True Nature: Revising Ideas On What is Pristine and Wild

I thought this was interesting, as it came across my screen right after our discussions of “ecological integrity” in the new planning rule. My hypothesis is that every twenty years or so the same “truths” are rediscovered..because the shifting and fragmenting nature of disciplines leaves scientists unfamiliar with previous thought on the same topic.

So here’s an article in Yale Environment 360. It fascinates me that this is reported as if Dan Botkin (yes, the same who spent time at Yale Forestry School) said much the same in his book Discordant Harmonies in 1992 (over 20 years ago). The use of the idea of “museum exhibit” reminded me of this paper by Connie Millar and Bill Libby in Fremontia in 1989, when they used the more colorful term “Disneyland”. Due to my disciplinary loyalty, the photo above is of Disneyland and not a museum.

Given the discussion we’ve just had about “ecological integrity,” here’s an interesting excerpt:

For instance, it calls into question the conventional view that ecosystems such as rainforests are complex machines, or super-organisms, that have emerged through a long process of co-evolution of species to fill ecological niches. But, if that is so, asks ecologist James Rosindell of Imperial College London, how come alien species are so good at invading other ecosystems, frequently becoming fully integrated neighbors?

Ecosystems begin to look a lot more accidental, random, and transient than niche theory would suggest. They are constantly being remade by fire and flood, disease, and the arrival of new species. They are a hodgepodge of native and alien species. This fits a rival model for how ecosystems work called “ecological fitting,” first articulated by the legendary U.S. ecologist Daniel Janzen of the University of Pennsylvania. He said that co-evolution is a bit-part player in ecosystems; most of the time, species muddle along and fit in as best they can.

Far from reaching some equilibrium state with niches filled, ecosystems have always been in a constant state of flux, says Stephen Jackson, of the Southwest Climate Science Center in Arizona, in Novel Ecosystems. “Change, including rapid and disruptive change, is a natural feature of the world.” Humans may have dramatically speeded that up, but novelty is the norm.

In that light, we need to look afresh at conservation priorities. Novel ecosystems cannot be dismissed as degraded versions of proper ecosystems, nor can alien species be demonized simply for not belonging. If novelty and change is the norm, Hobbs and colleagues ask, does it make sense for the growing business of ecosystem restoration to try and recreate static historic ecosystems? By doing that, you are not creating a functioning ecosystem; you are creating a museum exhibit that will require constant attention if it is to survive.

Gee, I said the same thing.. But of course those folks and I did not redefine “restoration.” Also, Pearce keeps using “virgin” inappropriately, in my view, as per my post in HCN here.

“Sustainable Recreation”: USDA /Forest Service Bites the Hand that Feeds Them?

First, let’s go back to the Mike Dombeck quote I cited previously from this article in Forest History:

The most enduring and powerful maxim of business is that “money flows to things people want.” People want their cultural heritage protected, clean air and water, healthy forests and rangelands, good hunting and fishing, sustainable supplies of timber and forage, etc.

Actually, Mike’s only listing of recreation was hunting and fishing on this list, but recreation is clearly the #1 use of the national forests by people of the U.S. (and other countries).

Friday, I reviewed the history of the sustainability concept in various planning rules. In the 2012, a new concept hit the street. This is “sustainable recreation”. I know all of you who are specific and careful about words are wondering “what’s up with that?” doesn’t everything have to be sustainable? Why single out recreation to be called “sustainable recreation” every time?

Well, it’s not really clear but I guess it’s because there is an internal strategy/framework about “sustainable recreation.” Here is a link to a document about the strategy from 2010. The strategy is an easy read, and makes a great deal of sense. I thought it was well done, even though I’m not usually a fan of “strategies.” I didn’t find anything particularly novel, although I’d be interested in what readers of this blog think.

However, I wonder about the “sustainability” (ink, paper, electrons) of adding an extra word (sustainable) every time you write about one of the multiple uses in a regulation when it’s already required to be sustainable.

So let’s see how it is talked about in the 2012 Rule.

The final rule provides direction for sustainable recreation throughout the planning process. The final rule retains the term ‘‘sustainable recreation’’ to recognize that planning should identify, evaluate, and provide a set of recreational settings, opportunities and access for a range of uses, recognizing the need for that set to be sustainable over time.

