Collaborative Forest Management: What the FACA?

Recently, one of the main the topic of conversation here at NCFP has been about collaborative forest management. We have wandered though several posts and many comments into the controversy surrounding, in particular the Montana Forest Restoration Committee in Montana and the Tongass Futures Roundtable in Alaska. In these discussions, there have been those sitting just beyond the perimeter of a collaboration who feel that something is amiss. Concerns often expressed by local environmental groups include, “Who is at the table, collaborating, and who is absent?” That is, Is the committee biased? If so, what type bias? On the other side of this divide are those who champion collaboration, particularly some National environmental groups who seem tired of litigation battles and stalemate, and to prefer more direct forms of engagement. These would-be collaborators don’t seem too uncomfortable with the make-up of collaboration committees. Because they are well-represented?. Sometimes they look askance at those who challenge the validity of specific collaborations, even accusing local environmental groups of being obstructionists. Local environmental groups counter, and accuse the Nationals of “selling out,” becoming part of the problem that is often labeled “Washington D.C.”

As I’ve watched and participated in surrounding discussion, I’ve wondered: Whither FACA? The Federal Advisory Committee Act FACA) was passed in 1972 in an effort to reign in federal agency ‘capture’ by special interest groups, particularly corporate interests. By the late 1990s there was substantial interest in collaboration in natural resource policy, but FACA was seen by many as a barrier to effective collaboration: Too bureaucratic, too heavily-laden with process requirements. But collaborators seem to have forgotten, else never understood a little facet of the law: an advisory committee doesn’t need to be declared to be a FACA Committee to be held accountable to at least some aspects of FACA law.

A good overview of this FACA problem/opportunity can be found in “The Federal Advisory Committee Act and Public Participation”, 1999 (pdf) publication by Resources for the Future. The act itself can be found here. Another useful reference is “The Federal Advisory Committee Act and Its Failure to Work Effectively in the Environmental Context”, (pdf) 1995, Boston College Environmental Affairs Law Review. After reading the latter, I was about to give up on FACA, in part because the courts had failed pretty much to allow people to challenge federal agencies under FACA. And the prevalence of closed-to-the-public advisory committees was still substantial in 1993:

FACA has … failed to fulfill Congress’s goal of opening all advisory committee meetings to the public. Closed-door advisory committee meetings still prevail, despite FACA’s mandates that meetings be open to public participation.218 The GSA, which monitors advisory committee activity throughout the government, reported that, in fiscal year 1993, there were more closed and partially closed advisory committee meetings (2,225) than open meetings (2,162).219 It is clear from these statistics that a substantial amount of advisory committee work is still done in private, away from the public scrutiny and participation that would help limit the influence private interest groups have on the agencies they are advising.

In short it looked like those finding themselves on the outside of collaboratives couldn’t find much recourse via the courts. Then I found an interesting little decision (pdf) rendered after the Idaho Wool Growers Association successfully challenged the Forest Service in Idaho, 2009. In Judge Winmill’s decision I saw a ray of hope that indeed FACA challenges might still reign-in committees that bias agency decision-making. In particular I found this interesting:

Memorandum Decision and Order – Page 18
FACA defines an “advisory committee” as “any committee, board, commission, council, conference, panel, task force, or other similar group, or any subcommittee or other subgroup thereof . . . which is . . . established or utilized by one or more agencies in the interest of obtaining advice or recommendations for the President or one or more agencies or officers of the Federal Government . . . .”

Memorandum Decision and Order – Page 19-20
“When a committee is established to provide expert summaries or interpretation of technical data, their reports can be ‘in the interest of obtaining advice or recommendations for . . . one or more agencies.’” . . .
“Even though [the committee] provided the USFS with only narrative summaries of scientific information, and made no policy recommendations, the [committee] drafts and the final assessment provide the framework, context and information that the USFS will rely on in making policy decisions.”

Memorandum Decision and Order – Page 20
FACA imposes a number of requirements on advisory committees. See, e.g., 5 U.S.C. App. II, §§ 2, 5, 9-14 (records must be made available for public inspection; charter must be filed; upcoming meetings must be announced; meetings must be held in a public place; minutes must be kept; attendance must “be fairly balanced in terms of the points of view represented” and may “not be inappropriately influenced by the appointing authority or by any special interest”). Typically, a close examination of each requirement, contrasted against the circumstances in a particular case, is warranted when determining whether a FACA violation occurred.

