Diagram from Dept of Interior Adaptive Management Technical Guide
Adaptive management could be a component of a new planning rule. In previous posts we’ve discussed the need for adaptive governance. We’ve discussed the legal challenges. In a previous discussion thread, Martin points out what some consider a flaw in the 2005/2008 planning rule, where we “simultaneously deep six NEPA (at plan level) while forwarding some ill-defined adaptive management/EMS framework.” But is it possible to make the commitment to adaptive management? Does the Forest Service have the management and science capacity?
“Examination of existing literature on the implementation of adaptive management by the USDA Forest Service in the Pacific Northwest offers a few key lessons, however it also raises many interesting questions that cannot be answered with existing data. All of the literature indicates that the designation of areas devoted to adaptive management was not a successful strategy for promoting adaptive management. It appears that only one adaptive management area actually implemented anything that could be called adaptive management, and in that one case, the administrative designation does not appear to have been an important causal factor – instead, it appears that the designation occurred because of innovative research that was already occurring at the site.” p. 17
Here is a presentation from a 2005 conference from Forest Service research scientist Bernard Bormann on adaptive management in the Northwest Forest Plan. Here and here are some additional publications.
In his presentation, Bormann says that adaptive management is harder than they first thought because adaptive management was never considered a “core business”, and most adaptive management areas are now idle. There are institutional barriers including lack of leadership, low budgets, and lack of learning structures. One idea he has is that the next generation of plans might contain “learning objectives.”
There are many compelling reasons for the Forest Service to move from an “event driven” planning model (where large plan revision efforts occur every 15 years) to a more “continuous” planning model. NFMA itself says that the planning rule should “insure research on and (based on continous monitoring and assessment in the field) evaluation of the effects of each management system to the end that it will not produce substantial and permanent impairment of the productivity of the land.” 16 USC 1604(g)(3)(C) What will it take to successfully implement this requirement?
submitted by Dave Loomis
After World War II, the University of Chicago’s newly created Program in Education and Research in Planning was enormously influential in setting the direction of planning theory. Keynesian economists, pushed the faculty to define and systematize core areas of knowledge in planning, perceived essential to practice. It was the search for this core for the profession that led to the development of a generic model for planning in capitalist democracy and incorporation of ideas from various social scientific disciplines, including economics and political science. The rational planning model, became a guide in the profession and beyond as an approach to problem solving in the public sphere ;
1. Ends reduction and elaboration;
2. Design of courses of action;
3. Comparative evaluation of consequences;
4. Choice among alternatives;
5. Implementation of the chosen alternative.
The five steps were later simply described as “Desires, Design, Deduction, Decision, and Deeds. Reproduced, more or less, in countless presentations since, these steps describe a problem-solving framework for complex human enterprises. The model is both self-evident due to simplicity and unachievable due to its demands on resources and expertise. Chicago planners recognized complexities, including the elusiveness of the aim of serving the public interest and politics’ resistance to scientific analysis.
Even before publication, the rational planning model had its critics. It has suffered battering from countless quarters since. Yet, for about 20 years it remained the most widely subscribed planning theory. To this day, its logic can be found in the justifications and methodological outlines given in the introductions to most plans. It remains a major underpinning of planning school curricula. Moreover, theoretical and methodological work detailing and extending the model continues. This includes efforts to compare alternative rules for aggregating individual preferences, examination of the implications of risk and uncertainty, and consideration of the impact of new and faster computers on our abilities to ascertain public preferences and completion of the necessary calculations.
By drawing on Keynesian economics and policy studies in political science, the rational planning modelled to the incorporation of numerous social scientific concepts into planning offices. It highlighted planning’s role in correcting market failures related to externalities, public goods, inequity, transaction costs, market power, and the nonexistence of markets. Justifications for planning included reduction of nuisance and congestion, protection of resources, reduction of taxes or of public costs, provision of a stable business environment, and the improvement of environmental quality and livability. Planning borrowed the tools and language of cost-benefit analysis and operations research, including notions of decision criteria, multiple objectives, constraints, shadow pricing, willingness-to-pay, optimization, and minimization.
