Forest Environmental Management Systems

EMS to the NEPA Rescue!

On Monday James Connaughton, Chairman of the Council on Environmental Quality, issued a Federal Register notice [PDF] of a "proposed guide" — Aligning the Complementary processes of Environmental Management Systems and the National Environmental Policy Act [PDF].

The proposed guide promotes EMS as a remedy to the governments' long-standing inability to "address the full range of ongoing activities (and products and services) … with the intent to continually improve environmental performance." And all this time I thought that was the intent of NEPA compliance. The CEQ has long stressed the importance of programmatic to site-specific linkages, connected actions, cumulative effects, and more.

One way to view the notice and guide is that CEQ is taking the next step along the road to better compliance with NEPA. Another, darker way to view the notice and guide is that the federal government is taking yet another step along the path of process gridlock. As we opined earlier, there are three EMS paths forward:

• EMS buries the Forest Sevice—in process and "paper,"
• The Forest Service buries EMS, or
• EMS transforms Forest Service culture to adopt adaptive management.

Which path will be taken is still a significant question.

Let's pursue the latter path a bit. Adaptive Management is a remarkable idea, and stands a reasonable chance of transforming (for the better) both landscapes and institutions. The Resilience Alliance, for example, is dedicated to that particular proposition.

But there are serious omissions in the description of adaptive management in the "proposed guide," relative to the way adaptive management is commonly framed. In particular in the proposed guide, adaptive management is framed in the narrow confines of what is referred to as a "'predict-mitigate-implement-monitor-adapt' model." that "adjusts actions to foster desired outcomes and reduce undesired ones." Nowhere to be found is the 'surprise, uncertainty, novelty and ignorance' side of the adaptive management endeavor. This is a serious, perhaps fatal omission in the guide.

To gain a better perspective on the two-part harmony of managing both the expected and the unexpected, take a look at, e.g. Karl E. Weick and Kathleen M. Sutcliffe, Managing the Unexpected.., Lance H. Gunderson and C.S. Holling (eds.), Panarchy: Understanding Transformations in Human and Natural Systems, and T.F.H. Allen, Joseph A. Tainter, and Thomas W. Hoekstra, Supply-side Sustainability.

Will EMS prove to be the saving-grace for NEPA compliance? Or will EMS prove up on an anonymous USFS employee's (who came with EMS experience from the private sector) remark that: "EMS is an expensive excuse to pay consultants to tell us what we already know." The jury is out.

E-MESS: Three Paths Forward

Last week an EMS fellow-traveler and I were discussing process requirements, Forest Service agency culture, and our hopes, dreams, and nightmares regarding the next few years.

We concluded, that very likely EMS process requirements would bury the Forest Service or the FS would find means to bury EMS—deep-six it. But we also discussed a third path. On the third path we caught a glimpse of a positive future where EMS would transform the Forest Service into an agency that actually knows its process requirements and no longer takes pride in ducking its own directives.

As the process requirements of EMS become ever-more-clear and more widely shared, more and more FS folks are getting the "deer in the headlights look." Early FS EMS arm-waving suggested that the similarities between our extant and emergent planning and adaptive management processes and the EMS world would make the transition easy and relatively quick. But the realities are beginning to dawn differently and we are becoming aware , rhetoric aside, that we are not an adaptive management organization, and will face much difficulty in the transformation.

It will prove interesting to see which path the Forest Service takes. If the first, the agency may not survive much past its Centennial celebrations. On the second path, agency immune system responses will trigger to reject the EMS processes and its emphasis on disclosure, process compliance, process improvement, and so on. On the third path the Forest Service might use EMS as a catalyst to become an adaptive management organization. The jury is out! The challenge is ours. Which path will we follow?

• EMS buries the Forest Service
  
• Forest Service buries EMS
  
• EMS transforms FS culture into Adaptive Management

Blogging in Government: Catch the Wave

Andy Budd is a blogger in the UK. He recently shared his "take" on Blogging in Government (Dec. 8, 2005). Here are Budd's key findings:

• …weblogs were great for internal communication and a way of cutting down the huge weight of email most large companies are drowning in.
  
• …weblogs were essentially free (or very cheap), lightweight and disposable content management systems.
  
• …blogs could be used for internal knowledge management, by encouraging key staff to blog their collective knowledge rather than keeping it locked up.
  
• …benefits of blogging to management ... how staff blogs could help managers know what was going on in their organisation. Conversely, it would also let staff know what their manager was doing.
  
• …governments could use external blogs to connect with the people they served. An external blog could really help demystify the workings of government, while at the same time creating a sense of empathy and trust.

Read "the rest of the story" for Budd's advice on prudent use and managment of blogs and bloggers:

How I Learned to Stop Worrying and Love EMS

I'm not sure when it happened, but sometime recently I began to love EMS—likely for all the wrong reasons.

