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.

What’s Pew Up To?

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A blog-buddy told me that he had received an invitation to a meeting for leaders of faith communities put on by Pew Environment on the planning rule.

The Pew folks seem to be fans of the “national standard” approach although it’s a bit hard to tell based on their press release.. also a brief scan of their website did not yield a letter or other clear information on their views.

Jane Danowitz, public lands director for Pew, also backed calls for the agency to maintain concrete standards to protect viable plant and animal species and protect watersheds critical to public health.

“Our national forests are the source of drinking water for more than 120 million Americans and host more rare species than even our national park system,” she said in a statement. “We hope that the administration will back up its proposal with clear standards for water and wildlife protection.”

Now the planning rule is not your run-of-the-mill issue- it’s pretty complex, or arcane, depending on your point of view. So I was surprised that Pew would choose to focus attention on it- but to invest in getting folks outside our resource community up to speed raised a question.

This is from the Pew Environment website:

Pew is a major force in educating the public and policy makers about the causes, consequences and solutions to environmental problems. We actively promote strong conservation policies in the United States and internationally. Pew applies a range of tools in pursuit of practical, meaningful solutions—including applied science, public education, sophisticated media and communications, and policy advocacy.

I’ve always been a bit confused with how this fits in with the broader Pew goals.

The Pew Charitable Trusts is driven by the power of knowledge to solve today’s most challenging problems. Pew applies a rigorous, analytical approach to improve public policy, inform the public and stimulate civic life.

It’s OK to be an advocate. It’s OK to use “sophisticated media and communications.” But concerned people might wonder how that fits with the “the power of knowledge” and a “rigorous, analytical approach.” If they read a press release, which side is speaking?

And back to the religious leaders. What’s that about? I prowled around the Pew website and didn’t find anything. Have any readers any more information?

P.S. This post is not to be taken as a general criticism of Pew efforts per se. I worked with an excellent group of folks on the Pew Agbiotech Initiative where everyone put a great deal of effort into ensuring that different voices were heard and objective information evaluated. The kind of quality work they did can be found here.

Nice Article on 4FRI

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We’ll probably all be interested in following as 4FRI unfolds.

This is the most detailed story I’ve seen..nice work, Pete Aleshire!

T

he threat prompted timber interests and environmentalists together with forest researchers from Northern Arizona University to forge an agreement on the need to use a reinvented timber industry to thin some 2.4 million acres of forest. Instead of asking taxpayers to shell out $500 to $1,000 per acre for hand thinning, backers hope the timber mills can essentially cover the cost of the thinning by selling the small trees they harvest. That would require convincing the timber mills to invest millions in chipboard and particle board manufacturing operations plus a network of power plants that can burn the wood scraps.

A study by economists from NAU predicted that long-term contracts feeding wood steadily to a network of mills and power plants would generate about 1,000 jobs annually in the region and save the taxpayers the $1.2 billion cost of hand thinning such an expanse.

“If an effort of this scale is going to work anywhere, it’s going to work here,” said Ethan Aumack, Director of Restoration Programs for the Grand Canyon Trust.

“From the science to the social license to the wood utilization capacity, we have all the necessary pieces in place and now it’s time to move them in unison forward.”

And

The timber interests want 20- and 30-year contracts to guarantee a sufficient supply of wood to produce a profit. The conservationist groups want the Forest Service to accept what amounts to a ban on cutting the largest trees — generally those more than 16 inches in diameter.

Why Three Planning Levels?

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Anyone who has followed this blog knows that I am fond of talking about adaptive management (here) and railing against planning. (here, here, here). Sometimes both at once. Today I puzzle, once again, over why the Forest Service insists on three levels of planning: national, forest, and project or activity. Note: it used to be four levels, adding “regional”, but that is likely a trivial point. I ask: Why? Why? Why?

