Here it is.
Extremely user friendly page, in my view. Nice work!
Forest Service Recreation Funding II: What Would You Do?
Your responses to the post below on the San Gabriel and charging for some Fourteeners were intriguing, and the topic of how to fund recreation on the national forests seems worthy of more exploration.
It seems to me that water and recreation could be argued to be the two most important services that national forests provide. Yet the funding of recreation does not seem to have the vociferous, organized and powerful support that it should to ensure adequate budgets from Congress. Here’s an op-ed from the Grand Junction Sentinel yesterday that says there isn’t enough for watershed protection either; so recreation is not alone.
So here is the situation- the 14ers area is not unique- quoted from the Colorado Springs Business Journal article here:
The Forest Service says it doesn’t have the funds to minimize the effects of hikers on the environment.
On average, 4,500 people visit the basin during the summer climbing season, with a 3- to 5- percent increase each year for the past decade or so.
With heavy use, the main system trails are being degraded, climbing routes are being eroded and human waste is a major concern, Crespin said. Fecal chloroform levels in the streams are high. Also, wildlife has become accustomed to humans.
Another issue is the frequency of search-and-rescue calls to the area.
The proposal behind the new fees limits the Forest Service to spending the revenue it collects only within the fee area.
Opponents say that over-use problems need to be resolved without fees.
“There are signs the area is being over-used. But there are better ways to manage over-use than to price people out of using their own public lands, which is what I think this will do,” Kitty Benzar, president of the Western Slope No-Fee Coalition, said.
The coalition isn’t opposed to a permit system to limit the number of people in the basin at any one time; it just doesn’t want permits to cost money.
Crespin said fees would allow the Forest Service to install trash dumpsters on the South Colony access road, do ecological monitoring and continue restoration efforts. The agency has spent $1 million in the last 15 years for restoration in the affected area.
Which door would you open in this situation?
Update 5/23: In this op-ed Kitty Benzar makes a couple of interesting claims.
1. “consider that its congressionally appropriated funding has increased by 72 percent since 2000, compared to inflation of about 28 percent during that time. And no, that increase did not all go to firefighting.”
2.”The Herald’s May 18 editorial said that a fee of merely $10 or $20 won’t deter mountain climbers, but the Pike-San Isabel National Forest must disagree because that is exactly why its managers want to do it. Their primary stated reason for the fee is to reduce visitation.” Note.. this does not agree with the remarks of Paul Crespin quoted above.
Also here’s the Denver Post editorial board on the same subject.
But money for natural resource management is scarce, and we don’t see a fourteener usage fee as a great departure from the current practice of managing other federal resources, whereby fees are charged to enter national parks and campers pay to use camp sites.
Update 5/24 Here’s a broader article on the topic by Bobby Magill for the Coloradoan. As usual (IMHO), he has a clear and even- handed approach to the topic, including some thoughts by John Loomis, an economist at Colorado State University.
Wilderness, Commercial Enterprise and Speech
The Salmon-Challis forest supervisor, Frank Guzman, is coming under attack from the Idaho Conservation League and Governor Butch Otter for up-holding the letter of the Wilderness Act. Guzman denied a public television station’s request to film a documentary in a wilderness area. Guzman explained to the Idaho press that the Wilderness Act bars commercial enterprises; the filming is a commercial enterprise; and, thus, the filming is not permitted.
ICL and Otter argue that public television is non-commercial; a claim readily dismissed by anyone who has ever listened to public television’s sponsorship credits. More problematic still is ICL’s argument that the television station’s record of supporting pro-environment programming justifies the wilderness filming. Content-based speech regulation is a slippery slope that ICL should know better than to be encouraging.
Supervisor Guzman is no great friend of wilderness or forest preservation. He’s likely tickled that public television gave him a chance to offend free speech purists, environmentalists, and wilderness advocates who downplay the Wilderness Act’s restrictions as they seek to add wilderness areas to the system. Nonetheless, I’m happy to commend Guzman for obeying the law.
