Forest Planning Directives

Can Blogs Help in Updating Directives and Other Quality Improvement?

Before we ask whether web-logs (blogs) might help in updating directives, we might ask whether this blog helped in the developing R4 comments on the NFMA Planning rule. In particular, did “Forest Planning Directives: What’s right, What’s wrong” help Intermountain Region employees in working up a consolidated regional response?

The answer to the latter question is, “Probably not.” Why? I believe there are several reasons for this failure:

Possible reasons why the “Forest Planning Directives” blog didn’t help:

• Forest Service field-level people are overwhelmed with too much work and are too stressed to work up comments on something as esoteric as "directives."
  
• Forest Service field-level people believe that this work is rightly done by the WO, in consultation with the ROs.
  
• Forest Service people are fearful that if they speak major-league ill against draft directives (or anything else) there will be repercussions, perhaps subtle but repercussions nonetheless.
  
• Forest Service folks are not familiar with web-logs, and are still captivated by email.
  
• Regional sponsors (particularly me) did not advertise the blog well to chum folks into using it.
  
• People may be overwhelmed (or underwhelmed) by the task of redoing the massive NFMA draft directives. Underwhelmed because the NFMA directives have never been wildly acclaimed as helpful. Why bother to work on changes to something that isn’t perceived helpful anyway—and will likely not be abandoned by “the powers that be?”
  
• People who have submitted comments on things in the past, know all-too-well that there is little chance that what they say will even be read, let alone attended to.
  
• There a feeling shared among some, perchance misplaced, that our organizational morale is at an all time low.

Might blogs be helpful in directive review, and quality improvement in general? Perhaps, assuming major organizational malaise can be overcome.

Ways that blogs might help in quality improvement efforts:

• Quick way to share information, suggestions, policy and practice proposals, etc. and acquire feedback. There is an added bonus that all stakeholders can see feedback and comment on the feedback as well as original suggestions, etc.
  
• Non-intrusive way to share information – only those who want to be informed will take time to look, and can do so at their discretion. (This can only happen, however, once people become accustomed to checking-in on a regular basis, and once system operators learn to structure blogs so that those who want blog entry reminders can get them in time frames that work for them.)
  
• Automatically creates a historical chronology that allows for tracking of progress in many ways. With embellishment we ought to be able to track areas of agreement and disagreement that tend to shape-shift through time.

Some comments on FSM 1920

FSM 1921.03g (p. 25):  Replace “Monitoring and data collection…should…” to “Monitoring and data collection shall.”  I understand we’re trying to avoid unnecessary ‘shalls,’ but looking at the direction contained in this part, I can think of no reason why a Forest could be justified in not observing it.

FSM 1921.08 (p. 29):  Delete #8 (“Follow the plan model…”).  The Plan Model is a useful reference and may be helpful in guiding preparation of Plan Documents, but it requires a great deal of interpretation and adaptation to the specifics of an individual Forest’s circumstances.  In any case, the true ‘model’ of a Forest Plan is continually evolving, especially in these first few years.  Requiring Plan Documents to follow the Model in its current stage of development will limit the creativity and flexibility needed as we all learn to implement the new Rule.  Also, this requirement is unnecessary for establishing consistency across Plans, since the required 5 Plan Components and other parts of the Plan Set of Documents are indicating in many other parts of the Directives.

FSM 1921.12 (p. 30): Modify #2 to read: “The statement of desired conditions is the plan component that describes the attributes of ecological, economic, and social sustainability that characterize or exemplify the outcome of land management.”  This strengthens and clarifies the need to link desired conditions to elements of sustainability that are considered most important for the Forest.

FSM 1921.17d (p. 37):  The fact that “land where timber harvest could occur” includes both lands suitable for timber harvest and lands suitable for timber production (as defined in #1 of this section) probably ought to be clarified.

