SAF Principles for a Planning Rule

Here’s a link to the Society of American Forester’s letter on the planning rule.

They started with some principles (I numbered them for the purpose of discussion):

An effective PR:
1) enables forest plans that are simple and efficient to prepare and amend to account for changing conditions, rather than overly prescriptive and onerous to prepare;

2) enables forest plans that reflect the aspirations of communities of place (i.e., local communities), communities of interest (i.e., groups interested in particular aspects of National Forest management regardless of their residence or direct use of the forest), and communities of use (i.e., groups of forest users);

3) enables forest plans that facilitate, rather than impede, on-the-ground project implementation;

4) provides clear criteria for determining whether projects are consistent with forest plans;

5) requires forest plans to describe the types of projects needed to restore habitats and achieve other plan goals, and the forest conditions under which such projects are needed;

6) requires forest plans to set realistic targets for production of commodities and ecosystem services upon which communities of place, interest, and use can rely;

7) establishes appropriate scale and requirements for species surveys, thereby reducing the need for project-level species surveys, because such surveys often provide little information regarding either the quality of the project or the species‟ status;

8 ) elevates the roles of resource monitoring and assessment at appropriate scales to evaluate achievement of forest plan objectives over time;

9) encourages forest plan amendments as needed to reflect changing conditions, rather than encouraging forests to allow their plans to become obsolete, whereby plan revisions require excessive effort and resources; and

10) enables forest plans that are flexible in the face of fluctuating Congressional appropriations and mandates, and responsive to emerging local/regional/national/global issues.

I like the idea of having principles; generally I like these principles (especially 1) although I think there might be some tension between 6 and 10 (another way of saying 6 is, perhaps, unrealistic). But then again, maybe principles should not be required to be realistic.

What do you think?

Timber-Itching or Past-Hankering

Agency must curtail ‘timber-itch’

By Jim Furnish | Posted: Thursday, May 26, 2011 12:15 am

Aldo Leopold, the iconic American conservationist, spoke of once watching “a fierce green fire” dying in the eyes of a wolf he killed, noting “there was something new to me in those eyes.” The she-wolf was not just a varmint, and he came to regret his youthful “trigger-itch.”

Likewise, the U.S. Forest Service must overcome its long-established “timber-itch.” With the agency creating new rules for the vast acreage under its management, and the way we use these valuable resources changing dramatically, we now have no choice but to be concerned.

The division of the Department of Agriculture that once responded mostly to the timber industry now needs to measure its mission not in harvesting trees, but in recreation visits, sheltered wildlife and protected water resources.

But old habits die hard. The agency had long suffered from such a timber-itch when Hubert Humphrey, as a senator and before he was vice president, fought to pass the 1976 National Forest Management Act. It was time to rein in overly aggressive cutting, and elevate consideration of other bedrock values like water and wildlife.

Yet, incredibly, timber harvesting continued to climb, peaking in 1990 at 12 billion board feet (it’s about 2 billion today), until a federal judge intervened, finding that agency officials had “willfully violated the law.” It was the low point for a once-proud agency with a high calling.

Today the agency faces a strong residual urge to cut timber, plus the added challenges of urbanization, energy development, climate change and off-road vehicle abuses. What’s needed now is a progressive planning framework that charts a clear path towards sustainability, water and wildlife protection, and diverse recreational values of the natural landscape as the greatest assets of national forests.

Unfortunately, the proposed planning formula hints at, but does not squarely embrace such a vision. The regulation seeks to protect agency discretion where, instead, clear commitments and accountability are needed. The danger is that the new rule won’t give Forest Service managers the tools to make the vision real. Clarity and specifics are required to do what’s right. While some flexibility is inherently necessary, too much elasticity could snap the agency back to old behaviors that would threaten to give away too much and protect too little.

The agency was not bashful about pursuing aggressive timber harvesting for many decades, stopping only when required by lawsuits. And it should not be bashful about declaring – firmly and convincingly – that those days are over. It is time to embrace conservation and lead the country into the 21st century with this vision in mind. Rather than asking for more discretion, the Forest Service needs to build trust with strong commitments and then keep them.

