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

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

 

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

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

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

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

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

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

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

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

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

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

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

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

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

  

Western Governors on Planning Rule

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Here is the link..

Below is the summary in the press release.

The governors said it is imperative that the U.S. Forest Service coordinate with states and others in refining and implementing the new rule. The letter was signed by Gov. C.L. “Butch” Otter (Idaho), Chairman of the Western Governors’ Association, and Gov. Christine Gregoire (Wash.),WGA Vice Chair.

“Given the joint authority and shared goals, it is imperative that the Planning Rule consistently and clearly recognize state authorities, as well as the need for inclusive processes and transparency, which will improve planning efforts and collaboration while reducing litigation,” the letter stated. “Further, given that both the Western Governors and the Obama administration have made the strengthening of our transmission grid a high priority, the Planning Rule must ensure that forest plans recognize this.

“With our recommended improvements to the draft rule, we can together ensure the health and productivity of our nation’s forests, watersheds and wildlife.”

The Governors comments and recommendations also included:

The planning rule fails to acknowledge the unique authority states have to manage wildlife, forest and water resources and to protect public health and safety within their boundaries.
A common landscape-scale vision for the sustainable management of forests is needed.
The rule should be amended to consider how the Forest Service will work with Governors on large multi-forest, multi-state projects. A subsection of the rule should be developed to specifically address planning for transmission lines; other utility infrastructure and facilities; and mineral and energy resources.
Because the management of public lands can significantly impact the economy of some local communities, the planning rule must provide additional direction for an increase in large-scale forest restoration and more active management. The current definition of “productivity” should be amended to include economic productivity.
The USFS should coordinate with states and ensure that forest, resource and fire management plans incorporate the plans and policies of state and local governments. States should have the opportunity to review, advise and provide suggestions on those issues and topics that may affect or influence state government programs.
State wildlife agencies should be consulted and their data integrated into the planning processes at the earliest possible stage. The current language in the proposed rule only requires the Forest Service to “consider” state and locally developed water, wildlife and community fire protection plans.

With regard to this

A subsection of the rule should be developed to specifically address planning for transmission lines; other utility infrastructure and facilities; and mineral and energy resources.

I am reminded of a recent trip to visit county commissioners in which it appeared to them that federal efforts on public land use, energy and transportation are not as coordinated among agencies as one might hope. Don’t know if a planning rule is the best way to help fix that, or perhaps a piece of the puzzle..

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

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

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

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

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

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


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

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

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

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

Science and the Planning Rule Redux

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See this story in the Sacramento Bee:

Critics say Obama abandons science in forest rules

GRANTS PASS, Ore. — The Obama administration’s proposed new rules for protecting clean water and wildlife on the United States’ nearly 200 million acres of national forests goes against the president’s pledge to let science be the guide, conservation groups and two former Clinton administration officials said Monday.

The administration made a “clear commitment” to make conservation policy based on sound science when it took office, said Jane Danowitz of the Pew Environment Group.

“One of the things we are asking for today is simple: Use science to set clear standards,” Danowitz said. “Make sure water and wildlife are protected for generations to come.”

The comments came in a teleconference from Washington, D.C., marking the end of a 90-day public comment period on new rules governing administration of the National Forest Management Act. The U.S. Forest Service expects to come out with final rules by the end of the year.

Also participating was Jamie Rappaport Clark, a Defenders of Wildlife executive and former U.S. Fish and Wildlife Service director. Clark said forest supervisors being given unprecedented discretion under the new rules need strong standards and guidelines to resist the political pressure they regularly face in making decisions on managing their lands.

Jim Furnish, a former deputy chief of the Forest Service, said the proposed rules tell local forest supervisors to consider science but leave them room to ignore science when making decisions on protecting clean water resources, fish and wildlife habitat, and endangered species.

The proposed rules represent another shift to the right on environmental issues for the Obama administration, which recently stood aside as Congress lifted Endangered Species Act protections for wolves in the Rocky Mountains and took steps to ramp up domestic oil production by extending drilling leases in the Gulf of Mexico and off the coast of Alaska.

The 155 national forests and grasslands managed by the Forest Service cover 193 million acres in 42 states and Puerto Rico. They provide about 40 percent of the nation’s clean water and threatened and endangered species habitat.