Again, everything has to be sustainable so…??

Ah so now we encounter the Directives, let’s look at BRC’s comments:

E. The draft Handbook at 23.22b – “Sustainable Recreation Resources” and “Opportunities to Connect People with Nature” Does Not Properly Track the Rule

The draft Handbook inappropriately modifies the definition of Sustainable Recreation. Again, the Handbook contradicts the Rule, and whether intentionally or otherwise sets up the agency to fail the newly-configured duty to provide “sustainable recreation.” The Rule states: Sustainable recreation. The set of recreation settings and opportunities on the National Forest System that is ecologically, economically, and socially sustainable for present and future generations.
(36 CFR 219.19)

The draft Handbook modifies this definition here:
Plan components must provide for sustainable recreational settings, opportunities, and access. Sustainable recreation opportunities and settings are those that are economically, socially, and ecologically sustainable for the future. To be sustainable, the set of recreational settings and opportunities must be within the fiscal capability of the planning unit, be designed to address potential user conflicts among recreationists, and be compatible with other plan components including those components that provide for ecological sustainability.
(Chapter 20 at 23.22b Page 80 underline emphasis added) I

Ironically, the Rule’s definition of “sustainable” recreation troubled agency recreation staff, who proposed changes to the definition that they feared would “set the bar too high.” See email correspondence dated Oct. 13, 2011 (AR 0125036-0125039). The draft Handbook not only ignores but builds on these fears, again with the effect of creating an unnecessarily high burden.

Most, if not all, USFS Programs are not adequately funded. Indeed, the shortfall in the roads maintenance budget, and the trail maintenance backlog for trails in designated Wilderness, is well documented. The language here raises the concern that the agency may attempt to rely on lack of funding as an excuse for lack of effort and creativity in comprehensive recreational planning and motorized recreational travel planning specifically.

That’s the BRC point of view.. my point of view is … let’s call things as they are and not redefine commonly used expressions like sustainable, (or restoration, for that matter) to mean something different. It seems like you are trying to put something over on the public rather than clarifying your intentions and being transparent.

If the FS means ” there’s a great many multiple uses, but only recreation will be subject to the “fiscal capacity” test. I wouldn’t call that “sustainable” because it doesn’t have the same meaning as other uses of the term. I would call it “fiscally prudent” recreation approach. Other proposed terms are welcome in the comments. In English, are they thinking:

We fully recognize that recreation is the most popular to the citizens of the US who provide this funding. We also value our partnerships, volunteers and other ways (outlined in the Sustainable Recreation Framework).

But we are holding recreation to a higher standard than any other use, because ______.

I’m trying to understand how they would fill in the blank.

It seems to send a message “we’re not so sure we want you recreationists out there, despite all the partnerships and volunteering” which could ultimately be a funding death spiral. Not enough money, we’ll kick you out, you won’t want to fund the FS, therefore fewer people and shoddier facilities, so more will be kicked out..

As Mike Dombeck said above, “money flows to things people want.”

Or perhaps recreationists aren’t organized enough across the motorized and non-motorized spectra to resist, as oil and gas, timber or ranching might be, so they are an easy target for integrity- promotion? Or maybe it just sounded like a good idea to someone and was stuck in the directives randomly?

Maybe someone can shed some light on this.

The Incredible World of Sustainability Definitions in Planning Rules

I want to talk about “Sustainable Recreation” in the planning directives. But first we need to lay the groundwork, so we need to go back to the Rule. Clearly everything has to be (plans must promote) sustainable, as in every rule since the 2000.

Sustainability is defined in the 2012 Rule as:

Sustainability. The capability to meet the needs of the present generation without compromising the ability of future generations to meet their needs. For purposes of this part, ‘‘ecological sustainability’’ refers to the capability of ecosystems to maintain ecological integrity; ‘‘economic sustainability’’ refers to the capability of society to produce and consume or otherwise benefit from goods and services including contributions to jobs and market and nonmarket benefits; and ‘‘social sustainability’’ refers to the capability of society to support the network of relationships, traditions, culture, and activities that connect people to the land and to one another, and support vibrant communities.

