March 10, 2005
Forest Planners Gone Wild
Although not perfect, to a certain extent, the new Forest Service planning rule is an attempt to move Forest planning closer to the latest thinking in the planning profession, organizational psychology, and the management literature. Those of us in the Forest Service planning business have for years seen forest planning as essentially broken. A typical planning team will cost a little over one million a year, and we typically take five, six, seven, or more years to complete a plan. Meanwhile, we were seeing the final product becoming less and less relevant to managers, while being less and less accessible to citizens who care about forests. At the same time, those who cared enough about National Forests that they expected plans to actually be implemented quickly learned that they never could really be followed.
So the new rule and our new model of a plan is so exciting! I'm hoping to share our hopes with everyone on this forum. It's not about streamlining planning or that those of us in the planning profession are lazy and don't want to do a thorough job. Rather, we want to do planning that matters, that informs managers and those who wish to collaborate. We want planning that is relevant and useful in guiding the Forest Service in using scarce federal dollars wisely. We want planning that helps to reestablish trust. We want planning where those who get involved can really make a difference.
Posted by John Rupe on March 10, 2005 at 08:52 PM | Permalink
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Posted by: Tony Erba
John is correct. I find interesting in reading the recent Defenders of Wildlife et al lawsuit against the 2004 planning rule that people believe the 1982 regulations still have merit 23+ years later. While one could argue that some provisions in those regulations could still be applicable today, many of the provisions are outdated. As John points out, it is an exciting time to explore how to make planning more relevant to the management scenario experienced today as opposed to locking ourselves into a mindset that nothing changes, either the world around us or the management schemes developed decades ago.
Tony Erba | Mar 15, 2005 11:08:09 AM
Posted by: Anne
Ok, you piqued my interest: specifically the phrases "closer to the latest thinking in the planning profession, organizational psychology, and the management literature" and "it's not about streamlining..." I'd like to hear more about this aspect - specific literature and particularly how we can work to ensure that the process isn't hijacked by those who don't like public input or plans that have meaning.
Anne | Mar 17, 2005 11:43:46 AM
Posted by: John Rupe
About the same time as the rule was being developed (and it's been about four years now) the Forest Service put together a small group of folks (I was involved and so was Tony) to develop a "prototype" of what we wanted a plan to be. Meanwhile, the rule was being developed like sausage, but in small ways it began to incorporate some of the things we were doing. Then, the directives, (which just came out today), incorporated significant parts of what we were doing. We put together two documents, one on what a plan would look like, and the other on the process. Here is a link where you can see the latest version of the documents (updated to match some of the language of the rule.) I can go into the specifics of some of the literature we looked at on a later post.
John Rupe | Mar 17, 2005 5:48:35 PM
Posted by: Andy Stahl
In regard to Tony Erba's concern that the 1982 rules are too old to be relevant today. Why is age relevant? What about the Constitution? Is it too old to be relevant today? I suppose the corollary to Erba's point would be that the law, NFMA, must be even more out-dated (by 6 years) than the rules.
Speaking of the law, why does the FS believe it can relegate standards and guidelines that NFMA requires be regulations to its internal handbook and/or manual?
Last point (for now) . . . why are Short-Range Tactical Plans (1906.2) not subject to NEPA? Courts have uniformly held they are, e.g., National Wildlife Federation v. U.S. Forest Service ("Mapleton" case in which 7-year timber sale action plan requires EIS) and EPIC v. Forest Service (Six Rivers Fire Management Plan requires EIS).
Andy Stahl | Mar 18, 2005 12:28:58 PM
Posted by: Sharon Friedman
It would help me understand all of your points of view to be more specific- if you could talk about which parts of the 1982 regs you consider still relevant today or not, and why. Suggestion: let's pick a few specific topics in the 82 regs and discuss them in greater depth.
Sharon Friedman | Mar 19, 2005 8:08:37 AM
Posted by: Andy Stahl
In response to Sharon's entreaty, below is an example of a relevant and an irrelevant provision from the 1982 rule with supporting rationale. It would be nice to know if the Forest Service ever went through the same exercise, i.e., an incremental analysis of NFMA rule changes.
Sec. 219.19 Fish and wildlife resource.
Fish and wildlife habitat shall be managed to maintain viable
populations of existing native and desired non-native vertebrate species
in the planning area.
Reason: There remain hundreds of wildlife species on the national forests whose viability is threatened, e.g., black-backed woodpecker. It remains a worthwhile goal of national forest management that wildlife should be protected from becoming threatened or endangered. Thus an enforceable, substantive rule that accomplishes that goal is justified.
Sec. 219.9 Regional guide content.
(a) The regional guide shall contain-- [etc.]
Reason: The Forest Service gave up on regional guides long ago. To the extent that coordination among forests is necessary, multi-forest decision documents and EISs have sufficed, e.g., Northwest Forest Plan.
Andy Stahl | Mar 21, 2005 11:43:18 AM
Posted by: Tony Erba
Andy, I agree with you that not all provisions of the 1982 regulations are outdated, or irrelevant, to use my own words. It's not the age that the problem, it's the way they were written.
Let's think about how those regulations were written - very prescriptive on specific processes and outputs with little room for interpretation and modification to reflect a specific national forest's situation. "Net public benefit" (along with its economic shortfalls) was the focus of management plans. If the regulations had been written reflective of the NFMA (guidance instead of prescribing specific actions), those regulations would still be relevant today. That guidance could ebb and flow with new scientific discovery along with planning theories. The 2004 regulations present planning guidance that can do just this.
Whether these regulations fulfill people's expectations on "viability" remains to be seen. However, I am having a hard time reconciling the supposed conflict between managing for viability under the 1982 regulations and for sustainability under the 2004 regulations. Aren't they two different pathways to achieve the same endpoint: making sure that human actions are not the reason that species cease to exist?
Tony Erba | Apr 3, 2005 9:00:04 PM
Posted by: Steve Funk
Is anyone going to take on Wildlaw's analysis of the new planning rule? I'd like to see some discussion therein.
Steve Funk | Apr 4, 2005 12:36:44 PM
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