Balance between industry and conservation in those areas has been tough to find since the existing rules took effect in 1982. The existing rules were the basis for lawsuits that cut logging by more than 80 percent to protect salmon, the northern spotted owl and other fish and wildlife.

Tony Tooke is overseeing development of the rules as Forest Service director of ecosystem management coordination. He said the agency is trying to write rules that will guide a collaborative process based on science and other information sources. It looks forward to improving the rules after reviewing more than 100,000 public comments received, he added.

“There are other important sources of information as well, used in the planning process,” Tooke said. “For example, local indigenous knowledge, public input, agency policies, the results of the monitoring process and the experience of land managers on the ground.”

On national forest policy, the Obama administration came into office supporting protection of undeveloped areas known as roadless areas and payments to rural counties hurt by the loss of logging revenues.

Earlier this year Agriculture Secretary Tom Vilsack said he wanted to break through the logjam of political conflict over forest management by using science to do what is best for the forests.

More than 400 scientists and a bipartisan group of congressmen wrote letters urging Vilsack to also include more specific protections for clean water and wildlife habitat in the rules.

“This policy is probably one of the most important conservation measures I think this administration will ever undertake,” said U.S. Rep. Martin Heinrich, D-N.M.

I have a couple of thoughts on this article:
1) Does it unnecessarily politicize the debate? People like or don’t like the proposed rule across a wide political spectrum. For example, Jim Furnish seems to be called a “Clinton Administration Official”; yet as far as I know he was a career employee in a career position when he retired. Also, “The proposed rules represent another shift to the right on environmental issues for the Obama administration.” What if this article said they represent a faithful response to public comment, or a “shift to the center.” You know what I think about unnecessarily partisanizing public lands debates: it’s a bad idea.

2) I don’t think any of the cited people are scientists, nor students of science and technology studies. The idea that it is more “scientific” to have a policy with one standard from forests in Puerto Rico to Alaska, from New Hampshire to San Diego doesn’t reflect my experience in science.

3) It’s interesting to think about a thought experiment with the same quotes and considering energy policy (another natural resource policy) instead of the planning rule.

For example “One of the things we are asking for today is simple: Use science to determine which sources of energy we use” or

“Governors can consider science but national policies leave them room to ignore science when making decisions on regulating different energy sources in their state.”

and I don’t know if Vilsack really said this:

Earlier this year Agriculture Secretary Tom Vilsack said he wanted to break through the logjam of political conflict over forest management by using science to do what is best for the forests.

But how is that working for the climate science policy – using science to “break through the logjam” (did he really use that word?) ?

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

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

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

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

 

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

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

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

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

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

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

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

Assessment Goal

Coarse Screening Question

Need for change in plan components or monitoring program

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

Design of process for revising a plan or monitoring program

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

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

Part 2 will describe how an assessment might be conducted.

Fire Retardant EIS Out for Comment

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Aircraft spreads retardant on Indian Gulch fire in Jefferson County. Joe Amon, The Denver Post

A while back, I had asked Andy Stahl for a description of the desired condition he hoped to achieve by the fire retardant litigation. I am still curious and I got more information from this news story from the Helena Independent Record. Now I don’t know much about the details of this controversy, but this story was very helpful at understanding the different points of view. Any feedback from blog readers on the accuracy? Kudos to Eve Byron, the writer!

The only question I have on the information in the story that does not match my personal experience is with regards to the Indian Gulch Fire (the one I refer to as “in back of my house”). That fire was not on Forest Service land and it wasn’t an FS managed fire, so I was thinking that at least the State of Colorado must use fire retardant. An internet search yielded this link to California which apparently also uses retardant. Perhaps someone in the fire biz could give a more complete view of which states do and don’t use it.

The U.S. Forest Service is proposing a few changes, but wants to continue using retardant to slow the spread of wildfires, according to a draft environmental impact statement released for public comment Friday.

Glen Stein, who put together the 370-page draft EIS, said they’re already working with individual forests where retardant is used to map areas where threatened or endangered plants, fish and animals are present and they will try to avoid those areas.

