Planning

All’s Well on the Planning Front — Or is it?

by

The year was 1995 (or thereabouts). I attended a Forest Service sponsored meeting on Strategic Planning at Grey Towers. I carried my brand new copy of Henry Mintzberg’s Rise and Fall of Strategic Planning to the meeting, referring to Mintzberg’s death-knell for planning whenever I could. (Here is a six-page summary pdf) A few souls agreed that Strategic Planning as envisioned by the NFMA regulation ought to have died even before Mintzberg penned his classic. But most in attendance were true soldiers from the Forest Service and a few other government agencies — looking only to do better at their assigned/accepted tasks.

Now it is 2010 and the Forest Service is once-again playing the Frame Game to make sure that the status quo planning frame is not upset too much. Or so it seems to me. As always, I hope I’m wrong. The game is to rewrite the regulatory “rule” for NFMA. If he Forest Service believes it to be a “planning rule” my guess it that the game is lost before it begins. To set a stage the Forest Service is hosting a bunch of so-called collaboration meetings. First out the chute, a Science Forum — a two-day gathering of “scientists” early this week. The outcome of the meeting will likely prove up my 1995 observation-warning that the Forest Service hadn’t (and hasn’t yet) learned its science lesson:

It is folly to assume that, “Science will find the answer,” as if science alone were the key to resolving social problems. Such thinking hasn’t been helpful to medical practitioners, engineers, even scientists when challenged to help explain the cultural mess we’ve gotten ourselves into relative to sustainability.

A framing question lingers: Why is the Forest Service once-again leading with science if the intent is to reframe policy and/or management?

On the heels of the Science Forum, the Forest Service will host three two-day sessions in Washington DC, and a series of one-day sessions in the hinterlands. Not enough time for thoughtful deliberation of what social mess (or wicked problem nest) the Forest Service is in, neither how it got there, neither how it might begin to move forward.

A framing question lingers: Why is the Forest Service once-again hosting a series of meetings to begin reframing the “rule”? Isn’t there any other way? Or is tradition rearing its head once again? Some of us have advocated for Blogs (internet discussion forums) to begin discussing serious policy matters and Wikis to actually write alternative versions of policy. (See, e.g. here.) But all, so far, is to no avail. We’ll see what will happen this time relatively soon. For now, though, let’s step back again in time.

The year was 2002. I began to preach the gospel of Panarchy: Understanding Transformations in Human and Natural Systems (Buzz Holling’s intro to the Panarchy idea), following on the heels of Barriers and Bridges to the Renewal of Ecosystems and Institutions, The Politics of Ecosystem Management, Managing the Unexpected and a few other key books. (See: Collaboration Readings for Reflective Practitioners). I continued to do so until my retirement in 2007. Nobody, other than a few who blog here, seemed to care. Nobody seemed anxious to seek a different path. At least no one in power circles seemed to care.

Inevitably each new idea that emerged was transformed into “Planning”: assess, plan, act, evaluate, plan, …. Planning swallowed up adaptive management without a hiccup. Planning swallowed up Environmental Management Systems, or almost , again without a hiccup. (my 2005-2007 EMS blog) But it was pretense. Pretend adaptive management. Pretend collaboration. Nothing remotely real about it. Still, it suited the Forest Service bureaucracy well. It could be force-fit into the rigid straitjacket of the Manual/Handbook system. Nothing would change the planning juggernaut that was launched way back in 1979.

All could be pretended to be well. If only the damn enviros would just quit suing. After all the Forest Service was/is no longer rapaciously clearcutting. Never mind the mining/drilling interests, the grazers, the commercial recreation interests, etc. Never mind the suited men behind the curtains. Why can’t the enviros just settle in, kick back and enjoy (by 2009) the stimulus money that is being thrown thither and yon, some of it for so-called ecological restoration. Note: the reason the “rule” is once-again ‘in play’ is because some damn enviros sued and got the last one thrown out. (Personal admission: I am one of those ‘damn enviros’, and was long before retiring from the Forest Service.)

