There is power in “framing” political discourse and policy development: Those who control the frame, control the content, the context, and more. In short, “He Who Sets the Frame Controls the Game”.
What just happened in the NFMA Rule Development game? The comment period closed yesterday. The frame was set by rehashing experience in planning, then constructing five “Substantive Principles for a New Rule” and three “Process Principles” (each with a battery of related questions). How many people, do you suppose, chose to respond outside that frame? How powerful was the frame?
In my formal comment I said that I wish the Forest Service had simply established a blog, and begun with a simple question, like: “Given the noble ideas embedded in RPA/NFMA (Wikipedia link) and other principal laws related to the Forest Service, how might the planning/management process of the USDA Forest Service be improved?” Then I said that I hoped someday the FS would indeed engage the public in meaningful inquiry as to its operations and the management of the national forests. Not yet, though. I added:
Unfortunately but not unexpectedly given the RPA context, these regulations have been dubbed a “planning rule.” If one looks at RPA/NFMA through the lens of adaptive management, the process outlined in Section 6 looks much different than if one views it through the lens of comprehensive rational planning. Unfortunately, all previous “NFMA rules” (and associated forest plans) have been developed under the “comprehensive rational planning” frame.
We must remember that the Clinton era Committee of Scientists recommended that a forest plan be viewed through an adaptive management lens — viewed, figuratively, as a loose-leaf compendium of all assessments, decisions, monitoring and evaluation efforts, etc. that affect an administrative unit of the national forest system. …
If so-called “planning rule” development is viewed, once again, as yet-another comprehensive, rational planning exercise, the agency will be mired again in analysis paralysis and process gridlock. If viewed as a mandate for adaptive management with a heavy dose of collaborative engagement on the part of other agencies, other governments, and citizens, then a whole new world of opportunity and challenge opens up to the Forest Service.
Please do not fall into the ‘planning trap’ again.
Now we wait for “next steps” and for a “Draft Rule.” And we hope that we — all of us, both the Forest Service and the public — won’t be trapped in an inappropriate “frame.” It is not that I believe that the Forest Service deliberately manipulated the “frame” in this case. Just the opposite. I believe the Forest Service fell into common decision traps: “frame blindness”, “lack of frame control”, “plunging in”, others?
Army Officer at Nine Mile Camp, Mt. Baker National Forest, 1933, photo by W.L. Baker
The more we look at the literature, the more evidence we find that our current NFMA management system doesn’t align with the current thinking about land use management. We gravitate toward adaptive management, but we don’t quite grasp it yet.
A slight twist on the adaptive management idea is the concept of “adaptive governance.” The word “governance” instead of “management” recognizes the collaborative aspects. It’s similar to the idea of “adaptive co-management” that Dave Iverson has described in his post here and here on this blog, citing the summary from the Resilience Alliance.
The concepts of adaptive governance are worth considering in the forest planning and management system for a couple of reasons. First, it includes the idea of learning-oriented planning similar to what Jim Burchfield proposes in his earlier post on this blog. Second, the role of science is different. Instead of relying on scientific management as the foundation for policy development, adaptive governance integrates various types of knowledge in a contextual manner. This is similar to what Sharon describes here and here about analyzing specific questions posed by land managers and the public .
In the book Adaptive Governance: Integrating Science, Policy, and Decision Making by Ronald Brunner, Toddi Steelman, Lindy Coe-Juell, Christina Cromley, et. al., the authors use five case studies across the West. amazon.com oxford journal review
The authors make the following points about adaptive governance:
- Planning sets goals. You try alternatives. The burden of decision making shifts to monitoring and evaluation and terminating policy alternatives that fail.
- No policy is permanent because interests, knowledge, and other significant details of the context are subject to change.
- There is an understanding that politics are unavoidable. Participants assume responsibility and accountability for the policy because they must live with the consequences of implementing it.
- Best available science is integrated with other kinds of knowledge, including local knowledge.
- Science must be contextual, necessitating interpretations and judgments that integrate what is known about the context.
These guidelines appear to converge with other ideas that we’ve noted on this blog. There seems to be evidence that this works. Although NFMA and the previous forest planning rules are grounded in the scientific management process, the 2000, 2005, and 2008 rules introduced the concept of collaboration in all aspects of planning, monitoring, and evaluation, and required the consideration of uncertainty and risk. But what is missing in those rules is the idea that we are committed to using dynamic monitoring and a collaborative evaluation process in order to change policy. For those that think that the NFMA planning rule is just about writing a Forest Plan, this would be a huge surprise and some would argue, a wake-up call. Are the concepts of adaptive governance the next step?