They’re also proposing to limit the use of retardant in waterways unless it’s needed for the protection of human life; previously, it also could be applied when the potential damage to natural resources outweighed the possible loss of aquatic life and when alternative fire line construction tactics aren’t available. Already, the Forest Service tries to avoid using retardant within 300 feet of waterways.

The Forest Service also said it would start to annually monitor 5 percent of fires on less than 300 acres where retardant has been applied to determine whether any adverse effects occurred, and if so, what to do in the future. In addition, they’ve laid out steps to take in case of misapplications.

“We feel this does a better job of protecting sensitive resources while allowing us to meet our obligations to protect people and property, and do so safely,” Stein said on Friday, adding that their preferred alternative now is different than what they initially proposed, based on initial public comments. “Now we’re waiting to see what the public thinks.”

The draft EIS is the result of a July 2010 decision by U.S. District Court Judge Donald Molloy, who directed the Forest Service to follow national environmental policies and prepare an EIS to outline the impacts on plants, animals and fish after dropping the retardant. The Forest Employees for Environmental Ethics had filed a lawsuit in 2008, alleging the retardant, which includes ammonia-based fertilizer, is toxic to fish and threatens rare plants.

Molloy ruled in July 2010 that it “is probable that substantial questions are raised hereas to the environmental impact of the annual dumping of millions of gallons of chemical retardant on national forests.” Last month, he ordered the federal government to pay $95,000 to FEEE for court costs and attorney’s fees.

In a press release, Forest Service Chief Tom Tidwell defended the use of the retardant, and noted that from 2000 through 2010 it was applied only on about 8 percent of wildfires on National Forest lands. In addition, during the past decade, on lands managed by the Forest Service, U.S. Department of the Interior, and the states, only one of every 5,000 retardant drops has impacted waterways.

“The use of fire retardant, in concert with firefighters on the ground, allows the Forest Service to safely protect landscapes, resources and, most importantly, people’s lives,” Tidwell said. “Research and experience demonstrate that aerially applied fire retardant, used in an appropriate manner, reduces wildfire intensity and the rate of spread, which increases the effectiveness of our fire suppression efforts on the ground.”

But Andy Stahl, FEEE executive director, argues that the Forest Service’s research in laboratories can’t be applied to real wildfire conditions, where heavy winds often created by the fire can make it rapidly spread. After a quick read of the draft EIS, Stahl said what was important to him was what the document didn’t include.

“The Forest Service makes no effort to show that fire retardant use changes the outcome of wildfires in terms of houses destroyed, lives threatened or acres burned,” Stahl said. “Tables in the draft EIS show scores of national forests use no retardant — never did — and they don’t show any different outcomes. They don’t suffer from lack of that.”

He added that while acknowledging the environmental harm, the document also doesn’t calculate any significant benefits.

“I think they’re going to be compelled to do somewhat better than this,” Stahl said. “If they’re proposing to build a dam or highway, or log a forest, there are some environmental downsides but also some kind of economic pluses. What the Forest Service has not done is told us what the pluses are when using the retardant.”

He added that state firefighting agencies, like those in Florida and Texas, don’t use retardant on wildfires and there’s no significant difference. In the West, though, he said it’s often used on fires on federal lands.

“In Florida and Texas, where forest fires are ubiquitous, retardant isn’t used because the federal government isn’t paying for it because they don’t have federal national forests,” Stahl said. “This is a federal boondoggle. State firefighting agencies without the federal treasury behind them never found retardant to be cost effective, and that the benefits outweigh the costs.”

Stein said they plan to continue to use retardant on wildfires this summer, and Tidwell will decide what course to follow after the final EIS is completed. The EIS must be completed by 2011, under Molloy’s ruling.

“We don’t know what will happen next year,” Stein said. “It depends on how this is received by the court.”

The release of the draft environmental impact statement begins a 45-day public comment period, and it can be found in this story online at helenair.com.

NRDC Planning Rule Comment Form

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For those of you who haven’t found this site: here’s the page:

Tongass
Save the Tongass National Forest
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When you take action and become a BioGems Defender we will keep you informed by sending you alerts and progress reports (learn more »).

Consider adding your own thoughts before you click Send — personalized messages are especially effective.

