Forest Policy - Forest Practice

Forestry Source on "Sagebrush Rebellion Renewed" Dave

The April issue of The Forestry Source, leads off with "The Sagebrush Rebellion Renewed: Bills Aim to Create Trusts to Manage Federal Timber," by Steve Wilent, Forestry Source editor. The article begins with what I perceive to be a very narrow view of the origins of the 1980s Sagebrush Rebellion, blaming it all on "environmentalists". The article ends with what I perceive to be cheerleading for "forest trusts" as a solution to current problems including the impending drying up of "Secure Rural Schools and Community Self-Determination Act" funding. It is an opinion-editorial, so Wilent is entitled to his perspective. But I thought I'd share it with you, since my own framing of this matter is much different. I see the 1980s Sagebrush Rebellion being just one of many from a West that was always angry over public lands. In my frame, fully funding Payments in Lieu of Taxes is a better solution to the rural schools problem. And I find the "forests trusts" idea a non-starter in dealing with America's national forests.

Wilent's article begins:

In his 1993 book, Federal Land, Western Anger R. McGregor Cawley describes the Sagebrush Rebellion as "a protest originating from three interrelated perceptions: first, that environmentalists had succeeded in gaining a dominant position in federal land policy discussions; second that the environmental community's influence had created an underlying bias in favor of preservation over development in federal land management decisions throughout the 1970s; and third, that the only way to counteract the increasingly restrictive character of federal land management decisions was to precipitate an open confrontation."

The first shot in that confrontation was fired in 1979, when the Nevada state legislature passed a bill that sought to transfer control of 40 million acres managed by the US Bureau of Land Management (BLM) – about 79% of Nevada – to the state. …

In February, Utah fired a new salvo when its house of representative passed the Transfer of Public Lands Act….

My own framing, built in part off the Public Land Law Review Commission's "History of Public Land Law Development", here, tracks the Sagebrush Rebellions (several of them, with continued skirmishes in between) back to the fights for statehood in the USA. In my state of Utah the fight was nasty and long-standing. Some Utahan's were mad back then and continue to be mad today, with their anger welling-up periodically. Ron Arnold may have captured the spirit of that 1980s "Rebellion" as well as did the Society of American Foresters (SAF) article, calling it "a temper-tantrum over public lands thrown by a handful of cowboys". That "temper-tantrum" turned into yet-another bandwagon that powerful rural Western politicians could jump onto—which they ultimately parlayed into substantial gains. Here is what Frank J. Popper had to say about these "gains" in “A Timely End of the Sagebrush Rebellion” (pdf), National Affairs 76, Summer 1984.

The Sagebrush Rebellion did not fail—it ended because it achieved many of its goals. The Reagan administration rapidly found clever, politically appealing ways to start to transfer some public lands without having to ask Congress for new legislation. Watt’s Interior Department undertook a “good neighbor policy” that allowed state and local governments to request the department’s “surplus” lands. The initiative was soon broadened to an Asset Management Program whereby all federal agencies could sell their excess land in the West and elsewhere; the eventual sale of 35 million acres–an area the size of Iowa–was expected. Separately, the Forest Service prepared to sell up to 17 million acres. The federal land agencies sped up the transfers to Alaska’s state government and Native Americans authorized by the 1958 Statehood Act, the 1971 Native Claims Settlement Act, and the 1980 National Interest Lands Conservation Act. The BLM experimentally revived homesteading in the Kuskokwim Mountains in central Alaska. Numerous federal-Western state land exchanges were in exploratory stages, and seemed most advanced in Utah. [p. 68]

Another look at the 1980s Sagebrush Rebellion, from "A Brief History of the Anti-conservation Movement" frames the issues as conservatives v. liberals:

At its most basic level the Sagebrush Rebellion was a conservative backlash against the growth of federal power represented by, among other things, such landmark environmental legislation of the late 1960s and '70s as the National Environmental Policy Act (NEPA), the Clean Air Act, the Clean Water Act and the Endangered Species Act. These legislative programs created new roles and concerns for managers of federal land — protection of endangered species, water quality, air quality, etc. This required closer scrutiny of activities on federal lands, including the activities of miners, loggers and ranchers who operated there. Significantly, these businesses usually enjoyed substantial operating subsidies by virtue of longstanding below-market rates for grazing, mineral and timber rights on federal land. This closer scrutiny inevitably led to federally imposed restrictions when mining, grazing and foresting practices damaged the water and air and threatened endangered species. Recognizing that a return to the good old days of less regulation would be good for business, the movement took support and comfort from the 1980 election of Ronald Reagan, one of whose campaign planks was reduction of the size and power of government. Certain Reagan cabinet appointees, most notably James Watt as Secretary of the Interior and Anne Gorsuch as head of the Environmental Protection Agency, were selected in part for their willingness to further the de-regulatory agenda of Reagan and the right wing of the Republican Party. …

The Anti-Conservation Movement further benefitted from the attention it received from industries with something to gain. In particular, big agriculture (the American Farm Bureau Federation, The Cattlemen's Association), the extractive industries (mining, including coal, oil and gas) and timber producers (who thrive on easy access to federal forest lands) saw a reduction of federal regulatory power working to their advantage. This message of the economic benefit of deregulation appealed as well to small businesses. After all, if workplace safety regulations could be reduced or eliminated, the money saved could be plowed back into the business.

During this period anti-regulatory forces sought to define and project an agenda that would be publicly acceptable. Throughout the 1980s the anti-regulatory/anti-environmental sentiment was expressed largely as support for the Reagan Revolution and its promise to deliver the country from the clutches of over-zealous, regulation-happy bureaucrats.

In studying the various Sagebrush Rebellions we would all probably benefit from a good class on the history of the American West. Here is one (pdf, syllabus) from Professor Chris Lewis, from the University of Colorado. Lewis places Cawley's book in a class lecture on "'The Lords of Yesterday' and the Sagebrush Rebellion". The book is well-placed there, since it is evidently written from the perspective of 'the rebels', according to a Great Plains Research book review (pdf). There is nothing wrong with that. One of my favorite books is Howard Zinn's A People's History of the United States, which is unabashedly written from the perspective of those who lost (and/or who were horrible abused) in the struggles to form the United States. Zinn acknowledges his bias, but is quick to note that no "history" is written without bias. But what is wrong with Wilent's piece, in my opinion, is to use the book to suggest that one particular perspective is the only perspective that counts. Still, opinion/editorial pieces often do that. So, I'll just leave it at, "I beg to differ".

Wilent's article goes on to highlight various ongoing problems including the impending falldown in Secure Rural Schools and Community Self Determination Act funding—problems which are clearly still with us. These problems don't necessarily cry out for the solutions that are being proffered in the various bills currently working their way through Congress. But you wouldn't arrive at that particular conclusion from Wilent's article, which concludes by essentially cheerleading attempts to put federal land management into "land trusts." "Cheerleading" is how I see it. What Wilent actually said was this: "Management by a trust dedicated to maintaining revenues to schools and other beneficiaries may offer a solution. …"

Wilent didn't bother to daylight any other "solutions." So cheerleading is where I'll leave it. When dealing with 'trusts' my question is, as has been for a long time, "Land trusts provide a solution to what?" Yes land trusts are a good way to generate revenue if that is all you are interested in. But I thought that the 'public trust doctrine', under which the national forests were carved out and managed, is much broader than 'revenue generation'. And we are not living in 1900, when income taxes and other revenue generation means now available to the federal government were not established.

