What Should Plans Do?

What is forest planning?

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I’m trying to work up yet-another forest planning post tracing the evolution of Forest Service decision-making from the rational planning era to the adaptive governance era. So I decided to solicit opinion in advance. What do you think forest-level planning is? Here are some possibilities. Feel free to add more, and I’ll update this post.

What best describes “forest-level planning”?

  • Anachronism – an artifact of a bygone era
  • Distraction – a relatively safe place for environmentalists and other “forests service malcontents” to wage war against the forest service, distracting them from larger arenas where they might prove more damaging to forest service agendas
  • Nuisance – nonsense that keeps foresters and “ologists” out of the woods
  • Abomination – a “pox on all our houses,” a legal/administrative nightmare
  • Communitarian Decision Container – a place for people to gather together to build community and resolve problems about a national forest they love
  • Rational Decision Container – a place for professionals and scientists to help managers make rational decisions about best use of a national forest

[Updated: 3/28/2011]

Standards in Planning

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

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

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

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

Types of Standards Used in Forest Planning 

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

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

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

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

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

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

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

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

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

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

Why Standards?

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

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

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

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

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

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

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

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

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

Planning Rules, Manuals and Handbooks – a flashback

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Here is a post from a short-lived blog I ran in 2005, Forest Planning Directives, about Forest Service planning Manual/Handbook rewriting. I think it may shed light on our planning rule critique as well. And it can serve as a guidepost, for the inevitable Manual/Handbook rewriting that will ensue just after the Draft Planning Rule moves to “Final.” Here it is, lightly edited:

Any role at all for NFMA Directives?

I have struggled for the last few days to better understand management and planning systems and ask myself whether we ought to keep any parts of the "interim directives." As usual I answer, No! You may find my thoughts amusing. You may find them bemusing. There is an odd chance you may find my thoughts enlightening. Here they are:

Land Management Planning as an Embedded Process

We have many processes (or systems) to help us manage the national forests and other public lands. Problem is these systems are often fractured and fragmented, and sometimes work at cross-purposes. We have tried to run our systems as pieces of a well-oiled machine. But it can’t work that way. The world is too complex for that, and sometimes politically wicked as well. A better management model is one that mimics nature, one comprised of self-organized complex adaptive systems. See Margaret Wheatley and Mryon Kellner-Rogers A Simpler Way for more.

Looking at things hierarchically, in a complex systems frame, we can see land management planning systems embedded in planning systems, embedded as part of "management systems."

Forest Service Management Systems
It proves helpful to see the map of interrelated systems that aid in adaptive management/organizational learning. Commonly recognized systems include:

  • Assessment Systems
  • Evaluation Systems
  • Inventory Systems
  • Monitoring Systems
  • Planning Systems

Add to these supporting systems, like:

  • Education and Training Systems
  • Personnel Recruitment and Support Systems
  • Budgeting and Finance Systems
  • Information Technology Systems
  • And so on

Now overlay all these with various "functions," like:

  • Vegetation management (timber, range, etc.)
  • Bio-physical resource management (soil and water, wildlife, plants, etc.)
  • Fire management (suppression, pre-suppression, etc.)
  • Facilities management systems
  • Recreation management systems
  • And so on

Finally overlay all with what we refer to as "Line Management," with about:

  • 900 District Rangers, who report to
  • 120 Forest Supervisors, who report to
  • 9 Regional Foresters, who report to
  • 1 Chief Forester

Now we can begin to get a glimpse of the complex nature of the management systems that we attempt organization with. The trick to all this is to make sure that the systems are not only complex, but adaptive and purposefully interrelated as well. No small order. And there are traps along the path we need to be aware of.

Decision Traps
Identifying systems and subsystems can either empower us or disable us. There are two traps that people commonly fall into here. First, we do not want to overly-reduce the complexity that enfolds us or we may develop overly complex systems or components in any one area, and at the same time neglect other important areas. This trap has been called "Abstracted Empiricism" or "Methodism."

Second, we may simply trap ourselves in the identification of the complex systems themselves. This trap is called "Grand Theory," where the trapped are paralyzed by their own overly-generalized identification and specification of complexity in the universe. In extreme form, this trap paralyzes people to the extent that they do not attempt any organization at all.