A framing question lingers: Did I fall into the ‘Good Will Hunting’ trap? Here is the trap in a nutshell: Badboy Will said to his psychiatrist, in essence: “You people baffle me. You spend all your money on these fancy books, you surround yourselves with ’em — and they’re the wrong fucking books.” (Great movie, btw)

Did I read the wrong books? If so, assuming that any power brokers in the Forest Service actually read, what books ought I to have been studying and preaching from. And if ideas, visions, and paths forward are not to have come from books, what ought I to have been looking for smoking?

Just a few Sunday thoughts to ponder while awaiting the meetings, and the posts that will flow here and in the official FS nonblog.

Forest Planning Without Knowing the Mission

by

The definition of multiple-use management provides no guarantees.

In 1972 two brothers with cattle grazing permits within the Prescott National Forest in Arizona had a gripe with the Forest Service.   One brother’s permit had been reduced from 517 to 250 head, and the next year the other brother’s permit was reduced from 158 to 50.  The numbers had been reduced to protect the watershed from overgrazing, but Thomas and David Perkins questioned if these drastic reductions constituted a revocation of their grazing permit.  So they took the Forest Service to court. In 1977, the District Court sided with the Forest Service, but the brothers appealed to the Ninth Circuit.

When the case made it the appeals court, the Perkins’ attorney tried a new argument.  They asserted that the 1960 Multiple-Use Sustained-Yield Act (MUSYA) established a mandate to allow multiple-uses such as livestock grazing.   MUSYA is perhaps the only statement from Congress about the purpose of managing National Forests and Grasslands.  The Organic Act established timber and water flows as dominant uses, and the agency was built on Gifford Pinchot’s philosophy of the greatest good for the greatest number of people in the long run, but it wasn’t until the MUSYA that the idea of multiple-use was codified.  The MUSYA said that forests were to be managed for recreation, range, timber, watershed, wildlife and fish, in addition to minerals and wilderness.  Renewable resources were to be managed to best meet the needs of the American people, without impairing the productivity of the land, and maintained at a high level in perpetuity.

The appeals court rejected the Perkins’ argument that the MUSYA established a mandate for use.   The Court wrote:

These sections of MUSYA contain the most general clauses and phrases. For example, the agency is “directed” in section 529 to administer the national forests “for multiple use and sustained yield of the several products and services obtained therefrom,” with “due consideration (to) be given to the relative values of the various resources in particular areas.” This language, partially defined in section 531 in such terms as “that (which) will best meet the needs of the American people” and “making the most judicious use of the land”, can hardly be considered concrete limits upon agency discretion. Rather, it is language which “breathe(s) discretion at every pore.”  What appellants really seem to be saying when they rely on the multiple-use legislation is that they do not agree with the Secretary on how best to administer the forest land on which their cattle graze. While this disagreement is understandable, the courts are not at liberty to break the tie by choosing one theory of range management as superior to another.”

The Perkins brothers’ case became one of the leading cases in the Ninth Circuit about the judicial standard of review.  Courts would limit their review to determining whether factual findings as to range conditions and carrying capacity are arbitrary and capricious.  The review was so narrow that very few challenges to multiple use decisions could meet it, semantically or practically. Plaintiffs could satisfy their burden of proof only by demonstrating that there was “virtually no evidence in the record to support the agency’s methodology in gathering and evaluating the data.”  A court would not choose among competing expert views.  The case also meant that MUSYA placed no real limits on the Forest Service, and that it was up to the agency to interpret the principles.

The discretion in MUSYA carried over into the National Forest Management Act (NFMA), which used MUSYA as a primary objective of Forest Planning.  Another Ninth Circuit decision observed that forest planning is inherently discretionary given NFMA’s broad authorizing language.  When the Prescott Forest Plan was completed, the Ninth Circuit refused to second guess the findings about suitable grazing lands.

Since MUSYA and NFMA were broadly discretionary,  Congress essentially left the work to the Department of Agriculture and the Forest Service to define a mission.  In the 1990s, the Forest Service developed its present mission statement: to sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and future generations.   Multiple-use management is relegated to the fine print.

Then, regulations issued by the Department became important in shaping the mission.  In the preamble to the 2001 roadless rule (p. 3252), the Perkins brothers case was used to explain that the Secretary’s discretion under MUSYA and NFMA allowed roadless areas.   Essentially, the preamble explained that the roadless rule itself was an NFMA rule.