FSM 1921.17g (p. 39):  The requirement that “[timber management projections] describe forest management systems, harvesting levels and procedures… and must reflect proposed and possible actions, including the planned timber sale program and the proportion of probable methods of timber harvest” seems to be a fundamental contradiction of the principle that Forest Plans do not authorize on-the-ground activities.  The argument will be made that if we can make such specific assumptions about timber harvesting activities, then we should be able to estimate the environmental effects (EIS) of such activities.  The premise behind the proposed CE is that Plans do not have specific environmental effects.  Either that premise needs to change, or the proposed CE must be dropped, or we must be more clearly instructed about how to make NFMA-required timber projections without making specific assumptions about on-the-ground activities.

FSM 1921.21 (p. 42):  The statement that “the Responsible Official has full discretion on deciding how and when to involve the public in providing input for management review” leaves open the possibility that there will be no public involvement in management review.  Assuming this is not what the directive intends, something to the effect of ‘the public must have meaningful involvement in the management review, but the Responsible Official has full discretion on how and when it will be solicited’ would be more appropriate.  If the directive does intend to leave open the possibility of no public involvement, then the cynicism of the entire body of regulatory direction will quickly become apparent and the public trust will suffer severely.

General comments about FSM 1921.3 (p. 43) and related direction: 

• There are semi-redundant logics throughout the planning directives, including Plan Vision/Strategy/Design Criteria v.v. 5 Plan components, EMS v.v. monitoring, Management Review v.v. Comprehensive Evaluation, Performance Measures v.v. Objectives, etc.  These conceptual models must be streamlined or better integrated with one another throughout the directives; currently they serve primarily to confuse the planning process.

• The 5-year comprehensive evaluation may identify need for change relative to one or more Plan Components.  When would such a change constitute a Revision, as opposed to an Amendment or an Administrative Correction?  I have found nothing in the Directives to clarify this.

FSM 1921.52 (p. 50):  In #1, change “should” to “shall.”  There is no good reason why a Plan should not be required to identify monitoring questions.

FSM 1921.7 (p. 54):  Add after first sentence of last paragraph: “Desired Conditions shall reflect those elements of sustainability to which the Forest should make the most meaningful contributions.”

FSM 1921.71 (p. 55): In first paragraph change to, “the evaluation must integrate the relevant elements of sustainability…”

FSM 1921.71 – Exhibit 1 (p. 56): The social and economic elements of sustainability should be organized based on the RPA Assessment Criteria (National Sustainability Criteria/MPCI), in the same way that the ecological elements are.

Professional Practice via Manuals and Handbooks: An Iverson family tale

On the way to work this morning I thought about manuals and handbooks guiding the professional lives of my brothers and sisters. First I tried to imagine my folk singer brother relying on a manual and handbook for his gigs. Horrible thought! Then I thought about my artist sister relying on a manual and handbook for her landscapes and other works. No better! Then I thought about my investment banker brother relying on a manual and handbook in moving money around the bond markets of the world. Nope! Then I thought of my brother-in-law managing a large county mental health program. No manual and handbook there either. Finally I thought of my small-business-entrepreneur sister and brother. I couldn’t imagine them relying on a manual and handbook either.

So I switched gears. How about my medical practitioners? How about my financial advisors? And so on. The only ones I could imagine following closely a plan would be house and general construction contractors. But here too there is no "manual and handbook."

Lastly, I thought about other aspects of my professional life. During the decade and a half I spent in city government I don’t think we ever felt naked without manuals and handbooks, although we did have our share of ordinances, building codes, laws, and what not. During the short time I spend in the corporate offices at Weyerhauser Corp. I don’t remember seeing people consulting manuals and handbooks at every turn.

A question lingers: Why is it that the Forest Service tries to reduce ALL to manual and handbook directives? Why would anyone try to reduce the art of strategic thinking, strategic planning to manual and handbook directives? Have we bought into some fallacies regarding how the world works? Is this ‘normal’ government practice? Maybe. But maybe that’s why there is so much pressure to outsource.

