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April 21, 2005

The Curious Case of Forest Planning and EMS

When the Forest Service published the 2004 NFMA Planning Rule, it also requested comments on proposed National Environmental Policy Act (NEPA) "implementing procedures." In simple terms, the agency proposed to exempt—to "categorically exclude"—forest plans from long-standing requirements to develop Environmental Impact Statements, except where "extraordinary circumstances exist." 

The comment period closed on March 7. So now we wait to see what the Forest Service decides to do. Incidentally, the Forest Service’s decision cannot be made until it is reviewed by the Council on Environmental Quality (CEQ) for conformity with NEPA regulations on agency decisionmaking procedures (40 CFR 1505.1, 1507.3, etc.).

In the meantime, we might ponder a simple rhetorical question, "If the Forest Service hadn’t conveniently affixed EMS to planning, would it still be proposing these categorical exclusions for forest plans?" Maybe so? Maybe not? But there are interesting rumors swirling around.

Rumors I’ve heard say that in late hours of inter-departmental NFMA Rule negotiation, high level Forest Service folks ran into a brick wall at CEQ over forest plan "categorical exclusion" language, then embedded in the draft NFMA Rule.

The rumor mill has it that the brick wall was torn down, supposedly and provisionally, when CEQ head James Connaughton proposed an Environmental Management Systems (EMS) process in lieu of the then-standard Environmental Impact Statements requirements for forest plans. This rumor might have legs, given Connaughton’s biography and his wealth of EMS experience in prior roles.   

On the other hand, there is reason to doubt the rumor. Why would Connaughton propose EMS in lieu of EIS, when his legal advisors advocate both processes?

Deputy General Counsel for CEQ Edward A. Boling’s recent paper "Environmental Management Systems and NEPA: A Framework for Productivity Harmony" lays out a general framework that could serve as a basis for doing both a forest plan EIS and an EMS. Boling suggests that there is no reason to substitute EMS for the EIS process. He argues that the two processes are compliments not substitutes. And he makes a good case for forest plans to be used as part of NEPA tiering whether or not accompanied by EMS.

Boling's paper sits on the same website with another, written by DeAnne Zwight, Asst Director of Ecosystem Management Coordination, USFS Washington Office. Zwight’s paper is titled "Smokey and the EMS ." Zwight’s rendition has it that the Forest Service found its own way to EMS and away from forest plan EISs as a means to "change and continually improve environmental performance." 

Zwight is emphatic that the Forest Service ought not to create an EIS for the forest plan. She argues that doing both an EMS and a forest plan EIS would in fact undermine the EMS:

An EMS could not be successfully used in conjunction with an EIS because the nature of the EIS process itself, court decisions that have led to more and detailed plan analysis, and public expectation of very detailed and predictive plans have spawned plans that have taken 5, 6, 7 or even 10 years to produce. This essentially prevents the timely change and adaptation EMS is designed to accomplish. However … the Forest Service would continue to do EISs for some portions of plans no matter what final decision is made. For example, a "legislation" EIS would be required for wilderness designations.

Note that Zwight does not advocate for an EMS in lieu of an EIS, but rather advocates separating the forest plan from the EIS process. But such advocacy leaves many unanswered questions. in particular, "Why isn’t a forest plan a useful piece of a NEPA tiering process?" "Is tiering a useful concept for forest management?" "If tiering is to be used and the forest plan categorically excluded from EIS requirements, then what is to be done?" 

Many years ago I also argued against saddling a forest plan with an EIS. But back then agency was trying to gain NEPA sufficiency all the way from forest plan to project in one EIS—something I used to call 'once and for all NEPA.' Since that time I’ve warmed to the NEPA tiering process. I believe it makes sense to have the forest plan EIS a part of NEPA tiering. We might call this 'once and forever NEPA.'

I agree with Zwight that we in the Forest Service have a terrible track record in trying to effect cumulative effects assessments. But I do not believe it appropriate to de-link the Forest Plan from the process. Instead, the agency had better find a means to deal with cumulative effects and others aspects of NEPA.

One last question lingers, "Are there other agencies that have stepped eagerly up to the plate to tie EMS to strategic planning?"  If there are, maybe we can learn from them. If there are not, why was the Forest Service so eager to dip a toe into these waters? This last question proves particularly troublesome since the Forest Service has a penchant to unnecessarily complexify everything it touches, including NEPA compliance. Why would we expect the agency not to over-complexify EMS too?

Posted by Dave on April 21, 2005 at 02:33 PM | Permalink


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Posted by: Joe Carbone

Well, every rumor has its spin and comments on rumors only add more spin and rumor. I'll try to slow the spin here, but ... well here goes.

1st: Deputy General Counsel for CEQ Edward A. Boling’s recent paper “Environmental Management Systems and NEPA: A Framework for Productivity Harmony” does not lay out the case for doing both a forest plan EIS and an EMS. The paper addresses how an EMS and the NEPA process harmonize - nothing about the case for a forest plan EIS. He does use an example of a plan EIS for tiering specific action NEPA documents to.

