Comments on Freemuth’s piece in HCN

Some of these comments sounded worthy of discussion. I was intrigued by the concept that somehow collaboration avoids NEPA and other legal requirements. I guess I was having trouble imagining collaborating at any level on anything  that ultimately results in decisions that violate legal requirements- because the legal nexus is the decision.  Can someone help me understand this concern further?

Monitoring- Solving the Puzzle

Alex Dunn raises another question that is definitely a piece of the planning rule discussion. What about monitoring?  People do a lot of monitoring; at the same time, there is never enough money for monitoring. Once I spent some time attempting to frame the “monitoring problem,” and even remember doing some interviews, but  could not even achieve consensus on the  framing of the problem. That’s when you know you have a serious problem.

Here are a couple of pieces to the puzzle:

A. Who decides what at what scale? Conundrum.

1. Logically each forest would develop an integrated monitoring plan from broadscale to project level.  Yet a variety of handbooks have different required monitoring, so it seems like it’s a patchwork. One unit told me once “we don’t know what we’re going to monitor because it depends on what the new wildlife biologist is interested in.” So it seems to be a constantly shifting patchwork.

2. But some very important things don’t make sense to be monitored separately by forests,  and have regionwide or species-wide plans for monitoring. Like a species, why would monitoring plans vary by forest?

3. Monitoring should be done across all lands, so how does that fit? Should the FS work with other agencies, the States, landscape scale collaboratives?

4. Watershed monitoring makes sense down a drainage/river. This scale would then be larger than the landscape scale collaboratives.

It’s almost like we should distinguish some basic things to monitor, say air and water quality, and basically do them the same nationwide and across all lands, and then the other important things to monitor each deserve consideration of what scale is appropriate.  Yet, we expect “forest plan monitoring” to be some kind of anchor. Why? What’s that about?

B. Another piece to the puzzle is that there are units that have monitoring programs that seem fairly successful; that annually stakeholders go out and review the results; and the stakeholders and the unit talk about potential causes of the results, and future research questions and potential changes in management practices.

These two pieces don’t really fit. Difficulty, challenges, and yet perceived success.

I’m sure there are more pieces to the monitoring puzzle; perhaps by carefully examining all the pieces we could attempt to solve the puzzle.   If we could decide, and explain how we would be accountable, it might be a convincing approach to appropriators, which would then possibly get around the funding problem.

Strategic Planning- The Literature- Mintzberg

Here is a book review of a book that was important in the development of my own thinking on the utility of strategic planning, by Henry Mintzberg, entitled The Rise and Fall of Strategic Planning. Recommended to all in this discussion. Some of Jim Burchfield’s observations reminded me of this book.

Book overview
In this definitive and revealing history, Henry Mintzberg, the iconoclastic former president of the Strategic Management Society, unmasks the press that has mesmerized so many organizations since 1965: strategic planning. One of our most brilliant and original management thinkers, Mintzberg concludes that the term is an oxymoron — that strategy cannot be planned because planning is about analysis and strategy is about synthesis. That is why, he asserts, the process has failed so often and so dramatically. Mintzberg traces the origins and history of strategic planning through its prominence and subsequent fall. He argues that we must reconceive the process by which strategies are created — by emphasizing informal learning and personal vision — and the roles that can be played by planners. Mintzberg proposes new and unusual definitions of planning and strategy, and examines in novel and insightful ways the various models of strategic planning and the evidence of why they failed. Reviewing the so-called “pitfalls” of planning, he shows how the process itself can destroy commitment, narrow a company’s vision, discourage change, and breed an atmosphere of politics. In a harsh critique of many sacred cows, he describes three basic fallacies of the process — that discontinuities can be predicted, that strategists can be detached from the operations of the organization, and that the process of strategy-making itself can be formalized. Mintzberg devotes a substantial section to the new role for planning, plans, and planners, not inside the strategy-making process, but in support of it, providing some of its inputs and sometimes programming its outputs as well as encouraging strategic thinking in general. This book is required reading for anyone in an organization who is influenced by the planning or the strategy-making processes.

Also there are some interesting  user reviews at the link.

Analysis Paralysis-Gridlock Redux- Who’s Responsible?

“Forest planning has been hijacked by a generation of planners who turned what should have been a narrowly-focused effort to constrain an out-of-control Forest Service logging program and turned it into a wasteful, endless, bureaucratic exercise with little merit. “ Andy Stahl (my bolding)

My memory was the that FS had identified overanalysis as a more general problem and had looked internally and externally to describe the sources and some solutions. NOTE: that this was more focused around project planning than forest planning, but one might hypothesize that some of the causes and cures would be the same.

I do remember some thinking going along the lines of : if people don’t want projects or plans to happen, and they appeal and litigate on procedural grounds (NEPA and NFMA processes), then the FS needs to develop “bullet proof ” documents.  This is a dynamic  which inexorably leads to over-analysis.