When I first saw the Prototype Plan teams playing with new ideas on planning I said to myself, “Finally, we have escaped our rational planning, control freak mentalities.” But my relief was short-lived. First came the NFMA rule to shatter my hopes and dreams. Then came the Manual and Handbook directives. So now once-again it is likely to be:

Back the inner sanctum of the bureaucracy! Keep your eyes on the manuals and handbooks and try to remember that somewhere ‘out there’ there are forest and trees and birds and fish and other charismatic megafauna (along with the many other creatures great and small). Mark Twain called these other creatures the higher animals. I wonder if he met some goverment planners who helped him draw that conclusion?

Don’t dwell on what it might take to manage ourselves and other humans and our relationships with what we call “Nature.” Instead, manage the Manuals and the Handbooks and see if there is any time left to think about land, and natural and social systems workings. If there happens to be any time left over, be sure use it to build ever-more-complex manuals and handbooks.

To get a feel for exactly how the Manuals and Handbooks (and the mentality that creates them) helps, I recommend that you read or re-read Kurt Vonnegut, Jr.’s “Harrison Bergeron.”

Hopes, Dreams, and Advice for NFMA Directives review: Iverson edition

Assuming that we couldn't yet rid ourselves of the National Forest Management Act (NFMA) Planning Rule, my first hope was for a one simple sentence Rule that went something like, “Every ten to fifteen years revise your forest plan.” That way people would focus on the RPA/NFMA law (badly in need of reform since the world no longer believes in the type comprehensive, rational planning it once did), and other law and policy that guides the management of the national forests.

One might have added a sentence a la Jack Ward Thomas’ admonition, “Tell the truth, obey the law, and practice ecosystem management.” But ecosystem management is now pretty much the expectation – what we all know we ought to be about. And having to tell folks to tell the truth and obey the law is at best a bit embarrassing. This is the same kind of embarrassment that stems from phrases like, “The responsible official must take into account the best available science.” What else would a “responsible official” do? Take into account the worst available science, mediocre science?

My one-sentence regulation didn’t happen, of course. In fact the NFMA Rule embeds language that kicks directive down to manuals and handbooks, just like the now-archaic NFMA law contains language directing the Forest Service to develop planning regulations.

So here we are. In critiquing the NFMA Rule Directives, my proposal is that we pay most of our attention to the FS Manual, part 1920 and elsewhere, and limit what is there to the bare minimum. We ought to devolve all Handbook materials to technical guidance and use the Handbook “placeholder” only to point to technical guidance repositories.

Risking much rent seeking by specialists who love to “direct,” we must remember that if there is one right way to do things, and our wish it to “direct” such, then it ought to be in the Handbook.

My advice still stands: No Handbook for planning!

Manual/Handbook Review and Writing Standards: FSM 1110

Here is a link to FMS 1100, Chapter 1110 "Directive System Structure and Standards" http://www.fs.fed.us/im/directives/fsm/1100/1110.rtf

This should help all in working up "proper" directives, and in reviewing draft work of others.. dave I.

Any role at all for NFMA Directives?

I have struggled for the last few days to better understand management and planning systems and ask myself whether we ought to keep any parts of the "interim directives." As usual I answer, No! You may find my thoughts amusing. You may find them bemusing. There is an odd chance you may find my thoughts enlightening. Here they are:

Land Management Planning as an Embedded Process

We have many processes (or systems) to help us manage the national forests and other public lands. Problem is these systems are often fractured and fragmented, and sometimes work at cross-purposes. We have tried to run our systems as pieces of a well-oiled machine. But it can't work that way. The world is too complex for that, and sometimes politically wicked as well. A better management model is one that mimics nature, one comprised of self-organized complex adaptive systems. See Margaret Wheatley and Mryon Kellner-Rogers A Simpler Way for more.

Looking at things hierarchically, in a complex systems frame, we can see land management planning systems embedded in planning systems, embedded as part of "management systems."