Criticisms and Extensions of Rational Planning
The incrementalist critique of rational planning gained wide circulation by the early 1960s. Political scientist Charles Lindblom (1959) suggested that comprehensive or .synoptic. planning, as he called it. was unachievable and out of step with political realities. He argued that political leaders cannot agree on goals in advance, as the rational model requires. They prefer to choose policies and goals at the same time. He thought that the rational model’s preoccupation with the comparison of all possible alternatives and their comprehensive assessment on all measures of performance exceeds human abilities. The relationship between science and policy choice was oblique at best. The real measure of “good policy” is whether policymakers agree on it. Lindblom’s alternative, incrementalism, calls for the simultaneous selection of goals and policies, consideration of alternatives only marginally different from the status quo, examination of simplified, limited comparisons among the alternatives, and the preference for results of social experimentation over theory as the basis of analysis.
If Lindblom’s late ’50s critique had shown a chink in the armor of rational planning, the social unrest of the 1960s brought a full frontal assault. Alan Altshuler’s (1965) doctoral dissertation examined the experience of land and transportation planning in the Minneapolis-St. Paul region. He found that planners were seldom able to achieve their objective I scientific aspirations. Their claims to comprehensiveness were not backed up by reality. Decision-makers often ignored their recommendations in favor of the wishes of politically connected stakeholders. Organizers of citizen input to planning processes railed against the often-futile nature of public participation.
The rational planning model gradually lost ground. Indeed, in the late 1970s, it was common to talk about a “crisis in planning theory” resulting from the loss of a center to the field.
A series of new directions emerged, focusing on planners’ facilitative roles in shaping decisions emerged. Often referred to as social learning theories, these contributions emphasized planners’ roles in bringing stakeholders together, gathering and sharing information, and helping social structures to learn from their experiences. Citizens and civic leaders, not planners, had to be at the core of planning if plans were to be implemented. The planner, acting as catalyst and boundary spanner strives to create a self-correcting decision structure capable of learning from its own errors.
By the late 1970s, planners recognized that the completeness with which they had embraced notions of science in their work had exacerbated their isolation from political decision-makers. Planning theorists began drawing from political philosophers who questioned mainstream social science.
Communicative planning theory asserted that through communicative strategies complementing their technical work, planners can alert citizens to the issues of the day, arm them with technical and political information, and otherwise encourage community-based planning actions. It would then be necessary for them to work in the midst of the wide variety of views expressed by diverse interest groups to formulate new consensus policies that might be widely supported.
Much recent activity has surrounded identifying better ways for planners to present arguments so that they will be persuasive in political and multicultural environments. One promising direction proposes that the often-quantitative orientation of urban planners matches poorly with the needs of decision-makers who are often moved by stories that convey human behaviors in terms they can understand. Storytelling is a proposed serious planning method that can accomplish what statistical analysis may never do. Other theorists are drawing on turn of the century American pragmatist philosophers to suggest that the emphasis on deductive reasoning in our statistical training is out of step with the more pragmatic. problem-solving orientation of most public decision makers.
The announcement went out today for the dates of the initial series of public meetings on a new planning rule, including:
A science forum in Washington D.C. on March 29-30.
Three National Roundtable meetings on April 1-2, April 20-21, and May 11-12.
Regional roundtable meetings in April:
The times and locations of the meetings have not been finalized. The Forest Service is working with the U.S. Institute for Environmental Conflict Resolution and its roster of collaboration consultants across the country to plan and assist at these meetings.
People collaborate best when they are in the woods talking about real forests and what to do with them. On the other hand, put them in a conference room to debate the merits of hypothetical silvicultural standards and you end up with the sort of nonsense we are seeing in northern Arizona. There several prominent, litigious environmental groups have made peace with local timber mills and workers regarding which trees to log on several national forests. The Forest Service, however, doesn’t want to play ball. Instead, its regional staff in Albuquerque is busily re-writing northern Arizona NFMA plans to include silvicultural standards that are inimical to agreements reached in the woods between the green groups and industry.
This bureaucratic passion play could be avoided altogether if NFMA plans were based on projects, not standards. Recall that NFMA requires only one thing of forest plans: “the planned timber sale program and the proportion of probable methods of timber harvest within the unit necessary to fulfill the plan.” Recall also that NFMA does not mandate one forest plan for each national forest. The Forest Service has broad discretion to decide the geographic scope of each plan, i.e., a single national forest can be divided into several NFMA plans.