Sign our Petition
Ask the Forest Service to protect our national forests
Consisting of more than 193 million acres, our national forests are the crown jewel of America’s natural heritage. They provide critical wildlife habitat for endangered and threatened species, as well as clean drinking water and recreational opportunities for millions of Americans. The U.S. Forest Service is now drafting new rules for their management. Please urge Agriculture Secretary Tom Vilsack to give our national forests the strongest possible protection.

Note: This action is for U.S. residents only. Please do not attempt to take action without a U.S. mailing address.
Your message will be sent to:

Tom Vilsack, Secretary of Agriculture

Subject line:

Adopt strong rules for our national forests

I am writing to ask that you adopt strong, conservation-oriented and science-based rules for our national forests. I appreciate your commitment to preserving and restoring this key piece of America’s natural heritage, and applaud the spirit in which the proposed management rules have been drafted.

The final rules must deliver and improve upon the intent of the draft version. A core function of these rules must be to produce good outcomes for national forests and to help ensure that local managers don’t make the kinds of mistakes that have degraded too much of our public forest estate already. That will require much stronger guidance in several key areas.

First and foremost, it is critical that these rules fully protect the species that depend on national forests for their survival. The final rules must ensure that management choices don’t contribute to wildlife and other species disappearing from parts of their ranges. Local extirpations of plants and animals strip national forests of some of their most cherished elements and weaken ecosystems, increasing vulnerability to climate change and putting added pressure on surrounding lands.

Second, the rules must include numeric standards to protect streams, wetlands, and other water bodies. Please make sure that the rules specify a minimum buffer zone around all national forest waters of at least 100 feet, where all management has to promote aquatic health.

Third, consistent with President Obama’s commitment to scientific integrity across the federal government, the Forest Service needs to be guided by the best available science. I’m concerned that as drafted, the rules only direct the agency to “take account” of the science. The final rules need to require that it rely on the best available science, not just consider and then ignore it.

And finally, I am quite concerned that the public have a fully meaningful opportunity to raise concerns about management decisions with top officials in the agency. Under the rules that now apply, citizens have 90 days to appeal local planning decisions to supervisors. It’s crucial that we have at least that much time for decisions that have been years in the works, fill multiple volumes, and rely on thousands of documents.

Thank you very much for considering my concerns. I share your interest in the welfare of these wonderful forestlands and in passing them on, unimpaired, to future generations. I look forward to management rules that will ensure that outcome.

I’m particularly interested in the “science” paragraph:

Third, consistent with President Obama’s commitment to scientific integrity across the federal government, the Forest Service needs to be guided by the best available science. I’m concerned that as drafted, the rules only direct the agency to “take account” of the science. The final rules need to require that it rely on the best available science, not just consider and then ignore it.

According to my count, that’s Science/Scientists as drivers of land management:
NY Times 1
Wilderness Society 1
Graduate student in ecology 1
NRDC 1

I found the comments to be very interesting as well

Noted, but not resident of US, so could not sign.
If something isn’t done to save what we have it would be a travesty!
“They took all the trees and put’em in a tree museum, and charged a dollar and a half just to see ’em” Joni Mitchell 1970
Forty one years ago they were singing songs about the environment, why has it taken so long? Why did it get to be a worse problem??

What do you think? How should the FS consider comments from people who click buttons based on info they read online?

Forestry’s Next One Hundred Years: Leopold

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Gifford Pinchot’s utilitarian philosophy and management methods dominated US Forest Service thought, policy, and action throughout the 20th century. A quick read of Harold Steen’s The US Forest Service: A History, David Clary’s Timber and the Forest Service, and Paul Hirt’s A Conspiracy of Optimism: Management of the National Forests Since World War Two is testament enough of Pinchot’s domination. Add in the Forest Service sponsored movie The Greatest Good for icing on the cake.

But the next century belongs to Leopold at least in the eyes of film producer Steve Dunsky, who produced The Greatest Good. Dunsky’s new film, The Green Fire is about Leopold and his influence. Leopold’s revolutionary ideas emerged with the publication of A Sand County Almanac (1966), but the transition to mainstream thinking would not happen in the 20th Century. Dunsky says the 21st Century belongs to Leopold:

I think that was what was so exciting about doing this film is we didn’t just want to do a film about Aldo Leopold’s life, we wanted to talk about why he’s important today and the reason that this is in a way a sequel to The Greatest Good is that we see Leopold as being kind of the guiding vision of the Forest Service in the 21st Century. Gifford Pinchot and his colleagues in the early part of the 20th Century had a different idea about conservation: that nature was there to be used by people and it is. But Leopold’s vision is much more about people being part of a natural community, and that shift has been occurring in the Forest Service over the last twenty years. And I think that now is the time that we are really seeing the manifestation of that in the agency’s policy and our actions and so the timing is really perfect for Green Fire to be coming out.