Some empirical evidence might be looking at other agencies and seeing how much they over-analyze (given that the right level of analysis is in the eye of the beholder) and attempting to correlate that with amount of litigation. I did have some experience with some APHIS NEPA that would suggest that since at the time they faced  little litigation, they did not over-analyze.

I was looking for the original FS report on gridlock, and ran across a couple of interesting things in my internet search.

One is a discussion between Neal Sampson and Andy Stahl about gridlock in 1995.

I also found the original report on Process Predicament from 2002. From the Executive Summary on page 5 :

Unfortunately, the Forest Service operates within a statutory, regulatory, and administrative framework that has kept the agency from effectively addressing rapid declines in forest health. This same framework impedes nearly every other aspect of multiple-use management as well. Three problem areas stand out:

1. Excessive analysis—confusion, delays, costs, and risk management associated with the required consultations and studies;

2. Ineffective public involvement—procedural requirements that create disincentives to collaboration in national forest management; and

3. Management inefficiencies—poor planning and decision-making, a deteriorating skills base, and inflexible funding rules, problems that are compounded by the sheer volume of the required paperwork and the associated proliferation of opportunities to misinterpret or misapply required procedures.
            These factors frequently place line officers in a costly procedural quagmire, where a single project can take years to move forward and where planning costs alone can exceed $1 million. Even noncontroversial projects often proceed at a snail’s pace


Finally I found a news report in which both Chris Wood and Mark Rey panned the above report. Now, usually Chris Wood and Mark Rey tend not to be on the same side, at least on things that are politically charged,  so the fact that they neither thought much of the Process Predicament report is somewhat intriguing.

It sounds like we (the combination of externals and internals) never really worked through this issue, and it remains unresolved.   Re-investigating the causes and cures for this phenomenon, or at least how it applies to forest planning,  may be important to design plans with appropriate levels of analysis and planning rules to require an appropriate level.

The Purpose of Planning

Contributed by Jim Burchfield, Interim Dean, College of Forestry and Conservation, University of Montana

Beyond rulemaking, environmental analyses, and the myriad of necessary procedural steps, land management planning on National Forests will be well-served to adhere to fundamental principles.  Planning strives to meet two interlocking objectives: (1) To create a more desirable future; and (2) To link knowledge to action.  Both of these objectives require ongoing effort, such that planning does not become a once-per-decade tedium of covering all contingencies via numbing documentation, but a continuing learning experiment.  Especially in an environment as complicated and dynamic as any given National Forest, the creation and re-creation of a coherent, “actionable” vision for a desirable future implies repeated political exercises of clarifying and allocating human values.  Unfortunately, the Forest Service is not quite ready for an immersion into these messy, real-world negotiations because, ironically, it’s afraid to make mistakes.  I say, bring on the arguments and dissatisfaction.  Confrontation breeds learning.  Plans will not be perfect.  Good.  If we learn from our mistakes we make the next iteration better.  We make progress.  What is necessary is comfort in imperfection.

The creation of learning-oriented planning argues for two unnerving transformations in the current planning process.  First, the roles of agency experts must change, and second, investments in analysis must be reversed from the front to the back end of the planning processes.  A more meaningful role for the mangers and scientists who guide the planning process is to promote landscape-level trials of different management possibilities – some “let burn” here, some intensive logging there – not much concerned with a particular site’s “suitability” but more focused on the responses of these lands to experimental actions (some obvious, already established criteria for suitability allocations, such as unstable soils, already exist and may continue).  Concurrently, these agency sponsors engage in new, interactive, political forums with the gamut of interested parties to negotiate where and at what intensity these experiments take place.  Design will be important and prior assessments of resource conditions relevant, but they will not overwhelm the overarching demands to act and learn.  The proposals emerging from deliberative arguments among multiple interests will commonly generate creative ideas for action, and importantly, a set of normative indicators of benefit that can be subsequently measured.  Each action is a risk, but a worthy one.  The good news, of course, is that nature is highly resilient, recovering from all types of human shenanigans.  We simply negotiate a new set of outcomes, and try our best.

Simultaneously, the attention of planning must be turned on its head from the tiresome tradition of pre-planning “assessment” to the dynamic practice of post-treatment evaluation.  The biggest change to realize this reversal is the funding of a systematized process to measure consequences, that is, a serious commitment to monitoring and evaluation (two distinct and often wrongly conflated processes).  The absence of evaluation is the commonly recognized Achilles heel of planning success, which is why adaptive management has been so rightly criticized.  Behaviors can’t be adjusted or “adapted” when there’s been no confident measurement of change.  The roles of different actors in planning become further clarified, as the science capacity of the agency comes into play far more significantly in the aftermath of planning (while it is now misplaced in the early phases), and the normative interests of the public ascend in importance in planning’s developmental stages.  Scientists will be crucial in clarifying robust measures of change and completing analyses of consequences, even though it will be the participants of planning exercises, including non-professionals, who help conduct these measurements, learning as they go whether the results of actions indeed create the conditions expected.