In the middle of Wilent's article, John Freemuth is quoted on both the complexity of federal lands management and his desire to reconvene a Public Lands Law Review Commission. I support Freemuth's desire. On the other hand, I'm pretty sure that just about no one who is ranting and raving in this (or the last) Sagebrush Rebellion has ever read the last Public Lands Law Review Commission Report. Why should we expect a new one to add value to this debacle? Still, I would like to see a new one, if only to force the Administration and the Congress to delve deeper into the issues (and the history) surrounding our "Angry West". But I'm not sure that a re-reading of the original Public Lands Law Review Commission Report wouldn't suffice to dispel myths surrounding each seemingly-novel episode when the American West, particularly the "rural West" explodes anew in yet-another "temper-tantrum." I guess we all get to pick our frames, and our scapegoats.

Related NCFP Posts:
Free America From Her Public Lands?
Utah's Sagebrush Rebellion Awakens
The Frame Game
The Blame Game

Cross-posted at A New Century of Forest Planning

When Policy Trends Toward Bullshit Dave

Much government policy and some law resides in a realm philosopher Henry Frankfurt labels "bullshit"—in earlier times called humbug or balderdash. Much US Forest Service policy falls here too: regulation, manual and handbook directives. At least that's the way I've seen it for a very long time.

Early in my Forest Service career, a colleague and I were conscripted into a week-long Forest Service Manual/Handbook writing exercise, specifically focused on the Forest Planning sections. A quick survey of the materials led us to conclude that our week had to be spent making sure that there was nothing in the FS planning manual that could possibly harm anyone. We knew that we could not 'fix' the manual, so we spent our week in a second-best endeavor.

A few years later a FS Planning Director asked a group of us for policy ideas at an economists conference. I suggested a bold move: Throw the Forest Service Manual and Handbook in the Potomac. I made the recommendation in the main because both the FS Planning and Economics Manual/Handbook materials were pretty much bullshit. Note that I immediately added that people should be able to swim out and retrieve portions of the policy manuals they deemed useful, and then upgrade them as necessary to help advise program development, project design and work generally. The point was to decommission the whole mess, and free the agency of both the manuals/handbooks and the mini-bureaucracy that oversaw them. Of course I didn't believe that the FS would act on my suggestion, at least not then. But one can always hope. [Note: I wish there were electronic copies of earlier FS Manual/Handbook materials to point to for historical (hysterical?) purposes. ]

I suggested "tossing" the FS manual and handbook to both Chief Dombeck (via Chris Wood) and Chief Bosworth. Both were somewhat warm to the idea, but nothing happened. I've once again raised that issue with FS top brass, suggesting that collaborative adaptive governance can't work if everybody shows up with several yards worth of "holy writ" that must be followed.

Later I called bullshit on the Forest Service's initiative to tie planning (and pretty much all else) to environmental management systems—chronicled in my Forest Environmental Management Systems blog (Oct. 2005 – April 2007). That particular mess went away, with EMS rightfully retreating to a minor place (facilities and fleet management) in Forest Service administration. I'm sure my blogging did not influence the outcome. But at least I left a record, so that we might learn from the mistake.

Common wisdom says, "When you find yourself in a hole, stop digging." Let's pause a moment and explore special characteristics of what we are digging through.

What is 'bullshit'?
Before anyone gets too upset with my BS terminology, maybe we ought to delve into Frankfurt's little book On Bullshit—an essay really, which you can read online. Frankfurt's little book adorned a special shelf in my FS office bookshelves, accompanied by Joseph Heller's Catch-22 and Something Happened, Lewis Carroll's Alice in Wonderland, and some other classics. Frankfurt begins On Bullshit with,

One of the most salient features of our culture is that there is so much bullshit. Everyone knows this. Each of us contributes his share. But we tend to take the situation for granted. … In consequence we have no clear understanding of what bullshit is, why there is so much of it, or what functions it serves.

Frankfurt attempts to tease out a 'theory of bullshit' for us. I'll not bore you with all Frankfurt's building blocks, but I at least we need to know that he distinguishes bullshit from lying, in part as follows:

The essence of bullshit is not that it is false, but that it is phony. … The bullshitter is faking things. But this does not mean that he necessarily gets them wrong. [But it does mean that they don't quite ring true.]

How much FS policy falls in this realm? Politicians tend to create bullshit to pander—to curry favor. Bureaucrats create bullshit for very different reasons. Frankfurt says,

Bullshit is unavoidable when circumstances require someone to talk without knowing what he is talking about. … [This is] common in public life, where people are frequently impelled—whether by their own propensities or by the demands of others—to speak extensively about matters of which they are to some degree ignorant.

Think about how Forest Service teams are put together, often without asking for volunteers and without too much regard for seeking out the most knowledgeable team members. It always seemed to my jaundiced eye that team members were selected to construct manual and handbook materials in the main because they were 'good soldiers', and particularly not 'radicals' who might rock the boat too much.

Why I've tried to stop the BS
I know that it is pretty much a fool's quest, but I've always tried to get the Forest Service bureaucracy to 'swing for the fences' and pull itself up from the morass of its own policy, manuals and handbooks. But, like many American institutions the Forest Service will not take a hard look at itself. Maybe it's due of fear. Maybe it is due to ennui—stuckness, lack of hope. Maybe it is something else. Maybe it is just because they don't realize that bullshit might be outright harmful, even toxic to the organization.

This proves especially true when bullshit policy is brought into court, "for the record," when people challenge federal actions, which must be based on federal policy. At the point federal policy bullshit makes an appearance in court, federal judges are not pleased to have to wade through it—so we too often get strongly-worded federal decisions against the Forest Service.

In any case, meaningful links between process and outcome in the Forest Service often simply don't exist in any practical sense. They are too encumbered by bullshit. For example, we often hear that if the Forest Service can't fix the Forest Planning process (for example) in 'rulemaking' then we'll fix it in forest plan implementation—as if that can happen. Isn't such talk just administrative governance denial?

I keep the pressure on, hoping against fate that a miracle will occur, as it did with General Electric not too long ago, just before GE was to fall in to a bureaucratic quagmire from which it would not, could not escape. Make no mistake, the GE rebirth was brutal. But the company is arguably much better today than before—now that fierce conversations are standard practice innovation is center stage, and people are required to challenge each other to do better, and to be better. Maybe someday the same will happen in a government agency, even perchance to the Forest Service. But I'm not holding my breath.

Illegal 'Adventure Pass': What were they thinking? Dave

The Ninth Circuit Court of Appeals recently overturned a lower court's ruling, declaring that the Forest Service's Adventure Pass violated the Recreation Enhancement Act (pdf). What I wonder is how the Forest Service thought that the Adventure Pass could pass a 'red face test' both in public and in the courts? Moreover, how did their USDA Office of General Counsel legal advisors feel that they could pass that red face test?

Is this yet another example of the Forest Service pushing forward with an initiative without much regard for the law, with both 'professional arrogance' and 'budget protection/maximization' motivations as backdrop? Finally, where does the Forest Service go from here?

In my book, given the austerity that the American people now face, and will face more squarely in the future, I think it time to talk seriously about what ought the Forest Service to manage for and at what cost, both in terms of direct cost to the US taxpayer and in terms of environmental costs. For me there is plenty of programs to prune, both within what the agency calls recreation and elsewhere. I believe it past time to take a careful look at Forest Service cash flows, sources and uses. Let's then try to figure out what more and what less to do, and what to do differently.

A Flashback
Fee Demo and Adventure pass discussions are not new to the Forest Service. The Forest Service had a chance to respond to critics of both way back in 1999-2000 on Eco-Watch [Note this link provides a flat file readout of a forum that was largely devoted to fee demo discussion/criticism]. The Forest Service chose to be silent, just as they did with the recent forest planning rulemaking process. See, e.g my Earth to Forest Planning: Get a Blog. In 1999 I could understand their silence, their reluctance to engage in social media discussion. Social Media was brand new and the Forest Service was toying with it.I no longer have patience with their reluctance to engage.

Evidently the Congress did listen, passing the Recreation Enhancement Act in 2004,to replace the Recreation Fee Demo Program of 1994. But the Forest Service somehow thought that it could evade the clear language of the latter Act.