Moving Beyond Agrarian Forestry
Like Dunsky, I believe the time is at hand for a change in philosophy from Pinchot to Leopold, or from “Group A” to “Group B” as Leopold described it:

[O]ne group (A) regards the land as soil, and its function as commodity-production; another group (B) regards the land as a biota, and its function as something broader. How much broader is admittedly in a state of doubt and confusion.

In my own field, forestry, group A is quite content to grow trees like cabbages, with cellulose as the basic forest commodity. It feels no inhibition against violence; its ideology is agronomic. Group B, on the other hand, sees forestry as fundamentally different from agronomy because it employs natural species, and manages a natural environment rather than creating an artificial one. Group B prefers natural reproduction on principle. It worries on biotic as well as economic grounds about the loss of species like chestnut, and the threatened loss of the white pines. It worries about whole series of secondary forest functions: wildlife, recreation, watersheds, wilderness areas. To my mind, Group B feels the stirrings of an ecological conscience.

Leopold’s Philosophy in Brief
Leopold began his Forest Service career in 1909. He was promoted rapidly and was proud to part of the “outfit.” He was true-blue green Forest Service. Leopold became a forest supervisor of New Mexico’s Carson National Forest at age 24. But his enduring philosophy developed later. [We wouldn’t expect many 24-year-olds to have much of the world figured out]. As he grew older and wiser, Leopold developed the philosophy that would guide him, along with many in the wildlands preservation movement, the environmental ethics movement, and more. Here is an essence: “We abuse land because we regard it as a commodity belonging to us. When we see land as a community to which we belong, we may begin to use it with love and respect.”

With age and wisdom, Leopold began to be more contemplative about his own and others attempts to “manage the land,” to “manage wildlife”, and so on. That led him to his commitment to help humanity discover a rightful place as “plain members” of a broader ecological community: “The land ethic simply enlarges the boundaries of the community to include soils, waters, plants, and animals; or collectively: the land. … In short, a land ethic changes the role of Homo sapiens from conqueror of the land-community to plain member and citizen of it.”

Ten Key Insights from Leopold’s Land Ethic (The Encyclopedia of Earth)

First, Leopold’s Land Ethic helped create the field now known as “environmental ethics” or, more generally, environmental philosophy. … [Leopold] makes human considerations regarding the land and land use central to environmental decision-making and practice, but does not go as far as to make the land itself deserving of human moral consideration.

Second, Leopold’s land ethic challenges us to rethink our notion of what it means to say something deserves our human moral consideration (is “morally considerable”). … Western philosophical tradition restricts moral considerability to (some) humans on the grounds that only humans are capable of reason and rationality, use language, are rights-holders, duty-bearers, interest carriers or are endowed with a soul. By making the land itself morally considerable, Leopold challenges traditional Western conceptions of moral considerability …. [F]or Leopold, “the land” was included in the realm of things deserving moral consideration.

Third, Leopold’s land ethic challenges us to rethink what it is to be human. … Western philosophical tradition is that humans are different from and superior to nonhuman animals and “nature” … Leopold’s land ethic challenges and repudiates this division.

Fourth, in place of the favored Western view of humans as unlike other animals and nature, Leopold posits the notion of human beings as [plain] members of both human and ecological communities. This notion of humans as embedded in social and ecological communities forever challenges the time-honored distinction between humans and “the rest of nature.” No longer is it “obvious” that there is an essential difference between superior humans and inferior nonhuman animals and nature….