In the  2000 planning rule,  the Secretary translated multiple-use management into the concept of sustainability.   The rule said that the first priority is to maintain or restore ecological sustainability and that it is essential that today’s uses do not impair the functioning of ecological processes.  In an appendix to the 1999 Committee of Scientist report for that rule, one of the scientists, Roger Sedjo, said this was a change to the Forest Service mission.  He noted that sustainability of a forest is fundamentally different than the sustainable production of multiple outputs.  Sedjo later wrote that the search for a new mission is being frustrated by a lack of clear consensus.

The 2005/2008 planning rule didn’t directly address this concern.  It acknowledged the MUSYA, saying ecological, economic and social sustainability were all equal, but focused instead on the mechanics of planning for a “desired condition.”  The weakness of this approach was that the rule never required planning teams to identify why those conditions were desired.   In practice, many planning teams using this rule overcame this weakness through a collaborative exploration of what each forest was about, through identification of the “roles and contributions” and the “niche” of each forest.  But these statements were not to be considered official “plan components” and would not be binding.  The plan had to focus on desired conditions, and all other plan components needed to be linked to those conditions.  But participants typically didn’t want to talk about desired conditions, they wanted to talk about uses.

Now we have begun work on a new planning rule.  The Federal Register notice discusses concerns like restoration, ecosystem resilience, and forest health.  The split in public opinion is again showing up in the formal scoping comments.  If this rule follows the pattern, it may be about more than planning – it may be about the Forest Service.

Fixing the “Rule”

by

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

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

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

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

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

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

Imagining A Changing Forest

by

 

A desired condition is not a picture.  It’s a movie.

This is a map of four seral stages for the Pagosa Springs district of the San Juan National Forest.  Young stands of trees (class 1) are very rare.  So are the purple areas representing the oldest stands of trees (class 4).  Most of the map shows middle-aged stands (red and green).  Think about how this information might be used in forest planning.  For instance, the purple areas might be important habitat for late-seral stage wildlife species, they might be mapped as ecological reserves, or they might have some unique social values we want to protect.

Here is a simulation of what could happen to these stands of trees over time due to fire, insects and disease.  Each interval in the movie is a 10-year increment.   It is based on work by Kevin McGarigal of the University of Massachusetts and Bill Romme now at CSU, for the San Juan Forest Plan Revision using a GIS-based simulator called RMLANDS.  It formed an understanding of the historical range of variability of vegetation for the DEIS.

The stand size and distribution is most dependent upon fire interval and fire size, randomly simulated based on historical data.  Over time, the tree conditions seem to float across the landscape like shifting sand.  There are some places where topography seems to influence the disturbances to allow persistence of older trees, but even these areas are eventually affected by the random events.

The smaller the scale, the larger the variation.  If you look at a particular place, there is more change over time in the color of the place.  The larger the scale, there is more likelihood that you’ll find the color you are looking for somewhere.

When planning for forests influenced by disturbance, landscape ecologists advise us that it’s important to think of time and space.   It calls for a discussion beyond static desired conditions.  Instead, a discussion is needed on the disturbance processes, if anything should be or can be done to shape those processes, and what we should do with the conditions that might result.  This is a very different type of forest plan than we have done in the past.

Putting Your Dot on the Map

by

They are “remembered landscapes.”

Nearly every weekend when I was growing up, my parents, my two sisters, our large family dog, and I would get in the car and head to my grandparents’ house in St. Maries, Idaho.  The trip was usually pretty boring for a kid, but we always got excited when we got to the White Pine Scenic Drive in the St. Joe National Forest.  The highway carved through the forest creating a tunnel effect, and in the middle was a sign along the highway that said “cool spring.”  Even the dog somehow knew when we were getting close to cool spring.  We’d stop, get a drink, walk into the woods a bit, and marvel at the dense trees with moss growing everywhere.  Down the road was the tallest white pine tree in the world, but that was just a boring statistic to a kid.   The statistics didn’t matter, but the place was special.