Americans should look for something new-evidence of a fierce green fire, a passion for exemplary land stewardship. Secretary of Agriculture Tom Vilsack has spoken with urgency about restoring and protecting water and wildlife values, and the Forest Service needs to deliver the goods.

– Jim Furnish is former deputy chief of the U.S. Forest Service.

My thoughts: Recognize that I don’t work in a timber region (not that I think they still exist; there are “used to be timber” regions), but it is human nature to like flexibility and avoid courtrooms and lawyers. It is also potentially less cost to the financially beleaguered taxpayer.

Jim says

While some flexibility is inherently necessary, too much elasticity could snap the agency back to old behaviors that would threaten to give away too much and protect too little.

Jim seems to imply that we might go back to “excessive” logging under the new planning rule. This seems unlikely to me for a variety of reasons, two of which are: 1) most of the itchy people have retired, 2) there is little or no timber industry in many FS places. Also, I don’t believe that national standards are necessarily the policy solution even if you subscribe to the timberphobic worldview.

The concept that making national standards is the only way to make strong commitments and keep them, in my view, tends to disenfranchise all the good work done day after day in collaborative groups- people that care about and understand specific pieces of land. In addition, it tends to reduce the role of local people and local governments. In fact, in my discussions with collaborative groups, they also want the FS to make commitments and keep them.

I don’t know what kind of experiences others have- but in my recent experiences with counties, and state and federal legislators I have found that they are public servants faced with a hard task of mediating conflicting goods (resources, environment, climate, jobs) and who are accountable, through elections, for what they do. To imply that something determined in D.C. as a “one-size fits all” could be better policy carries a whiff of what someone (was it Matt Carroll?) called “domestic imperialism.”

Forest Service Mindshift: From Regulators to Partners

The Forest Service seems to love the idea of partnerships, but questions remain as to how this happened, and where it will end. I’m not talking about government-to-government collaboration here, but so-called “partnerships” in other arenas. The notion is particularly contentious when partners are “for profit” corporations. In the early 1900s, the Forest Service would never have dreamed (except in nightmares) of “partnering” with big business. Instead, founder Gifford Pinchot wanted to regulate forest management on all lands, including and especially lands owned by big timber companies. But it was never to be. Not here in the USA.

In Harold Steen’s The Forest Service: a History we find enough of the tortured history of the Forest Service to give me pause. Forest Service people had to be tough to maintain their zeal in trying to encourage conservation and regulate long-term timber supply in the face of frontier ethics that pretty much said, use it or lose it. Gifford Pinchot didn’t last as long as he hoped as Forest Service Chief (1901-1910)—having crossed at least one politician too many in his zeal to reign-in business corruption. Still, Pinchot left a mark that would position the agency pretty much in his shadow for a Century. Half of that Century, almost, the Forest Service sought to regulate all timber harvest public and private, and much of the grazing in the country.

Just before the Forest Service finally gave up the all-lands regulation fight early in the Dwight D. Eisenhower Administration, after being libeled “socialists,” the Forest Service switched gears and rhetoric, and decided to be cooperators in sustained yield units composed of both public and private land. [Remember that this was the era of emerging McCarthyism, and being branded as a “socialist” was at minimum problematic.] The public good in these deals was that the Forest Service could pressure private industry to grow up and out of it’s “cut and run” behaviors—to at least replant cutover lands. To some extent it worked. To some extent the tragedy on private lands continued. But at least the Forest Service tried to achieve its regulatory dream, albeit via other means—cooperation.

Public-private cooperation is a difficult concept to wrap the mind around. How do you cooperate with “the government”? Isn’t a democratic government supposed to be an extension of the people? I can easily wrap my mind around the idea of complying with government dictate or regulation. But to “cooperate” with the government? I’m not even sure what it means. You can almost wrap your mind around the idea when you think of the Forest Service as one of many entities that manage land in the US, but when you contrast government land management (particularly multiple use management) with other land management, the idea still doesn’t make all that much sense. Still, I admit that there are areas where similar goals (e.g. biodiversity preservation) may indeed make sense to multiple owners as well as the country as a whole.