Under the current two-tier planning regime, the Forest Service and its protagonists get to fight twice over what to do with national forests. The forest plan fight is all about the adequacy of standards, the aspirational zoning of land, and the magnitude of largely irrelevant allowable sale quantities. The second fight, at the project level, often repeats all of the above (because forest plan standards become ripe for legal challenge only when implemented in a project), with plan-consistency arguments thrown in for good measure.
Let’s just cut out the middle man altogether. A forest plan should be no more than the logging projects the Forest Service proposes for the next several years. The plan’s NEPA document (probably an EIS, but an EA is not inconceivable if the logging projects are environmentally modest) would evaluate alternatives, disclose effects, and form the basis for any required inter-agency consultation. The plan’s Record of Decision would set forth the site-specific projects to be undertaken, eliminating separate project-based planning and decision-making. Forest planning collaboration, if pursued, would consist of people talking in the woods about each of the projects.
Forest planning got a lot more complicated in March 1990 when the Forest Service issued regulations at 36 CFR 228.102 in accordance with the 1987 Federal Onshore Oil and Gas Leasing Reform Act, and recommendations by a National Academy of Sciences group chartered by the Act. Under these regulations, there are six steps to leasing, and Forest Plans in the 1990s and 2000s addressed the first step, sometimes the second step, and sometimes even a preliminary finding related to the third step:
Step 1: The Forest Service identifies what lands may be available for leasing.
Step 2: The Forest Service authorizes BLM to conduct leasing on specifically identified lands and under certain stipulations (in some cases no surface occupancy, controlled surface use, or timing restrictions). The Forest Service leasing analysis can range from forest-wide to a smaller specifically defined area, with specific binding requirements to each 40-acre area.
Step 3: After parcels have been identified for leasing, the Forest Service verifies that potential effects have been adequately considered, and that leasing is consistent with the Forest Plan.
Step 4: BLM does an assessment, and determines if there are any additional stipulations for a parcel.
Step 5: BLM conducts a sale.
Step 6: BLM issues the lease and begins the permitting process. The lessee must fill out an “application for a permit to drill” (APD) that includes a Surface Use Plan of Operations (SUPO). The Forest Service approves the SUPO after an evaluation of environmental consequences and stipulation consistency.
It’s been challenging for planners to decide how many of these steps to link with the forest planning decision. However, only the first step is truly consistent with the current idea of a broad, strategic forest plan. In dedication to efficiency and economy, many decision-makers may naturally conclude that combining the first two steps is more efficient and economical than keeping the decisions and their supporting analysis processes separate. However, in a number of cases to date, imbedding oil and gas leasing decisions in forest plan revisions has been neither efficient nor economical. In fact, combining the first two steps in a single decision-making process has led to significant delays and increased costs, has been unwieldy to manage, and has confused the public. Since the emphasis on forest planning is being “strategic”, it’s difficult to combine the more detailed analysis and prescriptive oil and gas decision-making.
This has been especially difficult because a leasing analysis requires a “reasonably foreseeable development” (RFD) scenario report. This report provides a quantitative (if possible) description of oil and gas occurrence and development potential, along with well projections, and specific information about probable characteristics of wells and productions. This report can quickly become dated, and the longer a planning process, the greater the risk of inaccurate information.
If we want to streamline planning, it may be better to make the oil and gas leasing decision as a “program” decision outside of forest planning, much like specific road by road travel management decisions are made outside of forest planning.
Thanks to the generosity of the Society of American Foresters, we can post articles from the Journal of Forestry May 99 edition on this blog. This edition of the journal focused on the COS Report. Today I’ll post the Norm Johnson article here.
Since 1999, we have tried many of the ideas that the COS brought forward. I would be interested in how you all think these ideas have worked.
I will post later this week on my experience with trying out some of these concepts.
I hope all of us will post responses to the NOI for the planning rule that we find interesting. Frankly, we all are a bit overwhelmed at this point (some people have sent me copies of theirs, plus we will all be able to access the comments when they are published on the FS website). I hope to pull out interesting ideas from them and discuss them here, but for now I only have time to post and hopefully someone else will pull out the ideas. All are welcome to post their own responses to the NOI directly on this blog.
John found various response letters linked on the WISE blog. Here’s the link.
Information on WISE, from Mike Dubrasich, the Executive Director:
The Western Institute for Study of the Environment is a 501(c)(3) non-profit corporation and a collaboration of environmental scientists, resource professionals and practitioners, and the interested public.
