, suitability of areas, and may contain goals), not every issue or resource plan would require all five plan components.

 *All plan amendments must comply with Forest Service NEPA procedures. The proposed rule provides that appropriate NEPA documentation for an amendment could be an EIS, an environmental assessment (EA), or a categorical exclusion (CE) depending upon the scope and scale of the amendment and its likely effects.  (more on this later)

 *This section would provide that projects and activities authorized after approval of a plan, plan revision, or plan amendment developed pursuant to this rule must be consistent with plan components as set forth in this section.

 *The proposed rule would allow for this to occur, and in § 219.7, would require identification of priority watersheds for restoration

 *The proposed rule would require the responsible official to document how the best available scientific information was taken into account in the assessment report, the plan decision document, and the monitoring evaluation reports.

 *Finally, plan components would be required to protect, maintain, and restore clean, abundant water supplies (both surface and groundwater sources), and soils, and productivity recognizing their importance as fundamental ecosystem resources and services.  (& as stated elsewhere “The proposed rule would require that plans include plan components to maintain, protect, and restore public water supplies, groundwater, sole source aquifers, and source water protection areas where they occur on NFS lands.”)

 *The proposed rule would highlight the importance of maintaining, protecting, or restoring riparian areas and the values such areas provide by requiring that plans include plan components to guide management with riparian areas. The proposed rule also requires that plans establish a default width within which those plan components apply.

 Not included on my list is the diversity provision, as that deserves a separate post.

Martin Nie, University of Montana