So FACA may indeed be ‘in play’ in broader contexts than have heretofore been considered by many. That is, it matters not so much that FACA committees be chartered by agencies. What matters is what the players do, how they deal with the public interest and how they vet various interests/positions. Post Judge Winmill’s decision, it looks like the courts may finally be listening. Or not! If the courts are listening, we may be in for more FACA lawsuits to test these waters.

What does it all mean? How does and agency, say the US Forest Service, go about getting workable committees (defacto FACA committees) that can come to any agreement or give advice that is not all over the map?

I think that the answer lies in an area that the Forest Service is so far loathe to go. That area is the area of multi-scale adaptive governance that includes policy development as well as program and project management. The Forest Service seems to want to hold policy development to itself, yet to collaborate on site-specific watershed projects. That type arrangement gives no space to deliberate upon and enact the type preservation sought by John Muir naturalists, who want intact ecosystems for say, wildlife—big home ranges for large carnivores, protected corridors for migration, etc. So the whole idea of local-only collaboration is a nonstarter to many environmentalists.They want to deal with matters of broader scale and scope. But there is no such forum available in the 2012 NFMA rule. At least that’s the way I see it. No wonder environmentalists cry fowl. When will the Forest Service warm up to adaptive governance, with its emphasis on collaboration and adaptive management? Not likely anytime soon. So, for this and other reasons, we’ll just see what shakes out in FACA court room battles. When dealing with extant collaboratives, we are left to wonder: What the FACA? Or maybe just WTF?

Perhaps the answer, or part of it, has already been offered up in a NCFP comment from Terry Seyden, if only ALL would/could operate in good faith and keep the public interest in mind:

In my view, there is just no substitute for ongoing substantive dialogue to help the agency truly understand what the real underlying interests of various constituents are. Having a rich two way dialogue also assists the agency in creatively exploring all available options for meeting agency goals while trying to meet sometimes competing interests. … [T]o be legitimate and effective, any collaborative effort has to be well grounded within a larger public involvement strategy that gives the larger community of interests substantive opportunity to comment on and influence collaborative recommendations BEFORE decisions are reached.
Of course for any of this to work, the process has to be seen as credible and fair, both in terms of who directly participates in a collaborative group and how those “not at the table” have meaningful opportunities to contribute before decisions are made. While good faith among all interests is not a requirement for this approach to be successful, good faith on the part of the Forest Service or other third party convening any collaborative effort is absolutely essential.

This is echoed by An Optimist:

A good process… will seek to represent the ideas or interests of even non-participating groups. The challenge, however, is that a collaborative process is a learning process ….

In a Michigan Law Review article, Daniel Walters (pdf) seems to agree with both. He advocates for a “deliberative approach” to FACA. It all sounds right to me.

The challenge, for all of us is to be ever-vigilant to ensure that ‘collaboratives’ are indeed operating in good faith, and in the public interest. But if the many of the comments in the posts linked just below are an indicator, many such collaboratives in the past may not have been acting in good faith and in the public interest. Also the Forest Service needs to make sure that collaborative fora are available at appropriate scale to deal with relevant issues—not just at the local level. So let’s keep talking, keep challenging emergent collaboratives and broader policy both in terms of resource-related policy, programs and projects and in terms of collaboration design and operation. And let’s talk here about what I missed, what I messed up, and so on re: FACA, collaboration, and US Forest Service policy and planning.

Some related NCFP collaboration posts of interest:
Odd bedfellows try collaborating to resolve conflicts- from E&E News, March 15, 2012
“Collaboration on natural resource management is divide and conquer” The Wildlife News, March 11, 2012
New Research: Who Litigates, Who Collaborates and Why?, March 7, 2012
Two Views of the Tester Bill, December 22, 2011
Collaboration Can’t Fix What Ails Public Forest Management, October 6, 2011
Colt Summit- Garrity EditorialOctober 6, 2011

When Policy Trends Toward Bullshit

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

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

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

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

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

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

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

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

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

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

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

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

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

Why I’ve tried to stop the BS

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

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

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

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

Webinar Tomorrow on Conflict Management in Planning

Webinar tomorrow on conflict management in planning.
Here’s the link.
Don’t miss this upcoming Live Webinar sponsored by: USDA Forest Service .