Our mission is to further advancements in knowledge and environmental stewardship across a spectrum of related environmental disciplines and professions. We are ready, willing, and able to teach good stewardship and caring for the land.
W.I.S.E. provides a free, on-line set of post-graduate courses in environmental studies, currently fifty Topics in eight Colloquia, each containing book and article reviews, original papers, and essays. In addition, we present three Commentary sub-sites, a news clipping sub-site, and a fire tracking sub-site. Reviews and original articles are archived in our Library.
Thanks to John for finding this blog..
Can’t really link to the comment directly but Tim B. comments here on the WISE blog
Just my opinion, but as a field-based NEPA practitioner with 29 years of experience, I would say that anybody seriously considering an environmental analysis covering all the various types of restoration activities that might need to happen on a landscape 50,000 acres or larger has their head very far up their ***.
Much too wide a scope; a broad purpose and need statement will generate large numbers of proposed actions, which will generate a huge number of environmental issues to address. All this would create a number of likely very complicated alternatives, and it would be difficult to determine what an adequate range of alternatives might be.
From an appeals and litigation standpoint, if a large number of activities are included in a landscape level NEPA analysis and decision, said decision and everything in it would all be vulnerable to challenge by any crank who did not like just one of the proposed actions. Given the size and complexity of such an analysis, that person could likely convince a Regional Appeals Reviewing Officer or a judge that an inadequate range of alternatives was addressed or some pet issue was missed. And the document would be so cumbersome a judge could be likely to throw the whole thing out because he couldn’t understand it – and he’d be right.
It would be much better to do a programmatic overview of such a watershed, like a watershed analysis to develop the rationale for implementation of whatever restorations actions, then do a set of some nice, neat, narrowly focused and short environmental assessments that would be much more bullet proof appeal and litigation wise.
Our congresspersons could help us out a lot if they would quit writing these complicated, prescriptive (why employ foresters and all other manner of specialists if some dudes in D.C. are deciding what can and can’t happen?) Region-specific bills and work on simplifying and clarifying the ones on the books that have been problematic for years. I also find it interesting that as far as I know, these guys never talk with/to the folks on the ground that really know what may and may not work.
Plans are underway for a series of National and Regional roundtable meetings in March and April for public input and dialogue on a new planning rule. Details will be posted on the Forest Service planning rule website as they become available.
Since we spend some quality time on this blog talking about NEPA, you might be interested in commenting on this draft CEQ guidance. the climate change and mitigation and monitoring might be particularly relevant to our discussion, since the draft guidance seems to extend the NEPA regs to past implementation of the decision. Here are some questions relevant to federal land management, and the bolded ones seem to have to do with LMPs:
CEQ also requests comment on land and resource management issues, including:
1. How should NEPA documents regarding long-range energy and resource management programs assess GHG emissions and climate change impacts?2. What should be included in specific NEPA guidance for projects applicable to the federal land management agencies?
3. What should be included in specific NEPA guidance for land management planning applicable to the federal land management agencies?4. Should CEQ recommend any particular protocols for assessing land management practices and their effect on carbon release and sequestration?
5. How should uncertainties associated with climate change projections and species and ecosystem responses be addressed in protocols for assessing land management practices?
6. How should NEPA analyses be tailored to address the beneficial effects on GHG emissions of Federal land and resource management actions?
7. Should CEQ provide guidance to agencies on determining whether GHG emissions are “significant” for NEPA purposes. At what level should GHG emissions be considered to have significant cumulative effects. In this context, commenters may wish to consider the Supreme Court decision in Massachusetts v. EPA, 549 U.S. 497, 524 (2007).
Here’s the link.
New CEQ NEPA Guidance In conjunction with NEPA’s 40th Anniversary Celebration, CEQ is publishing three draft NEPA guidance documents for review and comment. Below are links to the draft guidance documents and instructions for submitting comments:
- ESTABLISHING AND APPLYING CATEGORICAL EXCLUSIONS
Comments are due 45 days after publication of the Federal Register notice.
Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa
- MITIGATION AND MONITORING
Comments are due 90 days after publication of the Federal Register notice.
Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa
- CONSIDERING GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE
Comments are due 90 days after publication of the Federal Register notice.
Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa
Additional information is available at http://www.whitehouse.gov/administration/eop/ceq/initiatives