The whole idea of “cooperation” didn’t make too much sense in the early days, and didn’t get better with time, as big recreation interests got more active in and around public lands. As the rhetoric shifted from cooperation to partnership, the task was not made easier. Ski resort complexes come immediately to mind. You tell me, where is the “public good” in a ski resort complex that cannot be obtained via contracting, else outright privatization? I know that there are those who believe that conservation is better obtained with a public-private regulation-partnership model in place. But I’m skeptical. On the other hand if we begin to privatize “inholdings” in government land, where does that game end? So maybe we just have to muddle through, grit our teeth and deal with the idea that there will be some limited, regulated private use of public lands, alongside public use.

I wondered back in 1999 what we ought to make of emergent coziness between the government and those who seek to profit from land and resource managed by the government—particularly such coziness with organized commercial recreation interests. Here are a few inquiry questions I posed then, and repeat now:

  • What type commercial uses are appropriate on the National Forest in the 21st Century?
  • Is a “wise use”/multiple-use policy still sufficient when biological diversity, Wilderness, and other public use issues loom large?
  • Is there still reason to be wary of large scale commercial interests?
  • How ought we to fund the management of the National Forests, the National Parks, BLM lands, National Wildlife Refuges, etc.? Are user fees appropriate mechanisms? Are commercial permit fees appropriate? If so, in what mix and under what circumstances?
  • What roles, if any, might non-government organizations play in the funding federal lands management? What roles, if any, might corporations and other for-profit organizations play? What roles, if any, might nonprofit organizations play? Are all nonprofits created equally?

Public Use
Clinton-era Secretary of the Interior Bruce Babbitt, once safely out of office, endorsed “public use”, suggesting that we ought to steer clear of “privatization” via things like government/private partnerships. Oddly (or maybe not) Babbitt did not mention commercial recreations interests, while explicitly mentioning timbering, grazing, and mining. I’ll assume that Babbitt believed that they too ought to be in the mix.

I’ll not go that far, even though I wish we had never allowed so much commercial use of public lands—i.e managing national forests for “private” rather than public use. I realize that a “public use” agenda is not the way history played out on the public lands, although there is still time/hope. Further, I doubt that we would still have the public lands in the amount we still do, if the idea of strict public use had been the agenda from the get-go. The public lands were born in controversy, and we ought to be glad that we’ve so far kept them intact in an American culture hell-bent on promoting individualism, and individual profit-making. Still, there is time to make a major course-correction toward public use.

My Views on Public v. Private Use of National Forests
Where do I stand re: privatized commercial use of public lands? I enthusiastically support public use, including scenic backdrops to development, biodiversity reserves, wilderness reserves, and more.

I’m OK with some private use of public forest products/services, managed under broad multiple use/ecological stewardship guidelines. I’m OK with private use of wood products from the national forests. Although, I’ve argued that we might be better off just selling the products to commercial vendors at “the loading dock”—some transfer station that would allow products to be transferred from public to private ownership—rather than allowing corporate interests to work the public lands to get the products. I might even be OK with, e.g. timber sales contracts—i.e. allowing commercial entities to work public lands for the forest products—as long as there are enough eyes on the contracts to make sure that the taxpayers get a fair deal, alongside the contractors. Similarly with “stewardship contracts” that allow contractors to keep and sell some forest products.

I’m Ok with commercial recreation interests, although not OK with making the national forests into Disneyland-type destinations. I’m still struggling with ski resorts and upscale marinas on public lands, but I guess I’ll have to allow space for them in my design—and I do use them, so it would be a bit disingenuous if I were to suggest otherwise.

As for “outfitters and guides,” I believe they ought to be able to operate on public lands, but with much less privilege than they now are allowed. And I don’t think the Forest Service ought to try to regulate them. This gets tricky, but maybe not as much as we might initially think, since the agency will have to allow for group recreational use of the national forests in any case, and if a group has a outfitter and/or guide that doesn’t seem to complicate the matter that much. One question: Why does the Forest Service seek to regulate outfitters and guides?

But I believe that marketing, e.g. signing and soliciting for any and all commercial use of the national forests should be minimal and in keeping with traditional rustic imagery of the national forests.

And I believe that fee collection should be both fair to the owners of the national forests and should be easily administered. For example, it would be better to charge an annual fee for use, than to charge for each occurrence. Why? Simply because it detracts from natural experiences when one is constantly grabbing for a billfold.