Interconnectivity, Dynamics, and Relationships
Traditionally we like to think of our organization as decentralized. But given law, policy, and Manual and Handbooks, etc. it is hardly decentralized.

We also traditionally think of our organization as working according to the dictates of "directives" that guide much of the action. Problem is, the directives tend not to be able to guide the workings of this (or any other) complex, adaptive, system. So what we have is a mess. We pretend to be decentralized, but that cannot be. We pretend to be directed in much of what we do, but the direction seems at best archaic, at worst unworkable from the get-go.

All the management systems are highly inter-connected. For now we will simply recognize them without pigeonholing them into some rigid structure like "plan-do-check- replan." This is not to say that we won’t keep that model in mind. Instead we don’t want to get trapped into thinking that is all we have to do. Our general approach should be mindful of our over-complexification dark side, our penchant to narrow our focus to the inner reaches of whatever box we find ourselves in and begin crafting ever-more- complex regulation, rules, technical guides, etc.

Take planning, for example. We have to plan before we develop any system or subsystem. But we can over-plan any system and ruin it. See, e.g. Henry Mintzberg, The Rise and Fall of Strategic Planning, 1994. In the Forest Service we have many over- planned and under-used systems. A lesson we continue to fail to learn, is that we need to design systems that can grow and develop as "users" continuously critique them and improve them. That means we have to start small, and let systems grow and develop as they are used. It also means that we have to weed out components, subsystems, and even whole systems that have outlived their usefulness. Pruning and tending are important, if unglamorous tasks in managing systems.

We need fewer teams of people to design work for other people, and more teams that design their own work and do it in ways that both improve and simplify the systems they work with. W. Edwards Deming champions such organization in his The New Economics: For Industry Government Education. Margaret Wheatley and Myron Kellner-Rogers lay out fundamental ideas and concepts on organization, information, and relationships in A Simpler Way. I recommend reading the books beginning with A Simpler Way, then moving to The New Economics, and finally for the devoted (and particularly for planning cheer-leaders) reading The Rise and Fall of Strategic Planning. But there is no way to practice adaptive management if we are unwilling to think about and read about ways to make it happen.

What does this mean for Manuals and Handbooks?
It means only that we had better do something very different from 18-30 feet of shelf space filled with cumbersome Manuals and Handbooks. We had better cut it all to the bare minimum. We had better take advantage of what’s out there in professional practice, and only add what must be added to help professionals work in our environment. It means The End of Bureaucracy & the Rise of the Intelligent Organization, which is also a very informative book written by Gifford and Elizabeth Pinchot. {Note Gifford is the grandson of the Forest Service’s founder.}

In this spirit, the Forest Service economists recently reduced about 100 pages of Manual and Handbook materials (FSM 1970, FSH 1909.17) to about 2 ¼ pages each for Manual and Handbook. The manual says, in essence, address social and economic context in various ways and places to help set a stage for managerial decision making. And highlight the social and economic consequence of proposed (and actual) action to the extent practical and foreseeable.

What does this mean for the Land Management Planning Manual & Handbook?
For Land Management Planning it means that we need to design and work with a subsystem that contributes to the whole rather than being parasitic on the whole. It means we need to quit thinking about controlling other systems. We need instead to think about contributing our small part to a broader whole.

First lets look at broad management systems. What might such a systems look like? What directives might guide it? The system is a complex web of multiply interrelated systems, all sharing some information with other systems while holding some information within any given system since it only adds "noise" to other systems. All systems are interrelated as well by the relationships between them, and by the relationships between those who take care of each system, and by the relationships of these people with those whose focus is broader, covering several or all systems.

Sustainability
The system is purpose driven, wandering down a path toward what many call sustainability. We know that the path is long, winding, and indeterminate. Sustainability is a vision quest. Sustainability is something that shape-shifts as we move down the path. But sustainability is also something that we are ever-mindful of. It is a goal that hovers in front of us, guiding us. Ecosystem constraints bound the path – some associated with natural and biological systems, some associated with human systems.

Long term, we are rewarded when we stay on the path toward sustainability, and punished when we stray beyond the bounds. Short term, we often blow the boundaries, sometimes by political design and sometimes by human error. Such deviations are punished, but the punishment may be felt by "contemporaneous others" or "future others." There are lags, often very long ones, in the feedback loops.