So I decided to try and understand how this particular three-level planning scheme came to be. “National” is understandable, at least in some contexts—particularly budgeting and organizational accountability, and some policy development. “Project or activity” is where work gets done. Logical enough, at least for budgeting and work planning and accountability. But I don’t know what role such plays in a forest plan, unless we are taking about the “loose leaf compendium” that the Clinton-era Committee of Scientists recommended.

“Forest”? That too makes sense for budgeting and work accountability, etc. Remember the “cut and sold” reports, during the good old go-go timbering days? I do — painfully! But there again I can’t quite wrap my mind around ecosystem/social system planning or management at this “level”, unless we are once again talking about the “loose-leaf compendium” for administrative purposes. But even here the case for a “forest” level of planning is weak. Better to work toward planning at scales where “sense of place” and/or “sense of purpose” are in play. These type scales often cross forest borders, and often include other than forest service lands.

Finally, I began to think through the history of the Forest Service and in particular try to better understand the run-up via controversy to the National Forest Management Act (1976), following in the heels of the then recently passed Renewable Resources Planning Act of 1974. Not much help there. NFMA mandates a “forest plan” but doesn’t require the type forest plan the forest service keeps writing into its “rules.” Note that the timber sale, etc. restrictions in the NFMA can still be applied even with the COS “loose-leaf compendium” notion of a forest plan.

For completeness, here is what the Clinton-era Committee of Scientists recommended, in part (from Proposed Summary of COS Report, Feb 9, 1999):

The NFMA calls for development of an integrated land- and resource-management plan for each national forest and grassland. In our approach the integrated plan is the assemblage of all policies and decisions affecting an administrative unit. It can include regional guidance for conservation strategies relevant to the area; the strategic vision, policies, and multiple-use goals developed through large landscape planning, including the description of the desired future conditions; proposed management pathways for achieving the desired future condition and multiple-use goals; implementing decisions and proposed project-level management activities developed at the small-landscape level; and sufficient records and documentation from monitoring to support ongoing adaptive management. As the foundation of administrative policy and guidance, this planning documentation also should include the budget and staffing needs for implementation as well as the procedures and timing of monitoring and review processes. As a management tool, the plan not only includes monitoring processes, but also records ongoing results and subsequent changes in both strategic and implementation decisions.

In the past, the use of administrative units as the planning units often caused large-scale ecological, economic, and social processes to be neglected or resulted in inconsistent decisions by adjacent administrative units. Therefore, the Committee suggests a planning and decision-making hierarchy whose geographic extent will often not be limited to the boundaries of a particular national forest or grassland but whose physical repository will rest at [sic] within multiple administrative units.

Thus, the land- and resource-management plan should be in the form of a loose-leaf notebook that contains all of the policy directions, strategies, and implementation proposals from decisions that have been made at all levels of the planning process. It is the official repository of decisions big and small that have been made and reviewed in the strategic and landscape-level planning processes. It must also contain the monitoring methodologies that will be implemented as well as the evaluation results from monitoring. Because this model of the land- and resource-management plan is different than that employed during the first round of NFMA planning, the process of plan amendment is also different. Rather than a formal process involving review and comment, these loose-leaf plans are dynamic and evolving, readily reflecting and accommodating the outcomes of adaptive management. Thus, as decisions are revisited and revised in response to changing social understanding, natural and social events, and policy priorities, the loose-leaf notebook immediately reflects those changes. Consequently, any “amendments” made to these plans reflect decisions that have been made and reviewed elsewhere.

I find no fault with the COS recommendations! I’m just puzzled why they are not on the table this time around. I am well aware that these recommendations were developed at the very end of Clinton’s term of office, and the incoming George W. Bush Administration moved quickly to nullify all that they could that were marked by Clinton’s footprints. (including the 2000 NFMA Rule (pdf)). Why were they not followed in the 2000 rule development?

I’m puzzled. Maybe some of you who are smarter than I can help me understand what the hell is going on here with these bizarre “three levels”? And what has been going on since 1979. What were/are the drafters of these various rules thinking? Is it just “Tradition”? (Like in Fiddler on the Roof), i.e. the language was there in 1979 rule, so it will stay until hell freezes over. Something else? Can it be justified today?