2nd: It doesn't make sense to say that the FS is substituting EMS for the NEPA process when each is designed to operate differntly with different process objectives (although they both can ultimately contribute to a better environment -Section 101 of NEPA). I would say that if folks thought the loss of an EIS for a plan meant a loss of accountability then perhaps an EMS conforming to ISO would provide for some sort of accountability, but that's not a direct substitute for the same sort of accountability associated with an EIS either.

3rd: “Why isn’t a forest plan a useful piece of a NEPA tiering process?" "Is tiering a useful concept for forest management?" "If tiering is to be used and the forest plan categorically excluded from EIS requirements, then what is to be done?” Answers: A forest plan is not a NEPA document, Yes, tiering can be done.

Because the term "tiering" is used in the CEQ regulations, within the NEPA concept the term is specific to EISs. Neither the planning regs, nor the CEQ NEPA regs require nor prohibit tiering in reference to EISs or plans. Also, beyond NEPA, I would expect projects would "tier" to plans in a general use of the term in that they implement the broad strategic direction of the plan. Webster's "tiering": "to arrange or rise in tiers." A "tier" is one that "ties", or "one of a series of rows placed one above another." Plans would be the tier above the project. Also, to further complicate things, I suppose tears have been shed over plans and planning rules.

Joe Carbone | Apr 22, 2005 11:52:02 AM

Posted by: Dave Iverson


“1st: … Boling “does not lay out the case for doing both a forest plan EIS and an EMS. The paper addresses how an EMS and the NEPA process harmonize - nothing about the case for a forest plan EIS. He does use an example of a plan EIS for tiering specific action NEPA documents to.”

I stand corrected. Boling’s paper is not about Forest Plans in particular, but rather about Environmental Management Systems and NEPA generally. I was a bit sloppy with my Post, so I amended the wording slightly to try not to put words into his mouth.

Still, it will prove interesting to see how the Forest Service is going to comply with NEPA if it chooses to break with traditional requirements to have forest plan EISs as part of NEPA tiering.

“2nd: It doesn't make sense to say that the FS is substituting EMS for the NEPA process when each is designed to operate differently with different process objectives.”

Other than as “rumor” I don’t believe I argued that point here. Still, it does prove to be an interesting rumor. I think that the FS has not done yet done a good job of telling people what it intends to do to comply with NEPA. Suspicions abound!

“3rd: …A forest plan is not a NEPA document, Yes, tiering can be done.”

Damn, in one place I forgot to append “EIS” to “forest plan.” So I’ve corrected that in the post. Elsewhere I was very careful to separate forest plans from accompanying EISs.

Thanks for the tips..

Dave Iverson | Apr 22, 2005 2:11:57 PM

Posted by: Sharon Friedman

So Ted (lawyer), Roger Sedjo (economist), DeAnn (planning practitioner) and me (biologist) may not agree about the best approach to protect the environment and do planning (see Roger's paper http://www.fs.fed.us/emc/nepa/ems/includes/article3.pdf). Totally NOT suprising.

In fact, all in the lawyer, economist, practitioner, and biologist communities don't agree. Vive la difference! Diversity is strength- at least in biology.

***I'd like to move on to the key question, given that the directives are out for public comment- what is it about the EIS that you or others think is important to have that is missing from the directives? Specific analysis of some kind? This would be very helpful information to those working on the directives. As I said below in the previous post to this forum, I'd prefer focus on things people don't like, and more deeply into "what would they like better". ***

The answer to the "other agencies" question can be found on the FS EMS public discussion forum:

"There's been a lot of discussion about how planning and EMS are best integrated.. I thought that the Canadian standard for sustainable forest management is a good illustration of one way to link them - very clear and straightforward. Not to say that we should do it in a similar way- it just shows the linkage between the standard (like our planning a bit) and the management system. As it turns out, Canadians have always been at the forefront of linking ISO and forest management. Here's the link at CSA- it's free: http://www.csa.ca/repository/group/Z809-02july.pdf

Actually they link C&I also and one can easily imagine linking to GPRA. Note that as of Dec 2004, 47.4 million hectares have been certified to this system (http://www.sfms.com/status.htm)."

I am hoping that you agree that we can learn from other countries who have good ideas as well as other federal agencies.

Finally, here's the writeup from somewhere else on this forum that addressed the EMS/EIS discussion.

"EMS was never intended to replace NEPA. They fundamentally do two different things- NEPA analysis looks at something in advance to figure out where to put and how to design projects, and EMS is a tracking system to show that you followed what you said in your NEPA document (as well as other requirements)and you are using that info to continually improve your environmental performance. Check out adaptive management in the CEQ task force report http://ceq.eh.doe.gov/ntf/report/ and the two NEPA and EMS papers on the FS EMS website:http://www.fs.fed.us/emc/nepa/ems/nepa_ems.htm

I think because EMS is in the rule, it gets linked in people's minds with not having EISs or EAs for forest plans (CEs are part of the NEPA regs and of course are NEPA documents). But the "use a CE for plans argument" is not linked to EMS. The "use a CE for plans argument" is linked to deciding only to allow strategic decisions in forest plans- like desired conditions and objectives and not like final decisions that impact the environment like specific road closures, timber sales, minerals leases, special use permits, or other projects and activities. This idea of delinking strategic decisions from EAs and EISs is that the place to focus NEPA analysis is just before you do something (when you have all the latest science and monitoring info) and you are trying to decide when where what and how you are going to do it.

