August 29, 2007
RPA/NFMA – Time To Punt
Dick Behan once — likely more than once — called for the repeal of RPA/NFMA (the Renewable Resources Planning Act of 1974 as amended by the National Forest Management Act of 1976). Here is part of Behan's reasoning:
… Idealized, perfect planning that is mandated in law [and Regulation], and constrained only by an agency's budget, will exhaust that budget. … There will come a time when the Forest Service can do nothing but plan ….Instead of following Behan's sage advice, the Forest Service blundered on—for three decades spanning several iterations of 'NFMA Rule' rewrites. Behan was (and is) an advocate for planning and management (as separate organizational functions). Still, he does not now and did not then see daylight in the path the Forest Service has taken. Behan adds:
… The agency has a long tradition of hard work, dedication, and "can-do" management; but we have given it, this time, an impossible task.
RPA/NFMA cannot be made to work. Its flaw is fundamental: it is a law, and it needs to be repealed. We failed, in our collective problem solving, by placing too much faith in planning and placing far too much faith in statute. It is time to punt.
The Key is Better Administration, Not a Better Law
Certainly we need to plan, to make assessments, and to write programs to submit to Congress. And we need … forest-level [site planning.]. … But planning can be done without statutory coercion, and it can be with a great deal less than perfection in mind. …
… [P]lanning is, finally, only planning—a precondition, not a substitute, for management.Time to reconsider? If not now, when? Why does the Forest Serivce seem incapable of learning? Sally Farifax's assessment of 'NEPA as a paper-chase' comes to mind as well. So does Herbert Kaufman's The Paradox of Excellence, pointing to the broader culture of the Forest Service laying the foundation for its own demise, or at mimimum 'very painful' transformation.
In the management of the national forests, we need to improve or construct some new approaches to problem volving—other than seeking legislative remedies and resorting to subsequent litigation. I believe a new pattern of public forestry is in order, in which the forest manager sees his task as actively solving public problems, not passively executing public laws. …
Instead of talking through the nature of administrative governance for the 21st century, the Forest Service seems to be attempting yet-another tweak of the NFMA rule, yet-another tweak of its own organizational structure via a "transformation" effort hidden behind intranet firewalls, and more without giving a moment's thought to the reality that 'form must follow function', not the other way around.
Behan's wisdom rings as true today as it did almost three decades ago. And it appears to be even more absent from the minds of FS managers than it was then.
Posted by Dave on August 29, 2007 at 11:58 AM | Permalink
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