One might wonder.. gosh, the concept of sustainability has been around for a long time (since the Brundtland report).. how did EI get into the definition?

So you might ask, how did they define ecological sustainability in 2005?

(b) Sustaining ecological systems. The overall goal of the ecological element of sustainability is to provide a framework to contribute to sustaining native ecological systems by providing ecological conditions to support diversity of native plant and animal species in the plan area. This will satisfy the statutory requirement to provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives (16 U.S.C. 1604(g)(3)(B)).

So we went from diversity of native plants and animals, to “its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity).” I have called it “everything” before, because I can’t think of anything that isn’t covered, being within NRV AND resilient.

I use the ticks standard.. could lawyers argue that a project changes the compositions of species of ticks on elk (or the genetic composition of species of ticks on elk, or viruses..) ? And we see “no” in 2005, and yes in 2012. Because ticks are not plants or animals.

But in 2012, you would have to know what the species composition was during the reference period. Except like so many things, you never could know. Maybe we need historic tick ecologists and modelers? You may say, that’s silly. But it’s composition, which is listed as a “dominant ecological characteristic.”

So what does the 2000 Rule say (remember the COS gave input on that rule, and thus the Sedjo discussion and point of view, we described previously here)?

So I looked at 2000

Similarly, the Forest Service and scientific community have developed the concepts of ecosystem management and adaptive management. Scientific advances and improved ecological understanding support an approach under which forests and rasslands are managed as ecosystems rather than focusing solely on single species or commodity output. Indeed, ecosystem management places greater emphasis on assessing and managing broad landscapes and sustaining ecological processes. Ecosystem management
focuses on the cumulative effects of activities over time and over larger parts of the landscape. Planning and management under ecosystem management also acknowledge the dynamic nature of ecological systems, the significance of natural processes, and the uncertainty and inherent variability of natural systems.
Ecosystem management calls for more effective monitoring of management actions and their effects to facilitate adaptive management, which encourages changes in management emphasis and direction as new, scientific information is developed. In accord with ecosystem management, regional ecosystem assessments have become the foundation for more comprehensive planning, sometimes involving multiple forests and other public land management units. The Northwest Forest Plan, for example, affects 17 national forests and 6 BLM districts in a three-state region. The Interior Columbia Basin Ecosystem Project encompasses 25 percent of the entire National Forest System and ten percent of the public lands administered by the BLM nationwide.

(As an aside, our appetite for these giant projects seems to have dissipated in the last 13 years. Does this have to do with the apparent lack of capacity to do any adaptation? Why is that? Would like to hear opinions of folks experiences with NW Forest Plan and ICBEP).

And what was ecological sustainability then?

Ecological sustainability: The maintenance or restoration of the composition, structure, and processes of ecosystems including the diversity of plant and animal communities and the productive capacity of ecological systems.

Hmm.
2001
Maintenance OR restoration of composition, structure and processes.

2012
Capability of ecosystems to maintain ecological integrity

Which is, again:
The quality or condition of an ecosystem when its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity) occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

So if we use my ticks example, under the 2000 Rule, we would be able to argue that our project was not changing (maintaining) the same tick species as on the current elk.

According to 2012, though, we would have to figure out what the reference period was and see if our project “promoted” the species composition which occurred during the “reference period.” Unless I’m missing something?

What on Earth have we gotten ourselves into?

For those who claim that this is all “science” take a gander at SY_CallicottMumford1997paper (which you can get for free through this link, but not from Wiley..)

Ideas that scientists and philosophers exchange about the world and how things should be are not “science” in the sense of hypotheses that can be verified. This paper also brings up another normative science idea, health, but lends an interesting view of how the different disciplines see what’s important (I’ll give you a hint, it’s what they spend their time studying )

I tried to copy out the salient paragraphs but it doesn’t let me, nor could I extract the page. Check out the left hand column on page 37. Note that this discussion is clearly normative, and argues that “ecosystem health” is good for managed landscapes(sustainable) and “ecosystem integrity” for preserves. Just to be clear, I think it’s fine for academic philosophers and scientists of all stripes to talk about concepts…but putting vague normative science ones into regulation is quite questionable. Indeed, then stating that it is “science” to value the “reference period” is pretty clearly.. well.. not “science”, despite the fact that some scientists espouse it.