EMS was chosen to put in the rule because public comment showed concern that having more flexibility in the rule, while allowing more ability to change with increasing knowledge and science, would allow local officials to make decisions that would hurt the environment. The EMS is intended to provide that accountability for the way the environment is treated- to be the very public contract administration of the social contract in the strategic plan. But EMS is only a piece of accountability..

What is going to keep FS officials from doing bad environmental things include: 1) environmental statutes and regs such as ESA CWA and Clean Air Act, FIFRA, etc., etc.
2) Analysis through CEs EAs and EISs for every project or activity that has environmental effects and meets the requirements for being subject to NEPA. The same old timber sale, oil and gas, grazing, OHV EAs and EISs as before the new rule are still required.

And EMS, for aspects chosen to be of special importance to the public in terms of impact and severity of environmental consequences.

Again, EMS is required by a Clinton administration executive order. So it seems like by itself, it is considered to be innocuous at worst, pro-environmental at best. Perhaps EMS is experiencing "guilt by association," because it is in the rule with things some people don't like?"


Sharon Friedman | Apr 22, 2005 5:33:58 PM

Posted by: Dave Iverson

Sharon poses a key question: “…given that the directives are out for public comment- what is it about the EIS that you or others think is important to have that is missing from the directives?”

For me the question is “key,” but not in the sense Sharon supposes. I believe the “directives” are much more the problem than a solution to the woes of the Forest Service. For many years I have advised the Forest Service to dump its Manual and Handbook system and let professionals, working hand in hand with the public, work out the management of the national forests.

Professional codes of ethics, standards, etc. are useful. Law, regulation, and policy are useful too. What is not useful, in my mind, is the over-regimented approach to EVERYTHING that the Forest Service seems to believe necessary. Such Methodism is a well-researched decision trap, one the agency seems caught up in almost endlessly.

The Manual/Handbook system have elevated Methodism to an art form. It is past time that for us to focus our attention on managing the forests rather than the Manual/Handbook system. And we might begin to focus some attention on managing our agency as well.

This is not to say that people don’t need to reach out for guidance. For guidance on:

- Ecosytem management start with Aldo Leopold’s "A Sand County Almanac"
- Management, Margaret Wheatley and Myron Kellner-Rogers’ "A Simpler Way"
- On why people feel compelled to try to tightly manage everything, and order their lives rigidly, Erich Fromm’s "Escape from Freedom"
- On why we ought not to so tightly order things, E.F. Schumacher’s "A Guide for the Perplexed"
- On why we will likely order things tightly anyway, and why some of us will fight this penchant forever, Albert Camus’ "The Rebel"
- And so on.

The reason we study books is not to get ready-made, formulaic answers to life’s many questions, The reason we study books is to gain wisdom, to provide context. The search for formulaic answers following undue process requirements in planning and adaptive management is a fools quest—bureaucratic gobbledegook.

In the Forest Service we manage roads and trails, manage a few other facilities, cut a wee bit of timber, graze a few cows and sheep, try to offer some recreational experiences, etc. We have biologists, ecologists, archeologists, and more to help us not screw up things too much in the process. We have open public processes to aid us as well.

To believe there are formulaic answers or helpful highly-structured process guides to ethics, aesthetics, and other social value questions that guide our attempts to balance these many endeavors is nonsense. We are stuck with myriad wicked problems, or social messes as they are sometimes called. Like others in administrative governance we have to deal with them as best we can.

So let’s get on with it. Let us be very afraid of our tendencies to over-complexify, over-scientize, over-bureaucratize everything. Such tendencies will only get in the way of our very social outreach-endeavor of managing the national forests.

And as a first step, let’s dump (i.e. decommission) the Forest Service Manual and Handbook. Folks will informally keep parts that ought to be kept (I supect there will be few of these). Other parts will simply go away for the betterment of the agency and others. Some parts will have to be formally decommissioned, since they have been put in place via the Administrative Procedures Act. Good. That will give us more chances to talk it over.

But please don’t ask me what more we might add to the 18 plus feet of Manual/Handbook shelf-space filled with at best archaic and at worst never-helpful directives that the Forest Service maintains. And particularly don’t ask me to add to “directives” for planning—that most complex and wicked endeavor.

Better that we do what Forest Service social scientists are now attempting, and move all our guidance and advice to a non-mandatory, Internet “knowledge base.”

For those things that ought to be regulated, of course we should use the regulatory process. For most all-else lets use the best sources we can find for advice on management, professionalism, leadership, etc. Let us develop ever-better communities of practice. In this betterment process, we need to relearn–or learn for the first time–the meaning of words like management, leadership, and professionalism. We need more discussion on what ought to be formally regulated and what ought to be handled more loosely, allowing for adaptive management, creativity in design, application, and so on.

Regarding NEPA compliance, why not follow the law and CEQ regulation. I have never understood why the Forest Service has to put its own spin on regulation that CEQ handles quite nicely. Bureaucratic arrogance? If decisions made in a forest plan warrant and EIS, then an EIS ought to be done. Leave that decision up to those making the decisions rendered via a forest plan.