Surrounding our complex of managerial systems, and connected to them are broader-framed social systems with names like science, ethics, politics, beliefs, participation, that are part of the social/cultural environment. These systems interrelate with natural systems in the physical and biological realms.

Now let’s look at land management planning systems, embedded in ever-larger adaptive management frames.

Land Management Planning
What questions might guide our inquiry? (Similar questions might be framed for any planning)

  • What is planning?
  • How does it fit into adaptive management?
  • What do we expect from planning?
    • What if desired deliverables do not include a plan? Remember that Scenario Planning advocates and many others do not believe that the goal of planning be the production of a plan. Instead, they stress the importance of planning to rehash the past and rehearse the future.
  • If we expect a plan, along with other deliverables, what do we want it to do?
    • If we only want a plan to be a vision document, perchance highlighting vision over a variety of landscapes, but not making any how-to decisions, then we will answer this question much differently than if we expect a much more comprehensive, detailed plan.

Why bother with any Manual or Handbook? Why isn’t the NFMA Rule enough directive? Perchance the NFMA Rule is already too much directive, but that is a question for another time.

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

Is A New Rule Worth It?

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I went back and looked at the 2009 Notice of Intent today to refresh my memory regarding why implementing a new rule is so important to the Forest Service. From the NOI:

Developing a new rule will allow the Agency to integrate forest restoration, watershed protection, climate resilience, wildlife conservation, the need to support vibrant local economies, and collaboration into how the Agency manages national forests and grasslands, with the goals of protecting our water, climate, and wildlife while enhancing ecosystem services and creating economic opportunity.

I’m wondering, what is it about the existing rule that doesn’t allow the national forests to do this?  While the current language might not be very good at requiring some of these things, it certainly doesn’t prohibit them.  Any national forest is free to write a plan that attempts to do all of these things.

Sure, current requirements for things like designating and monitoring management indicator species (MIS) don’t work as originally envisioned and probably are largely as waste of time and money.  But most forests have figured out apporaches that can survive a legal challenge.

Some forests such as the National Forests in Mississippi are developing plans right now that meet the existing rule requirements while incorporating new approaches such as a framework for ecosystem diversity. The rule doesn’t require it, but it makes sense and has widespread support.

What challenges will a forest developing a plan under the new rule face?  How about legal challenges to the list of items in Martin’s post “We’ll Consider It” ?

Does the forest plan appropriately consider “various stressors or impacts?” How about “the physical (including air quality) and biological integration of the terrestrial and aquatic ecosystems within a landscape.” How well does the plan take into account “other forms of knowledge”, and so on down the list?

All of these points will be debated in the courts, just as MIS, viability, and monitoring have been since NFMA was signed into law. We won’t know what they really mean until the judges tell us.

Dave commented on Martin’s post  that:

In talking with two FS planning directors earlier this week, both seemed more intent on fixing “planning” via rule implementation than in fixing the “rule.” This is unfortunate in my estimation.

The “rule” ought to have framed things up for whatever follows re: national forest management. Instead, it appears that the rule development process is now largely viewed by many in the FS as a “throwaway,” so that they can get on with “God’s work” whatever the flavor of that might be this year.

I agree that it is unfortunate. It really is time for a new rule.  From where I sit, I would like to see a rule that goes  further in terms of establishing the kind of adaptive management approach that Dave talks about. I would like to see a rule that speeds up the process and eliminates some of the requirements that most of us agree don’t make sense anymore. I would like to see a rule that requires all of the considerations in Martin’s list and perhaps a few more.

But if I were a beleaguered forest planner, I might prefer to take my chances with the devil I know rather than one I don’t.

In Search of Our Desired Forest

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Jumbo Peak, Gifford Pinchot National Forest, photo by Tom Kogut

“What we leave on the land is more important than what we take away.” – Forest Service Chief Dale Bosworth, 2002

“Narrowly defined desired future ecosystem conditions, particularly if they are historical conditions poorly aligned with the unprecedented future, will seldom provide useful targets for management intervention.” – Stephenson, Millar, and Cole In Beyond Naturalness, 2010

What’s the true value of a Forest Plan?  Over the history of Forest Service planning, the answer has changed. Now it’s changing again – plans in the future will not be measured by the accuracy of their detailed descriptions of fixed “desired conditions”, but how robust and flexible the plans will be when dealing with uncertainty.