My question is broader than to allege that the Forest Service routinely ignores the Congress and the Courts. My question is, When will the Forest Service engage in public discourse, in public deliberation? And I'm not taking about the many, mostly facilitated, highly spun so-called dialogue efforts that the Forest Service too often employs. [Note: I am a champion of dialogue, when used for deep inquiry. But I'm afraid that the Forest Service is now in the process of turning "dialogue" into another "inform and involve" spin mechanism.]

Footnote on Framing, Blaming
I threw this post together in response to Sharon Freidman's earlier post over at New Century of Forest Planning on this subject. Both posts are examples of what I call The Frame Game and The Blame Game. Sharon's post frames this as "a problem if the FS can’t charge fees and doesn’t get funding from Congress." Whether by oversight or by design, the Forest Service is framed as the victim and the Congress or those who block general fees/contributions are framed as villains. My post frames the issue as one where the taxpayer and/or the public interest are victims and the Forest Service is villain. Neither frame adequately addresses the problem at hand.

In both cases—in every case—we ought not to forget that these twin forces, framing and blaming, are almost always at work. And we must never forget that there are plenty of victims (real and imagined) and plenty of us who can rightfully be viewed as villains from time to time. What remains a challenge and an opportunity is to be able to work together toward betterment of the public interest as best we can when we mostly see only our own shadows playing in reflection off the walls of caves that keep our thoughts narrowly confined.

Parsing Economic Sustainability: The 2012 NFMA Rule Dave

To make sense of economic sustainability we have to delve into sustainability. Then we can see what sense is (or is not) made of 'economic sustainability' in the 2012 proposed NFMA rule (pdf).

Sustainability
At root, what we call sustainability (Wikipedia link) is a vision quest—a movement to better align human action with Nature and natural systems evolution. In Wikipedia, sustainability is said to have ecological, social and economic dimensions. All dimensions are interconnected. Sustainability found its way into the 2000 NFMA rule, and has been there since. But the framing has been tweaked at bit since. Let's take a close look at "economic sustainability" as framed in the newly proposed NFMA rule, in the context of the overall quest for sustainability.

Social and Economic Sustainability

§ 219.8 SUSTAINABILITY. ... (b) Social and economic sustainability. The plan must include plan components, including standards or guidelines, to guide the plan area’s contribution to social and economic sustainability, taking into account: (1) Social, cultural, and economic conditions relevant to the area influenced by the plan; (2) Sustainable recreation; including recreation settings, opportunities, and access; and scenic character; (3) Multiple uses that contribute to local, regional, and national economies in a sustainable manner; (4) Ecosystem services; (5) Cultural and historic resources and uses; and (6) Opportunities to connect people with nature.

Sustainability Defined

§ 219.19 DEFINITIONS. ... Sustainability. The capability to meet the needs of the present generation without compromising the ability of future generations to meet their needs. For purposes of this part, “ecological sustainability” refers to the capability of ecosystems to maintain ecological integrity; “economic sustainability” refers to the capability of society to produce and consume or otherwise benefit from goods and services including contributions to jobs and market and nonmarket benefits; and “social sustainability” refers to the capability of society to support the network of relationships, traditions, culture, and activities that connect people to the land and to one another, and support vibrant communities. {emphasis added}

I don't quibble with the framing on social sustainability, but the language on economic sustainability seems tortured to me. Worse perchance is the fact that what is called 'economic sustainability' is not linked to 'ecological sustainability', not even to 'social sustainability'. How bizarre is this 'economic sustainability' frame? As I read the 2012 rule, economic actors can do whatever they want with an umbrella of 'economic sustainability' overhead. Is this by intent? By oversight? Or am I off base in my allegation?

I looked to the 2000 NFMA Rule (pdf) to see if they had allowed such discretion. Nope. Not that I agreed with that rule either, but at least that particular mistake was avoided. I went to the 2005 rule (pdf) to see if the economic sustainability language was separate from ecological sustainability. Yep. This is where it began. It was framed as if economic sustainability and ecological sustainability were competitors instead of compliments. The 2008 rule (pdf) is similar to the 2005 rule in this regard. And so is the proposed 2012 rule.

The Wikipedia page on Sustainability, by contrast does not allow for such separation of ecological, social and economics in their rendition of sustainability. In Wikipedia, sustainability is said to have ecological, social and economic 'dimensions'. All is interconnected.

Perhaps I'm nitpicking. But I believe that something is lost when 'dimensions' or aspects of sustainability are framed separately as if they are independent, without interconnections to affirm wholeness. Bridging the gap from philosophy to actionable procedure proves difficult when dealing with something as novel, important, and threatening to the status quo as sustainability. I get that. But the Forest Service has had a few years to mull over this misstep. How was it missed? Or was the separation set up on purpose? Anyone care to clear the air on this?

Personal Addendum (for sustainability nuts)
I began promoting sustainability in the early 1990s (see, Eco-Watch Archives, particularly 1991 , 1994, 1995). In 1994 Zane Cornett and I even proffered a definition for sustainability in the context of what we then called ecosystem management. Our definition, like most others, focuses both on the need for humans to relate better to the environment, and for humans to act in less destructive ways toward the environment. Like most others we tied ALL together, following John Muir: "When we try to pick out anything by itself, we find it hitched to everything else in the Universe." Here is our rendition:

Sustainability is a relationship between dynamic cultural, economic, and biophysical systems associated across the landscape such that quality of life for humans continues -- both for individuals and cultures. It is a relationship in which the effects of human activities do not threaten the integrity of the self-organizing systems that provide the context for these activities. To further clarify this definition of sustainability, we need a complementary definition for integrity. The philosophy of ecosystem management integrates biophysical, cultural, and economic systems into the single concept of "ecosystems". An ecosystem has integrity if it retains its complexity and capacity for self-organization (arguably its health) and sufficient diversity, within its structures and functions, to maintain the ecosystem's self-organizing complexity through time. The definition for integrity is applicable to each of the economic, cultural, and biophysical subsystems, as well as to the integrated ecosystem.

At the end of the 1998, when I penned my First Epistle to the Clinton Era NFMA Committee of Scientists, I anchored the whole of my commentary around sustainability and the contextual, multi-scale/scope nature of public lands management. To approach sustainability, public lands management must interrelate various ecological and social systems at various scale across multiple ownerships. Anything short of this is to miss important linkages needed to inform prudent decision-making in setting policy, in program development, and project design. At least that was how I saw it then. I'm still preaching that gospel today, e.g my Adaptive Governance Roadmap for a NFMA rule rewrite.

Opportunity (and Context) Lost: The 2012 NFMA Planning Rule Dave

The long-awaited NFMA "proposed planning rule" is out. It looks pretty much like the Draft rule to me. I have longed to see the Forest Service embrace adaptive management for public lands, or adaptive governance, as I argued here last year in Fixing the Rule: An Adaptive Governance Roadmap. But much like in the Draft, the preferred planning rule (Alternative A, pdf) in the Final Rule workup is a far cry from adaptive management.

Although draped in ecosystems rhetoric, when looked at from the real-world perspective of interrelated natural and social systems the 2012 Rule leaves much to be desired as adaptive management or adaptive governance. Here are four key points: First, the three levels of decision making—national strategic, forest administrative unit, project or activity—belie underlying realities of power and decision-making in the Forest Service. In short it stretches the imagination that important Forest Service decisions regarding ecosystems are to be made at the "forest administrative unit", except for maybe the Tongass, The National Forests of Texas, and so on.

Second, desired (future) conditions are ineffectually dealt with at the forest or project scale, and often cry-out for contexts that don't fit well under the category "national strategic." Admittedly, the Forest Service has left itself an "out" re: broader scale assessments, but it is doubtful that many such efforts will yield substantive results.