Comments on the Planning Rule Process from Mark Squillace
Mark Squillace, Director of the Natural Resources Law Center at University of Colorado Law School, wrote a piece on the Red Lodge Clearing House blog..here. Some quotes.
First, the Forest Service deserves substantial credit for initiating this remarkable process. The agency wisely chose to hire an outside professional consultant (Meridian Institute) to organize and facilitate public involvement and the consultant performed admirably. Moreover, recognizing that not everyone has the time, inclination, or interest to participate in workshops, the Forest Service has supplemented this more conventional process, with a web page, blog, live web casts of the workshops, and other electronic resources, in an effort to engage a broader audience.
Second, if the first step to addressing a problem is admitting you have one, then the Forest Service seems well on its way to addressing its problem with planning. While the workshops certainly did not dwell directly on past failures, the unspoken premise for much of the discussion was that forest planning is broken. Agency officials seem to get that. Despite several substantial efforts to develop a workable planning process, going back to at least the early 1980’s, land and resource management plans, as they are called, take far too long to prepare and are too often the subject of appeals and litigation. Moreover, they tend to suck most of the energy (and financial resources) out of the agency, with the result that not much is left to adequately assess project level decisions and to engage in post planning monitoring of forest conditions.
Third, the Forest Service seems genuinely committed to engaging the public and hearing how they might improve the planning process. Numerous agency officials at all levels actively participated in both the regional and national workshops and they genuinely seemed grateful for the public’s sometimes disparate ideas for designing a smarter approach to forest planning.
Fourth, the level of dialogue among participants was, on the whole, quite sophisticated, but it was also welcoming toward the views of those with less direct experience in forest planning. Kudos once again to the facilitator, Meridian Institute, for attracting and convening a diverse group, and for structuring an efficient and effective program for engaging participants with varied backgrounds in the task at hand.
I have to say that Meridian did our regional roundtable in Denver as well and were equally excellent.
Two other things: First, on the Red Lodge blog piece it is mentioned that Mark has a piece on the FS blog called “Rethinking Forest Planning”. I tried to find it but couldn’t; the search on his name didn’t work for me.. if someone else can find it please let me know and I will post the link.
Second, in the Red House blog piece a comment referred to “Hidden Gems.” For the non-Coloradans, that is a wilderness proposal.
Place- Based Legislation: Should the Taxpayer Pay for Your Impacts?
Sometimes the idea of users paying for what they expect from the national forests (in terms of recreation) is simply incendiary. I, frankly, don’t really understand why, since it is not so for state parks or national parks. Here is an editorial from the Durange Herald (Durango, home of the Western Slope No-Fee Coalition) that takes a more reasoned view (IMHO) concerning the idea of charging for various services when people climb certain fourteeners in Colorado.
Here’s a quote from the editorial:
There is, however, another reason serious hikers might want to consider footing some of the bill: Respect. The biggest non-tax contributors to the Forest Service budget are extractive users, who do pay extra – although, in many cases, probably not enough. With relatively low fees, recreationists could buy some clout. That is an investment worth considering.
In contrast, an article in the LA Times touches on some of the same issues (recreation impact) and suggests a solution- place based legislation- to make the San Gabriels a wilderness. Not sure exactly how this would translate into more funding to protect from recreationist damage- except that it would clearly come from the national taxpayer. Would it be simpler and more direct to simply charge the recreation users, as in the Fourteener example?
The Durango Herald editorial has an amazing quote from Kitty Benzar, president of the Western Slope No Fee Coalition in Durango, as she told The Associated Press,
“The Forest Service didn’t create the mountains, and they have no right to charge access to them
Based on this same principle the Forest Service couldn’t charge for oil and gas, or coal, or timber. LIke I said, I really don’t understand why some folks think recreation users should make the general taxpayer pay for their use of the federal lands. Can someone enlighten me?
The Precautionary Principle and Forest Planning
“Better to be safe than sorry.”
“Nothing ventured, nothing gained.”
“First do no harm.”
“Fences are made for those who cannot fly.”
“An ounce of prevention is worth a pound of cure.”