Of course, maybe the true value of planning was never what we thought. It may have simply been about drawing a map of the areas where activities could occur, and creating a certain level of accountability with the public about how the activities would be conducted. But the idea persists today that the central purpose of plans is to describe detailed “pictures” of our desired conditions, and the specific structure, composition and function of the necessary ecosystem elements.

What a history we’ve had! NFMA plans were originally conceived as essentially one big timber sale. During the Senate floor debate in 1976, Hubert Humphrey said that no project level NEPA documents would be required after a plan was completed. All the parts of the plan were equally important. That changed in 1990, when former Chief Dale Robertson began to assert that standards and guidelines were more important than objectives. Throughout the 1990s, we shifted our focus from the uses of the forest to the condition of the forest itself. While changing the NFMA planning rule, the 1999 Committee of Scientists described the purpose of forest planning as “outward looking, built upon assessments; grounded in current scientific understanding; collaborative in nature; and focused on desired future conditions.” Planners were told to concentrate on “what we leave on the land.”

Meanwhile, planning was requiring huge investments of time, and plans were being written with a few pages of goals and objectives followed by 100 or more pages of forest-wide or management-area-specific standards and guidelines. Good standards were difficult to write, because they required inventories of current conditions that weren’t available, understanding of changing technology, and the need for difficult projections about the level and intensity of likely future activities in the face of changing management priorities and changing conditions on-the-ground. It was difficult to set standards for things like old growth or riparian areas when we didn’t even know how many acres were out there.

So the 2005 and 2008 planning rules were written to make plans more strategic and vision oriented, like county comprehensive master plans, and less dependent upon prescriptive standards. The preamble to the 2008 planning rule explained that “plans are more effective if they include more detailed descriptions of desired conditions, rather than long lists of prohibitive standards or guidelines developed in an attempt to anticipate and address every possible future project or activity and the potential effects such projects could cause.”

But a funny thing happened when we started writing plans under the 2008 rule. Instead of 100 pages of standards and guidelines, we now had 100 pages of desired conditions. Rather than broad, strategic goals, descriptions of desired conditions were becoming specific, detailed, highly-parameterized descriptions of vegetation conditions: percent species composition, numbers of trees per acre, desired ranges of basal area, numbers of snags, etc. The idea was that detailed desired conditions could ease the burden on project planners in developing the “purpose and need” for projects. At the same time, these desired conditions writeups were suggested as a tool for “accountability”.

Meanwhile, we probably lost the idea that forest plans should be readily understood by the lay reader who treasures a forest.  For many people, a forest is a place.  It’s not a list of attributes.

But here’s the fundamental question about planning:  Do National Forests change because of Forest Plans or in spite of Forest Plans? Can we really control nature? Is intensive end-oriented management possible everywhere? In the Rocky Mountain west, we work in fire-dominated ecosystems with very long fire-return intervals. We have seen huge swaths of trees dying of insects or disease. The rates of change are enormous, and for some forests, current FIA data doesn’t represent the current conditions on the ground. We are heavily influenced by severe storm events – intense snowstorms, rain on snow events, patterns of drought, summer floods, even tornadoes. There is no equilibrium condition. Our Forest Plan modeling shows dynamic, ever-changing forests.  We have become focused on the types and rates of forest disturbances.  At the scales we’re dealing with, it may not be possible to map a single desired condition, or even a reasonably understood “range of conditions”.

The dynamics of climate change create uncertainties at the scales we are working at.  Connie Millar has said that “although DC statements may be written broadly (“habitat for species x exists in adequate amounts to maintain current populations”), equally often they emphasize limited views of the future, or very narrow ranges of conditions (“4-6 snags per acre”). This suggests that the possibility of multiple ecosystem pathways, unexpected events, major interactions among elements, and threshold events are not really accepted by managers or the public. DC statements that recognize ranges of outcomes and not just singular states as acceptable are more realistic.”

Florida State Law professor Robin Kundis Craig has argued for new types of plans and regulations because “Stationarity is Dead“:  “we are moving into an era where ecological change might not be predictable and when external factors, positive feedbacks, or nonlinear instabilities in a system will cause changes to propagate in a domino-like fashion that is potentially irreversible. As land, air, and water temperatures generally increase, patterns of precipitation alter in terms of both amount and timing, and species shift as best they can to cope, “restoration” and even “sustainability” have the potential to become close to meaningless concepts. We are moving along an at least somewhat unpredictable path to an as yet unpredictable final destination.”