Third, "standards" are better structured/set in contexts far from forest-level planning. I'll be watching, but I can't right now think of any meaningful standards that ought to be made in the development or revision of a forest plan.

Fourth, Why is the Forest Service hell-bent on replacing the federally accepted "appeals" process with an "objections process"? Does the Forest Service really believe that this is a change for the better?

My beef is not with many ecological/social concepts embedded in the 2012 rule: sustainability, species diversity, ecological integrity, etc. I have championed these for many years. But I have argued for years that they are better structured in an adaptive governance frame, rather than the rigid straitjacket of this rule. Is it time for Congressional oversight hearings on RPA/NFMA? Has this particular law outlived its usefulness? After all, the law was put in place in an era when production planning was still in vogue, before The Decline and Fall of Rational Planning. The law did not envision an era of collaborative stewardship of public lands.

Let's look at each of the four identified problems in more detail:

Three levels of decision-making
In the old days when forest were viewed in large part through the eyes of production planners, it made sense to empower forest unit managers with setting up goals and objectives for individual national forests (as individual production factories). Projects and activities flowed from this goal setting: timber sales and other output production goals, for example. National or strategic goal and policy setting sat at the top and was informed by lower-level decision-making, although political pressures were arguably the main driving force for production goals like "getting the cut out." This reasoning made its way into the RPA/NFMA and set the stage for the 1982 NFMA rule that still governs (despite repeated attempts to update it) the administration of the national forest system. But the days of viewing forests as production factories has ended.

Desired Conditions
Absent appropriate context, how is a forest supervisor to declare "desired conditions?" In my view, these appropriately derive from broader-scale assessments and policy considerations. Within such, a forest supervisor might make a periodic call as to forest or sub-forest niche(s). But to expect such without appropriate context-setting is asking the impossible. And it escapes me how this rule will promote effective context-setting.

Standards
Someone will have to show me just where forest level standards make any sense at all. I have argued before that they do not, and that standards are rightfully set and revised situationally as needed, not according to some time-clock for forest plan revision.

Objections Process to replace Appeals Process
I have never understood the need for this. It is at best a minor variation on a theme that could have as easily been made to work under the more-familiar appeals process. At worst, it proves a means to dodge public deliberation responsibility—to deny collaborators an opportunity to seek redress for surprise changes in proposed action as it becomes "federal action." The only redress then becomes court challenge. It seems to me that in an attempt to streamline the process, the forest service only made things worse.

In Sum
Since the Forest Service has chosen not to take the adaptive management/governance path, why not revisit the RPA/NFMA law with an eye toward collaborative stewardship? I new or revised law might help the agency see how interrelated ecological and social systems require the interrelated efforts—at context-dependent scales—of both forest service line, staff, and research as well as collaborators from other agencies as well as interest groups and others who hold a stake in outcomes.

If the Forest Service had embraced adaptive governance in this rule, we would see broad-scale assessments well up at appropriate scale and scope, accompanied by broad-scale policy, plans, or programs meant to address problems identified in the assessments. Monitoring regimes would accompany both. All would be structured at scope and scale appropriate to resolve issues and problems identified. Maybe we'll see such anyway, somehow welling up for so-called forest plan implementation and other policy. Or maybe we'll see endless, mindless, context-blind rituals at the forest scale: pretend assessment, pretend planning, pretend monitoring—forever missing opportunities for adaptive management, for adaptive governance.

Related: Fixing the Rule: An Adaptive Governance Roadmap

My Wars Against Economic Fundamentalism Dave

I spent most of my working life in the US Forest Service, battling fundamentalism. Most of the battles dealt with economics. My first job was to coordinate use of a linear programming model (FORPLAN) in the development of forest plans. The model may (or may not) have been useful in projecting overall timber sales volumes from big-timber forests, but to have used it as an overall planning model was a mistake. Forests are not factories. Multiple uses for timber, recreation, wildlife, minerals and oil and gas, livestock grazing (and so on) must be carefully balanced against preservation and conservation efforts in the dynamic self-organizing systems that we call Nature—forest and grasslands in particular. That balancing act is not the stuff of simple, formulaic problem solving.

I remember one day in 1979, before I joined the Forest Service, having lunch with FORPLAN developer K. Norman (Norm) Johnson when a memo came down from the Forest Service Washington Office declaring FORPLAN to be the primary analysis tool for forest planning. Norm said, "My God, we've just lost the war." No truer prophecy was ever uttered. But that was just the beginning of my nightmares with what I call economic fundamentalism. The problem extended beyond the FORPLAN follies, into project and program cost-benefit analysis generally. When passion for this type fundamentalism began to wane, a new threat appeared in the form of free-market fundamentalism. That latter threat is still very real, while the two former threats have faded into memory.

The FORPLAN Fiasco
During the early years of US Forest Service "forest planning" (1979-1985, generally) there was a big problem with what we then called "analytical determinism." The problem, simply stated entails placing too much faith in narrowly framed analysis, with too little synthesis, ignoring broader contextual relevance. It is a problem that plagued the Forest Service practice of Operations Research, narrowly focused on the linear programming model FORPLAN (Forest Planning). No matter how hard some of us tried to get beyond mindless application of the FORPLAN model — set up with a maximize "present net value" objective function — the message never took hold. In retrospect, the whole agenda was wrong-headed, as Oregon State University Dean of Forestry John Beuter and I finally tried to show in a Critique of Forest Planning by contrasting FORPLAN with a model we called MARVIN. [See: Beuter, J.H. and Iverson, D.C. (1987): FORPLAN: an economic perspective. In: T.W. Hoekstra/Dyer A.A./LeMaster D.C. (Eds.) "FORPLAN: an evaluation of a forest planning tool," U.S. Forest Service General Technical Report IRM-140, pp. 87-95] Marvin was not a real model, in particular not an algorithmic or formulaic model, but rather the name of a wise fellow who used to manage the Oregon State University school forests. No model was ever going to replace Marvin. Finally, the Forest Service abandoned FORPLAN in favor of simulation models projecting forest ecosystem trajectories. FORPLAN died with a whimper, with no death announced. But by then I had moved on to other wars against fundamentalists.

Rational-Planning Economics
In about 1983 I took a step upward (so I thought) in the Forest Service, moving from Regional Operations Research Analyst to Regional Economist for the Intermountain Region. I was hoping for higher standards than were common among the Operations Research crowd. Instead, I found the broader economics practice at minimum every bit as backward. During that era, the Forest Service Manual and Handbook championed an obsolete branch of economic thinking called Neoclassical/Rational Planning (See Alan Randall's classic article on resource economics schools of thought, 1985). Interestingly, Alan Randall had already declared "economic rational planning" dead just about the time I arrived on the scene. I spent a couple of years trying to get my Forest Service economic colleagues to recognize the death, or a least to engage in dialogue about various schools of economic thought—and what each school believed relative to other schools. But it was not to be. Nobody wanted to hear that message, neither to engage in that conversation. Instead they just wanted practice their economic priestcraft, narrowly framed around so-called "efficiency analysis"—concocting Present Net Value indices, alongside "economic impact assessments," trying to associate jobs and income with forest-related programs. My major "beef" was with the "efficiency analysis." I left equally vexing problems with "impact assessment" to my colleague Hank Robison. Since I could not practice what the Forest Service Manual and Handbook mandated, I set out to develop an alternative practice. I initially set out my "advice" in a small publication that I handed to people whenever/wherever I felt the need. I finally framed my advice (Economic Advice for Forest Managers) as part of a three-part series that I aired on Eco-Watch,1995.

But long before then I began research into who else was in the battle against government rational planning economics. It turned out that many were (and had been for a long time) waging a similar war in broader government settings. I compiled their findings and reconfirmed my view that I would not help people jinn-up formulaic, cost-benefit analysis numbers. I also advocated against the practice: Cost-Benefit Analysis: Wonder Tool or Mirage?