The idea that the Forest Service can declare in a NFMA Rule that a forest plan is something not warranting an EIS seems foolish and arrogant to me. How the agency effects NEPA compliance should depend on what decisions are made, where they are made, how they interrelate with other decisions, and so on.

Dave Iverson | Apr 24, 2005 11:41:07 AM

Posted by: DeAnn Zwight

Did the FS wake up on day one of the rule development process and say, "Gosh, what do you want to do today? Let's get everyone all worked up, and jettison 20 years of producing EIS's for plans." Well, no it didn't happen that way.

First choice originally? We suggested revised CEQ rules that more clearly separated plans from projects. We were looking for revised rules which more clearly laid out what plans do, the kinds of analyses needed to support them, and provided plan development processes to better help people work together.

There was no interest in change/revision of the CEQ regulations. So, if the mountain won't go to Mohammad? The FS worked with CEQ (and many many others) to redefine what our plans do, and make them more consistent with the existing CEQ regs. Which is why we can categorically exclude plans (if done under the planning rule guidance) from EIS's.

EMS came along at the same time, but not as an EIS substitute.

Of course there were and are advocates for use of both EMS and an EIS. If given huge budget increases, as likely as world peace or the cessation of reality shows, sure--a combination of both processes is theoretically feasible. It's always good to dream, but our budgets will double when pigs fly.

DeAnn Zwight | Apr 24, 2005 8:01:43 PM

Posted by: Joe Carbone

Well DeAnn, FERC heard about your flying pig proposal to double the budget - a "pig launcher" proposal: http://www.epa.gov/fedrgstr/EPA-IMPACT/2005/April/Day-22/i1897.htm
In response to Dave, the new planning rule allows for decision makers to use an EIS, EA, or CE for plans, as appropriate which is what you seem to advocate. Under the '82 rule there was no discretion as it required an EIS.

Joe Carbone | Apr 25, 2005 9:22:58 AM

Posted by: Martin Nie

I have a question about the new planning regulations that perhaps someone here can help answer. There is a good chance that I’m missing something, but a few knowledgeable people I talked with didn’t have an answer, so maybe someone here will.

Given the changes to the nature of forest planning, and how the FS interprets plans as strategic and aspirational in nature, and not final decisions:

Question: Will plans be subject to Congressional review as defined by the Congressional Review Act? Outside of the appropriations process, is Congress willing to relinquish its power to review plans/“rules” as defined in the SBREFA?

(The CRA was included as part of the Small Business Regulatory Enforcement Act of 1996, Pub. L. No. 104-121, 110 Stat. 857, 868 (codified at 5 U.S.C. §§801-808 (Supp. III 1997)). The CRA provides Congress with a mechanism to review and disapprove federal agency rules. Also interesting to note is that the law was supported by Republicans who were concerned about burdensome regulations and wanted a way to review and possibly repeal them.)

The General Accounting Office, for example, concluded that the 97 Tongass plan constituted a “rule” under the Small Business Regulatory Enforcement Fairness Act (SBREFA), at 5 U.S.C. § 804(2), designed to restore balance between Congressional laws and executive implementation. According to its General Counsel, “[I]t meets the elements of a ‘rule’: it is of general applicability (it affects many parties, private and governmental concerning the National Forest) and future effect (10 to 15 years in duration), and it implements, interprets, and prescribes law and policy.” GENERAL ACCOUNTING OFFICE, CONGRESSIONAL REVIEW ACT: APPLICATION TO THE TONGASS NATIONAL FOREST LAND AND RESOURCE MANAGEMENT PLAN, GAO-/T-OGC-97-54 (Jul. 1997) (statement of Robert P. Murphy, General Counsel), at 3.

I have not dug deep on this issue, nor pursued it after the GAO opinion in 97. So I’m sorry if I missed a later development that answers my question. If not, however, I think this is an interesting situation that raises fundamental questions about agency discretion and Congressional oversight.

Thank you, Martin Nie

Martin Nie | Apr 25, 2005 9:26:20 AM

Posted by: Forrest Fleischman

This thread raises an interesting set of questions. Why do people value NEPA for Forest Plans, or for anything else for that matter?

In my fairly limited experience working with NEPA (and also with CEQA - California's state level equivalent of NEPA), I have observed that NEPA's primary value to the public is in insuring an open and public process where the government is formally accountable, albeit in a limited fashion, to the concerns of citizens.

Where I grew up, in rural New England, community decisions were made at town meetings. Most of a small town might show up on town meeting day, debates were frequently bitter and divisive, and votes frequently revealed deep splits in local opinion. But everyone knew exactly how a decision was made, and why. When people disagreed with a decision, they had to work with their neighbors to alter the political balance by the next March. The important aspect of this direct democracy was that local people were highly empowered to make decisions about their local community based on their values.