The planning problem is not just about natural forces – it’s also about societal changes. We are seeing new uses of National Forests, and more and more projects are proposed by somebody other than the Forest Service.  For instance, how can we anticipate in advance what standards and guidelines apply to laying a new type of fiber-optic cable across a forest?

As explained in the business and public administration literature, the purpose of a strategic plan is to identify core strengths, intended roles and contributions, and a “vision” which can be a rallying point or goal to be achieved. A plan should be robust and flexible, so it can adapt to changing conditions, changing knowledge, and changing politics, while being consistent with the organization’s core strengths and vision. A highly detailed plan will detract from the day to day sensing necessary to manage the unexpected. As Karl Weick and Kathleen Sutcliffe state in their book Managing the Unexpected:

“A heavy investment in plans restricts sensing to expectations built into the plans and restricts responding to actions built into the existing repertoire. The result is a system that is less able to sense discrepancies, less able to update understanding and learn, and less able to recombine actions into new ways to handle the unexpected.”

Park Service scientists Robert Bennetts and Bruce Bingham have pointed out the reasons that it is highly difficult, if not impossible, for managers to achieve desired conditions, because of lack of information, lack of management control, unavoidable circumstances, and trade-offs based on societal values. They talk about the “punitive paradox”: managers aren’t going to report impaired conditions if they are being judged on the difference between existing and desired conditions. They conclude that desired conditions could be a useful scientific research question, but they don’t work as a management tool.

So where does this leave us?  Actually, some of the answers have already been mentioned on this blog.  There are some exciting planning techniques being implemented in the field.  We’ve got the tools – let’s see what we can do.

Defenders’ Planning Checklist

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Here’s a new report from Defenders of Wildlife providing a checklist for evaluating the impending 2011 forest planning rule: Defenders’ Planning Checklist in PDF. 

This is sure to be the first of several upcoming evaluations and critiques, and we’ll post those here as well. 

I don’t see any big surprises here.  The group is obviously focused on a mandatory species viability standard, but it also calls for an “external factors” exception to the standard when necessary, such as when activities on private land threaten a species on an adjacent national forest.  This is something that Sharon has written about on the blog.  Also included in this section is a call for a “non-discretionary monitoring program to ensure that habitat is supporting viable populations.”

Lots more of course.  Including a section, close to my heart, calling for a strong framework of national standards, guidelines, and objectives.

And here’s the report on the Defenders’ blog:  http://experts.defendersblog.org/2011/02/obama%E2%80%99s-forest-rule-a-checklist-for-success-from-defenders-of-wildlife/

Rethinking the Recreation Opportunity Spectrum in Forest Service Plans

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“Primitive.” 

“Semi-primitive non-motorized.” 

“Roaded-natural.” 

The fine print of most Forest Service Plans contains terms from a recreation zoning scheme that is essentially the same as when it was developed in the 1980s.  The Recreation Opportunity Spectrum (ROS) is a means to subdivide a forest by desired physical, social, and managerial features to provide a setting for compatible recreational activities.  Although the basic framework has been in place for nearly 30 years, it may be lost in the discussions about a new forest service planning rule, and the system is showing some wear.  The system was never fully integrated across resources.  Forests and Regions have developed processes independently, leading to inconsistencies within and across Regional boundaries.  Naming conventions vary, and there are differences in how wilderness areas are mapped, and how seasonal distinctions are addressed.  Now, the importance of ROS maps in Forest Plans may be even greater than previously thought, after at least one court ruling saying these maps are constraints on recreational activities.

The 1979 ROS Users Guide, the 1990 ROS Primer and Field Guide, and the 2003 National ROS inventory mapping protocol describe the six distinct settings that are mapped in a Forest Plan:  urban, rural, roaded natural, semi-primitive motorized, semi-primitive non-motorized, and primitive.  Used in conjunction with Sense of Place (SOP) mapping, the Scenery Management System (SMS), and Benefits Based Management (BBM), ROS is an approach to display human values, meanings and attachment to the landscape.