Some observers have found forest service planning and management to be strange indeed. So a Dr. Strangelove analogy may fit. Dick Behan long ago suggested that it was "Time to Punt" when the agency codified planning into law via RPA/NFMA. Before that Sally Fairfax declared NEPA to be a "Disaster in the Environmental Movement," that proliferation of paper would overshadow any efforts to manage the land. Herbert Kaufman, author of the much-touted The Forest Ranger suggested that he envisioned deep trouble ahead for the forest service as he was researching his book. That trouble has since come to pass. See Kaufman's The Paradox of Excellence.

As for me, I see the agency at best trying to make some sense of its actions and the actions of others in the context of adaptive management. At worst, I see all as bureaucratic bungling, careerism, and professionalism run amok. The Forest Service has been accused as being maladaptive rather than adaptive in its approach. The 2005 Regulation for NFMA—the "new rule"—is supposed to change all that. Some of us are doubtful. Enter EMS!

EMS is a system developed from and structured to deal with closed loop manufacturing processes, not open adaptive natural and social systems. It will prove challenging indeed, I suspect, to see how such a system will overlay the "social mess" of forest service planning and management.

If we work EMS up with care, it may daylight the truly complex nature of our undertaking and the political wickedness of the decision-framing and decision-making faced by the agency. In this sense EMS can be a catalyst to aid the agency in moving from maladaptive to adaptive behavior.

If we work EMS up with care for the forest service we will necessarily approach the task much differently from what many other organizations have done, since our "social mess" of wicked problems and open, adaptive systems cries out for an approach much different from those in use for closed-loop manufacturing enterprises.

If we work up EMS blindly, on the other hand, we'll find it to just one more bureaucratic burden, one more way that practitioners are drawn into paper chases and process-chases that detract from our ability to interact and adapt to the ever-changing systems that enfold the agency. In this light EMS may become more a cancer than a catalyst.

The challenge is to disallow EMS to grow into a cancer that will on its own gobble up money and energy without doing the work of adaptive improvement. The challenge is also to nurture EMS into a true support system that helps ride herd on current rogue behavior in other management systems.

My cynical side tells me that the forest service will do with EMS what it did with Planning and NEPA, and Sally Farifax and others with have a heyday with it as the latest, greatest paper chase. My hopeful side says, "Let's work to make it otherwise."

Interrelating Forest Planning and EMS

Like EMS, forest planning is a system. Both are subsystems in adaptive management (AM), with EMS fitting more into AM monitoring and evaluation. Remember that the last "Committee of Scientists" informed us that a forest plan was, paraphrasing, a loose-leaf compendium of all decisions great and small that affect the management of the forest. The Committee of Scientists' language is all-encompassing, rendering the forest plan an interrelated information system. In what follows I'll try to be more specific as to components and interrelationships, so we can figure out how, in particular, the forest plan revision might link up with EMS.

Forest plan revisions receive much Forest Service attention these days. But it is just one event in a ring of events in the plan creation set of AM subsystems. We also have a set of plan implementation subsystems, a set of plan monitoring and evaluation subsystems, etc. Each of these subsystems has its own 'plan, do, check, adapt' learning loop, and all are interrelated one with another.

I use subsystems language because we have a set of plans that logically tier to the forest plan (or are a part of the forest plan family, if we use the Committee of Scientists language): fire management plan, vegetation management plan, hydrologic systems plan, travel management plan, etc. And often these plans have sub plans tiered below them.

Our challenge with EMS (and with forest planning) is to make sense of these systems, and figure out who plays what roles in administering, monitoring, and updating them, as well as to figure out how they interrelate with all else that we do in realms like law, policy, professional practice, and so on.

Forest Plan Revisions are designed to be aspirational, identifying desired conditions, wide-ranging objectives, perhaps a few guidelines, identifying general suitability of areas for differing types of uses, etc. Most of the details are left to sub plans. I see two potential ways EMS might be linked to forest plan revisions.

Two Paths to Link EMS and Forest Plan Revisions

One path we might follow to link an EMS and a forest plan revision might be called "the path of least initial EMS commitment." In this path, we would keep the forest plan revision quite ethereal, identifying desired conditions very broadly, and working our objectives up fuzzily as to how to bridge the gap between existing and desired conditions. This would be in keeping with a philosophy more aligned with scenario planning, where the intent of planning is to "rehash the past, and rehearse the future." Following this path we would commit ourselves to little or nothing in the plan revision, leaving that task to sub-plans, and other activities. Following this path I see no direct links to EMS in the forest plan revision, leaving such to fleshed out in sub plans, program development, and other activities. Am I wrong?