What bothers many professionals is that this form of planning – deliberative, action-oriented, and uncertain – means things go wrong.  But utopia remains an illusion as the land and its inhabitants change too fast for idealized models to keep up.  The measurements made in monitoring could show something entirely different than the anticipated results.  Fine.   After all, management actions aren’t the only forces at play, especially with latent, large-scale perturbations (think climate change or big wildfires) overwhelming modest interventions.  What will have changed, however, is that whatever the outcome, we know we have only ourselves to blame, and this democratization of blame takes the sting from negative consequences that have been previously viewed as career-ending mistakes.   We are not just wounded but wiser. 

This commitment to knowledge from planning means that we have participants in planning who aren’t vested in being correct.  We need humble, curious planners, who are capable of setting up public learning systems.  That planning is so imprecise, ongoing, and political annoys scientists to no end, which is why they are such lousy planners.  They are trained to be cautious and correct.  It’s not that we don’t need scientists – we need them desperately.  They simply need to be empowered to be evaluators instead of creators.  Perhaps school teachers would be better planners.  They understand conflict.  They are trained to discover what their constituents want.  They can encourage people to do work.  They are skilled at demonstrating the tools for measurement. The next day’s class starts the process again.  We might even get something done.

NFMA, the Timber Wars Filter and the 21st Century

I agree with Jack Ward Thomas when he talked about “walking around the field of battle bayoneting the wounded” in, I think,  this still relevant testimony from 2000. There are also some other relevant observations from this testimony for this planning rule discussion.

21st century planning is obviously tied to NFMA, but a challenge is to divorce ourselves from the timber -o-centric nature of the statute and the “timber wars filter” that affects the way we see and frame issues . Sometimes I wonder if those of us who remember that time have some kind of filter that we can’t see beyond- and I am speaking of both those outside and inside the agency.

My wake-up call to see my own filter was moving to the Rocky Mountain Region where day to day questions include skiing, oil and gas, travel management, grazing, fuels treatments- and the supply of wood far exceeds the demand. We have little-talked about (nationally) issues of urban forests everywhere dumping, shooting ranges, crime; we also have encroachment, trespass, the need to keep our water rights and deal with water developers, we have the important but often overlooked national grasslands with prairie dogs and energy development issues.

It is only by spending time outside the larger forest policy discussion that I came to see how the old timber filter can get in the way of seeing the future clearly, including the future of the timber industry.

One idea would be to take the Southern Cal forest plans (which are relatively timber free), and see what issues they have and how they were framed, both by the forests and the plantiffs in the lawsuit.

Another idea would be to take a group of 20-35 year olds, a combination of externals and internals  – some of our most creative  thinkers and soome  experienced with current procedures, and ask them to design a  planning rule alternative. After all, they will probably be implementing, appealing and litigating the plans while we are sitting on porches sipping iced beverages and playing with grandkids.

Finally, I think that if there were a broadly supported, surgical amendment to NFMA to get rid of requirement that were clearly outdated (or relieve low-timber production forests from dealing with them) it is within the realm of possibility to pursue it.

K.I.S.S. Part II

Contributed by Andy Stahl

In comments on K.I.S.S. (Part 1, I now realize), John Rupe suggests that NFMA requires that forest plans be an “umbrella document” to guide all national forest activities.  There are three reasons for thinking that’s not the case.  First, the existing plethora of non-NFMA forest-wide plans argues that the Forest Service has never acted as if NFMA plans are all-encompassing.  These include separate plans for roads and trails (“Access and Travel Management Plans”), fire suppression and use (“Fire Management Plans”), and recreation infrastructure (“Recreation Facilities Analysis”).  None of these forest-wide plans is a part of the NFMA planning process or that law’s planning regulations.

Second, NFMA is most parsimoniously read as I suggested in K.I.S.S. Part 1.  The “one integrated plan” language Rupe cites requires only that plans include “all of the features required by this section.”  As I noted previously, the only mandatory feature NFMA requires of its plans is “forest management systems, harvesting levels, and procedures.”  What makes NFMA revolutionary, for its day, is that NFMA plans must make timbering decisions “in light of” the multiple uses.  That means the Forest Service must demonstrate that logging decisions are not made in a vacuum as if other natural resources don’t exist.  Thus, for example, NFMA requires an interdisciplinary team prepare the plan and that the plan be based on inventories of “applicable resources,” e.g., fish and wildlife.