Caution or boldness? What happens if doing nothing is worse? This is one of the debates emerging from the Forest Service planning rule development.
In the 1970s, the Black Forest in Germany was obviously deteriorating. Acid rain associated with sulfur and nitrogen emissions from industrial, commercial, and transportation sources was the suspected culprit, but science could not provide firm evidence of cause and effect. Despite this scientific uncertainty, the German government instituted regulations to reduce power plant emissions. The policy became known as “Vorsorgeprinzip”, which translates into the “principle of advanced caring.” After evolving into a key component of German environmental law, the concept of precautionary action gradually gained wider acceptance across Europe and was incorporated into various international treaties, conventions, and declarations. The concept grew into what is known today as the precautionary principle.
The precautionary principle states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absense of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those who advocate taking the action. This principle allows policy makers to make discretionary decisions in situations where there is evidence of potential harm in the absence of complete scientific proof. The principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk. These protections can be relaxed only if further scientific findings emerge that provide sound evidence that no harm will result.
The principle has become very popular, embraced by governments around the globe. In the European Union, the application of the precautionary principle has been made a statutory requirement. It has been incorporated into many treaties and resolutions, including the Rio Declaration, the Montreal Protocol, the Convention on Biological Diversity, the 1992 Climate Change Convention, the Treaty on European Union, the Convention for the Protection of the Marine Environment of the North-East Atlantic, and the Helsinki Convention on Marine Protection in the Baltic. In 2005, the city of San Francisco, adopted a precautionary principle purchasing ordinance.
At a 1998 conference convened by the Science and Environmental Health Network at the Wingspread House in Racine, Wisconsin, a group of scientists, philosophers, lawyers, and activitists developed a widely-cited consensus statement about the precautionary principle:
When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.
The precautionary principle has been proposed by various environmental groups as a central theme of a new Forest Service planning rule. It became one of the discussion questions during the third planning rule national roundtable last week. But there are questions about the appropriateness of the principle in a typically value-laden forest planning process lacking agreement on goals, and when inaction could be as risky as action.
Although it was only briefly mentioned at the planning rule science forum in the question and answer period for the first panel, it was highlighted in Booz Allen’s summary report of that meeting. Tom Sisk from Northern Arizona University observed that when we lack information we still need to make tough decisions. In order to protect the environment, management should be appled according to the ecosystem capabilities. Sisk said that a lack of uncertainty should not be used to adopt environmental protections. Later, there was a follow-up question from the audience about whether we should be using adaptive management instead of the Precautionary Principle. Sisk reminded everyone that the Precautionary Principle cuts both ways: both taking and not taking action. We should not let uncertainty stop us in our tracks.
Alston Chase has argued that the precautionary principle does not always benefit society, could produce more ecological and social harm than good, with consequences not known until it’s too late. He explains that in “game theory” there is no such thing as a “correct decision” under conditions of uncertainty, and that all choices are subjective, reflecting the values of the decision-maker. When applied to natural resource planning, he argues that it presupposes the idea of a self-regulated ecosystem, seeking to protect conditions that never existed, never will exist, or never could exist.
In the middle of the debate over the use of the precautionary principle in Forest Service planning is the set of Forest Plan amendments comprising the Sierra Nevada Framework. The principle played an important role in the 2001 amendments. However, risk and uncertainty assessment teams in 2003 observed the dangers of applying the principle, and a new decision was made in early 2004. (On separate issues the decision was litigated and a Federal Register notice to supplement the analysis was issued earlier this year).
In 2004, Hal Salwasser, School of Forestry Dean at Oregon State, and former director of the Pacific Southwest Experiment Station, wrote about his experiences with the complex and messy forest planning in the Sierra Nevadas, and the problems he saw with the application of the precautionary principle in these types of “wicked problems” .