Fifth, Leopold’s land ethic challenges us to rethink what counts as a morally relevant value in ethics, ethical decision-making, environmental policy and philosophy. No one before Leopold had ever defended the view that ecosystem integrity, diversity and beauty were morally relevant—perhaps deciding—values in human interactions with other humans, nonhuman animals or the natural environment. In doing so Leopold went far beyond traditional theories of ethics, ethical selves and ethical values: He made the “integrity, diversity, and beauty” of ecological communities, along with the requisite nutrient flows and energy cycles that are necessary for “land health” (or, the ability of the land to self renew), as themselves morally relevant values—ones which sometimes could and should trump traditional values of human self-interest, individual rights, human freedoms (or liberties) and economic efficiency. …

Sixth, Leopold’s land ethic challenges humans to rethink the role of emotion, care, love and empathy not only in ethics, ethical decision-making, and ethical policy, but also in what it means for humans to owe things to each other and the land. For Leopold, the development of an “ecological conscience”—necessary to the adoption of the land ethic—requires the development of emotional, experiential (e.g., hands-on) ecological literacy. Rational intelligence that is not exercised in concert with affectional or emotional intelligence is simply inadequate in ethics, environmental ethics and environmental decision-making.

Seventh, Leopold’s Land Ethics has yet to be understood and appreciated. It challenges us to understand the relationships between ecological diversity and cultural diversity in the creation, maintenance and perpetuation of human and land health. Leopold explicitly links cultural diversity with biodiversity when he writes, “Wilderness was never a homogenous raw material. It was very diverse, and the resulting artifacts are very diverse. These differences in the end-product are known as cultures. The rich diversity of the world’s cultures reflects a corresponding diversity in the wilds that gave them birth.” … Leopold laments the “exhaustion of wilderness” and “world-wide hybridization of cultures” as the destruction of both ecological and cultural diversity. For Leopold, the “wild roots” of cultures and the importance of our ecological heritage are part of our humanness and our human cultural heritage that should be recognized and preserved. …

Eighth, Leopold’s land ethic makes forest and wilderness preservation necessary for any adequate ethic, environmental ethic or environmental policy. …

Ninth, Leopold’s land ethic is that he saw the valuable roles to be played by both the ecological scientist and the ordinary individual in the preservation of [wildness]. …

Tenth, Leopold’s land ethic challenges us to rethink the relationships among ecology, ethics and economics. Leopold rejected the conception and practice of both traditional laissez-faire economics and ethics because neither made ecological awareness and sensitivity to ecological contexts central to their enterprises. He writes: “That man is, in fact, only a member of a biotic team is shown by an ecological interpretation of history. Many historical events, hitherto explained solely in terms of human enterprise, were actually biotic interactions between people and land. The characteristics of the land determined the facts quite as potently as the characteristics of the men who lived on it.” …
[footnote and hyperlink references omitted . See here]

One Final Leopoldian Notion
I’ll finish with one of my favorite Leopold quotes: “Obligations have no meaning without reference to conscience, and the problem we face is the extension of social conscience from people to land.”

Is Leopold’s time at hand?

More on the Green Mountain Lookout

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Here’s an opinion piece in the Everett Herald Net.

Now I will be the first to confess that I don’t know what side if any is “right” in this debate. However, there are a couple of themes that are found more widely in various discussions around the West.

First,

Defending against petty lawsuits will likely divert most of the Forest Service’s dwindling wilderness budget from the mountains to the courtroom.

and second,

We encourage Wilderness Watch to drop the lawsuit. We also encourage people to make your voices heard. Congressional representatives need to hear from the public why this lookout needs specific legislative protection from humorless people who would tear it down.

The themes that I hear are:
(1)Why this battle?: Local person to group- “Out of all the environmental issues in the world, especially given that you are not from our area, it’s not clear why you would pick this particular battle. What’s this really about? Can we talk? ”

(2) Why this tactic (litigation)?

a) If you choose litigation as a tactic, others can choose to try to get legislation (a la wolf, see Baucus quotes here). I would think that this is a necessary constitutional co-evolutionary trend, but how optimal for everyone concerned?

(b) Forest Service budgets are not going up- is its possible that other uses of FS funds (like wilderness rangers) may lead to more environmental protection than copying documents or other litigation activities? What are the environmental “opportunity costs” of choosing litigation as a tactic?

Below is the opinion piece in full.

Lookout belongs right where it is
By Leah Tyson

In response to a pending lawsuit by Wilderness Watch to force the U.S. Forest Service to take down the Green Mountain fire lookout, the Darrington Historical Society would like to explain why the lookout does, in truth, belong there.