When I lived in small towns in rural northern California, I learned that NEPA (and CEQA) was playing the role of the town meeting. With very limited local government, and large areas of industrial timberland and federal land, NEPA was the only tool locals had to participate in decision-making. This led to situations that a young man from rural New England found amusing. The California Transportation Agency was planning a highway bypass around a small town, and many locals wanted the bypass to be smaller, and to follow a different route, than Caltrans was proposing. Rather than talk about their values (i.e. preserving local scenery, slowing the pace of development and rising property values) the locals were arguing that the proposed highway was going to destroy a rare oak woodland. The only way for these locals to influence the powerful state agency was by finding holes in its EIS. In New England, instead of hiring a lawyer to sue Caltrans over an insufficient EIS, we would have had a vote over whether we wanted the transportation agency to build a bypass, and if so, what kind.

Forests face a similar problem. Concerned citizens have very limited means to influence National Forest management. The only real opportunity they have is to submit substantive comments in response to NEPA documents. In theory, line officers have "the greatest good" at heart in all of their decision-making. In practice, we know that this is often not the case (and would not be the case in even the best run of bureaucracies), and the history of the Forest Service seems to be littered with poorly made "expert" decisions. The chief protection citizens have against arbitrary or destructive decision-making is the appeals and litigation process.

So what concerns many citizens about the new planning regulations is that they eliminate the NEPA process for plan development, and substitute:
1. EMS, a process which, whatever its' merits may be, has very little to say about substantive public influence and oversight over agency decision-making.
2. Some very vague non-binding language about collaboration.
In other words, it is not at all clear how the public can influence plan development under the new regulations. Centralized planning without public oversight has been tried before, and while I haven't read much about the collapse of the Soviet Union, it is my understanding that the inefficiencies of this system contributed to its collapse.

To me, the most interesting aspect of this is the collaborative management problem. There are many examples now of succesful collaborative processes in National Forests, and many examples of unsuccesful or very moderately succesful ones as well. There is an enormous body of scholarly research on what makes collaborative processes effective. If you are interested in this, my favorite source is Elinor Ostrom's classic, Governing the Commons: The Evolution of Institutions for Collective Action, although much has been written more recently that is more specifically relevant to National Forests. The new directives and regulations completely ignore all of this research. It appears that the Forest Service is intent on paying lip service to collaboration, but has little interest in implementing it.

NEPA certainly is a highly imperfect tool for including the public in decision-making, as it only allows citizens to challenge the Forest Service with regards to its use of science, rather than for its ethical decisions. I do believe that it is better than no substantive public input at all, which is what the new directives appear to propose.

Forrest Fleischman | Apr 27, 2005 1:27:37 PM

Posted by: Tom Mitchell

Sharon Friedman in her April 22 note asked the following questions:

“...what is it about the EIS that you or others think is important to have that is missing from the directives? Specific analysis of some kind? This would be very helpful information to those working on the directives. As I said below in the previous post to this forum, I'd prefer focus on things people don't like, and more deeply into "what would they like better". ***”

I would like to address the question of what analyses could be part of planning and would be necessary to meet NFMA and its intent as well as the MUSY. As I’ve indicated in past correspondence, the new plan regulations can lead to development of plans which meet the letter and intent of NFMA and MUSY including the purposes as laid out in 36CFR219.1. At the same time, given definitions of such terms as “desired conditions,” “objectives,” and “guidelines” in the new regulations, it is very possible and highly probably that plans done under the new regulations will not meet the purposes stated in these regulations nor meet the requirements of these laws.

The difference between these two possible outcomes is the “specific analysis of some kind” that should be at least alluded to in the regulations, included in “directives”, and for which training and support should be provided to Forests. Besides capital investments such as roads, trails, camp grounds, and water tanks, management of forests involves manipulation of vegetation OR deciding not to manipulate vegetation in some areas. There is a myriad of ways to manipulate vegetation and almost an infinite set of vegetative patterns that can be created. Some of these can even be created and maintained through time (depending on how one defines “pattern of vegetation”). Before describing the analyses that could/should be part of forest planning, lets first define “superior” alternative. A superior alternative is one that produces the same amount of something at less cost OR said another way one that produces more of the desired something at the same cost (with cost being both dollar costs as well as detrimental environmental effects). Given this, then, analyses that could be/should be part of forest planning (if the intent of NFMA and the purposes in 36CFR219.1 are to be achieved) would include:

First, in order to make sure the goals/desired conditions selected are superior, it seems one would have to analyze:

1. Out of all the ways to manipulate vegetation (and if need, install capital improvements such as watering ponds) to create patterns that will provide habitat for deer on a sustained basis, which way(s) are superior?
2. Repeat question 1 for turkeys, squirrels, goshawks, three toed woodpeckers, the spotted owl, elk, moose, black bear, grizzly bear, wolf, etc. for all of the native wildlife species for which there is or could be habitat on a forest?
3. Out of all of the ways to manipulate vegetation to provide a sustained yield of forage for domestic livestock (including necessary capital investments for each), which are superior?
4. Out of all of the ways to manipulate vegetation and a network of access roads for a sustained yield of timber, which ways are superior?
5. Out of all of the ways to manipulate vegetation by watershed that will maintain water quality and flow and be most resilient to possible unforeseen events such as wild fire, insects, disease, which are superior?
6. Can some of the ways of achieving habitat for deer be combined with ways of achieving habitat for squirrels and oven birds? If so, what would this look like and which combined way(s) are superior?
7. Repeat 6 for other possible combinations of wildlife habitat.
8. Can some of the ways of achieving habitat for multiple species of wildlife identified in 6 and 7 be combined with ways of achieving a sustained yield of timber? If so, what would these look like and which of these super-combined ways are superior.
9. Do the same for various types of recreation and visual quality to finally identify patterns of vegetation that if achieved and maintained would provide, on a sustained yield basis a specific type/mix of wildlife habitat, timber, water quality, water quantity, aquatic habitat, visual quality, and recreation opportunities and list the road network, fire protection/suppression practices, prevention practices for harmful insects and diseases, and vegetative manipulation practices necessary to maintain this pattern of vegetation.