The precautionary principle has several flaws that make it questionable as a guide to decision making (Beckerman 2000). First, if the future is really all that uncertain, then we cannot be confident that action taken or not taken today will not make the future better rather than worse. Second, what constitutes harm is not always clear and could vary over time and space. When the precautionary principle is applied to dynamic ecosystems to constrain actions, such as fuels thinning needed to restore the system’s resilience to fire, it sets up the potential for major long-term harm: harm from inaction could be greater than harm from proposed action. Inaction creates “opportunity benefits,” that is, benefits foregone because action was not taken (Wildavsky 1995).
It is not possible to have full certainty regarding most of the important things in life, and ecosystems are certainly no exception. The standard for burden of proof about certainty in the precautionary principle is infinitely high. And taking no action precludes the opportunity to learn from trial and error. The upshot of applying the precautionary principle is either nothing will ever get done or the preconditions for action are so time consuming and burdensome that action is excessively costly, too timid, or too late. The consequence will be countless unintended harms as a result of inaction. Care, thoughtfulness, and testing of ideas make sense, but extreme precaution is hardly prudent in a dynamic ecosystem, especially one that is vulnerable to uncharacteristic disturbance events. Thus, in situations such as those that confront Sierra Nevada ecosystems, stakeholders, and managers, the precautionary principle sheds no light on prudent choices.
The precautionary principle appears to have greatly influenced how risk or uncertainty about forest management impacts on certain fish and wildlife entered the decision rationale in the 2001 Sierra Nevada Forest Plan Amendment. It appears that uncertainty was assumed to have only negative potential outcomes; however, uncertainty means outcomes or future events are uncertain in both directions. The rationale for how tradeoffs were made warrants open critical thinking and review of what uncertainty implies, what harm is, and how it is judged vis-à-vis other objectives. The 2004 revised Record of Decision handles risk with more boldness, yet even it is insufficient to address the magnitude of risk to late successional forests and their ecological values posed by uncharacteristically intense fires”.
Salwasser adovates decision analysis and adaptive management learning processes used in other disciplines for complex problems (things that have been discussed on this blog).
In the planning rule roundtable meetings, some participants have suggested that the Forest Service develop a framework using experimental approaches with a precautionary underpinning to address forest challenges. But others have noted that forest restoration is expensive and suggested that caution (whether enacted actively or passively) is the appropriate framework to reduce costs in the national forests. Both risks and benefits are apparent in the multiple-use mission of the Forest Service, so this is an important debate.
Environmental lawyer Carolyn Raffensberger, one of the leading advocates of the precautionary principle, has said that it’s about setting goals, reversing the burden of proof, looking for the safest alternative, and emphasizing public health and the environment over economics. But she also concludes that the final element of the precautionary principle is democracy:
If we’re faced with scientific uncertainty, we need to set goals, and choose the safest alternative to achieve these goals. These processes involve values and ethics; it is not something that scientists or government bureaucrats can decide alone. We need to bring affected parties to the table. This gives us a chance as a public to set the goals that we want to drive toward; it helps get on the table a much wider array of options for solving problems and looking for alternatives. So democracy is also an essential component of the Precautionary Principle.”
Perhaps a conversation is a good place to start.
Welcome Visitors from the Missoulian!
In our blog stats, I noticed a number of visitors from a link to the Missoulian, which turned out to be from a story about Martin’s place based legislation work, with a link to this blog.
Please feel free to comment or submit a blog post to Martin or me.
You might be interested in recent discussions about litigation in Montana (Region 1 of the Forest Service) and the science behind fuels treatments.
The Hartwell Paper and A New Forest Planning Rule
For those of you who aren’t familiar with this paper, it was a recent effort to figure out if another approach to climate policy could be more successful.
Here is quote from Mike Hulme in this essay on the Hartwell paper .
To move forward, we believe a startling proposition must be understood and accepted. It is not possible to have a “climate policy” that has emissions reduction as the all-encompassing and driving goal.
We advocate inverting and fragmenting the conventional approach: accepting that taming climate change will only be achieved successfully as a benefit contingent upon other goals that are politically attractive and relentlessly pragmatic. Without a fundamental re-framing of the issue, new mandates will not be granted for any fresh courses of action, even good ones.
