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June 05, 2006

Paper Promises: easy to create, hard to live up to

How many court cases is the Forest Service losing on the basis of "paper promises" that have proven "Oh So Easy" to create? To find these promises, open up any part of the multi-volume Forest Service Manual and Handbook and look for paper promises. Open up any of a number of "rules," like, say, the January 2005 "National Forest System Land Management Planning Final rule [PDF]." Open up any of various "Memorandums of Understanding" between the Forest Service and whomever. What do we find? I think we find a case study of how easy it is to make sincere, yet "impossible to comply with" promises that can and do come back to haunt government agencies.

The other day, following an Environmental Management System (EMS) legal-complaince trail, I wandered into the State of Utah Nonpoint Source Management Plan for Silvicultural Activities [PDF], 1998. It is addendum to the Utah Nonpoint Source Pollution Management Plan [PDF], 2000, itself an outgrowth of the Clean Water Act.

What struck me was that in a seemingly innocuous Memorandum of Understanding (appended to the "Plan for Silvicultural Activities") that led up to the development of the silviculture plan, the Forest Service agreed to 15 items, the State of Utah agreed to 10. Then my mutual affirmation, both entities agreed to 15 moreā€”and that's just for "silviculture" under this one agreement (signed in early 1993). Most of these agreed-to items recur, and must be revisited periodically. Have they been looked at recently? Who knows?

What struck me second, was that the Utah Nonpoint Source Management Plan for Silvicultural Activities is itself 91 pages long and filled with promises. The Utah Nonpoint Source Pollution Management Plan proper runs 110 pages, and includes Best Management Practices (BMPs) for things like, "Grazing Management on Rangelands," "Soil Stabiliztaion of Rangelands," "Riparian Area Management," "Riparian Area Stabilization," "Silviculture-Forest Water Quality Guidelines" from earlier-mentioned addendum, and "Hydrologic Modification." The US Forest Service, agreed to abide by these BMPs, along with other entities including the USDA Natural Resources Conservation Service, the US Army Corps of Engineers (pg. 96). Who knows how many promises are embedded in the BMPs and perhaps other aspects of this Plan?

Why do I say such promises are impossible to comply with? The promises themselves are not onerous. But if the Forest Service has no systemic reporting/updating system(s) for these promises then they do easily fall into the "impossible to comply with" category. The jury is out. But EMS processes may help us better sort out what promises have been made, by whom and for what, and how well the Forest Service is doing in keeping its numerous promises.

Posted by Dave on June 5, 2006 at 04:12 PM | Permalink


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