Today the sign is gone, cool spring is gone, and the trail has been expanded for motorized use.  White pine is incredibly susceptible to blister rust and many trees have died.  The large tree has fallen over.  My dad and my niece got their picture taken by the incredibly huge roots.  It doesn’t matter that the forest has changed, but the place will always be special.

When I was working in the Black Hills, I once talked to a county commissioner on the Wyoming side.  She told me that when she was growing up, her dad loaded up the Studebaker and headed up a road that isn’t even recognized as a road today.  They would reach a large meadow and have a picnic lunch.  Today, that meadow is overgrown with dense small trees, and probably needs to be thinned.  The place is special, but her experience is gone.

In Colorado, Monarch Pass feels like it’s on top of the world.  From the top, you can see an expanse of trees that seems to go forever.  For folks that have traveled on U.S. 50 from the east, this is their continental divide experience.

In the San Juan Mountains of Southwest Colorado, you can go on a hike from the desert to a meadow with a stream running through it, and look up at snow capped peaks as high as you can imagine.  It’s unreal that you can see desert and tundra at the same time.

Social scientists often group participants in a forest planning process as members of a “community of place” or “community of interest.”  I don’t have a direct economic or social stake in how forests in Idaho are managed.  I don’t even live in Idaho any more, but I am still connected to a “place” in a forest along a 12-mile stretch of highway.

Before 1976, the Forest Service conducted “unit planning” with units roughly the size of ranger districts.  In part to increase the working circle of potential timber harvest to assure a continuous supply, NFMA established Forest Plans.  But Forests often were too big for the community of place.  Then, the scale of planning grew even bigger.  The St. Joe and White Pine Drive were administratively split between the Clearwater and the new monolithic Idaho Panhandle National Forests.   The area around cool spring fell on the Clearwater side.  The old Forest Plan put White Pine Drive in a scenic corridor management area, but the area was too small to show on the forest plan map.  The Clearwater has now combined with the Nez Perce to complete one large planning effort.

The area in the Black Hills fell into an inventoried roadless area subject to the 2000 roadless rule.  Monarch Pass was designated in the Westwide Energy Corridor EIS as an important corridor.  The multi-state decision doesn’t mention how the corridor entirely covers the Monarch Pass Ski Area.

Forest planners have discovered that place matters.  The Medicine Bow-Routt-Thunder Basin has done three plans.  The Pike-San Isabel-Cimarron-Comanche will do two.  There are some excellent examples of place-based planning in the Beaverhead-Deerlodge, Chugach, and GMUG forest planning processes, where forests are subdivided into “places” for planning.  These were discussed in a 2003 workshop in Portland.    The authors note:

“Place-based planning” refers to land and natural resource planning efforts that bring together diverse human values, uses, experiences, and activities tied to specific geographic locations. Although planning efforts have always focused on specific places through land use zoning frameworks, place-based planning is different from other types of approaches. For example, whereas land use zoning segregates dominant uses from one another on the landscape, place-based planning takes a more holistic approach, focusing on identifying current uses, values, and meanings. In addition, place-based approaches tend to take a longitudinal perspective, exploring desired future conditions for the landscape. This approach enables participants to identify a variety of uses that might occur concurrently rather than designating one primary use for the upcoming 10 to 20 years.

Some commentators are concerned that place-based planning and the new emphasis on collaboration are putting National groups at a disadvantage.  Ohio University political science professor Nancy Manring wrote a paper in 2004 about the 2005 planning rule provision that replaced the appeals process with an objection process.   She observed:

“McCloskey (2000), Coggins (2001), Foster (2002), Hibbard and Madsen (2003) and Kenney (2000) all have argued that collaboratives may maximize community-based interests at the expense of national stakeholders and values. As Weber (1999, p. 482) cautioned, “The danger is that such communities will develop a sense of themselves apart from and to the detriment of the nation.” No doubt, it will be easier for communities to develop a separate sense of themselves if representatives of national interests and values are not physically present at the negotiating table. The potential tensions between local and national values – between the communities of place and the communities of interest – are thrown into sharp relief by the realities of collaborative planning without the traditional appeals process as a safeguard. “

At the beginning of the planning process for the San Juan Forest Plan Revision, participants at public meetings were given sticky dots to place on a map.  There was even a parallel process on the web, where you could put a computerized dot on the map.  The idea was that participants could identify their special places, and where resource conflicts might occur.  These sticky dots were used in drawing the the forest plan map.  The Plan will use geographic areas as big as ranger districts, and within the areas, there are subdivisions displayed by using eight development “themes.”  A final Plan is expected next year.