Title: What do you do when people start throwing food at the table? A conflict management perspective

Session Details:
Nov 18, 2011 12:00 pm US/Eastern Duration: 01:00 (hh:mm) vCal iCal
*** Please join the session 15 minutes prior to the start of the webinar. ***

What will you learn?
The 2011 Changing Roles webinar series has a theme: Considering Natural Resources in Land-Use Decision Making Processes. Natural resource professionals often refer to “being at the table” in reference to their participation in multi-stakeholder processes such as land-use planning and therefore, this same language is used in the session titles of this series. Each session will address the theme from a different perspective. This is the final webinar in the four-session series. This session will address common challenges faced in multi-stakeholder group processes and is aimed at resource professionals who are already “at the table” and engaged in land-use planning processes. This webinar will present strategies for working through conflict to create solutions to complex and contentious land-use issues. learn more here…

Who should participate?
Foresters, Land Managers, Natural Resource Professionals, Planners

Presenters/Authors:
Steve Smutko, Spicer Chair of Collaborative Practice, University of Wyoming, Department of Agriculture and Applied Economics

There are many other interesting webinars and other information at this site. I liked this one about Carbon and Forest Products.

Forest Planning- Invitation to Artistic Collaboration

I’ve always wondered if the feel of planning would be different if we kicked off revisions with a, say, Blank National Forest art week or weekend, with readings, visual arts, music and theater (possibly with juries and prizes provided by NGOs?) around what the forest means to people. Aspects of this art might then become touchstones in the often head and not heart-filled planning discussions. Anyway, I guess right-brain planning remains unexplored for now, although here’s a contribution from a planning practitioner who prefers privacy (how’s that for alliteration?) who feels the same longings. I wonder how many of us feel this way?

As for me, I have implemented 1982 Rule

Planned to implement the 1994 draft (remember?)

Participated in the evaluation of 2000

Worked on training modules for the 2005

Attempted to implement the 2005

Attempted to implement 2008

Attempting to implement 1982 – again

Anticipate implementing 2011-12 before I retire.

So I offer as a practical exercise and a bit of fun (but I don’t want this classified as “planning humor”) a real online attempt at collaboration of a different kind – an artistic collaboration if you will. But as you may garner, I believe this very concept can transfer into real forest planning collaboration, although perhaps not in rhyme or free verse.

I have for you a poem. You may or may not agree with its contents. Some stanzas are perhaps well formed, some in obvious need of refinement. Maybe some readers who have not made entry or comment will choose to participate. I hope so. Use your creative powers. If you have a replacement for a stanza, reply with the stanza number. Here goes:

The Planning Rule Poem

1. Forget “the best science’

And admit this way’s useless

To “manage” a forest

And follow a plan

When the buzz words change

More than the public can stand

2. New perspectives, no

Ecosystem management, better

EMS, AMS, CER, now ASSESS

All the same, but it’s DIFFERENT

THIS TIME and responsive

To everyone everywhere always, you bet

3. We agree we adore it

We plan to “restore” it

We want it to be

What WE want it to be

And our science is better

Than your science, you see

4. I have this idea

I may be a heretic

To blaspheme “the best science”

As relates to a forest

And employ in its stead

The best ART – there, I’ve said it

5. In the segments of planning

I completely agree

Assess, plan, monitor

One, two, three

And back ‘round again

As the case may be

To adapt, but collaboratively

6. Which is not to say

That Americans should outsource

Our need for the things

That come from the forest

Or underneath it

Of course that IS what we practice today

6. By law forests should

And must in the future

Provide goods and services

(Oh – I’ve heard that before)

With all the new jargon that only confuses

National forests are still about “multiple uses.”

7. ADMIT IT, ADMIT IT, ADMIT IT, I say

Congress has never left NFMA

Behind, so just say to the interested parties

Let’s work together to create in these woods

An artistic collaboration of goods

And services to provide for us and our children to be.

8. Sure we folks in the forest are going to leave evidence

Of our presence, our passing, our needs at this time;

As we need to use resources we know they aren’t limitless

As we play in the forest and know that it succors us

We must simply take care that we don’t take too much

Is that really so hard? Why such a big fuss?