After this analysis, it would seem that the planning team in collaboration with the public and researchers would have the set of “forest conditions” necessary to meet the purposes outlined in 36CFR219.1. In other words, they would have identified a set of superior vegetation patterns that collectively provide biodiversity, habitat for all native species of wildlife, perpetuation of all native vegetation and that would “...sustain the multiple uses of its renewable resources in perpetuity while maintaining the long-term productivity of the land.”

Lest you say that this is too much to expect of a planning team or that it would take too long to just do this, I would point out that at least two National Forests did these analyses during the “first round” of forest planning with one taking about 2 months to do this entire set of analyses and the other for a much larger and complex forest about 3 months. Of course, they had to invent this as they went along with no training or support offered from the agency for such tasks. But I digress...

Once these forest conditions have been defined, it would appear that further analyses are needed to address such questions as:

1. Where, on the forest, can we achieve each of these conditions?
2. How much of each condition should achieved and where should that occur so that legal/policy related requirements are met such providing habitat for viable populations of native wildlife species, legal requirements/agreements on stream flows, biodiversity, assuring that some of each plant/plant community native to the area is provided for, etc.
3. Often, based upon 1 and 2, there are still choices to be made, so how much of each forest condition should be achieved where to address various types of needs/wants of the American public as well as those socio-economic systems associated with the forest.

The first of these three types of analyses is probably best handled by a planning team for these questions are relatively straight forward and based on biological realities rather that values. These are the “suitability” questions. The second and third of these analyses are exactly the kinds of analyses that can be done collaboratively with the public, stake holders, and researchers with such things as interactive GIS mapping and the ability to look at quantitative results of possible “allocations.”

All of the above looks at those “timeless” forest conditions, but there is a real forest that is not in any of these conditions, so the next set of questions relate to trying to achieve these conditions over time within realistic budgetary expectations. Yes, you could stop here and use the “design criteria” of each forest condition as “guidelines”, but there are objectives to be defined as well.

For example: If you want to achieve a vegetative pattern that can be sustained through time that includes creating openings of 5 to 20 acres in size, with 75% of the perimeter being in vegetation large enough and dense enough to hide an elk if viewed from 20 feet away, then just this description provides “guidelines” for projects designed to achieve this condition. So now you have two parts of the Forest Plan sortuv rolled up in one, forest conditions and guidelines.

Beyond this, though are questions of when you are going to do what and where that is going to happen to see if achieving those conditions is possible and if this can be done in a cost efficient way. In part, this is defining “objectives.” For instance, selecting the timing of the first harvest in area where we are trying to achieve the above condition for elk and how much harvest is needed over time after that within this area to achieve that condition while meeting forestwide or working circle wide constraints on timber flow will impact where you place those first harvest blocks as well as the spatial arrangement of all others. This all effects the costs necessary to implement the plan to achieve these conditions and if the National Forest is to try to do their work in a cost efficient manner, then addressing such questions would seem to be important. And that would be the subject of another set of analyses.

And then there are the analyses necessary to quantify how all of the above would effect local, dependent socio-economic systems and contribute to their sustainability. Also, because no forest is an island (or at least not most), there would be the analyses of how and what is done on one ownership will/could effect other ownerships and the spatial arrangement of habitats for wildlife as well as water quantity and quality.

So this is my answer to Sharon’s question of what analyses would I like to see as part of forest planning. In fact, I am not sure how you can have an effective EMS with the purpose to adjust management through time as needed to achieve sustained production of multiple uses and maintenance of the long-term productivity of the land without addressing these questions and doing these analyses.

And of course, if you are going through all the time and effort to do these analyses and involve the public in these analyses in a collaborative manner, you probably should document this in an EIS so that the cumulative effects of the plan are displayed and you can tier all project level environmental analyses to this. This provides a great cost savings over time particularly when/if there are appeals and court cases that question cumulative effects of a specific project.

Tom Mitchell | May 3, 2005 3:48:11 PM

Posted by: John Rupe

I'd like us to think about these problems a little bit differently. In his post, Tom Mitchell is essentially describing the way plans were developed in the past. What we found, however, is how difficult it is to control the future so we can implement the optimal, or what he calls, the "superior" alternative. We often don't have a clue what the problem definition is, so it's hard to define a solution.