Addressing NFMA Timber Requirements Through the Restoration Lens

by

Arizona Lumber and Timber Company, Coconino National Forest, 1939, photo by Walter H. Shaffer

Sometimes language can get in the way.   Foresters are becoming aware that their traditional language for cutting trees confuses the public, and reduced their ability to explain what they are trying to accomplish.  This is especially true today when trying to reduce the chances of unwanted fire behavior, by “restoring” tree stands to conditions that were less dense.

In 2008, former associate chief Sally Collins coauthored a paper with Hutch Brown about the importance of rephrasing the purpose and need statement for vegetation projects, eliminating the use of traditional silvicultural terminology and replacing it with the language of a new collaborative process.  They pointed out that the technical language is difficult for lay audiences to understand, and because it originated in a timber culture, the language can cause confusion about a restoration project’s true purpose.  For collaboration to work and succeed, a new kind of language is needed that clearly communicates the intended restoration purpose.

In pointing out the problems with silvicultural terms such as “commercial” or “pre-commercial thinning”, “crown spacing”, “ladder fuels”, and “conifer competition”,  Collins and Brown point out: “Whereas Forest Service professionals and many interested groups are familiar with terms like these, others are not. Sustainable restoration efforts require broad public involvement and support, yet relatively few people are likely to engage in a project when they do not understand the terms used to describe it.”

The same criticism of timber project descriptions also holds true for planning under NFMA.  Perhaps there is a way to be faithful with the act, but translate the terminology in ways that explain the ecological purpose of the projects.

Here are some of the possibilities:

NFMA Requirement1982 TerminologyPossible New Terminology
Determine forest management systems, harvesting levels, and procedures, and the availability of lands and their suitability for resource managementMultiple-use prescription for each management areaAgree on a theme for an area – what is the degree of human influence on natural processes like fire and insect and disease outbreaks?;What are acceptable changes and rates of changes to the forest?What are acceptable types of burning of the forest?
Identify lands not suited for timber productionLands suitable or not suitable for timber productionIdentify areas where trees can or cannot be removed and sold
Insure that cut designed to regenerate an even-aged stand will be used (for clearcuts only where its optimal) where such cuts are consistent with soil, watershed, fish, wildlife, recreation, esthetic resources, and regeneration of the timber resourceEven-aged silviculture and even-aged standsIdentify landscapes where we prefer trees at the same age
Insure timber will be harvested only where there is assurance that such lands can be adequately restocked within five years after harvestRestocking lands within 5 years after final harvestProvide small 6-inch trees within 5 years after a stand of large trees has been removed

Considering the Science Of Land Use Planning

by

submitted by Dave Loomis

Rational Planning

After World War II, the University of Chicago’s newly created Program in Education and Research in Planning was enormously influential in setting the direction of planning theory. Keynesian economists, pushed the faculty to define and systematize core areas of knowledge in planning, perceived essential to practice. It was the search for this core for the profession that led to the development of a generic model for planning in capitalist democracy and incorporation of ideas from various social scientific disciplines, including economics and political science. The rational planning model, became a guide in the profession and beyond as an approach to problem solving in the public sphere ;

1. Ends reduction and elaboration;
2. Design of courses of action;
3. Comparative evaluation of consequences;
4. Choice among alternatives;
5. Implementation of the chosen alternative.

The five steps were later simply described as “Desires, Design, Deduction, Decision, and Deeds. Reproduced, more or less, in countless presentations since, these steps describe a problem-solving framework for complex human enterprises. The model is both self-evident due to simplicity and unachievable due to its demands on resources and expertise. Chicago planners recognized complexities, including the elusiveness of the aim of serving the public interest and politics’ resistance to scientific analysis.
Even before publication, the rational planning model had its critics. It has suffered battering from countless quarters since. Yet, for about 20 years it remained the most widely subscribed planning theory. To this day, its logic can be found in the justifications and methodological outlines given in the introductions to most plans. It remains a major underpinning of planning school curricula. Moreover, theoretical and methodological work detailing and extending the model continues. This includes efforts to compare alternative rules for aggregating individual preferences, examination of the implications of risk and uncertainty, and consideration of the impact of new and faster computers on our abilities to ascertain public preferences and completion of the necessary calculations.