Leaving stuff around on the internet became my common practice, since I'd grown weary of trying to publish in so-called "refereed journals"—each associated with its own narrowly framed version of economics. Of course, none of it would make a dent in economic practice in the Forest Service, since FS Manual/Handbook materials were considered gospel. I often referred to it as the Gospel According to Marx, not Karl but rather Groucho. Finally though, just before my retirement in 2007, we whittled the Forest Service Economics Manual/Handbook down to two pages, that said in essence, go forth and practice economics according to the ideas/philosophies/methods of whatever school of economic thought a practitioner aligned themselves with. (Assuming that the court of public opinion could sort out economic wheat from chaff). I wonder what has happened since? [Note: In a world of my design, I would have just banished the Economics Manual and Handbook, right alongside almost all (or all) of the rest of Forest Service Manuals and Handbooks. But that was not to be]. This saga doesn't end here, there was yet-another fundamentalism to deal with, the fundamentalism of right-wing free-market fundamentalists.

Free Market Fundamentalism
About the time my rational planning wars were winding down, the Republican "right" gained much power in the United States and around the world (late 1990s – 2008). Part of their pitch since at least the time of Ronald Reagan was that markets will free us, government with its red-tape will bury us. In short: Markets Rock! Government Sucks! The agenda, according to spokesperson Grover Norquist was to "Shrink Government down to the size that we can drown it in a bathtub." These some call free-market fundamentalists, or market fundamentalists, some call them theoclassical economists. In the mid-1990s, Dick Behan called them Economic Taliban.

Free-market fundamentalists believe that individuals are supremely qualified to make all value decisions — or at least almost all — and that allowing government to interfere is pretty much a slippery slope to socialism. They do allow for voluntary collaboration of individuals—as long as it is done outside the purview of "government." They elevate "the market" to the end-all-be-all for providing for social benefits (allowing minor space for faith-based and other non-government institutions), and denigrate government wherever possible. To earn the title free-market fundamentalists, practitioners must subscribe to some form of market worship.

Ed Cone sums up the idea of "market worship", talking about the 2007-2008 financial implosion:

[T]he latest iteration of the old boom-and-bust story has reached the part where a few people get led away in handcuffs, while the legal crooks on Wall Street slink into the background until the next promotional cycle begins. The plot is timeless even as the details change with the decades.

This time it was supposed to be different. This was the millennium of the market. That may yet prove true in some ways, as the market economy is not about to join communism on history's ash heap. But things look depressingly familiar here in the era of capitalism triumphant. America's near-religious faith in the magic of the market has been revealed as idol worship.

The truth is that markets and corporations are not good or evil. They are machines, often very powerful and useful machines, but no matter how well you build them, they are run by human beings, and they are thus subject to the frailties of their designers, owners and operators. Only a think tank economist could be surprised to discover that business people are venal more or less in proportion to the general population. Certainly this is not news to anyone who has ever spent time in close proximity to an actual business.

Market worship goes way beyond the belief that private property and open economies can do the most good for the most people, or the assumption that there is a moral quality to economic freedom. Even the no-more-business-cycle claptrap of the Internet bubble was just an offshoot of the ideological view of markets that took root in this country during the '80s, flourished in the '90s and was last seen buried beneath a pile of worthless WorldCom shares.

The greatest impact of this market cult has not been on the economy, which is, after all, treading a beaten path, but on politics. A corollary of market perfection has to be the undesirability of nonmarket forces, especially in the form of government. Whatever else was driving the anti-government fervor of the late 20th century, the certainty that markets always knew best was part of the equation.

Some have argued that Free-Market Fundamentalism died sometime in 2007-2008 with the implosion of world financial markets. But that tragic event more likely emboldened free market fundamentalists in their quest to return the world to what they perceived as the wonderworld of yesteryear, with small shopkeepers and other independent entrepreneurs—as if that could happen in a world ever-more globalized—ever-more dominated by large global corporations.

I believe that free market fundamentalists helped lead us to that 2007-2008 day of financial reckoning, postponed at minimum by bad decisions by the US Federal Reserve—led by a supposedly reformed free market fundamentalist, Alan Greenspan. Many of us thought that the financial market bubbles would burst in the late 1990s, but even with the dot-com bubble burst, the markets (with the help of the government) were just catching a second breath. And no, I don't let other government players off the hook either, neither Wall Street's self-proclaimed "titans of finance," nor the so-called independent ratings agencies. There is plenty of blame to go around, but free market fundamentalists get their fair share of this blame. The battle against free-market fundamentalists goes on. I do my small part.

Free-market Environmentalism
A curious branch of free market fundamentalism attached itself to public lands and the environment. It was/is called "free-market environmentalism."This group too are fundamentalists: too narrow a perspective, too much emphasis on exorcising devils they believe they know, while allowing devils they don't know to gain power.

Free-market environmentalists, like their broader libertarian fellows seem to cluster around a narrow "Austrian School" or "Classic Liberalism" view of economics.

Practitioners tend to demonize the role of the state, and champion the workings of the market, based on deeply help principles necessitating, then elevating to near divine stature the idea of private property ownership. They leave little room for public ownership or control—mostly just the military. The Cato Institute, a hotbed of Austrian economic thought and "dedicated to the principles of individual liberty, limited government, free markets and peace"—sounds good so far—favors abolishment of these branches of the US Government (partial list): Department of Education, Department of Energy, Department of Agriculture, Department of Interior, Department of Transportation.

As for the public lands, they want the government to disappear. Specifically they advocate for either privatization of public lands, else some kind of fiduciary trust where money is a main driver. See, Chapter 23 of the Cato Handbook for Policymakers, 2009 (pdf). Or for a shorter version, see here. And it's not just Cato. The whole crowd of self-proclaimed free-market environmentalists have a similar agenda.

Given Cato and fellow travelers' "abolishment agenda" I find their public lands ideas disgusting. Wallace Stegner once declared the national parks our nation's best idea. The national forests/grasslands are just a step removed, and often provide a scenic/re-creational "context boost" for the national parks. Call me a public lands fundamentalist if you wish, but I find no meaningful rationale for Cato's stand. I can not stand idly by and let CATO and friends denigrate our public lands institutions based on a flawed reasoning. It is the stuff of a "leap of faith," justified in the main by a predetermination that "Markets rock! Government sucks!" that seems to drive them into their dreamland. Instead I side with Thomas More in his paper "Privatization of Public Lands," which ought to be subtitled "A bad Idea,"

[Note: For more on why some things ought to be dealt with as "public interest" and not left to the vagaries of the market, see in particular Mark Sagoff's The Economy of the Earth, Elizabeth Anderson's Value in Ethics and Economics, and Margaret Jane Radin's Contested Commodities. Note too that not all who are heavily influenced by Austrian economic thought fall into the fundamentalist trap. To fall into that trap, one must, like CATO, declare government to be the enemy.]

I continue a long-standing joust with the free-market environmentalists, which for me began many years ago at Utah State University, and will not end soon. I fully expect them to once-again serve up the public lands for privatization (in whole or in part) as the Congress begins to grapple with US national debt that has for too long been ignored. If/when that prospect becomes reality I'll be back on the battleground. In the meantime I'll continue my studies in heterodox economics.

Heterodox Economics
As for me, I believe in economic heterodoxy. Like Stephen Jay Gould I view economics as a history of technology and development, not as some formulaic quest to tame wicked social problems via mathematical economics. I believe we can learn from various schools of economic thought, as long as we remember that much of our study is to "avoid being deceived by economists" as Joan Robison once put it. I've learned much from various schools of economic thought including Austrians, Marxists, Keynesians and Post-Keynesians, practitioners of Ecological Economics, Institutionalists (including Evolutionary Economics), Behavioralists, Complexity Theory economics, from Information Economics. I base my own practice on a belief in separation of powers. Markets AND governments are both beneficial and necessary, but both also tend to abuse power. I believe that a natural tendency (in our age) is for business/industrial combinations to get big and powerful and corrupt. So too with government. The best we can do is to be ever mindful of power and its tendency toward corruption. We can not abolish either government or markets by administrative or legislative fiat. On the other hand we can work toward ever-better checks and balances on abuse of power wherever it arises.