The ROS system was at the heart of a sixth circuit decision discussed here a couple of months ago which struck down the revision of the Huron-Manistee Forest Plan.  In that decision, the court addressed the concern about providing “quality recreation opportunities for hikers, backpackers, and cross-country skiiers” by upholding the ROS system as a “thoughtful methodology for matching settings and activities, among other planning purposes.”   However, the court then went further and said that the Plan should not allow activities such as gun hunting and snowmobiling that are inconsistent with ROS descriptions like semi-primitive non-motorized.  The court said: ”The [Forest] Service cannot expect us to defer to its ROS descriptions when they support its decision (which we have done above), but then to disregard those same descriptions when they conflict with its decision.” ….  “the [Forest] Service’s decision not to balance these competing uses, and to disregard its own ROS descriptions, is what fell outside the relevant standards.”

One of the esoteric debates among forest planners these days is where exactly an ROS map fits in a forest plan.  Often, ROS maps don’t match management area maps, and treatment of ROS zones varies from plan to plan.  Some plans contain ROS elements as part of an aspirational “desired condition” while other plans list the identification of an ROS class as a “standard” that all projects must meet.  Although ROS is very similar to the idea of a suitability map, like timber suitability or grazing suitability, ROS is not specific to a particular activity.  It merely describes a setting for recreation activities, and only suggests certain recreational activities that might be compatible in that setting.  Because the actual conditions of the recreation setting need to be validated on the ground, it’s difficult for a forest plan to specifically identify recreational opportunities.

Arguably the most important element of the ROS mapping process is the separation of semi-primitive non-motorized areas from other motorized or roaded settings.  Essentially, a SPNM area is a contiguous unroaded area of at least 2,500 acres. A plan should have consistent direction for ROS, scenery management, travel management, road construction, and other developments.  This part of a forest plan can be very important, because it can limit road building and other development on parcels smaller than the 5,000 acre threshold for potential wilderness areas, or areas previously mapped as roadless and controlled by roadless policies.  While a “roadless” area by definition is larger than 5,000 acres, backcountry recreation activities are certainly possible in areas as small as the 2,500 acre threshold.

ROS needs to be featured as a central part of the forest planning rule.  But it needs to be updated.  Here are some considerations:

  • The terms need to be simplified.  Many people don’t understand the concept of “semi-primitive.”  In some forest plans, management areas adopted a simpler concept known as “backcountry.”
  • New categories may be necessary, to address distinctions between summer non-motorized and winter non-motorized, variations within Wilderness areas, or roaded-natural areas that may be roaded but generally non-motorized.
  • The ROS concept should be expanded to incorporate other activities and resources.  This might best work by requiring ROS zones to be integrated into the forest plan management area process.
  • ROS classifications probably shouldn’t be treated as forest plan standards.  There are too many variables that influence what recreational activities can occur in an area.  However, the planning rule should treat the ROS idea as an important feature of forest plans and plan objectives, standards, and guidelines should be consistent with the ROS classifications.
  • The designation of ROS zones needs to be made at multiple scales.  ROS zoning is subject to the same pitfalls as general management area zoning – it can tend to fragment a forest, and doesn’t lend itself to the larger question of regional recreational experiences.  One report suggests that the inability to “think and act regionally” leads to a homogenization of recreation experiences which suboptimizes and reduces the flow of recreational experiences in the region. 

The ROS system is a sophisticated tool that has been adopted by other agencies and even extended to nonfederal lands.  It’s time to dust it off, and make sure it’s a key element of the new planning rule.

Place-Based Legislation- Red Rocks National Scenic Area

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Here’s a link to an article on a Red Rocks Scenic Area near Sedona, Arizona.
Here’s a link to the bill.

Here are some quotes from Senate candidate Glassman’s website:

National Forests are far more development-friendly than other types of federal land and are vulnerable to land swaps that could ruin the scenery. The community and the U.S. Forest Service have already put in place protections within the Forest Management Plan. However, that plan is not a permanent answer. The Sedona Community Plan calls for “maintaining existing limits of the private lands and preserving the National Forest lands within the city.”

Establishing a National Scenic Area would codify plans already in place, having been developed with the Forest Service and Verde Valley community leaders at the same table. It would restrict land swaps that could leader to development further into the Red Rocks. Establishing the NSA would open up the Sedona area to more federal grants to protect this natural resource.