Forest Service Management Systems
It proves helpful to see the map of interrelated systems that aid in adaptive management/organizational learning. Commonly recognized systems include:

• Assessment Systems
• Evaluation Systems
• Monitoring Systems
• Inventory Systems
• Planning Systems
• Monitoring Systems

Add to these supporting systems, like:

• Education and Training Systems
• Personnel Recruitment and Support Systems
• Budgeting and Finance Systems
• Information Technology Systems
• And so on

Now overlay all these with various "functions," like:

• Vegetation management (timber, range, etc.)
• Bio-physical resource management (soil and water, wildlife, plants, etc.)
• Fire management (suppression, pre-suppression, etc.)
• Facilities management systems
• Recreation management systems
• And so on

Finally overlay all with what we refer to as "Line Management," with about:

• 900 District Rangers, who report to
• 120 Forest Supervisors, who report to
• 9 Regional Foresters, who report to
• 1 Chief Forester

Now we can begin to get a glimpse of the complex nature of the management systems that we attempt organization with. The trick to all this is to make sure that the systems are not only complex, but adaptive and purposefully interrelated as well. No small order. And there are traps along the path we need to be aware of.

The “Rule” a Basis for the Directives?

The planning rule provides in several locations for the development of further requirements in the Forest Service Directives System.  In reviewing the draft directives it might be interesting to consider them in light of that language in the rule.  Following are quotes from the rule language I was able to find that reference further guidance to be provided in the directives. 

§ 219.1(c) “The Chief of the Forest Service shall establish planning procedures for this subpart for plan development, plan amendment, or plan revision in the Forest Service Directive System.”

§ 219.2(c) “…Requirements for project or activity planning are established in the Forest Service Directive System.  Except as specifically provided, none of the requirements of this subpart applies to projects or activities.”

§ 219.5(c) “Pursuant to § 219.1(c), the Chief of the Forest Service shall establish procedures in the Forest Service Directive System to ensure that appropriate EMSs are in place.”

§ 219.12(b) “NFMA requirements. (1) The Chief of the Forest Service must include in the Forest Service Directives System procedures for estimating the quantity of timber that can be removed annually in accordance with 16 U.S.C 1611.

   (2) The Chief of the Forest Service must include in the Forest Service Directives System procedures to ensure that plans include the resource management guidelines required by 16 U.S.C. 1604(g)(3).

   (3) Forest Service Directives System procedures adopted to fulfill the requirements of this paragraph shall provide public involvement as described in 36 CFR part 216."

§ 219.13(b) Submitting Objections. “…Specific details will be included in the Forest Service Directives System.

Policy statements in FSM

enclosed is a document I put together to take a comparative look at the various policy sections in FSM 1900.  It takes 1903, 1920.3, 1921.03, and 1922.03 and relates them to the regulations and the handbook, with my suggestions for deletions and/or edits, including comments.

I incorporate it here as a download to simplify the "track changes" method used.

Download id_1920-policy_rewritten.doc

Chapter 43: Ecological Sustainability

Page 11:  Introduction, par 1, sentence 2

If this sentence is going to cite the CFR, it should do so completely; otherwise, confusion will result.  The CFR says that the goal is “to contribute to sustaining native ecological systems by providing conditions to support diversity of native plant and animal species in the plan area.”  The focus on “native” is absent from the introduction.  The aspect of “sustainability” is absent from the introduction.  The limitation of “within their ranges” is absent from the rule.  If this introductory section does not reflect what is in the rule, the field will have difficult when it comes to implementing. 

o     Suggest that the second sentence of the introduction be replaced with the following ”The primary focus is at the scale of the ecosystem, in developing plan components to provide a framework to contribute to sustaining native ecological systems by providing conditions to support diversity of native plant and animal species in the plan area (36 CFR 219.109(b)).” 

Page 11:  Introduction, par 1, last sentence

This sentence states that a species-specific approach “may be necessary”; however, FSM 1921.7 states that for the federally listed species, species-of-concern, and species-of-interest, existing information “should be assessed. . . .”  Which is it?

o     Suggest the terminology match. 

43.1 – Ecosystem Diversity

FSH 1909.12, Chapter 40 Science and Management

Chapter 41-Scence [Reserved]:  It does not help with review that the Science chapter is still missing.  This was a major piece of the 2000 version of the rule that was removed from the 2004 version.  How this is handled via directives will be important.