I'd like us to focus on "evaluation" rather than "analysis", focusing on understanding what's been going on in the past, and think about the myriad ways that the future could pan out. There is no one clear solution or superior alternative. Rather, I'd advocate the use of other technical tools, such as values clarification (what does it mean when we say we desire certain vegetative conditions?), core competencies (what is really special about a National Forest, what is it's niche, what are the types of roles and contributions that a Forest makes that we value), and then think about future scenarios (plausible future outcomes, not necessarily predictions.) We need to stay away from highly deterministic and quantitative predictions, because those details can be misleading.

I'd also encourage the use of performance measures, not as a predictive tool, but as an evaluation tool to use in the adaptive process. I've been telling people that this planning process spends more time on monitoring and evaluation, and less time on up-front "planning".

Finally, we want the analytical process to support the collaborative process (as Tom correctly points out), not the other way around like we've done in the past where public involvement is confined to "comment" on a more-or-less closed analytical process as documented in an EIS.

John Rupe | May 4, 2005 12:03:04 PM

Posted by: Tom Mitchell

This is in response to John Rupe's comment of May 4 and is mostly for clarification purposes...

When I talked about "superior" solutions/alternatives - it was not in context of a superior or optimal FOREST PLAN, but rather exactly what he talks about in the second paragraph... he says "... I'd advocate the use of other technical tools, such as values clarification (what does it mean when we say we desire certain vegetative conditions?)"

This is exactly what I was calling for in the early part of my last comment. Identify forest condtions and then do analysis of these possible conditions to find the why's of each as well as identify some of the better ways of achieving/maintaining them. Again, this is not a set of forest plan alternatives, rather a set of "forest condition" alternatives that are used/mixed and matched in various relative amounts to build forest plan alternatives.

I only know of two National Forests that addressed this set of questions in the first round of planning and only one went through the process as discussed in my comment. And given this, I disagree with John's assertion that I am "...essentially describing the way plans were developed in the past" ... one or two forests out of 124 planning units does not make the norm.

Further, the development of forest conditions and then sorting through them to identify "superior" ways of achieving each is a process that can easily involve the public and stakeholders... In fact, it is one where there can be real learning and sharing of information between the public and a forest. For instance, some of the public may want to make sure that the grizzly bear, or three-toed woodpecker or Mexican Spotted Owl are provided for on a forest. The question then becomes, what comprises habitat for any of these species - what mix of vegetation in what spatial arrangement over how large of an area will provide that habitat ... and is there a need for more than one location for that on a forest ... and if there is, then how can these be connected. Note, that this often requires some educated "guesses" for such questions are rarely addressed in research. So, through a collaborative process, the public, researchers, those from academe, other agencies such as the Fish and Wildlife Service and the ID team on a forest work together to try to identify what vegetative condition would provide habitat for three-toed woodpeckers ... and if there are alternative ways of providing this habitat, then which ways are the "superior" ones. (A note, these conditions should be described in such a way that they are sustainable through time. In some cases, that may mean identifying a minimum "patch" or area necessary in order to achieve and maintain that condition through time.)

And this is only a single set of conditions that address a specific species of wildlife. This can then be done so that you have at least one condition for each of the species of wildlife native to a forest. At that point, I suggest, that you will find that some conditions for one species or set of species, with minor changes in design standards, provide habitat for multiple species. So you may end up with fewer forest conditions than species of wildlife just because what is good for oven birds is also good for squirrels. And this is just for wildlife, there would be others for riparian areas, aquatic ecosystems, range, etc.

The final set of forest conditions generated through this process, then, are the ones that can be used to develop a forest plan. They are the "building blocks" of a forest plan. Areas where they can be achieved, where each is suitable, can be identified using GIS. Often, there will be areas on the forest that are suitable for multiple forest conditions. Further, there will be multiple areas on the forest suitable for a specific condition.

That brings us to a second place for collaborative planning, not only with the public but with those on the Forest that know each of these areas better than anyone else (e.g., District staff who walk, ride and know the areas). In this second collaborative planning action, alternative mixes and locations of these forest conditions can be mapped. As they are suggested or mapped by a group, for instance in a public meeting, they could be analyzed on the spot or later as to whether or not basic legal minimums are met such as providing habitat for all wildlife species, providing for all native plant species, and maintaining water quality, stream flow and aquatic habitats.

Other analyses can be done at this point as well, including identification of the costs that would be involved in maintaining these conditions on a sustained basis ... not only of the practices necessary to keep a specific age class distribution for timber, for instance, but given the rotation age and intensity of management included within that condition, how much additional cost would be incurred to protect this area from insects, to do fire presuppression actions, and given stand size and spatial arrangements defined by the condition, how likely is it that fire could travel through the area quickly.

Though this is just a first step of planning analysis discussed in my earlier comments, I think you can start to see the tenor of my comments.

The analysis I am calling for is the kind which tries to capture our full knowledge - that of the ID team, that of the rest of the Forest, that of the public and that of other knowledgable people such as researchers and those from academe. Each "forest condition" so developed becomes a hypothesis - if this condition is achieved some place on the forest, then it can be expected that this mix of stuff/goods and services/habitat for these species of wildlife - will be produced. Each, then, is also a target toward which management of the forest can be directed. (This is NOT building a linear program model focussed on timber harvest scheduling as in what is often thought of as the "traditional" way forest plans were done in the past).