This idea, at least as told here, seems to fit in with the idea that forest plans are necessary, but not sufficient to protect areas from development.

It sounds like some people are afraid that by revising, they will lose important agreements that they have made through forest planning, e.g.,Amendment 12. They seem to be saying that really important agreements should not be revisited through planning. That is the same kind of thinking that led to rulemaking in Idaho and Colorado roadless- there are important land use decisions best not revisited through planning.

I see some paradox here in that we have worked for years on planning rules and plans, to say what you can and can’t do in specific areas. If many feel that “lines on maps saying what you can and cannot do” need to be codified through a more permanent process, what is left that is important and essential to do in forest planning? At the risk of sounding heretical, would it be more cost effective to do lines on maps once and codify than to revisit every 15 years?

If we did this, we could have each forest develop more of a visionary plan with learning objectives and monitoring that would not need to be in regulation.

I also wondered whether it is true that a designation will make it easier to get federal grants? If so, once word gets out, I would see a potential for a serious case of nation-wide Designation Proliferation.

Rethinking Forest Planning – Guest Post from Mark Squillace

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Mark Squillace is a law professor and the Director of the Natural Resources Law Center at the University of Colorado Law School. Some of his views on the process-related issues surrounding the current round of forest planning are set out in a post titled Engaging the Public in the Latest Round of Rulemaking on Forest Planning on the Red Lodge Clearinghouse blog.

After two days of intense discussion about the forest planning process at the May 11-12, 2010 workshop in Rockville, Maryland, I’d like to offer these observations while they are fresh in my mind. First, kudos to the Forest Service and the Meridian Institute for establishing such an open and effective process for engaging the public. I have written more specifically about the process on the Red Lodge Clearinghouse website and those comments can be found here. In this post, I would like to suggest a few principles that I believe should govern the rulemaking process for forest planning and a few ideas for establishing a process that reflects those principles.

First and foremost, the Forest Service must not lose sight of the fact that the central problem with the current framework for forest planning is that it is too complex. As a result of this complexity, plans often take many years to develop, and their very complexity invites appeals and litigation. Let’s not ask too much of our forest plans. They should offer a vision for the future management and use of discrete areas and not much more. They should be simple enough that they can be completed within a year – two at the very outside. They should be relatively short – no more than 150 pages, and they should be accessible to the general public so that the general public can meaningfully participate in the planning process. Plans are likely to be most accessible if the alternatives that are being considered can largely be understood by looking at series of maps reflecting the alternative visions for forest management.

The complexity contained in most of our current plans relates largely to the fact that the Forest Service has historically used the plans to establish detailed standards and guidelines for managing particular forest resources. My sense is that this largely traces back to the Forest Service’s belief back in the early 1980’s that forest plans developed under the 1982 rules could essentially govern all future decisions on the forest, at least until a new forest plan was developed. I think we know now that this model does not work. Yet the Forest Service still seems to cling to the belief that more complex forest plans will make project level decisions easier. If they stepped back and thought about this they would surely realize that more complex plans do not make anything easier.

This leads to my recommendation that the planning rules should establish a process for “tiered planning.” Tiered planning borrows a concept from NEPA. Under a tiered planning regime the Forest Service would first develop a large scale, “bird’s eye” vision for the forest that would meet the basic legal requirements of NFMA for land and resource management plans. This would involve a NEPA process that considers various alternative visions for a forest, before a final vision is chosen. Among the decisions to be made at this large scale level would be what resources on that particular forest required separate resource specific plans. The large scale plan would guide the Forest Service in the development of these sub-level, tiered (and integrated) plans for the particular resources identified during the land use planning process. These tiered resource-specific plans would be accompanied by separate NEPA processes and separate opportunities for review. Different forests would need different resource plans. Project level decisions that relate to particular resources studied in a sublevel plan would then fall under a third tier, but since not all forest resources would necessarily require a sub-level plan, some project level proposals might simply flow from the large scale plan itself.