Potential for Collapse of Forest Ecosystems

A guest post from Kevin Matthews:

A substantial body of science shows a general pattern, that when the ecological integrity of a natural ecosystem is degraded, its response curve is non-linear. The state that occurs when the response curve becomes non-linear, such that small additional impacts result in large losses of ecosystem integrity, is sometimes referred to as ecosystem collapse.

One of the scientific bases for why ecosystem collapse tends to catch humans by surprise is pretty interesting with regard to the O&C checkerboard forest lands of western Oregon.

Natural ecosystems tend to be very resilient, accommodating heavy damage and still recovering, up to typically somewhere between 50% and 90% damage. This lulls humans into complacency, to the sense that they can keep taking, and the ecosystem will keep recovering.

Then, somewhere in the range of substantial alteration of from 50% and 90% of habitat area, ecosystem resiliency breaks down. A threshold gets crossed, where things fall apart fast and hard. And in a relatively short time frame, the habitat is changed (loss of soil, hydrology, key species, whatever) so the ecosystem no longer has a viable path to recovery.

The point of collapse is hard to predict because the system responses go rapidly non-linear. Past rates of recovery, however well-researched, become almost instantly irrelevant.

A rough, understated estimate would be that the overall O&C checkerboard is already at 75-80% substantial impact, based on close to 100% impact to the industrial part, and optimistically 60% impact to the BLM part. (Looking just at old growth remnants, 90% or more impacted would be defensible.)

Add in the ongoing impacts due to climate change, and there’s a strong basis to believe the checkerboard forests are hanging on the edge of serious collapse.

Interestingly, much same thing is true for ecosystems overall, viewed at the global scale:

http://arch.designcommunity.com/viewtopic.php?f=22&t=37314

Habitats incorporating giant trees were endemic across the well-watered areas of what is now the U.S., from the Appalachians to the Great Plains, from the Carolinas to Maine to Minnesota. After a few centuries of western expansion, all that remains of those great tree forests is a thin fringe along the western edge of the continent. And this thin fringe is critically endangered.

Time to change our ways.

If we were ecologically realistic, given the heavy impacts on western Oregon forests to date, in order to avoid collapse we might want to plan for significant disturbance to not more than 25% of the checkerboard lands, and that, only in lands heavily disturbed already.

Key questions then would be, how could we make a sustainable level of harvest, contained by that threshold, work for the economics of rural communities? Could we continue needed building construction with the resulting output of sawlogs? Could we maintain a timber culture that we would all be proud of?

Recent calls by Senators and other politicians to increase logging, without addressing these broader and deeper issues, are fundamentally misinformed.

http://www.tester.senate.gov/?p=press_release&id=2883

I’d like to see all sides work together in seeking a true balance, based on clear evidence, for forest policy in this new century.

Warning: Fuzzy Concept in Regulation- “Ecological Integrity”- IV- After the “AND”

Fortunately for everyone this will be my last post on the concept of “Ecological Integrity”as described in the NFMA Rule. Perhaps unfortunately, not my last post on the planning directives. Other guest posts on the directives are welcome. Wading through the directives was a lonely business, and thanks much to the others on this blog who suffered and shared.

So let’s return to the definition in the regulation of “ecological integrity”:

“The quality or condition of an ecosystem when its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity) occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

We have discussed the first part in previous posts, here, here and here… now let’s look at after the “and”:
“can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

Well, that sounds like a good idea. But what “can withstand and recover”? It appears to be the “dominant ecological characteristics” composition, structure and function, species composition and diversity”. That sounds like “everything you can possibly think of.” So everything would have to go back to being the same as it was prior to “most” perturbations. And how is that?

Natural range of variation (NRV). Spatial and temporal variation in ecosystem characteristics under historic disturbance regimes during a reference period. The reference period considered should be sufficiently long to include the full range of variation produced by dominant natural disturbance regimes, often several centuries, for such disturbances as fire and flooding and should also include short-term variation and cycles in climate. “Natural range of variation” (NRV) is a term used synonymously with historic range of variation or range of natural variation. The NRV is a tool for assessing ecological integrity, and does not necessarily constitute a management target or desired condition. The NRV can help identify key structural, functional, compositional, and connectivity characteristics, for which plan components may be important for either maintenance or restoration of such ecological conditions.

