September 15, 2006
Jeremiah was a
Bullfrog Forest Planner
Some may remember Three Dog Night's old rock and roll tune, "Joy to the World." It begins like this:
Jeremiah was a bullfrogThose lyrics have taken on new meaning to me lately, in the context of forest planning, accompanying Regulation and Directives, and generally in what I'll call Forest Service WO-speak.
Was good friend of mine
I never understood a single word he said
But I helped him drink his wine.
He always had some mighty fine wine
Joy to the World…
As an indicator of the problem, reflected in practice, all should read a recent N. District of Calif., US District Court decision ("People of the State of California"(Bill Lockyer, Calif. Attorney Gen.) v. US Forest Service) [PDF] on the Grand Sequoia National Monument plan. In this case the court found that the Forest Service failed "to create a discernable and comprehensible plan" in violation of the law. Although argued under the 1982 "planning rule," I think the decision is a harbinger of things to come under the 2005 planning rule/directives as well. On many fronts, it seems to me that the Forest Service is proving itself incapable of anything that would pass a "discernable and comprehensible" test.
In the last couple of weeks Forest Service in-house email flurries have focused on so-called "prohibitions" in forest plans. Some Forest Service Washington Office (WO) staffers are suggesting that forest plans, in order to be "aspirational," cannot prohibit things. Instead the plans can articulate "desired conditions, "objectives," and guidelines, but must do with positive rather than negative words. Some Forest Service field practitioners are pushing back a bit, trying to figure out just what forest plans are intended to be and how they are to comply with the 2005 Planning Rule (36 CRF part 219) and with the voluminous FS Directives that accompany the rule.
Just yesterday practiterions got the latest in "prohibition," via email as "Planning Tip of the Day" from DeAnn Zwight, [Assistant Director for Planning, Ecosystem Management Coordination Staff, USFS WO]. The email focused on "implementation as commonly used in forest plans." Here's a snip:
Ms. [Kathryn] Toffenetti [USDA Office of the General Counsel (OGC)] has made a comment approximately 9,437 times that she does not like, will never ever ever like the word "implementation" as it is commonly used in plans. [W]hen we talk about implementing the plans, it implies there's one path laid out, it's some ministerial action w/ no discretion, on one set of projects, and that the plan can indeed be "implemented" in some particular way--instead of the strategic framework envisioned. …Not much argument from me. For a many years I have advocated that the agency use scenario planning and abandon its longtime focus on "comprehensive rational planning" with detailed plans, but….
Kathryn [Toffenetti, USDA Office of the General Counsel (OGC)] would like to move forward in life without ever having to see the words "implementation" or "implement the plan" or "plan implementation" in plans again, and I would like to move forward in life without ever having to read Kathryn's comments on this matter again. OGC attorneys are very, very focused, and besides that, I bow to her OGC expertise.
SO! Please say something like "future projects and activities" or "subsequent projects and activities" proposed (or carried out, or approved) under the plan. [Kathryn Toffenetti] says the message we want to send is: that the plan is a general framework to guide the forest when it will propose, analyze, and decide upon on-the- ground management actions.
Scenario planning is not what the FS seems to be about. Scenario planning is a means to simply rehash the past and rehearse the future. It is a way to set a stage from which to do adaptive management. Scenario planning stops short of articulating "desired futures." Scenario planning stops short of laying out "objectives." Scenario planning doesn't prescribe "guidelines." Scenario planning doesn't lay out elaborate monitoring and evaluation schemes associated with "the plan," including language that says (36 CFR 219. 6 (b) (2)):
The plan-monitoring program shall provide for: (i) Monitoring to determine whether plan implementation is achieving multiple use objectives; … (iii) Monitoring of the degree to which on-the-ground management is maintaining or making progress toward the desired conditions and objectives for the plan…. (emphasis added by Iverson)
The Forest Service still appears to want it both ways: "aspirational" and loose when challenged in court, but "by the book," when dealing with things internally. I see more storm clouds ahead. "Discernable and comprehensible plans" are hard to envision when planning-related "rules" and "directives" continue to be a mess.
Here is an example of my pleas to move to scenario planning:
Planning is indeed a big opportunity (if an opportunity lost on the FS). Royal Dutch Shell and others champion scenario planning, where the object is to do two simple tasks: 1) rehash the past, and 2) rehearse the future. The idea is to hone skills in planning games, so that as the universe unfolds in daily organizational life we can be ready to practice adaptive management and organizational learning .
This may be considered a planning opportunity lost, so far, by the Forest Service. We hatched Planning in the FS as comprehensive, rational planning and although we are slouching toward scenario planning we have not yet arrived.
Posted by Dave on September 15, 2006 at 02:38 PM | Permalink
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Bullfrog Forest Planner:
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