By drawing on Keynesian economics and policy studies in political science, the rational planning modelled to the incorporation of numerous social scientific concepts into planning offices. It highlighted planning’s role in correcting market failures related to externalities, public goods, inequity, transaction costs, market power, and the nonexistence of markets. Justifications for planning included reduction of nuisance and congestion, protection of resources, reduction of taxes or of public costs, provision of a stable business environment, and the improvement of environmental quality and livability. Planning borrowed the tools and language of cost-benefit analysis and operations research, including notions of decision criteria, multiple objectives, constraints, shadow pricing, willingness-to-pay, optimization, and minimization.

Criticisms and Extensions of Rational Planning
The incrementalist critique of rational planning gained wide circulation by the early 1960s. Political scientist Charles Lindblom (1959) suggested that comprehensive or .synoptic. planning, as he called it. was unachievable and out of step with political realities. He argued that political leaders cannot agree on goals in advance, as the rational model requires. They prefer to choose policies and goals at the same time. He thought that the rational model’s preoccupation with the comparison of all possible alternatives and their comprehensive assessment on all measures of performance exceeds human abilities. The relationship between science and policy choice was oblique at best. The real measure of “good policy” is whether policymakers agree on it. Lindblom’s alternative, incrementalism, calls for the simultaneous selection of goals and policies, consideration of alternatives only marginally different from the status quo, examination of simplified, limited comparisons among the alternatives, and the preference for results of social experimentation over theory as the basis of analysis.

If Lindblom’s late ’50s critique had shown a chink in the armor of rational planning, the social unrest of the 1960s brought a full frontal assault. Alan Altshuler’s (1965) doctoral dissertation examined the experience of land and transportation planning in the Minneapolis-St. Paul region. He found that planners were seldom able to achieve their objective I scientific aspirations. Their claims to comprehensiveness were not backed up by reality. Decision-makers often ignored their recommendations in favor of the wishes of politically connected stakeholders. Organizers of citizen input to planning processes railed against the often-futile nature of public participation.

The rational planning model gradually lost ground. Indeed, in the late 1970s, it was common to talk about a “crisis in planning theory” resulting from the loss of a center to the field.

A series of new directions emerged, focusing on planners’ facilitative roles in shaping decisions emerged. Often referred to as social learning theories, these contributions emphasized planners’ roles in bringing stakeholders together, gathering and sharing information, and helping social structures to learn from their experiences. Citizens and civic leaders, not planners, had to be at the core of planning if plans were to be implemented. The planner, acting as catalyst and boundary spanner strives to create a self-correcting decision structure capable of learning from its own errors.

By the late 1970s, planners recognized that the completeness with which they had embraced notions of science in their work had exacerbated their isolation from political decision-makers. Planning theorists began drawing from political philosophers who questioned mainstream social science.

Communicative planning theory asserted that through communicative strategies complementing their technical work, planners can alert citizens to the issues of the day, arm them with technical and political information, and otherwise encourage community-based planning actions. It would then be necessary for them to work in the midst of the wide variety of views expressed by diverse interest groups to formulate new consensus policies that might be widely supported.

Much recent activity has surrounded identifying better ways for planners to present arguments so that they will be persuasive in political and multicultural environments. One promising direction proposes that the often-quantitative orientation of urban planners matches poorly with the needs of decision-makers who are often moved by stories that convey human behaviors in terms they can understand. Storytelling is a proposed serious planning method that can accomplish what statistical analysis may never do. Other theorists are drawing on turn of the century American pragmatist philosophers to suggest that the emphasis on deductive reasoning in our statistical training is out of step with the more pragmatic. problem-solving orientation of most public decision makers.

What Have We Learned Since the COS Report?

by

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

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

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

CEQ Guidance Comment Period

by

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

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

Here’s the link.