Twenty Years of Forest Blogging Dave

It was 1989 and the "timber wars" were raging. Having failed to gain voice on any important issues in the Forest Service via traditional channels, a few of us joined with Jeff Debonis to form a non-profit called the Association of Forest Service Employees for Environmental Ethics (AFSEEE, later FSEEE). We adopted a three-part mission: to speak up as concerned citizens, to organize, and to protect whistleblowers. Not long thereafter, I began to blog as a Forest Service employee on government time. Not a blog, really, but an email list, that I later named Eco-Watch. I simply passed along forest policy-relevant materials to a rather large email list. By 1992 I began to compile a feedback list of comments and "comments on comments," that I passed along via my mailing list. The list caused quite a stir in the Forest Service Intermountain Region leadership team, and maybe "higher up."

Eco-Watch and I somehow managed to be a topic of conversation at many a Regional Leadership Team meeting. Interestingly, the "leadership team" was pretty much split, with a lot of the members supporting my attempt to open up communication via email. Deputy Regional Forester Bob Joslin once told me, paraphrasing: "If [the Regional Forester] mentions your stuff once more time, the next message is going to come from my inbox. … I don't agree with all you write, but do believe that we [the Forest Service] need to discuss these things."

I remember numerous tense meetings with my boss, the Regional Planning Director, about feathers that were being ruffled, not only by my emails, but also by my being on the board of that nonprofit organization FSEEE. It got worse once I became president of FSEEE's board. I once told our Planning Director that if the Regional Forester had a problem with my being a part of FSEEE, I would gladly have lunch with him to discuss it—but that I did not talk about my FSEEE role at work since it was an exercise in free speech as a citizen, not as a public employee. As FSEEE board members and Forest Service employees we knew we were walking a fine line with the FSEEE stuff. Another time I was asked to talk to our Director of Information Systems about the email list. So I did, and he told me that the Forest Service email system had been set up for multi-way communications (after a proposal for top-down communications had been batted about, then batted down by either the Department of Ag or the Forest Service). He also told me he was not going to be a "DG cop" [the DG was then the Forest Service's computing platform]. He also wanted to know more about FSEEE. He was curious about our daring venture.

Eco-Watch
By 1992, I began to send out follow-up comments and "comments on comments" to my email lists. Eco-Watch was born. The rough and rocky road that connected me to both the Forest Service and FSEEE was paved, in part by my Listserv. And finally near the end of the FSEEE-friendly Clinton Administration, I got approval to take Eco-Watch to the next phase, making it into a Forest Service-blessed Policy Dialogues Forum, via Hypernews. With Mark Garland's help we put all my email listings on the internet, along with emergent policy dialogue threads. The tracks of this era still reside on the Forest Service servers, here, with numerous broken hyperlinks. Sadly, all the policy dialogue threads are lost, although I did manage to salvage most of them and have them on my own Forest Policy site as Eco-Watch [retaining much of the character of the old site, but linking to "discussion threads" of the past, rather than to ongoing discussion forums]. During this same era we tried to get Mark Garland's Forest Service in the News to be a partnership between FSEEE and the Forest Service, even a three-way partnership adding in a timber industry group. That discussion was a non-starter. Mark continues to this day with his Forest Service in the News, hosted by FSEEE.

Eco-Watch Policy Dialogues Forum ran from 1999 until its demise in the Spring of 2005—right in the middle of the Bush/Cheney Administration War Games /Homeland Security—when the chant was "If you are not with us. You are against us."

Why did the Forest Service drop its love affair with Hypernews? I don't know, but suspect it had to do more with Homeland Security paranoia, than with FS internal politics. But maybe it was simple paranoia over Internet viruses, etc. All I know is that one day the forums were dead, and so too with all other forums that were being hosted on Forest Service Hypernews software. My inquiries into the matter led me to an odd dead end—something like, "It was just too hard to maintain the software." I still believe that similar software powers many internet forums today, and maybe even Wiki sites. But I let it go. After all, we were at war in the wake of the Sept. 2001 World Trade Center bombings.

Forest Policy - Forest Practice
Early in 2005 I threw together a real blog, Forest Policy–Forest Practice, subtitled 'A communities of practice weblog.' My goal was to emulate what others had done by then, in other fields far from natural resources—to engage practitioners in policy/practice dialogues. I reached out to a few old friends and let it fly, this time on my own dime and on servers that couldn't be shut down by FS bureaucrats, whether by design or by neglect.

We started out OK, but never got it up to steam—just couldn't muster the participation needed to make it a strong platform for "voice." Maybe it was me, being my usual flaky self, not getting anything "real" going. But I think not. I think that it was just too new, and some of the "academic" friends I courted were too busy with traditional meetings, publications, trade associations, etc. to be bothered with blogs. Oddly, there are still very few, maybe only one, active discussion blog on forest policy.

A few of us did kept the discussion alive for several years, but it just wasn't the "in your face" immediate gratification that the email list or the Hypernews forums had been. I tried a few other things, like a blog tied to Adaptive Forest Management, a theme I continue talking about today. On another blog I chronicled the rise and fall of what I like to call "Planning cast up as Environmental Management Systems" or "EMS cast up as Planning." Among other things I unveiled in my Forest Environmental Systems blog was a clever little powerpoint about why bureaucrats don't want to "mess with anything". Policy wonk Ron Brunner told me that it was the best example ever of why bureaucracies can't change. The EMS/Planning love affair was short-lived, and the blog only ran for about a year.

A New Century of Forest Planning
Today a few of us are blogging forestry and forest policy, under the guise of "forest planning" here. It will prove interesting to see if/when the Forest Service joins other agencies that allow/encourage many blogs and wikis, by individuals or groups. But it doesn't seem likely just now.

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I continue to cross-walk to my earlier blogs, but realize that they are pretty much just a place where I store stuff. I also continue to blog matters at the confluence of complex systems, wicked problems, politics, finance, economics, and ecology at Ecology and Economics: a cross-disciplinary conversation and Economic Dreams-Economic Nightmares. Mostly I just dabble at the edges, and continue to hope that more folks will jump in to re-frame politics, science, and public administration in the US and around the world.

From Forest Planning to Adaptive Governance Dave

"If planning is everything, maybe it's nothing." Aaron Wildavsky

Let's face it, the "forest land and resource management plan" is an anachronism—an artifact of a bygone era. That era was in its heyday when the Office of Management and Budget (OMB) reigned supreme after President Richard M. Nixon consolidated rule-making and other powers in the OMB via executive order in 1970. Economics-based, comprehensive rational planning was the rage. It is no surprise that The Renewable Resources Planning Act was passed in 1974, just after Nixon consolidated power under the banner of rationally planned and carefully audited governmental process. Twenty years later Henry Mintzberg penned The Rise and Fall of Strategic Planning (1994). Mintzerberg's classic pretty much laid a tombstone atop rational planning exercises. Or at least it should have.

The Forest Planning Era
Following passage of the National Forest Management Act of 1976 as an amendment to the Renewable Resources Planning Act of 1974, it was thought that forest program management decisions could be adequately fit into a forest plan "decision container"—that somehow each forest could develop a forest-wide plan that would integrate programs now and into the future in a such a way as to allow disclosure of environmental consequences that might flow from said decisions. Project level National Environmental Policy Act (NEPA) disclosure would disappear with proper forest planning and environmental disclosure at the forest level.

Allowance was made for FS administrative region plans, and for a national RPA Program plan. Given the upper two tiers, it was believed that decisions would be integrated vertically, and cumulative effects—according to NEPA standards—could be adequately disclosed.