But how do we know if something (er.. everything) will “withstand and recover from “most” perturbations?” Who gets to decide what “most” is?

While I thought that the 2000 rule was a full employment program for fire ecologists and historic vegetation ecologists.. this sounds like a full employment program for lawyers and modelers, as well as the fire ecologists and historic vegetation ecologists. I wonder who was sitting around the table or on the phone when this rule was developed, and if there is some correlation between the disciplines of those folks and the disciplines advantaged by this language ?

If we agree that climate change is unprecedented, then with climate change, the past cannot be a predictor of the future.. so we don’t really have any information, not do we have any predictive capability other than modeling. Of course, our climate models are not particularly accurate at the scales we are interested in, and humans are constantly not doing what we assumed they would do when we ran the scenarios in the models.

But for me, all this is a distraction from dealing with real environmental problems of today (dirt in streams, invasive species) and acknowledging that time’s arrow only goes one way. Yet this rule and its directives have us spending time digging up the past (sorry, Bob) and modeling the unmodelable. We simply have no clue about the future at the detail required in this rule.

Before climate change, we used to hear a lot the paraphrase of Haldane “ecosystems are more complex than we think, they are more complex than we can think,” with the sense that we needed to preserve species. Which is fine. But if in fact they are that complex, then what are we doing depending on models over observations today in a regulation?

It’s clear that it is not really about “science”. I like to go back to Michael O’Connell’s warning of 1999 in his testimony here (my italics).

Ecosystems are more complex than we think. There are many complexities at all levels of biological organization that cannot be measured, perceived, or even conceived of, that directly affect the viability of conservation solutions. Science can never provide all the answers to questions about conservation, so the response should be to exercise both caution and prudence when designing answers. Wise solutions don’t necessarily try to compensate for factors that cannot be defined, but at the same time they leave room for them. A good example of this is true adaptive management, where the results of ongoing monitoring are used to adjust the conservation program based on new information and changes in circumstance.

Nature is full of surprises. Ecological systems are characterized by non-linear, non-equilibrium and often seemingly random dynamics. Both unexpected events and unanticipated consequences affect the long term viability of any conservation solution. This uncertainty is a given, and its runs directly counter to the political, social and economic desire for predictability in the outcome of conservation plans. It is better to be forthright in acknowledging that the issue of “no surprises” is not a scientific question of predicting the future, but instead a social question of how to deal with those surprises.
Conservation planning is interdisciplinary, but science is the foundation. Creating a long-term solution for species and the ecosystems on which they depend is a complicated exercise in reconciling social, political, legal, economic and biological factors. But if science must be one of several competing interests in the negotiation instead of the method of evaluating how to reach specified objectives, then conservation outcomes will always be undermined. This raises the critical issue of how to integrate both scientific information and scientists themselves into the planning process.

So let’s take a real world example.. say a ski area. Does having an area suitable for skiing “promote ecological integrity” ? Well, a ski area would be outside the RNV, so that’s out, so we don’t have to go to perturbation. So are we expecting that the next White River Plan revision will be litigated for having ski area suitability and thereby not promoting integrity?

So let’s move on to resilience.. say the climate is warming and drying. You want to thin some ponderosa pine trees so they have enough water to stay healthy and do some fuel reduction. A lower basal area (than in the past historical period you picked for NRV) would be better in terms of resilience to “perturbations” . But as far as the historians tell you, that is not in NRV. So the two requirements for “ecological integrity”, NRV and resilience, could actually be in conflict. (aside: picking a reference period can’t really be “scientific” so this idea of NRV seems like “science” but isn’t really). As in you can have one or the other, but not both.

My question is “are we way overthinking this?” WTH is this doing in a regulation and thereafter in the court system?

Here’s what Mike Dombeck said: just plain English and inspiring. Have we changed so much since he said this? Here’s the link, the whole thing is worth a read.

My expectation is that everything we do—every environmental impact statement we write, every timber sale, recreation plan, mining plan, or allotment management plan we approve—will not compromise the health of the land. I want to make it very clear that no Forest Service program has dominance over another. Timber is not more important than wildlife and fisheries. Nor is wildlife and fisheries more important than timber or recreation, or cultural resources, and so on.