Another path might be called "the path of greater initial EMS commitment." (Anybody have better names? Different paths?) Following this path our forest plan revision objectives would be more tightly defined, not quite getting to activity schedules, but rather committing ourselves to "aspirational" rates of implementation for various general courses of action to attempt to move, say, vegetation from current conditions to desired conditions.

Following this path I see definite linkages from the revision documents to an EMS. I see EMS-related activities (that have environmental aspects and impacts) being identified in the forest plan revision as well as the EMS with "operational controls" being related to various processes at work in the forest and "objectives, targets, and programs" identified that will attempt to move the forest toward desired conditions. Such would provide a beginning to both an EMS and to at least the implementation side of forest plan monitoring and evaluation.

NEPA Challenges

Following the first path, there is a greater chance that NEPA compliance for forest plan revision decisions will be relatively easily effected. The big challenges for NEPA compliance would then rest with the sub plans, and any plans or policies that may be developed programmatically above those sub plans that direct or influence programs or activities.

Following the second path, there is a greater chance that NEPA compliance for the forest plan revision will be a more complicated task, and may well indeed require an EIS, unless the plan is specifically "categorically excluded" from such. Interesting political games!

Nuance

A national fire plan with an associated EIS, for example, may not directly interrelate with a forest plan revision decision, but might more directly relate to a subsequent fire management plan for the forest.. Similarly for a national OHV rule, and so on. I suspect that I would consider the NW forest plan to be more closely interrelated with a forest plan revision than I would a national fire plan. But all is the stuff of complex systems, complex and wicked problems, etc.

We have to remember that both EMS and forest plans are the stuff of systems and subsystems and complexes of actors, arenas, decisions, actions, feedback, and if we are lucky some organizational learning.

Other Paths?

Open… Let's hear from others…….

Adaptive Management and EMS

Adaptive management (AM) is an enigma. On the one hand it is as simple as learning by doing, thinking, and paying attention to what you've done; comparing what you thought might happen relative to what did happen and readjusting your thinking accordingly.

On the other hand it is as complex, as understanding the transformational processes at work in environmental and social systems, then melding management processes into these complex, adaptive systems in ways that prove complex and adaptive themselves.

Most practices in adaptive management work from a 'change' or 'problem' focus. Something changes or needs to change, as determined from sensing, and sense is made of the situation in order to move the organization forward. In some ways learning is achieved, and if passed on throughout the organization, organizational learning is claimed.

Change may be a small, effected at micro scales, or at larger scales up to and including the organization itself or even society. That's why Gunderson, Holling, and Light titled their compilation of AM writings Barriers and Bridges to the Renewal of Ecosystems and Institutions, and Gunderson and Holling titled theirs Panarchy: Understanding Transformations in Human and Natural Systems.

Adaptive ecosystem management is interrelated with, and built from, among other things:

On the management side: Charles Peirce and John Dewey's Pragmatism, Herbert Simon and James March's Bounded Rationality, Chris Argyris and Donald Schön's Action Science, W. Edwards Deming's Management Method, Peter Senge and others' Organizational Learning, Karl Weick's Sensemaking, and Margaret Wheatley and Myron Kellner-Rogers' A Simpler Way.

On the politics side: Pragmatism, Pluralism, Participation.

On the science side: Complex, Adaptive Systems Theory, Ecology, etc.

Environmental Management Systems

The environmental management systems (EMS) approach also builds from some of the basic building blocks of adaptive management. But at least in my interpretation, whereas the primary focus of adaptive management is learning from a variety of sensing mechanisms including 'science and nature,' assessment, planning, doing, evaluation and feedback, etc. EMS tends to focus more narrowly on the learning acquired by primary feedback, design and adjustment of operational controls, etc. That is, EMS is more tightly focused on the evaluation and monitoring aspects of adaptive management.

EMS and Forest Planning

One challenge facing us is to figure out the interrelationship between EMS and the evaluation and monitoring (E & M) required by the 2005 NFMA rule. Even though not explicitly stated, we know that E & M spans the space of 'implementation, effectiveness, and validation' monitoring, evaluation and learning. I argue that EMS does too, although in the initial stages we will see much more tight focus on implementation. Our challenge will be to design EMS in ways that are not too complex and cumbersome that begin AND end with implementation, and associated single-loop learning.

Another challenge will be to design our EMS system so that is doesn't become a tail wagging the dog of adaptive management. To do so will be to repeat the mistake we made with comprehensive rational planning when planning over-dominated an adaptive management approach.

A final challenge will be to develop the type organizational culture that encourages individual and organizational learning. This challenge and promise of organizational betterment, is highlighted in Adaptive Management: A Tool for Conservation Practitioners, from the Biodiversity Support Program.