9. Art’s a translation of human sensations

Into a thing that can be experienced

By others as substance, or form, or event

Art is creation, not explanation

Or a scientific finding of association

And a plan’s not a “fact,” it’s a human creation

10. Art moves us ways that can’t be explained

By pieces and bits of data contained

In findings of science

And forests move us in that same way

We plan to create, not to explain or reveal

We know what we like, we know what we feel

11. Having stated what should be obvious

To those who are blinded by dogmatic adherence

To any one notion of “truth” when it comes

To the realm of forest “management”

Be it “preserve it” or “use it” or even “sustain it”

Or “make it resilient” as if WE understood it

12. But “plan” we will, and we’ll to it together

And attempt to find harmony among all the elements

Harmony – a musical artistic term that also is fact

That science can explain, but the notion came first;

It’s the combination of observation and imagination

That artistic collaboration makes a scientific reality.

How to do Assessments Under the Proposed Forest Service Planning Rule – Part 4: Beginning with the End

Gunnison National Forest, Colorado

This is the last in a series of posts about assessments for Forest/Grassland plan revisions under the proposed Forest Service planning rule.  The posts are a summary of this working draft of the asssessment process.  In previous posts, Part 1 described some suggestions about how the assessment process would focus on a series of questions derived from the rule.  Part 2 talked about the analysis and deliberation steps.  Part 3 described futuring and scenario planning.

Before revising a Forest Service plan, the proposed planning rule requires an assessment – both a product (the document), and a participatory process (deliberation and analysis).  There are three important outcomes of the assessment process:

  • It can provide baseline information for looking at the effects of a Forest Plan.
  • It can provide actionable knowledge about the need to change the Forest Plan.
  • As part of a broader adaptive governance framework, it can foster collaborative learning, especially when there is no agreement on the problems or solutions.

The assessment sets the stage for the subsequent proposed plan, an Environmental Impact Statement (EIS), and the who, what, when, where, why and how for the NEPA process.  The interplay between the assessment document and the EIS is of particular interest.  As a comprehensive look at the planning rule requirements, the assessment would look at the current plan and serve as a screening process for an EIS.  This would simplify the EIS since it would only need to focus on those requirements that the current plan isn’t expected to meet.  The assessment could also essentially become the “affected environment” chapter of the EIS. 

Several points need emphasis.  First, the topics covered in an assessment are at the scale of the Forest Plan decision under NFMA and its implementing rule.  The level of detail required to develop a Forest Plan is less specific than resource planning (like fire planning or forest-wide recreation planning) or project planning.  Second, an assessment is time sensitive.  It provides information for the subsequent plan revision and EIS.  The rule assumes a more or less continuous cycle of assessment, plan revision or amendment, and monitoring.  An assessment is a time step for those issues that are ripe for discussion.

“Actionable knowledge,” as researcher Chris Argyris has written in his 1993 book, “is not only relevant to the world of practice, it is the knowledge that people use to create that world”.   A forest plan assessment needs to provide information about what needs to be changed in the forest plan, and how those changes should be made.  An assessment shouldn’t merely be a compilation of “descriptive” facts about a forest.  The descriptive facts should be connected together in the context of the assessment questions and the experience and judgment of the participants.  We might know that there are 10,000 acres of dead trees in a forest.  But just knowing that there are dead trees doesn’t compel us to act.  However, if we have Forest Service employees, scientists, local residents, or others with experience about disease agents and how they might spread, within the context of a specific assessment question about wildlife habitat or timber salvage markets, we now have actionable knowledge that can inform how the forest plan might be changed. 

Argyris has said that actionable knowledge includes a deliberate, intentional search for error, understood as a mismatch between either intentions or assumptions and outcomes.  In a sense, these errors are surprises that we didn’t know about or think about when we wrote the original plan.  The whole idea of actionable knowledge is about having a reasonable process that facilitates timely recognition of likely, yet unpredictable surprises so that less costy actions are possible in response.  Actionable knowledge is about looking to learn, instead of assuming that what we think we know during a planning process will always be the case as we move forward.  The context in which we manage these public lands is just too dynamic for such assumptions.