So what happened between Mike’s term and now? Have we really changed this intention (no one is more important than the other), or are we so wrapped around the axle of fuzzy words that we can’t even tell what we mean? Are we adrift in a sea of legal hooks?

Planning Rule Directives Comments- New 15 Day Comment Period

I picked this up from the Teton Valley news here.

If you thought the 400 pages or more of directives were too daunting to review (and who didn’t, really?), you can now get pointed in a direction to check out certain parts, by the other comments in the reading room here...

I tried to check out Bill Imbergamo’s comments and it said that they were being checked for offensive content.. so you may not be able to see all of them. Or maybe it was just my computer?

I will also post on a few things on this blog, in addition to my ecological integrity posts, here here and here.

Reading Room For Planning Rule Directives Comments

You can find them here. You can search on a variety of things. Any ones you find particularly interesting, we can start a new thread.

Also, don’t know if there will be a webcast of the FACA committee meeting next week in Fort Collins.

Warning: Fuzzy Concept in Regulation- “Ecological Integrity”- III- Deja Vu From 2000

Thinking about the ecological integrity and NRV reminded me of my comments on the 2000 (yes!) planning rule. (Aren’t computer searches grand!)

Caveat: at this time of my career, I had not worked in planning or NEPA. Also I was working at OSTP at the White House when the 2000 rule was clearing, and OMB folks had some real concerns about the costs of doing the 2000 (I might have spoken with them to help clarify their concerns, but ultimately they were clearly told to stop being concerned).

Some have argued that this one (2012) has even more requirements for analysis and will hence be more expensive and time-consuming (despite intentions) than the 2000. I thought I had said that the pursuit of HRV seemed to be a “full employment program for historic vegetation ecologists”, but maybe not in this set of comments.

Here is a link to my comments.

Below are a couple of paragraphs..

4. Clear Conceptual Foundation

One of the basic concepts of land management is that while doing an activity anywhere (building a campground, using a road, fishing, cutting firewood, harvesting mushrooms) has some impact on the environment, there is a point at which the resource is being damaged, and at that level, the activity is not sustainable. Better scientific information tells us the many impacts of each activity and possible negative consequences. But somehow, someone has to draw the line between the social good of recreating, mushrooms or firewood, and potential damage to the resource that might result. Whether you call this sustainability, or something else, this is the same concept as what has been in place throughout the history of the FS. Our knowledge of effects is more sophisticated today, and the political climate is different than the heyday of timber management, but the concepts are the same. Balancing (a moving target, as conditions change) can occur through decisions at the national level (no OHV’s on national forests, for example) but in most cases, the actual effects of what people do vary by site, by elevation, by soil and by a host of other factors that cannot be summarized on a national level. That is why the local people and communities have an important role in determining that balance. If, on the other hand, like the FS’s sister agency the Park Service, the presumption is that people’s activities are generally negative and are to be kept to a minimum, then local knowledge and input is not as important. If Congress chooses the resource management philosophy, then special attention needs to be given to ensuring that local people’s balances are not overridden by outsiders, however well-intentioned, who are not familiar with the local situation. This is Congress’s prerogative, however, and not the FS’s choice to make. The tension between local and national interests is another real-life situation that must be considered in the design of the process. Like the role of an expert in a democracy, these are ongoing tensions in governance of this country, and natural resource management should acknowledge and reflect the legitimacy of these tensions.

One can read the whole history of “ecological sustainability”, “ecological integrity” and “range of historic variation” as a target, to reframe the debate so that scientists become the experts on what should be done. This gets away from the messy conflicts over policies, such as who wins and who loses. This does not build trust. “I don’t like OHV’s because they disrupt a species of wildlife on this watershed” is meaningful. “Roads disrupt ecological integrity” does not pack informational content and in effect obfuscates the terms of the tradeoffs or balancing of interests.