Breaking down plans into component parts, as the proposed tiering process would do, will not necessarily lead to less work for the Forest Service up front. But it will allow the basic plan – the vision document – to be developed more easily and more quickly, and it will allow conflicts and controversies to be better isolated to particular resources While tiered planning might be criticized for failing to promote sufficient integration of resource-specific assessments with land use decisions as required by NFMA, the Forest Service can address this problem simply by adhering to the basic principles of tiering articulated in the Council on Environmental Quality rules implementing NEPA. In particular, those rules describe “tiering” as appropriate when “it helps the …agency focus on issues that are ripe” and “exclude[s] from consideration issues … not yet ripe.” 40 CFR 1508.28(b). By divorcing the planning choices from the choices relating to specific resources, the Forest Service can put off consideration of those resource specific issues until the agency is ready to consider whether and how specific resources should be used.

Another great advantage of tiered planning is its potential for engaging the public in a more meaningful way. Tiered planning can achieve this goal because it allows interested parties to be involved at whatever level of detail they desire. Those most interest in the particular type of land uses that are going to be allowed on particular tracts of lands (or perhaps over the entire forest landscape) can participate only on the land use level decisions, with some confidence that the choices made during this large scale planning process will be honored as sub-level decisions are made. Those interested in the development, use, or management of particular forest resources can focus their attention on particular resource plans or project level decisions involving those resources and those lands where particular resources are authorized for use.

I want to conclude with one general observation about the current process. Even as I applaud the Forest Service for initiating this ambitious exercise in civic engagement, the agency should recognize that one of the risks associated with this process is that it invites even greater complexity in planning. The natural tendency of participants asked to consider ways to improve forest plans is to suggest additional requirements that might be imposed on forest planners. For all of the reasons expressed above, making forest plans more complex than they already are would be a huge mistake, even if, in the abstract, we might agree on an idea for further improving forest plans. A great example of this comes from the workshop and concerns the request to participants that they consider “restoration and resiliency” as one of six issues for forest plans. Understandably, most people think that restoration of degraded forest resources and managing forest resources to promote resiliency are generally good things. I don’t disagree. But restoration and resiliency cannot and should not be treated as ends in themselves. Indeed, it is generally accepted that restoration of degraded lands to their original condition is probably not possible, and maybe not even desirable. More importantly, restoration and resiliency should be seen for what they are – tools that might (or might not) help to achieve the goals and objectives established in a forest plan.

The elusive goal of finding a better way to do forest planning will only be achieved if we come to grips with the fundamental problem associated with the current process. It’s too complex. We need to rethink forest planning in ways that will allow forest plans to be concise, accessible to the general public, and developed and implemented within a reasonable period of time. I appreciate the fact that it won’t be easy. But I nonetheless believe that it can be done.

The Hartwell Paper and A New Forest Planning Rule

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For those of you who aren’t familiar with this paper, it was a recent effort to figure out if another approach to climate policy could be more successful.

Here is quote from Mike Hulme in this essay on the Hartwell paper .

To move forward, we believe a startling proposition must be understood and accepted. It is not possible to have a “climate policy” that has emissions reduction as the all-encompassing and driving goal.

We advocate inverting and fragmenting the conventional approach: accepting that taming climate change will only be achieved successfully as a benefit contingent upon other goals that are politically attractive and relentlessly pragmatic. Without a fundamental re-framing of the issue, new mandates will not be granted for any fresh courses of action, even good ones.

The paper’s first primary goal focuses on access; to ensure that the basic needs, especially the energy demands, of the world’s growing population are adequately met.

The second is a sustainability goal; to ensure that we develop in a manner that balances social, economic and ecological goals.

Third is a resilience goal; to ensure that our societies are adequately equipped to withstand the risks and dangers that come from all the vagaries of climate, whatever their cause.

Most regular readers of this blog will know that my approach to climate change for public lands is basically:
1. Do all the things we know we should have been doing (monitor and adapt in a transparent disciplined way)
2. Preferentially protect the fundamentals, especially water and air. There is no correct or incorrect composition of plants and animals, now or in the future.
3. Connect landscapes through riparian and other corridors.
4. Use land trades to decrease fragmentation of public lands and open areas to solar or wind development.
5. Develop sustainable biomass industries where needed to conduct fuels treatment or for ecological resilience.

I am also a big fan of Trout Unlimited’s “protect, reconnect and restore” as described in their “Healing Troubled Waters” document here.

So here’s the question- think about Hulme’s concepts, my concepts, TU’s concepts and your own concepts of what to do about climate change… what is the public lands piece to you? And what, if any of that should fit into a planning rule?