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

– ESTABLISHING AND APPLYING CATEGORICAL EXCLUSIONS

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

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

– MITIGATION AND MONITORING

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

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

– CONSIDERING GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE

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

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

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

FACA Frolics- Or- When an AC Has Your Back

by


While I agree that federal agencies may have too many advisory committees, and that the structure of FACA committees may involve large amounts of bureaucracy and paperwork, I think they can also serve a useful purpose. So here is my experience: I was the Designated Federal Official for the Forestry Research Advisory Committee for a year or two, and I also worked with the ACAB (Advisory Committee for Agricultural Biotechnology) and tangentially with the NAREEAB , (National Agricultural Research, Extension, Education, and Economics Advisory Board). I observed advisory committees run well and not so well, making recommendations of great, and little, utility. I experienced the frustrating paperwork requirements firsthand as a Designated Federal Official (trying to get the Office of White House Liaison to accept our nominees, and restarting the process when clearance packages got lost). My most recent experience was with the RACNAC (Roadless Area Conservation National Advisory Committee) as a staff person involved with the Colorado Roadless Rule, which entailed all the fun and none of the bureaucracy for me.

Here are a couple of reasons I think a formal collaborative group for the planning rule might be useful.
1) Commitment to the process. The formality of a FACA committee means that people (generally) take their responsibility seriously and put the time in to really work on the issue and understand it. Being a FACA committee is not the only way of getting this commitment (certainly the Colorado Roadless Taskforce had that commitment, but it was not within the federal structure) but formalizing it as opposed to having a generic kind of group seems to help. Perhaps this is because, as a FACA committee, the group can make formal recommendations.
2) Today, “bipartisan” is on the lips of many. Especially for planning rules and roadless rules, there has been a history of public policy as ping- pong ball from administration to administration. A set of recommendations from a collaborative group gives an opportunity for recommendations beyond partisanship. It also potentially gives political cover for the next administration not to mess with it. The bipartisan Colorado Roadless Rule Taskforce recommendations carried forward across governors of different parties. Most of us just want a planning rule that we can live with that will stick. The “will stick” part can be helped by a FACA committee.
3) Navigating the clearance process. Many agencies weigh in, some with strange and peculiar worldviews, and if you want your rule cleared, you have to go along or the Department has to spend political capital. If the recommendations left the FACA committee and the Department went along with them, it would be pretty transparent where the changes came in. Then advisory committee members could potentially set up educational meetings with the recalcitrant agencies, or call upon their own favor networks to facilitate progress.
4) Raising the level of dialogue. Some individuals will come to a public meeting and comments about how bad a certain idea is (along the lines of “my views are clearly based on goodness and light and yours are venal and unprincipled”). I have seen the RACNAC ask useful questions like “how would you change the proposal to improve it?” that served to focus the dialogue. In one case, a person had flown in to a public meeting who clearly didn’t know the topic and hadn’t been briefed and didn’t seem to have a clue about how to improve the proposal or on anything that would veer off the written statement. The agency itself would probably have simply felt uncomfortable asking for higher level input, as our role is not generally to question or improve public comments but be hospitable to the public and listen. Having expectations for, and hopefully, generating, substantive discourse would add greatly to an involvement process.

5) Providing media cover. Members of a FACA committee can say all the things about their recommendations in colorful ways that agencies probably can’t.. and defend their recommendations in the media. This keeps the agency from becoming either a punching bag, or perceived to be defensive and argumentative.

In summary, then, a FACA committee, in my experience, can provide all kinds of useful support and cover for a complex, divisive issue and is worthy of consideration. The only addition I would have would be to include some kind of peer-to-peer discussion with agency staff or a formal devil’s advocate, as to the practicality and economic cost of the recommendations.

Some would argue that this should be a committee of scientists, but I think the STS literature and particularly Mark Brown’s book “Science in Democracy” leads us to the conclusion that representational would be best (as was the RACNAC).

P. S. I think that Brown’s book is great, but is a bit heavy on the canon of political theorists for most casual reading. I haven’t thought about Locke, Hobbes and Rousseau since I worked on the 1995 RPA, where we tried to place them along Pinchot, Leopold and Muir to describe the “serving people” part of “caring for the land and serving people.”