An important theme of the planning process in the proposed rule is learning:

This new framework is science-based and would provide a blueprint for the land management process, creating a structure within which land managers and partners could work together to understand what is happening on the land, revise management plans to respond to existing and predicted conditions and needs, and monitor changing conditions and the effectiveness of management actions to provide a continuous feedback loop for adaptive management.” Federal Register p. 8487

Ideally, for adaptive management to work, learning objectives should be explicitly stated and incorporated into the objectives of the forest plan, with monitoring questions and indicators all tied to those objectives.  The proposed rule requires the identification of monitoring questions and indicators as part of the assessment process.  So it beomes important that participants use the assessment process by formally asking what they want to learn and why.

Elsewhere on this blog, we’ve discussed the need for the Forest Service to establish an adaptive governance framework, and some of the basic principles.  As part of that broader framework, the forest plan assessment process can be used to engage stakeholders and allow participants to invest in the planning process.  Without such an investment, we will not reach that basic standard of collaboration—are stakeholders, including the Forest Service, willing to live with the proposed changes?  Failing to reach that basic standard reduces the willingness to help get the job done and increases the willingness to challenge the decision administratively, legally, or through civil disobedience, such as ignoring new management rules. 

The assessment process will require a capacity to collaborate.  Based on a study of forest plan revision efforts, Sam Burns and Tony Cheng have developed six essential prerequisites for utilizing a collaborative process:

Is the Forest Service staff aware of collaboration ideas and principles?

Is there an understanding of the social and historical context for collaboration in the planning locale, including community understanding of collaboration and related collaborative capacities?

Is there internal capacity to do collaboration?

Are there clear collaborative expectations?

Are there ways to monitor and adapt the planning process?

Is there a design for how the collaborative process will work?

A collaborative learning process is essential because forest planning often behaves as a classic example of a wicked problem, where there is no definitive statement of the problem, and hence there can be no definitive solution.  (See for instance Salwasser’s description of the Sierra Forest Plan amendments).  The forest planning process will involve fragmented stakeholders, high-uncertainty, disagreement about the role of science, political engagement, and an ebbing and flowing of Forest Supervisor control.  As the assessment process goes through the iterations of deliberation and analysis, The Forest Supervisor should determine if it still helping define the problem, or still building relationships and capacity for subsequent planning and project work.  There will be no easy rules of thumb for when the end the assessment process.  There are no “right” answers for many of the assessment questions.  The proposed planning rule gives some flexibility by allowing the assessment process to overlap with the revision and NEPA process.  It also gives the Forest Supervisor the discretion on when to end the process.  Hopefully, the Forest Supervisor has communicated early in the process how she/he will decide when to end the process, participants shouldn’t be surprised when management intervention is taken.

The design and implementation of the assessment process needs to have its end in mind.  It’s about convening, exploring and learning, in order to act and move ahead.  Ultimately it’s not about a plan, it’s about implementing a plan.  But you can’t implement until you know what you’re doing.  You also can’t implement a plan without support of those affected it.  A well designed assessment process can improve the final plan document, provide a fair process for the participants, and foster relationships with people that can later help implement the plan.   So let’s begin.

How to do Assessments Under the Proposed Forest Service Planning Rule – Part 3: Scenario Planning

Mendocino National Forest, Bear Creek Campground, photo by Tiffany Flanagan

 

What is the future of our National Forests?  How do we fulfill NFMA’s challenge to plan for sustained yield of products and services into the future?   

In the messy world of forest planning, there are demands for certainty and assurances about the future, so subsequent project work can be done.  Planners have responded with deterministic linear programming models, reasonably foreseeable development forecasts, ranges of historic variation, or simply promises.  If uncertainty remains, there is a promise to monitor, and to eventually adapt.  Sometimes these approaches have worked, often they haven’t.  

The challenge of the proposed planning rule is to assess present and potential future conditions in order to plan for them.  In previous posts, I offered suggestions to review assessment questions derived from the rule through an interactive process using analysis and deliberation.  If Forest Plans are to be strategic and guide projects from one decade to the next, they must be able to address an uncertain world.  However, the appearance of certainty comes at a price, both in the cost of the plan’s preparation, and its reliability.  One thing becomes clear: forest planning should not try to reduce uncertainty – instead, it should embrace uncertainty.

One approach to addressing uncertainty is to set up adaptive management.  You establish a hypothesis, then test it through monitoring and evaluation.  But adaptive management only works when the Forest Service is in control of the forces affecting the forest.  For uncertainty that can’t be controlled, a better approach is to develop a plan that is robust and flexible to respond to the unexpected problems that “walk into the District Ranger’s door”, or to address the uncertain events that the proposed planning rule calls “drivers, stressors, and disturbances” or “risks”.