Update: As Sharon points out in comments, the 1999 Committee of Scientists Report is available on the sidebar. Here the Synopsis: pdf

We’ll Consider It…

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Tongass NF, SE Alaska. The draft regs require that "the physical and biological integration of the terrestrial and aquatic ecosystems within a landscape" be taken into account.

Instead of taking on the proposed forest planning regulations in one fell swoop, I’d like to use our blog to analyze it in sections, with a lot of debate and discussion along the way.  There are things in the proposed regulations that I really like.  And I’m planning on writing about those soon.  But I’d like to start with some connected questions that our readers might be able to help answer. 

1.  Do the regulations give too much discretion to National Forest Supervisors?  The USFS, like most bureaucracies, will go down swinging in order to protect their administrative discretion.  It’s part of the agency’s (and Sharon’s) DNA.  And there is a considerable amount of discretion provided in the proposed regulations, though nothing close to 2005 or 2008 versions.  It will be up to the discretion of each National Forest to determine what the specifics look like in every place (and how standards, guidelines, suitability, monitoring, and other plan components are used).  Discretion cuts both ways and the regulations could be used to draft very different forest plans in the future.  This is not necessarily a big change from the past. 

 2.  Do the regulations ask planners to do too many things?  Does the 2011 rule ask more things of the agency than does the 1982 or 2000 versions?  I read Andy Stahl’s insightful comments before I finished reading the regulations, so I was influenced by his argument that the proposed regs are a form of “ecological rationality.” 

So I made a note of how many times the regulations ask planners to “consider” or “take into account” X, Y, Z.  This is pretty standard in environmental law and planning, but I’m curious if these regulations take it up a notch? 

Instead of mandating that the agency shall do this or that, the regulations require all sorts of important things to be considered or taken into account.  I can’t complain because I asked the agency as part of its Science Panel to consider various things when planning, so I’m guilty too (like most groups whom asked the agency to consider something better in the future).    

Before skimming the list below, consider a few questions:  Are these required considerations a good thing? Will they impact agency decision making?   Is the agency capable of doing all this?  How do these required considerations simplify planning? Are the considerations nothing new, maybe already required or done as part of NEPA analysis? 

Here are some examples, with Fed. Reg. page numbers provided: 

The planning process would take into account other forms of knowledge, such as local information, national perspectives, and native knowledge. 8481.

In doing so, responsible officials would take into account the various stressors or impacts that could affect the presence of ecological resources and their functions on the unit.

This section of the proposed rule addresses the role of science in planning and would require that the responsible official take into account the best available scientific information.  8485.

Additionally, the proposed rule would require the responsible official to use collaborative processes when possible, to take into account the various roles and responsibilities of participants and the responsibilities of the Forest Service itself, and to create a process that is open and accessible. 8486.

 In designing plan components to maintain or restore ecosystems and watersheds, the proposed rule would require the responsible official to take into account the physical (including air quality) and biological integration of the terrestrial and aquatic ecosystems within a landscape.  8490

Agency proposes that the planning rule require responsible officials to take into account cultural conditions when developing plan components for social and economic sustainability.  8492.

 In developing these plan components, the responsible official would be required to take into account through the collaborative planning process and the results of the assessment the social, cultural, and economic conditions relevant to the area influenced by the plan; the distinctive roles and contributions of the unit within the broader landscape; sustainable recreational opportunities and uses; multiple uses, including ecosystem services, that contribute to local, regional, and national economies in a sustainable manner; and cultural and historic resources and uses.