It was a relatively innocent era, when viewed through the "green-eyeshaded accounting lenses" of OMB over-see-ers. The innocence collapsed relative soon in the forest arena as litigation proved that the three-level administratively-bounded review was not going to pass muster in the courts. Not only were projects not going to be shielded from NEPA review by a forest plan, there was increasing evidence that at least one level of planning/disclosure might be needed between project and forest.

An initial remedy to the seemingly endless process gridlock brought about by too many levels of planning was to eliminate regional plans. I referred to this then as the Texas two-step solution (forests/projects), since at that time the Forest Service's National Planning Director was from Texas. But that was a solution looking for a problem, or better still a "non solution" not looking for anything but an easy way out. The problem between forest and project remained. Another problem was to be found elsewhere, framed larger than forest plans but not fitting into regional plan containers.

Spotted Owls, Roadless, and more
Much time and effort was now spent in the 1970s, 80s, 90s on above-forest policy making, brought about by actors and actions taken either against the Forest Service or from within the Forest Service responding to the Endangered Species Act of 1973. They were, "Spotted Owl Management Plans," "The Roadless Rule," "The Northwest Forest Plan," and more. These decision containers were bounded as regions, not FS administrative regions but geographical regions more appropriately suited to the issues and the actors petitioning for problem resolution. Note that the policy-level decision making was largely about curtailing timbering and roading, but the Forest Service chose to name the efforts after the initiating issues, not the federal actions being considered.

Forest Planning Proves Resilient, if not useful
The forest planning paradigm still captured much attention, but the three-level planning process swirling around the forest plan—projects/mid-scale/forest—was felt by forest planners and the Forest Service generally to be too cumbersome. Something else needed to be done. While the rest of the world was waking up to complex systems, wicked problems, and adaptive management, as was part of the Forest Service via the Northwest Forest Plan, the Forest Service via the NFMA rule was still stuck in the wonderful, if overly complex and somewhat bizarre world of capital P "Planning." And the Forest Service was always trying to force-fit things into forest-level and project-level decision containers. But times were changing by 1990 and at least for a time, the Forest Service seemed to be ready to catch up to the rest of the world.

Adaptive Governance: Emergence in the Clinton Era
Adaptive management seems to be evolving in name to Adaptive Governance, following a path laid down early on by Kai Lee in Compass and Gyroscope: Integrating Science and Politics for the Environment (1993). For a time the Forest Service seemed inclined to follow. [Note: Today, the "adaptive governance" path seems already well-discussed, if not well traveled. That is if my "adaptive governance" Google search is an indication. But my Wikipedia search didn't give me much. Recognizing that the only viable adaptive management for dealing with public lands management has to deal with both Kai Lee's Adaptive management compass and his civic-engagement gyroscope. I'll go ahead and use the term "adaptive governance" hereafter.]

In what we might call Clinton era management, Chief Michael Dombeck sought to bring about a Leopoldian awakening (see, e.g. here, here) to Forest Service thinking. That "awakening," as per Leopold's earlier thinking, was about adaptive governance. But the largely Republican-dominated Forest Service resisted. Chief Dombeck was never accepted by Forest Service managers since he was from the BLM and appointed by an environmentally left-leaning Clinton administration. Things didn't get better under Chief Jack Ward Thomas, himself a huge fan of Leopold. The road from Pinchot to Leopold was not going to be an easy one. Adaptive governance thinking was soon on the chopping block along with pretty much all else from "new forestry" to "new perspectives," etc. following the election of George W. Bush as a new Administration came to Washington.

Adaptive Governance: Bush/Cheney Backlash
The Bush/Cheney public lands legacy can be viewed as a legacy of war—war on the environment and war on anything the previous Clinton Administration had built under the rubric of "ecosystem management" (See generally Bob Keiter's Breaking Faith with Nature: The Bush Administration and Public Land Policy). Under Mark Rey as Undersecretary of Agriculture, the Forest Service moved into its "Healthy Forests Initiative," followed soon thereafter by the "Healthy Forest Restoration Act of 2003." As Bob Keiter notes, the names could be viewed as cynical, as part of a well-orchestrated backlash against Clinton era reforms. To Keiter:

By using the Healthy Forests Initiative to expand the scope of NEPA categorical exclusions and to alter the ESA consultation process, the Forest Service has further enhanced its authority and reduced the potential for judicial review of its decisions, which is also what the [Aquatic Conservation Strategy] and species inventory revisions to the Northwest Forest Plan would have done. Congress has abetted this de-legalization effort by including NEPA provisions in the HFRA and the Energy Policy Act that either eliminate or reduce environmental analysis requirements for timber thinning and energy exploration projects.²⁷⁹ Add to this the Bush administration's approach to its ESA responsibilities—which include an overt hostility to new listings, a rush to delist species, and contemplated revisions to the section 7 consultation process and critical habitat designation and critical habitat designation criteria—and the land management agencies could well be relieved from meaningful regulatory oversight. Related efforts to eliminate administrative appeal opportunities are plainly designed to further insulate management decisions from review. The net effect is to minimize opportunities to enforce environmental standards and procedures, and thus shield criteria—and the land management agencies could well be relieved from meaningful regulatory oversight. Related efforts to eliminate administrative appeal opportunities are plainly designed to further insulate management decisions from review. The net effect is to minimize opportunities to enforce environmental standards and procedures, and thus shield the agencies from any meaningful accountability. It is a return to an era when discretion reigned supreme. [Footnote in original]

All good things come to an end. So do all bad things. The Bush/Cheney regime and its war on the environment ended in January 2009, although effects (and federal judges) linger. [Personal aside: My friend from the early "planning days," Dale Bosworth served as Forest Service Chief early in the Bush/Cheney Administration. I believe Dale did what he could to curb the worst of the what might have been done to the Forest Service during that era, but didn't take my advice the be take a firm stand and be the first Chief since Gifford Pinchot to be fired for standing up against the powers that be. Had I been in his shoes I might not have taken that advice either. Who knows? But it wasn't in Dale's nature to work that way. I don't find fault with Bosworth's leadership/management during that era.]

Adaptive Governance: Obama's 'Audacity of Hope'
Unfortunately for Leopoldian dreamers, incoming President Barrack Obama's audacious plans have not yet been focused on matters environmental, other than green energy. Nor will they likely anytime soon, even if Obama or anyone in his Administration were prone to do so—which itself is in question. Obama is too distracted with two wars, emergent unrest in the Mideast and Middle America following Tea Party elections in statehouses and the US Congress. Not to mention continued after-shocks from the near-disaster of the financial meltdown that arrived coincidentally (or not) right as Obama was entering the White House.

Obama cut his political teeth on community organizing, and that is in a sense Kai Lee's gyroscope to accompany his adaptive management compass. So we can at least hope for endorsement from Obama if planning is replaced with adaptive governance. Whether or not it will be a good thing depends largely on whether or not untoward devolution happens—or is perceived to likely happen—under adaptive governance schemes. Time will tell. But I get ahead of our story. The Forest Service hasn't yet embraced adaptive governance, although I hear they are flirting with it. Instead they are still wedded to capital P "Planning." As Andy Stahl noted, the recent Draft NFMA "planning rule" (pdf) (as the Forest Service likes to call it), stages up a rational planning exercise. The difference is that this time it is driven by ecological rationality instead of the earlier economic rationality from the OMB era.

Adaptive Governance: Absent in the NFMA Draft Planning Rule
I suspect it was because the Bush/Cheney era NFMA rule was thrown away by the courts, but for whatever reason the Obama Administration chose to rewrite the "NFMA rule." There has been a flurry of commentary on this blog and elsewhere about the rule and associated planning. But does anyone really care about this type planning anymore? What decisions are really contained by a forest-level plan? Despite the language of the draft rule, I find no "ecological resilience" decisions, neither "ecological or social sustainability" decisions, nor any "species viability" decisions, nor … that can be contained in a forest-level plan. All such considerations will well-up at scales different from forest boundaries.