Contrary to an opinion expressed in these pages several weeks ago by George Nickas, the executive director of the Montana-based Wilderness Watch, the fire lookout on Green Mountain is not a “new” lookout. It is not a “replica.”

It not only looks like the old lookout — it is the old lookout. We know this because the Darrington Historical Society, and many other local volunteers, participated in the restoration project, which started in the 1990s.

The lookout was carefully restored with at least 70 percent of its original materials from 1950 (when the 1933 lookout was fixed because of snow damage), and the project was originally completed onsite. The only substantially new aspect to the lookout is the foundation and catwalk, which were redesigned to meet modern safety codes. This is a standard legal requirement in historical restorations.

Unfortunately, the new foundation design failed, and engineers determined that the lookout might not survive the heavy snows of the coming winter. Faced with a difficult decision, Forest Service officials decided to save it by removing the lookout with a helicopter. With a better design for the foundation, the old lookout was hauled back up and secured to the peak.

Despite the overblown rhetoric of critics, this was not an “egregious” act. The Forest Service was caught between the dictates of the Wilderness Act on one side and, simultaneously, the National Historic Preservation Act, which required the agency to do its best to preserve the lookout because it was placed on the National Register of Historic Places in 1987.

The Wilderness Act is not as cut and dried as Wilderness Watch would have folks believe. It includes some administrative discretion for managing agencies. While Wilderness Watch certainly has the right to file suit, we question their judgment. The lawsuit is entirely out of proportion to the infraction of procedure they allege and to the aesthetic value that is supposedly harmed. Defending against petty lawsuits will likely divert most of the Forest Service’s dwindling wilderness budget from the mountains to the courtroom.

Very few fire lookouts remain. The Glacier Peak Wilderness is an area almost the size of Rhode Island. The 14-by-14-foot cabin on top of Green Mountain is dwarfed by the landscape, a blip on the radar, really. Staffing lookouts with volunteers has, in fact, helped preserve some fragile alpine areas.

If this lawsuit succeeds, it could create an interpretation of the rules so narrow as to force the loss of a few remaining historic lookouts across the Northwest. It could also be interpreted to prevent the repair of washed-out trails and bridges. This may seem extreme, but it is the stated intent on the Wilderness Watch website.

It is not necessarily the stated intent of the Wilderness Act, which recognizes that preserving the wilderness character of a place can include “recreational, scenic, scientific, educational, conservation and historical use.”

The aesthetic Puritanism expressed by people who would tear down the Green Mountain lookout leads to spiritual satisfaction for a few at the exclusion of the many. We should acknowledge the reality of U.S. Navy jets running almost daily, low-altitude training sorties over the Glacier Peak Wilderness. In contrast, obsessing over tiny aesthetic complaints makes no sense.

We are not arguing for a return to the past, when fire lookouts dotted the backcountry and roads cut deep into the headwaters. We are simply calling for the maintenance of a historical icon that still has some life and lessons to pass on. For many of us, the rarity of such structures enhances appreciation of the enduring nature of wilderness.

We encourage Wilderness Watch to drop the lawsuit. We also encourage people to make your voices heard. Defending against petty lawsuits will likely divert most of the Forest Service’s dwindling wilderness budget from the mountains to the courtroom.

Defending against petty lawsuits will likely divert most of the Forest Service’s dwindling wilderness budget from the mountains to the courtroom.

Rural lawmakers fear planning rule will crimp timber harvests, spur lawsuits: ENN story

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FORESTS: Rural lawmakers fear planning rule will crimp timber harvests, spur lawsuits (05/05/2011)

Phil Taylor, E&E reporter

The Forest Service’s proposed planning rule could open the door to special-interest lawsuits and does little to ensure timber harvests will increase across the nation’s millions of acres of national forests, House lawmakers from rural districts warned today.

Both Republicans and Democrats said they are concerned the agency’s planning rule — a sweeping proposal announced in February to manage more than 198 million acres of national forests and grasslands contains problematic requirements to maintain viable wildlife populations and is too vague about the role of timber production (E&ENews PM, Feb. 2).