Instead of adding a new aspect to sustainability, the Agency proposes that the planning rule require responsible officials to take into account cultural conditions when developing plan components for social and economic sustainability. 8492

The proposed rule would require responsible officials to consider opportunities to coordinate with neighboring landowners to link open spaces and take into account joint management objectives where feasible and appropriate. 8495

 The responsible official would also be required to consider the landscape-scale context for management as identified in the assessment and the land ownership and access patterns relative to the plan area. These requirements reflect the ‘‘all lands’’ approach the Agency is taking to resource management.  8495

 Paragraphs (a)(8) and (a)(9) would require that the responsible official take into account reasonably foreseeable risks to ecological, social, and economic sustainability and the potential impacts of climate and other system drivers, stressors, and disturbance regimes, such as wildland fire, invasive species, and human-induced stressors, on the unit’s resources. 8495

Plan components must also take into account cultural and historic resources and uses. 8513.

Section 219.4(a) requires that when developing opportunities for public participation, the responsible official shall take into account the discrete and diverse roles, jurisdictions, responsibilities, and skills of interested and affected parties as well as the accessibility of the process, opportunities, and information. 8513

When developing opportunities for public participation, the responsible official shall take into account the discrete and diverse roles, jurisdictions, responsibilities, and skills of interested and affected parties; the accessibility of the process, opportunities, and information; and the cost, time, and available staffing. 8515.

(a) Integrated resource management. When developing plan components for integrated resource management, to the extent relevant to the plan area and the public participation process and the requirements of §§ 219.7, 219.8, 219.9, and 219.11, the responsible official shall consider:

 (1) Aesthetic values, air quality, cultural and heritage resources, ecosystem services, fish and wildlife species, forage, geologic features, grazing and rangelands, habitat and habitat connectivity, recreational values and settings, riparian areas, scenery, soil, surface and subsurface water quality, timber, trails, vegetation, viewsheds, wilderness, and other relevant resources; (2) Renewable and nonrenewable energy and mineral resources; (3) Sustainable management of infrastructure, such as recreational facilities and transportation and utility corridors; (4) Opportunities to coordinate with neighboring landowners to link open spaces and take into account joint management objectives where feasible and appropriate; (5) Habitat conditions, subject to the requirements of § 219.9, for wildlife, fish, and plants commonly enjoyed and used by the public, such as species that are hunted, fished, trapped, gathered, observed, or needed for subsistence; (6) The landscape-scale context for management as identified in the assessment; (7) Land ownership and access patterns relative to the plan area; (8) Reasonably foreseeable risks to ecological, social, and economic sustainability; and (9) Potential impacts of climate and other system drivers, stressors and disturbance regimes, such as wildland fire, invasive species, and human induced stressors, on the unit’s resources (§ 219.8).

 (5) To the extent practicable, appropriate, and relevant to the monitoring questions in the program, unit monitoring programs and broaderscale strategies must be designed to take into account: (i) Existing national and regional inventory, monitoring, and research programs of the Agency, including from the NFS, State and Private Forestry, and Research and Development, and of other governmental and non-governmental parties; (ii) Opportunities to design and carry out multi-party monitoring with other Forest Service units, Federal, State or local government agencies, scientists, partners, and members of the public; and (iii) Opportunities to design and carry out monitoring with federally recognized Indian Tribes and Alaska Native Corporations. 8521.

Etc.

Planning: The View from Plato’s Cave

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A “forest planner” friend called me the other night to chide me for missing one of the best powder skiing days ever. As our conversation progressed I shared my frustration with the Forest Service’s thirty years failed national forest planning efforts. My friend said that I ought not to expect forest planning types, including those charged with writing “new rules,” to do anything other than minor tweaking of older rules. After all, that’s what they know and where they find comfort. My friend has a point! Sometimes, however, there is Danger in the Comfort Zone.

Keep in mind that most people, both managers and employees prefer bondage in bureaucratic power-play organizations, “psychic prisons,” to the freedom and responsibility of adaptive management learning organizations (shorter verson, longer verson (pdf)). I prefer the empowerment of the latter.