As I've argued before, these are wicked problems. Wicked problems are not amenable to rational planning resolutions. Part of the "wicked problem" problem is that they are shape-shifters, they vary in problem identification and resolution across both time and space. They just won't stand still, and will not be force-fit into predetermined "decision containers."

In addressing wicked problems, I believe that scale-dependent futuring, and/or puzzle solving, is in order alongside scale-dependent assessments and monitoring. We ought to add in scale-dependent standard setting. They all fit under a header “puzzle solving.” Where scale-dependent is really the stuff of framing decisions/actions according to a “Garbage Can Model” wherein issues, actors, and arenas self-organize across the landscape into various and sundry decision containers. We all need to think hard about wicked problems and, e.g. Cohen, March, and Olsen’s garbage can decision model. Here’s a pdf of CMO’s 1972 article: "A Garbage Can Theory of Organizational Choice."

See too Pritchard and Sanderson’s chapter in Panarchy: Understanding Transformations in Human and Natural Systems (2002), “The Dynamics of Political Discourse in Seeking Sustainability.” After setting stage for adaptive governance, complete with "wicked problem identification" and "garbage can" resolution mechanisms, Pritchard and Sanderson conclude:

[Testing hypotheses and applying lessons learned] to the thorny puzzles of environmental management and governance are [noble] goals. The greatest promise lies in addressing political issues directly, rather than in avoiding or submerging them. The fondest hope might be that individuals, communities, and formal organizations engage the spirit of adaptation and experimentation, by allowing a set of contingent ideas to shape "the gamble" of democratic resource management, and citizen experts to report on the results. Of course, for such a profoundly disorganized and multiscale approach to thrive, government, market, and citizen must share a common vision—that all must address these puzzles in order that they might be engaged and worked on—not solved forever; that “expertise,” popular voice, and power are separable, and none holds the dice [from a "floating crap game" model of politics] for more than a pass.

A Few Questions Linger
Is an ecologically framed rational planning rule what we need to resolve controversy? Or is it time to embrace adaptive management, even adaptive governance in an attempt to tame wicked problems? Yes, I know that the preamble to the Draft NFMA rule claims that forest planning will be driven by adaptive management. Really? Read the rule and explain to me how the draft rule stages for more than rational planning.

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Related:
The Forest Service as a Learning Challenged Organization, Iverson, 1999
US Forest Service Deeply Flawed Planning Culture, Iverson, 2004

Planning: The View from Plato's Cave Dave

A "forest planner" friend called me the other night to chide me for missing one of the best powder skiing days ever. As our conversation progressed I shared my frustration with the Forest Service's thirty years failed national forest planning efforts. My friend said that I ought not to expect forest planning types, including those charged with writing "new rules," to do anything other than minor tweaking of older rules. After all, that's what they know and where they find comfort. My friend has a point! Sometimes, however, there is Danger in the Comfort Zone.

Keep in mind that most people, both managers and employees prefer bondage in bureaucratic power-play organizations, "psychic prisons," to the freedom and responsibility of adaptive management learning organizations. I prefer the empowerment of the latter.

Digging deeper into the FS comfort zone, I believe the Forest Service's "comfort" is much like that Plato talked about in his Allegory of the Cave (Wikipedia). In short, Forest Service top brass are too often like the inhabitants of Plato's cave, chained in some way to see only the shadows of outside reality flickering on the cave walls, but unable to encounter that reality themselves.

I admit that I too am blinded by ideology/methodology, taking too much comfort, for example, in adaptive co-management. None of us is immune to this failing. Still, questions linger: Which frame serves best, planning or adaptive management? Or are both bankrupt? If not these, then what? And if an adaptive co-management frame is better, how can the Forest Service ever get there? In answering the last question, remember what Kristen Blann and Stephen Light told us a decade ago, Adaptive ecosystem assessment and management will be The Path of Last Resort (doc)!

Links, for those unfamiliar with Plato's Allegory:
Allegory of the Cave, Wikipedia
Plato's Allegory of the Cave: A short summary (Warning: Not for those offended by the "f-bomb" and other "street talk")
The Cave: 8 min. audio (with text), that explains Plato's allegory well in contemporary context

New Planning Rule Fails as Adaptive Management Dave

What is a forest plan?  A committee of scientists once said that a forest plan is simply a loose-leaf compendium of all decisions large and small that affect the administration of a national forest.  Following adaptive management principles and practices, "decisions" can and are made at multiple scales: international, national whether or not made by the US Forest Service, regional and local. So too with assessments, and monitoring and evaluation measures.  All these are the workings of adaptive management, not planning.  The whole of the Forest Service ought to be charged to work together to accomplish broad conservation, preservation, and use goals through adaptive management.  Framing needs to be changed to do this. A central planning frame has failed for 30 years.  Why continue down this path?

In an adaptive management frame, forest supervisors oversee the day-to-day workings of a national forest administrative unit. But decisions affecting that unit are made in various ways at various scales, whether as part of laws, policies, programs, or activities.  There are no administrative "kings" in this worldview.  Instead we have various actors, some within the Forest Service and some without, working in interrelated systems that frame the workings of a national forest. We have whole organizations working together to accomplish the work of adaptive management.  The task is not left to "planning."

Now let's begin to parse the most recent "proposed rule" for developing a forest plan.  Note first that the three levels of administrative decision-making outlined in the proposed rule -- national, forest, project or activity -- don't fit the adaptive management model outlined above.  Why does the Forest Service continue to pretend that managing a national forest comes down to three levels of decision-making?  I can see no reason, beyond tradition for maintaining this hierarchy.  Can you?

If the Forest Service is incapable of understanding adaptive management, is there any hope in trying to fit adaptive management into the Forest Service culture?   After thirty years watching and attempting to participate in rule development for the RPA/NFMA I am once-again left to doubt whether any progress can be made.

Adaptive management is about organizations learning to adapt to ever changing environmental and social systems. Adaptive management is not about "planning."

Perhaps I'm too old to dabble in this stuff anymore.  Perhaps the "devil in the details" ought to be left to those younger.  But I believe I've seen this same rhetoric before -- since 1979 -- and it appears, broadly speaking, pretty much the same to me.  The Wilderness Society gives the proposed rule a B.  I give it, once again, an F. The Forest Service simply doesn't get adaptive management. The F is for "frame blindness," and other decision traps.

If I were a forest supervisor I would feel victimized by this (and earlier "planning rules").  Forest supervisors are asked to act as "forest kings," not forest administrators.  The Washington Office of the Forest Service does a disservice to both forest supervisors and regional foresters, as well as many in the so-called "staff" program areas of the Forest Service by continuing this tradition of laying it all at the feet of forest supervisors.  We might as well call them "forest scapegoats" if this tradition continues.  The Forest Service seems intent to continue its 30-year tradition of gridlock unless and until there is an awakening.

I will not comment here on the many process failings leading up to this proposed rule.  I've done it before. Suffice it to say, despite many pleadings, the Forest Service once again gathered some input in the early stages, then went into the isolation booth to hatch a rule.  It should surprise no one that it closely resembles earlier rules.  No "real" blogs,  no wikis, no true collaboration in rule development.  Why not?  Other government organizations use them. What we got instead was administrative politics as usual, with associated administrative gridlock.

It is likely too late to change this rule.  Despite billing it as Draft, we all know that only minor tweaking will be allowed between Draft and Final Rule. It would be refreshing for the Forest Service to admit that it botched this effort.  But American politics will not allow it. Too bad! Peter Drucker once remarked that one key measure of the worth of a decision is how rapidly it can be changed in light of new information.  Would that the Forest Service could "see the light," and change this rule.