On Monday James Connaughton, Chairman of the Council on Environmental Quality, issued a Federal Register notice [PDF] of a "proposed guide" — Aligning the Complementary processes of Environmental Management Systems and the National Environmental Policy Act [PDF].
The proposed guide promotes EMS as a remedy to the governments' long-standing inability to "address the full range of ongoing activities (and products and services) … with the intent to continually improve environmental performance." And all this time I thought that was the intent of NEPA compliance. The CEQ has long stressed the importance of programmatic to site-specific linkages, connected actions, cumulative effects, and more.
One way to view the notice and guide is that CEQ is taking the next step along the road to better compliance with NEPA. Another, darker way to view the notice and guide is that the federal government is taking yet another step along the path of process gridlock. As we opined earlier, there are three EMS paths forward:
- EMS buries the Forest Sevice—in process and "paper,"
- The Forest Service buries EMS, or
- EMS transforms Forest Service culture to adopt adaptive management.
Let's pursue the latter path a bit. Adaptive Management is a remarkable idea, and stands a reasonable chance of transforming (for the better) both landscapes and institutions. The Resilience Alliance, for example, is dedicated to that particular proposition.
But there are serious omissions in the description of adaptive management in the "proposed guide," relative to the way adaptive management is commonly framed. In particular in the proposed guide, adaptive management is framed in the narrow confines of what is referred to as a "'predict-mitigate-implement-monitor-adapt' model." that "adjusts actions to foster desired outcomes and reduce undesired ones." Nowhere to be found is the 'surprise, uncertainty, novelty and ignorance' side of the adaptive management endeavor. This is a serious, perhaps fatal omission in the guide.
To gain a better perspective on the two-part harmony of managing both the expected and the unexpected, take a look at, e.g. Karl E. Weick and Kathleen M. Sutcliffe, Managing the Unexpected.., Lance H. Gunderson and C.S. Holling (eds.), Panarchy: Understanding Transformations in Human and Natural Systems, and T.F.H. Allen, Joseph A. Tainter, and Thomas W. Hoekstra, Supply-side Sustainability.
Will EMS prove to be the saving-grace for NEPA compliance? Or will EMS prove up on an anonymous USFS employee's (who came with EMS experience from the private sector) remark that: "EMS is an expensive excuse to pay consultants to tell us what we already know." The jury is out.