Digging deeper into the FS comfort zone, I believe the Forest Service’s “comfort” is much like that Plato talked about in his Allegory of the Cave (Wikipedia). In short, Forest Service top brass are too often like the inhabitants of Plato’s cave, chained in some way to see only the shadows of outside reality flickering on the cave walls, but unable to encounter that reality themselves.

I admit that I too am blinded by ideology/methodology, taking too much comfort, for example, in adaptive co-management. None of us is immune to this failing. Still, questions linger: Which frame serves best, planning or adaptive management? Or are both bankrupt? If not these, then what? And if an adaptive co-management frame is better, how can the Forest Service ever get there? In answering the last question, remember what Kristen Blann and Stephen Light told us a decade ago, Adaptive ecosystem assessment and management will be The Path of Last Resort (doc)! Perhaps the “path” will never be taken at all. That would indeed be unfortunate.

Links, for those unfamiliar with Plato’s Allegory:
Allegory of the Cave, Wikipedia
Plato’s Allegory of the Cave: A short summary (Warning: Not for those offended by the “f-bomb” and other “street talk”)
The Cave: 9 min. audio (with text), that explains Plato’s allegory well in contemporary context

You’ve Got To Have Friends

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Dave Iverson, in responding to Sharon’s post The Ranchers and the Feds Should Be Friends said that:

“. . . the Forest Service has no business courting friendship.

The folks involved with the many “friends of” groups associated with a number of national forests might disagree.

 

A few years ago, I was fortunate to spend a week learning from the late Brian O’Neil, long-time superintendent of the Golden Gate NRA. Brian’s philosophy was never to do a job with government employees if a volunteer would do it instead. According to the NRA’s webpage,” Park staffing is augmented by a high level of volunteerism, generally exceeding 350,000 hours of volunteer service per year.”

The friends group that Brian cultivated, the Golden Gate National Parks Conservancy says its mission is “to preserve the Golden Gate National Parks, enhance the park visitor experience, and build a community dedicated to conserving the parks for the future.” Sounds pretty consistent with the best interests of the park and the people it serves.

Brian’s called his version of fund-raising “friend-raising.”  He never called it fund-raising, even though the Conservancy has contributed over $165 million dollars in support of the park.   He thought of it a long-term process where people first become aware of the NRA, then come to know it, come to care about it, and finally to support it through time, money, and advocacy.

[Interesting digression:  the GGNRA is currently using a negotiated rule-making process with an appointed committee to  to decide how best to manage dog walking in the park.]

 

The national forest in California that best exemplifies the friend-raising philosophy is the San Bernardino.  Their main partner group, The San Bernardino National Forest Association describes its mission as follows: “Since 1992, we’ve worked to complement the mission of the US Forest Service. We develop new resources and partnerships that create new opportunities, particularly through the efforts of volunteers, for conservation, education, and recreation that have added value to the forest’s role as public land.”

In light of all of the many “enemies of the national forests” who see public lands only as a source of profit that they would like a piece of, shouldn’t all national forests be actively trying to make more friends?  Have we already forgotten the Sagebrush Rebellion attempts to privatize national forests?

And what is the deep inner meaning of the title of this post?  Just ask Bete Midler:

“Cause you got to have friends
La la la la la la la la la“

4FRI Agreement Signed

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Here’s the link to an Arizona Daily Sun story.

On paper, they are all starting on the same page.

Now comes the hard part: finding the money and implementing one of the most ambitious forest restoration plans in the country.

More than 20 organizations — some of them past legal adversaries — signed a memorandum of understanding Wednesday in Flagstaff with the U.S. Forest Service for the restoration of 1.5 million acres across four forests: Coconino, Kaibab, Apache-Sitgreaves and Tonto.

The sheer size of the project had signatories grasping for superlatives.

“At hundreds of thousands of acres, you can just about manage for every kind of wildlife except grizzly bears,” said Wally Covington, executive director of NAU’s Ecological Restoration Institute. “This gives you the scale to protect watersheds, create wildlife habitat and attract viable businesses that can use the excess trees, provide jobs and stimulate local economies.”