Nimble, flexible planning requires some awareness of blind spots and assumptions about the future.  It requires a look at alternative futures.  In order to break out of people’s comfort zones, it’s important to offer stories with impact, that create a future shock.   These are the elements of scenario planning, or what is sometimes referred to as scenario thinking.  Scenario planning is a structured framework to identify actions that will be most effective across a range of potential futures to promote desired outcomes. Peterson, et. al. has described how scenario planning is useful in natural resource planning where there is high uncertainty and minimal control.  The Park Service is applying scenario planning for addressing climate change in park planning.

Applied to the Forest Plan assessment process, scenario planning would include the following steps:

  • In answering the assessment questions, find out what scientists know, think they know, and don’t know.
  • For the things that we don’t know, find out what are the most critical forces that affect the answers to the assessment questions.
  • Combine the most critical forces into different stories about how the future will play out.
  • Think about what should be in the forest plan to respond to the various scenarios.
  • Determine what important monitoring questions and indicators are important to see what scenarios may unfold.

Scenario planning focuses on multiple, reasonably plausible futures.  While these multiple futures can be thought of as analogous to multiple forecasts, true scenario planning seeks to describe multiple plausible futures.  Scenario planning does not seek to establish probabilities associated with those futures.  The emphasis on plausibility instead of probability is overlooked by some disciplines that have embraced the terminology of scenarios without understanding the origins of scenario planning.  Emphasis on probabilities reinforces a problematic search for a single best answer (see for instance, Mitroff and Lindstrom or Van der Heijden), a problem the founders of scenario planning sought to address (wikepedia link).

This difference between emphasizing plausibility and emphasizing probability creates a need to develop new Forest Service skills, because those trained in natural resource sciences are taught about probabilistic methods.  Some of the new skills needed require rethinking fundamental training, which is especially challenging.

The main goal of scenario thinking is to question basic assumptions about how the world works and to open people’s minds about possible futures that would otherwise be unimaginable.  Participants can break out of their standard worldview, exposing blind spots that would otherwise be overlooked in the generally accepted forecast.  It’s then easier to recognize a scenario in its earliest stages, should it actually be the one that unfolds.  The Forest Supervisor is also better able to understand the source of disagreement that often occurs when different people are envisioning different scenarios without realizing it.

Collaboration is central to scenario planning – engagement that includes but is not limited to that of technical experts and scientists.  This engagement is a scientifically valid method of bringing biases and assumptions to the surface and then using those to construct plausible alternative futures.  In contrast, traditional approaches to forest planning typically pit competing perspectives against each other in search for a single best forecast or scenario, occasionally looking for multiple single-point forecasts.  Chermack and Lynham explain that the search for a single best forecast makes traditional methods fundamentally adversarial, and therefore at odds with more collaborative, learning-oriented approaches to planning and decision-making.

Like most planning methods, there are some cautions with scenarios.  We’ve talked about Mintzberg’s classic book on this blog, and Mintzberg (p. 248) mentions the balancing act between developing enough scenarios and hitting the manager’s mental capacity.  He says that “hedging or remaining flexible has its own costs, primarily in the lack of commitment to a clear strategy.”  Plus, even when the planners are quite sure that one of their scenarios is on the right track, there remains the problem of convincing management to do something about it.   Still, despite Mintzberg’s and other commentors’ concerns, scenario planning is useful to begin a dialogue, to blend the “hard” analysis with a manger’s “soft” intuition, and engage the public.

Properly done, an assessment under the proposed planning rule should challenge the conventional wisdom and contribute to the learning of all participants.   That might be the greatest benefit of NFMA planning.

  

How to do Assessments Under the Proposed Forest Service Planning Rule – Part 2: The Process

In an earlier post I offered some ideas for doing an assessment under the proposed Forest Service planning rule.  The essential purpose of the assessment would be to review assessment questions derived from the rule to determine what in the Forest Plan needs to change for the Revision.