The mixing of these forest conditions across the forest landscape can become a plan "alternative" and these can be analyzed so that all can take a look at the possible costs and results - and this provides fodder for creating new and different "alternatives" collaboratively - "Gee, if we expand this in this area and then add in some of that over there, would that help meet the needs of local recreationalists?" and on and on until either a set of alternatives that all agree are good alternatives or a single alternative around which there is consensus is developed.

This/these arrangements of forest conditions and their anticipated effects/results/production of varous goods and services then can become:

1. a target for developing objectives based upon or within the limits of anticipated budgets.

2. given the current condition and the "speed" at which these forest conditions could be achieved through time provies a basis for identifying the "threats" to achieving/maintaining these conditions through time such as identifying the fire hazard, hazards posed by insects, etc. For instance, if one arrangement puts all the management for spruce in a specific area without breaking it up with stands of other species and various age classes, then the probability of loss to spruce budworm would be higher in this arrangement than in others.

The combination of all of the above including the anticipated costs and anticipated environmental effects of the mix and spatial location of each of these forest conditions provides a basis for three questions facing EMS:

1. Are we doing what we planned to do?

2. Are we creating the forest conditions we anticipated.

3. As progress toward those conditions are being made, are we having the effects/goods and services that we anticipated? Where effects include such things as habitats, population levels of wildlife, quantity and quality of water, timber production, recreation opportunities, visual quality, biodiversity... etc.

Answers to these three questions can be the focus of monitoring and evaluation. And can be the focus of part of EMS to identify if there is a need to change course/adapt to new information based upon these answers and adapt to new research that enhances/supports/contradicts research and/or assumptions including in specific forest conditions.

As I stated earlier, often there are gaps in our knowledge and in research. When we were trying to do some of the above dealing with oven birds in Indiana, the only research available stated that they need 25,000 (or something like that) contiguous acres of mature hardwoods. We found colonies of these birds in areas of 160 - 320 acres. Turns out that the researcher was working in an area of a bit more than 25,000 acres and because he found them there, he figured this was what was needed. And, unfortunately, that was the only research we could find for oven birds. It was by quantifying this and doing some on the ground assessments/analysis, that we were able to address that species in the forest plan. Similarly we ran into the 60/40 cover to forage ratio for elk. Again, it turns out that this research was done in an area that had this mix of vegetation. A 60/40 worked in that case, but would it work every where? What about 65/35 or 83/17 like white tail deer or ...??? So by trying to capture the shared knowledge of everyone on a forest, the public, and researchers in and out of academe, we have developed a quantified hypothesis that says if we tweak the involved ecosystems in this manner, the following will be produced. We can then measure whether that is happening or not so that we can figure out the range of ratios that could provide habitat for elk and adjust the "desired" forest condition accordingly through time.

To me, this how EMS is best linked to forest planning. We are as specific/quantified as we can be in the forest plan so that we can test those hypotheses through time as we manage toward those forest conditions.

And as we do this, as the needs/wants of the public change, as more research is done, as species that were once thought extinct are found, we have something solid that we can adjust and then test that adjustment trhough time and management of the forest can improve through time. Isn't that, after all, what we want? Isn't that the entire purpose of this exercise - to improve management based on a continually improving understanding of forest ecosystems and how to achieve and maintain them in healthy/viable conditions to protect the productive capability of the forest for ever and ever... Amen!

Natural systems, what are oft referred to as "ecosystems" are constantly growing, changing and evolving and even today, our understanding is imperfect. In such circumstances, one way to improve our understanding and anticipate changes is to do the best we can do - and that means some quantification/specification and analysis in a collaborative manner - in identifying forest conditions and use these as hypotheses to be tested through time. Some thought that bringing wolves into the Yellowstone area would decrease the elk population and thereby help recovery and management of riparian areas. After wolves were reintroduced, the desired effect on riparian areas seems to have been achieved, but not because of a reduction in elk population, instead because with the threat of wolves, elk don't hang out in the riparian areas any more... they may use them, but they don't hang there like they did in the past. We had got the desired effects but not how we thought we would. That is new information and helps our management grow and adapt through time. Said another way, by quatifying/specifying what we anticipated, then measuring what happened as we took actions, we learned something and understand the dynamics of involved systems better than we did.

In short, I think there is a place for analysis. I disagreed with the focus on linear programming and timber harvest scheduling as the only analysis done in the first round of planning. As early as 1980, I and others investigated MOSS and other GIS systems to support that first round. Some of us had experience in GIS modeling at that time and thought that that could assist in developing just the kind of hypotheses discussed above as well as collaborative planning using GIS.

For those who like historical tidbits, in some ways, though slanted slightly differently, the development of SSAM (Steady State Allocation Model), goal programming and use of GIS through the University of Georgia in the early 1980's for Forests like the Chattahoochee and Oconee National Forests was an attempt at the same/a similar analysis as discussed above. If it could be done or at least approached in the early 1980's with the tools available then, it surely can be done today.

Tom Mitchell | May 5, 2005 10:59:11 AM

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