The paper’s first primary goal focuses on access; to ensure that the basic needs, especially the energy demands, of the world’s growing population are adequately met.
The second is a sustainability goal; to ensure that we develop in a manner that balances social, economic and ecological goals.
Third is a resilience goal; to ensure that our societies are adequately equipped to withstand the risks and dangers that come from all the vagaries of climate, whatever their cause.
Most regular readers of this blog will know that my approach to climate change for public lands is basically:
1. Do all the things we know we should have been doing (monitor and adapt in a transparent disciplined way)
2. Preferentially protect the fundamentals, especially water and air. There is no correct or incorrect composition of plants and animals, now or in the future.
3. Connect landscapes through riparian and other corridors.
4. Use land trades to decrease fragmentation of public lands and open areas to solar or wind development.
5. Develop sustainable biomass industries where needed to conduct fuels treatment or for ecological resilience.
I am also a big fan of Trout Unlimited’s “protect, reconnect and restore” as described in their “Healing Troubled Waters” document here.
So here’s the question- think about Hulme’s concepts, my concepts, TU’s concepts and your own concepts of what to do about climate change… what is the public lands piece to you? And what, if any of that should fit into a planning rule?
Planning Rule Meetings Concluded – Tentative Future Meeting Announced
The initial phase of public involvement for a new Forest Service planning rule ended this week with a final national roundtable in Rockville, Maryland. Notes from the meeting will be published on the Forest Service’s planning rule website. The Forest Service has now hosted three national meetings and nearly 40 regional and local meetings across the country. Essentially, these meetings were listening sessions. Now all the ideas will be compiled and screened into specific proposals and alternatives.
For some issues, there is no clear consensus. There are significant differences in opinion between national and local participants, so further dialogue will be necessary. Also, while Forest Service employees were well represented at all the roundtable meetings, they were largely in a listening mode, and didn’t always present their point of view. There may be differences in opinion between the Forest Service and public participants, and there always seems to be differences of opinions within the Forest Service.
At this week’s meeting, a tentative future meeting was announced for the last week of July, to allow the public to discuss possible specific rule text. The rule writing team is open to suggestions on the next steps. Hopefully, there will be opportunties to increase understanding among groups across the country, and between Forest Service employees and the public.
K.I.S.S. Maps
Maps are planning’s most ubiquitous and useful tool. Maps put place in the center of the planning conversation. It’s no surprise that all of the place-based collaborative processes use maps as their exclusive planning tool. No linear programming optimizing models; no ecological forecasting models; in fact, no complex models at all are used in collaborative, place-based planning (in a future post I will discuss why complex models create more trouble than they are worth).
In the days before GIS, maps and transparent overlays were used to avoid placing clearcuts next to campgrounds. Conventional NFMA plans use maps to zone land, showing where uses are permitted or prohibited.
The proposed K.I.S.S. planning rule eliminates this discretionary zoning function from NFMA plans. Without zoning, what information would K.I.S.S. maps illustrate?
A map of the 3-year vegetation management and timber harvest program would be useful. This map would show the metes and bounds of lands slated for vegetation treatments. Using Google Earth as a base, the vegetation treatment map would show where the land to be treated is located in relation to towns, homes, or natural resource features and what the current vegetation looks like from a bird’s eye view. During the forest planning process, Google Earth could be used interactively with the public allowing anyone to build a kml file to recommend treatment sites to the planning team or illustrate why a proposed treatment is unwise.
Google Earth maps can display inventory information used in the planning process, such as the location of endangered species critical habitat. Planners and the public can use Google Earth to overlay vegetation management maps onto resource inventory maps to see the intersection of vegetation actions with the places and things they care about.
So what happens to zoning? NFMA does not require that forest plans zone national forests by use or prescription. Of course, where zones have been imposed by law, e.g., wilderness, the Forest Service must conform its management to the zone’s requirements. But there is no compelling reason for the Forest Service to zone uses in the NFMA planning process. People want to know what the Forest Service will do and where, on-the-ground, in the immediate future. Speculative zoning does not serve that purpose.