In order to assess the relevant conditions of a forest, or the risks to a forest, two activities are often described in the planning literature: deliberation and analysis.  (See for instance the National Research Council’s guide to risk assessment.)  These two activities can be thought of as complementary approaches to gaining knowledge about the world.  Analysis uses rigorous, replicable methods to arrive at answers to factual questions.  Deliberation is any formal or informal process for communication and collective consideration of issues.  Together, the combination of deliberation and analysis serves as the synthesis process, required for assessments in the proposed planning rule (see definition at 219.19).

The Deliberative Democracy Consortium defines deliberation as an approach to decision-making in which citizens consider relevant facts from multiple points of view, converse with one another to think critically about options before them and enlarge their perspectives, opinions, and understandings.  Deliberative democracy strengthens citizen voices in governance by including people of all races, classes, ages and geographies in deliberations that directly affect public decisions.  As a result, a citizen influences – and can see the results of that influence on – the policy and resource decisions that affect their daily lives and their future.

The assessment process would contain analysis and deliberation steps, but the process itself must be designed collaboratively by the participants.  The principal reason is that the participants should have sufficient ownership in the process.  If participants have ownership in the process, they will see it as fair, and therefore willing to live with the eventual outcomes.  The steps and the sequence should be agreed upon by the participants at the beginning of the process.  The Forest Supervisor needs to be fully engaged, explaining to the participants the sideboards for the process, and that she/he will retain the discretion to determine the scope, scale and timing of the assessment (proposed planning rule at 219.6)

David Straus has described in his book How to Make Collaboration Work (amazon link) that a flowchart of the steps of a collaboration process might look like an “accordion”.  For a plan assessment, here’s what it might look like.


There are cycles between deliberation activities and analysis activities.  There are also cycles between large group activities and small group activities.  Each cycle refines the answers to the assessment questions, and may bring in new participants and new sources of knowledge.  The flow chart expands with concurrent activities, then contracts into deliberative meetings, then expands again, hence the description as an “accordion process.”

Again, the focus of deliberation and analysis would be answering the assessment questions.  One of the first questions on the list relate to the values that participants place on a National Forest, and what roles and contributions they see the forest providing now and into the future. 

One approach that can be applied is David Cooperrider’s appreciative inquiry methodology.  This process moves from (1) discovering what works well in the current forest management situation; (2) envisioning what might work well in the future; (3) designing, planning and prioritizing what would work well; and (4) executing the proposed design.

Another key step is looking into the future.  The next post describes the potential role of scenario planning in the assessment process.

How to do Assessments Under the Proposed Forest Service Planning Rule – Part 1

Lynx and coyote tracks, Superior National Forest, Minnesota, photo by Larry Weber

An assessment is the gathering and integrating of information relevant to the planning area from many sources and the analysis of that information to identify a need to change a plan or to inform how a new plan should be proposed. – section 219.5(a)(1) of the proposed Forest Service planning rule

It is a synthesis of information in support of land management planning to determine whether a change to the plan is needed.  Assessments are not decisionmaking documents but provide current information on select issue. – section 219.19 of the proposed Forest Service planning rule

 

This is the first of a series of posts about possible approaches to preparing an assessment for a National Forest/Grassland Plan revision under the proposed Forest Service planning rule.  (It is based on some informal conversations that Peter Williams and I have had with folks inside and outside the Forest Service, but nothing here reflects official Forest Service policy or the deliberations of the team working on the planning rule.)

The proposed rule expects a process that integrates both science and collaboration: “the objective of this part is to guide the collaborative and science-based development, amendment, and revision of land management plans.” (219.1(c)).  Under the rule, an assessment must be collaborative and science-based, just as the overall plan revision process, because it brings together many sources of information, including social, economic, and ecological, whether qualitative or quantitative.  Moreover, the subsequent process must rely on information from an assessment if the process is to be collaborative and science-based.

Although one immediate purpose of an assessment is to identify whether a need for change exists, the second, equally important purpose of an assessment is to inform design of the subsequent forest planning process that will propose specific changes to the plan if a determination is made that a need for change does exist.

Under this definition, an assessment is both a product and a process

The product is a report similar to an “Analysis of the Management Situation” or other scoping documents under the 1982 planning rule.   It documents “existing and potential future conditions and stressors” that subsequently will be the foundation for the revision’s Environmental Impact Statement.  It describes the Forest in the context of the broader ecosystem, and what’s going on in the States and counties within and surrounding the Forest.