NFMA further emphasizes that logging’s environmental consequences are important by its reference to the National Environmental Policy Act.  16 U.S.C. 1604(g)(1).  But disclosing the environmental consequences of timbering decisions is not the same as comprehensively planning the future of all natural resource activities on a national forest in a single plan.  NFMA requires the first; it does not the second.

Third, NFMA’s legislative history shows that Congress was 100% preoccupied with curing the real and perceived sins of over-logging the national forests.  Beginning with the 1970 Bolle Report that criticized clearcutting and terracing on the Bitterroot National Forest, the 1971 hearings on clearcutting held by Senator Frank Church (the recommendations of which were adopted almost verbatim in NFMA), and culminating in the spirited debate between Senator Randolph (who favored a bill that would have banned clearcutting outright) and Senator Humphrey (who favored a planning process), it is clear that Congress cared about how logging was regulated on national forests.  Nothing about mining, grazing, ski area development, water use, campgrounds, utility corridors, recreation cabins, or any other national forest use, except insofar as it is harmed by logging, can be found in the Act’s extensive legislative history.

Far from a call for all-resource, comprehensive planning, Senator Humphrey believed the Act’s purpose was to “get the practice of forestry out of the courts and back in the forests.”  He wanted foresters to stop seeing forests “only as trees and trees viewed only as timber.”  Humphrey wanted “the soil and water, the grasses and the shrubs, the fish and the wildlife and the beauty that is the forest” to be integrated into “resource managers’ thinking and actions.”  That is, their “thinking and actions” about silviculture and logging.

Planning & Collaboration

Here’s an interesting piece by our friend John Freemuth, making some provocative connections between forest planning regulations, collaboration, and Senator Tester’s proposed Forest Jobs and Recreation Act.

I don’t see it John’s way on this matter.  But the interconnections are worth considering. 

I’m certain, for example, that widespread frustration with the forest planning process helps explain the growing interest in place-based (national forest-specific) legislation.  If you’re looking for greater certainty and stability in forest management (from roadless areas to timber supply), you’re not going to find it in plans that are nothing but “strategic and aspirational.”  Instead, you seek it through legislation, or some other formal agreement with the agency.  Of course, this is not the whole story.  But problems in planning most definitely help explain the growing interest in place-based forest law.


Contributed by Andy Stahl

Forest planning has been hijacked by a generation of planners who turned what should have been a narrowly-focused effort to constrain an out-of-control Forest Service logging program and turned it into a wasteful, endless, bureaucratic exercise with little merit.  Let’s review what the National Forest Management Act actually requires of plans and the planning regulations.  The reader can follow along here:—-000-.html

Here’s what a NFMA plan must contain:

1) the “planned timber sale program” including the “proportion of probable methods of timber harvest.”

That’s it.  There is no second item.

Now look at what NFMA requires of the planning regulations.  First, there must be guidelines

1) to identify the suitability of land for resource management;

2) for obtaining inventory data; and,

3) for identifying special conditions or situations involving hazards.

Second, the planning rules must

1) insure that economic and environmental matters are considered in the forest plan;

2) insure that plans provide for diversity of plant and animal communities;

3) insure plans address research and evaluation of management systems to prevent substantial and permanent impairment of land productivity;

4) permit increases in harvest levels based on growing trees faster;

5) ensure that timber will be harvested only where soil, slope or watershed conditions will not be irreversibly damaged, land is restocked within 5 years, protection is provided to water from detrimental changes, and harvest methods are not chosen based on greatest dollar return or unit output; and, finally,

6) ensure that even-aged cutting is used only where it is appropriate, natural appearing, not too big, and protective of other resources.

That’s it.  When read in the context of the times, i.e., the clearcutting scandals of the mid-1970s, it makes perfect sense that what Congress sought were timber sale programs for each national forest that ensured logging levels and methods were light-on-the-land and protected other resources.

In the 1980s, with national forest logging beyond 10 billion and up 12 billion board feet annually, that was no mean feat.  Today, with logging at or below 3 billion board feet, forest planning ought to be a snap.  But only if the Forest Service sets its cross-hairs only on the target Congress demanded.  Otherwise, it will continue to take 15 or more years to write 15-year plans that will make no decisions and be irrelevant in the real world the day they are signed.

Andy Stahl is the Executive Director of the Forest Service Employees for Environmental Ethics

Development, Forest Planning and an All Lands Approach

In the news over the weekend,  we have seen stories on the the move toward community forests in the Oregonian, and an article in the New York Times entitled “Housing Boom Near Preserves Hamstrings Conservation” on a study of the housing boom near forests and other conservation areas.

Given the pressure of development, and the desire for forest planning to take an “all lands” approach, what kinds of things should a planning rule or a forest plan contain?

Should a precursor to a forest plan be a mapping of wildlife corridors and linkages?