Rep. Glenn Thompson (R-Pa.), chairman of the Agriculture Committee’s Conservation, Energy and Forestry subpanel, said the Forest Service runs the risk of “mission creep” by implementing requirements in the new rule to catalog invertebrate species and incorporating climate change language that is likely to invite legal challenges.

Oregon Democrat Kurt Schrader added that the agency appears to be morphing into a hybrid of the National Park Service and Fish and Wildlife Service, thrusting species viability above the needs of rural economies that depend on multiple-use of forests.

“The original mission of the Forest Service has been lost,” he said at a hearing on the rule. “The law requires species diversity, not viability.”

The lawmakers’ comments underscore the tricky balancing act the Forest Service faces in crafting a rule that will satisfy the numerous groups that use the forests, including timber companies, miners, hikers, ranchers, water users and wildlife.

The agency’s draft proposal — which promises to speed planning efforts, incorporate best available science, engage the public and ensure forests’ resilience to climate change, pests and other threats — has also come under attack from some environmental groups that argue the rule fails to set specific guidelines for ensuring species viability and gives too much discretion to local forest managers to decide which resources are preserved (Greenwire, Feb. 11).

Harris Sherman, the Forest Service’s undersecretary for natural resources and environment, said today the proposal was developed from the “bottom up” based on roughly 40 public meetings and 26,000 comments. It is supported by top scientists within the agency and is expected to last several decades.

“What we’re attempting to do here is establish a new rule that is effective,” he told the House panel. It is modern, it is efficient, and it will serve the public well.”

Sherman emphasized that the draft rule — which is open to public comment until May 16 — is designed to restore the health and resilience of national forests suffering from decades of mismanagement that has led to increased diseases and invasive species, more frequent and intense wildfires, and degrading water quality.

Trimming the planning process from eight years to between one and three years, he said, should help catch more threats, including pests such as the mountain pine beetle, which has ravaged 40 million acres across the West.
Concerns about litigation

But lawmakers pressed Sherman to explain why the rule does not explicitly promote an increase in timber production at a time when rural economies are reeling from unemployment and lagging tax revenues.

“Why in the world should Wisconsin be importing timber from Canada rather than harvesting timber that is rotting in our national forests?” said Rep. Reid Ribble (R-Wis.).

Sherman said timber, as a multiple use, is expressly recognized in the draft plan, and added that the Obama administration predicted a slight increase in timber production in its new budget. “We will continue to see an upward effort to produce timber on our national forests,” he said.

Other lawmakers questioned whether the inclusion of climate change language and new requirements for agency managers to catalog invertebrates such as insects will overburden an already cash-strapped agency and offer new opportunities for special-interest lawsuits.

“Some have embraced the ideology that preventing human access to these lands is the best way to keep these forests healthy,” said Thompson, whose district includes the Allegheny National Forest. “With that in mind, I am concerned that this proposed planning rule is complex and will face the same sort of litigation that has hamstrung previous attempts to formulate a rule.”

Thompson added that timber harvests provide hundreds of thousands of jobs and billions of dollars in economic productivity, in addition to thinning overgrown forests and allowing optimal absorption of greenhouse gases.

“Indeed, the rule makes reference to climate change,” he said. “If this is an important issue, I can think of nothing more effective than taking care of our forests and harvesting a sustainable amount of trees.”

Sherman acknowledged that litigation has hampered past management efforts, but said the agency extensively studied past litigation and judicial decisions and believes the new rule will keep the agency out of the courts.

He was also pressed to explain how forest managers would implement the science-based guidelines prescribed in the draft rule considering the budget limitations facing the agency.

“This is not a call for original research or Ph.D. theses on various issues at all. It is a call to go to reliable, available information,” he said. “There may well be competing science on a given issue, and it is up to our local responsible [forest manager] to review this issue and explain how they handle these materials.”

But John Shannon, vice president of the National Association of State Foresters, said that while it is laudable that the agency is giving deference to local forest employees who know the lands best, the proposal’s best available science standard could introduce legal challenges and increase the workload for responsible officials.

“We need to give some deference to the professional opinions of those local forest employees,” he said. But “disputes over competing science have significant potential to further delay the planning process.”

This was summarized in this blog post “Forest Service plan draws fire from rural members of Congress from both parties” here on the Rural Blog.