The process involves convening multiple parties at multiple scales to determine if the current Forest Plan is working by answering a set of assessment questions derived from the rule

This rather long list of questions has the potential to be quite lengthy, so they need to first be screened to determine if they are relevant to the particular forest.  Screening questions would include:

Assessment Goal

Coarse Screening Question

Need for change in plan components or monitoring program

Is the information needed to inform and develop plan components (i.e., Is this a Forest Plan issue, not a program planning issue or a project issue)?  219.6(b)(1)
Is the resource present?  219.7(b)(2)(ii)
Is the resource important?  219.7(b)(2)(ii)
Is addressing the resource within the authority of the Forest Service?  219.8, 219.9, 219.10, 219.11
Is addressing the resource within the capability of the plan area?  219.8, 219.9, 219.10, 219.11
Is addressing the resource within the fiscal capability of the unit?  219.10
Is there an emerging public issue that needs be addressed?  219.6

Design of process for revising a plan or monitoring program

Is the information needed to understand the discrete roles, jurisdictions, responsibilities, and skills of interested and affected parties?  219.4(a)
Is the information needed to understand the expectations regarding the accessibility of the process, opportunities, and information?  219.4(a)
Is the information needed to determine the scope, methods, forum, and timing of public participation opportunities?  219.4(a)(1)
Is the information needed to develop required plan components (219.6(b)(1)), including information needed to inform design of the public notification and participation process?  219.7(c)(1)

In answering the questions, technical information is essential, but an assessment under the rule should not merely be a technical process – it is fundamentally participatory, drawing on information and knowledge from multiple sources and multiple participants.  During an assessment, the most accurate, reliable, and relevant scientific information is synthesized from governmental and non-governmental sources. But the process is also about clarifying values, because an important step is to identify why a particular National Forest/Grassland is important to the participants.  One reason for clarifying values is that the knowledge being sought includes how a new plan should be proposed.  That is a process-oriented goal.  To meet such a goal in a way that is appropriate for the local situation, the assessment must seek to understand procedural preferences—values—of stakeholders, including but not limited to those of Forest Service personnel. The second specific assessment purpose is worth highlighting again: the goal of an assessment under the proposed planning rule is to gather and integrate information that informs design of a participatory and collaborative process should one be needed to change the plan.

Part 2 will describe how an assessment might be conducted.

Desired Future: Whose Desire? What Future? Why?

The idea of a “desired future” is found frequently in Forest Service NFMA and NEPA discussions/writing. I decided to see if I could find out where the idea of “desired future” and “desired future condition” come from. It sort of shows up in the 1979 NFMA Rule, mainly w/r/t wildlife populations, but gains a major toehold on FS thinking in the 1982 rule:

Sec. 219.11 Forest plan content. The forest plan shall contain the following: … (b) Forest multiple-use goals and objectives that include a description of the desired future condition of the forest or grassland and an identification of the quantities of goods and services that are expected to be produced or provided during the RPA planning periods

And it has been a part of FS thinking ever since. I can understand back in 1982 that the Forest Service wanted to remake America’s national forests into something foresters would desire, while zoning out Wilderness, Wild and Scenic Rivers, and other “set-asides”. So the idea of “desired future” made sense, at least to foresters who were running the Forest Service back then, some of whom were desirous to see the allowable timber cut increased from 11 to 33 billion board feet.

But to continue to use the language in the 2011 proposed NFMA rule is a different matter. The focus these days is not on increasing “allowable cut,” but instead on restoring ecosystems resiliency. But there is still a hint of what author David Ehrenfeld called The Arrogance of Humanism, 1981 at work here. At least I think so. That is why I’ve advocated for simple scenario planning instead, in part to avoid what I believe to be a “desired future” trap. For an article length view, see Thomas Stanley’s Ecosystem Management and the Arrogance of Humanism, Conservation Biology, 1995 (pdf)

Let’s leave a couple of inquiry questions: Is the idea of “desired future” even needed in forestland adaptive management? Why does this language persist in NFMA rules.

[Update, 4/6/11: I noticed this AM that the Draft NFMA rule refers to "desired condtions" (219.7 (d)) instead of "desired future," or "desired future condition(s)" but the meaning appears identical, at least to me.]

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Related: In Search of Our Desired Forest, John Rupe, NCFP, 2/18/2011

From Forest Planning to Adaptive Governance

“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