Regarding concessionaires, I believe their presence is allowable (as it has been in the US Park Service since pretty much the beginning) but their operation ought not to be the “swinging hot spots” from Joni Mitchell’s Big Yellow Taxi. Instead concessionaires ought to be relative low-key operations. Exceptions might be made for ski resort communities, but maybe the best bet there would be to trade lands so that at least the most commercial of operations are not on the national forests. But that too has problems as I explained above. My preference re: campgrounds/picnicgrounds is for the Forest Service to manage them (likely via volunteers) and use them in part for conservation education.

As for grazing on public lands, I’m hard-pressed to see a good case for continuing it, if only because of the many disease-related problems in co-mingling domestic stock and wildlife. I’m not opposed to grazing on public lands if properly managed, e.g. onsite caretakers of a herd, but only if we can somehow get beyond the disease problem.

Mining and Oil and Gas exploration are at-minimum problematic, but I don’t see them stopping. Our best bet might be to continue vigilance and seek ever-better-regulation of these activities relative to both environmental and aesthetic considerations.

Whadayathink?
Have I joined with the forces of “darkness and evil”, i.e. those who would “marketize” the national forests? Or is this a useful beginning to ring-fence creeping marketization? In his book The Abstract Wild, in a chapter titled “Economic Nature,” Jack Turner describes the loss of shared social values, what others might call the virtues of civic engagement. These values might include sense of community, sense of place, sense of wildness in interacting with and attempting to be, once-again, part of Nature, etc. Through time, however, the world, and particularly the US is approaching a place where all values save one—money—are lost along the timeline of a society madly reinventing itself into crass-consumerism, accompanied by marketing madness. In Turner’s words,

Only one widely shared value remains—money—and this explains our propensity to use business and economics rather than moral debate and legislation to settle our differences. …

This rejection of persuasion creates a social order wherein economic language (and its extensions in law) exhaustively describes our world and, hence becomes our world. Moral, aesthetic, cultural, and spiritual order are then merely subjective tastes of no social importance. It is thus no wonder that civility has declined. For me this new economic conservation “ethic” reeks of cynicism—as though having failed to persuade and woo your love, you suddenly switched to cash. The new economics conservationists think they are being rational; I think they treat Mother Nature like a whorehouse. (pp. 57-8)

And what about partnerships? I still don’t much like the word, neither the word “cooperator.” And I’m particularly incensed when government people cozy-up to commercial agendas, even sometimes becomming cheerleaders for such. I do like the idea of collaboration in policy making, in program development, and so forth. I have reservations as to the manner that the Forest Service now chooses to engage individuals and public interest groups, but that is a matter for other posts—many of which I’ve already aired.

Endnote
No matter how the “use” and “commercial use” debates play out, with accompanying litigation and legislation, there are at least two intertwined “bigger issues” that remain on the table, in the background: biodiversity and associated species loss, and human population growth (with related resource extraction and pollution concerns that include human lifestyle concerns). These two issues under gird pretty much all others but are not popularly discussed. I hope that these two items will again find their way into mainstream talk in advance of catastrophe. But I’m doubtful that such will happen anytime soon, and I don’t believe we’ve got a lot of time left, particularly given the dynamics of doubling of human population growth (Wikipedia link) and the fact that the doubling curve is an exponential growth curve that is working into a very steep space—i.e. when 3 billion became 6 billion people (30 years, 1 generation) the curves looks remarkably steeper than when 3 million became 6 million people (1000 years, 33 generations).

Australian Bushfire Damage and Climate Change

Here on Roger Pielke’ Jr.’s climate blog is a peer-reviewed point counterpoint about climate and vulnerability with regard to bushfires in Australia. It makes me wonder.. we’ve had a number of posts about wildland fires and the need to rethink our approaches to managing fires. The recent discussion here on the use of retardant is one of those. Question: do the Aussies have any better ideas that might be worth importing? Is the debate different or framed in such a way that different solutions emerge?

What this story says to me is that people’s vulnerability to fires is actually, at least at the current time, fairly separate from climate and yet worthy of attention.

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

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

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

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

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

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

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.