The Coconino and Kaibab forests, the first in line to be treated, had a 750,000-acre action plan released last month. The public comment period continues through March 11.

A decade ago, Flagstaff-area forest officials, scientists, business groups and conservationists launched a plan to thin and restore 100,000 acres that is ongoing.

But public funding has been scarce, and the wood-products industry has said the scale of the harvesting is too small — a 20-year guaranteed wood supply is needed to justify private investment in a strandboard plant, which would pay for the thinning and other treatments.

The so-called Four Forests Restoration Initiative addresses that concern by prescribing thinning and controlled burns across the entire ponderosa pine forest. That had Pascal Berlioux, president and CEO of Arizona Forest Restoration Products Inc., anxious to get started Wednesday.

“Collaboration does not accomplish enough if it does not translate into action,” Berlioux said. “It is now time to cross that last bridge and complete the planning and contracting processes that will allow appropriate-scale industry to build a small-diameter tree utilization infrastructure capable of offsetting treatment costs and funding landscape-scale restoration in northern Arizona.”

Some of the conservation groups that signed the agreement Wednesday have tangled in the past with the Forest Service and even each other over standards for protecting wildlife habitat and sustainable harvesting. But they appeared to have called a truce Wednesday.

“Today marks a turning point for northern Arizona’s forests and the communities and species that call them home,” said Todd Schulke, forest policy analyst at the Center for Biological Diversity. “After a century of ecosystem decline, the long-overdue restoration envisioned by the Four Forest Restoration Initiative will set forested landscapes on a path of recovery. We’re excited to be part of that endeavor.”

Among other signatories were the Northern Arizona Loggers Association, the Grand Canyon Trust, and the Nature Conservancy of Arizona.

Here’s a link to the 4FRI website.

The Ranchers and the Feds Should Be Friends

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The National Grasslands don’t often get the limelight in our Forest Service discussions. Sometimes I think the filter of the timber wars obscures a vision of our best mutual future. But listen to these words and see if you think they might be relevant to some of our other disputes. Especially the concept- there are no villains here, and a lot of common ground.

This is from an editorial here in the Bismarck Tribune entitled “Forest Service, ranchers need to reach common ground.

Divergent uses and demands upon the national grasslands periodically conflict, but the relationship between the ranchers who lease range and the Forest Service has become adversarial to the point it has crossed over the line of good sense. Huge amounts of time and energy are wasted on the verbal and political conflict. The running disputes between the grazing association and the Forest Service are an obstacle to thoughtful management of the grasslands.

It is not a conflict between a heroic ranching ethic and federal bureaucrats who don’t know one end of a cow from the other. Nor is it a dispute between noble naturalists and ill-educated cowboys more interested in a quick buck from the sales ring than they are in taking care of the grass. The two sides have a great deal in common. As in all things, the black and white issues are really gray, and it’s compounded by a third party – the public, the ultimate landlords.

The needs of the two – ranchers and Forest Service – are not mutually exclusive.

North Dakota’s experience with the Forest Service has been good. Its employees are skilled and dedicated. The ranchers in the Badlands are our fellow citizens. And we appreciate their difficult economic challenges and their role in forging the state’s identity.

It’s in the state’s best interests for ranchers and the Forest Service to develop a plausible working relationship based on mutual respect.

Words, words, words

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In 1990, with one round of NFMA plans under its belt (but not yet knowing the wheels were about to come off), the Forest Service critiqued its planning process. The first recommendation to issue from that critique was to “Simplify, Clarify, and Shorten the Planning Process.”

Does the proposed new rule do so? The 1982 (aka, the current process) rule has 15,548 words. The proposed rule has 15,227 words. For perspective, the “unworkable” 2000 rule had 13,300 words. With those statistics, I doubt the new rule simplifies, clarifies or shortens.

[Updated — The 2012 rule has 13,252 words.]

BTW, my proposed K.I.S.S. rule has 1,400 words.