If “ecological sustainability” and pre-European North America are the targets, then the planning questions are “how quickly can we afford to shut down existing roads and campgrounds, and can we afford the law enforcement to lock people out of the NF’s? “ We will ignore fire threats and fuel buildup close to adjacent landowners because there were lots of massive fires prior to European settlement (although there were not enclaves of million dollar homes). Clearly then, there are parameters within which pre-European will guide FS thinking and others where it will not. No where is it clear in exactly what kinds of decisions the authors of the document think that this criterion will be relevant.

If the FS is to reestablish trust, I think a few things need to be in the regs and the regs are an important place to carry this out. First, the concepts, steps in the process, and decision space itself need to be so clear that any FS employee can explain them to any member of the public. Anyplace where ecological science expressions such as “functioning of ecosystems” occurs in the text, it needs to be translated so that the non-technical public can understand it. Everyone knows we’re not reintroducing grizzlies to the central Sierra, or closing ski areas, or replacing all exotic grasses with natives, so clearly there are distinctions and priorities. There is no reason they can’t be clearly stated, e.g. “water quality and quantity is #1 priority and while there were massive fires and sediment flows within the range of historic variation, we acknowledge that these levels of sediment are not desirable today.”

Warning: Fuzzy Concept in Regulation- “Ecological Integrity”- II

So what is this “ecosystem integrity” that we are now requiring in the 2012 Planning Rule?

Just looking at it, we see the word “ecosystem” with a value word “integrity”. Could this be an expression of what Bob Lackey calls “normative science”? Sure enough, several papers have been written critiquing the concept. You can do the experiment yourself, just go to Google Scholar and search on ( “ecosystem integrity” critique) . Note: I am going to equate “ecological” and “ecosystem” integrity since they seem to be the same to most authors.

One paper I found is DeLeo and Levin (italics mine) 1997. Here’s the link

Pressure for adequate answers creates a need to devise conceptual tools, such as ecological integrity, to help scientists and resource mangers grasp the complexity of biological systems (Bernstein and Goldfarb 1995). The concept of integrity is far from a panacea for any management problem. Its definition simply reflects the capability of ecosystems, however defined, to support services, including pure aesthetics, that humans value. Ecosystem integrity is not an absolute, monolithic concept, but a multidimensional, scale- dependent abstraction; there is no unequivocal way to apply it in decision making. Measures of integrity must recognize the importance of maintaining processes that support those critical services.

What are the practical implications of these discussions? How should a manager implement notions of ecosystem integrity? The first step is to recognize that this is not the domain of the manager or of the scientist alone. Integrity reflects the ability of ecosystems to sustain services to humans, and the identification of those services can best emerge from multisector partnerships, in which all stakeholders seek agreement on the uses to which an ecosystem will be put, recognizing the linkages with other ecosystems. From such agreement on uses can come the identification of a set of measures that represent the status and trends of those services. A basic research question then arises: how to characterize the relationship between structural features of ecosystems (such as biodiversity or trophic linkages) and measures of functioning? This is an inchoate and nascent area of investigation, but one that holds tremendous potential for advancing the science of management (Daily 1997, Levin 1997, Levin and Ehrlich 1997).

Hmm. The people studying it say “there’s no unequivocal way to apply it”. Should we intentionally put it into a regulation? Isn’t this handing a court a can of worms? If it’s too difficult for us resource folks to figure out, do we just give our “inchoate” ideas to judges? I wonder whom this approach empowers and whom it disempowers.

Someone who has published often on natural resource disputes and science, Bob Lackey, has this to say in his “Seven Pillars of Ecosystem Management” here .

The terms ecological health and ecological integrity are widely used in scientific and political lexicon (Rapport, 1989; Costanza, et al., 1992; Norton, 1992; Grumbine, 1994). Politicians and many political advocates widely argue for managing ecosystems to achieve a “healthy” state or to maintain ecological “integrity.” By implication their opponents are relegated to managing for “sick” ecosystems.
Scientists often speak and write about monitoring the health of ecosystems, or perhaps the integrity of the ecosystem. There is usually the assumption that there is an intrinsic state of health or integrity and other, lesser states of health or integrity for any given ecosystem (Norton, 1992). Some scientists explicitly advocate ” . . . that maintaining ecosystem integrity should take precedence over any other management goal” (Grumbine, 1994).

Much of the general public seems to accept that there must be a technically defined healthy state similar to their personal human health. After all, people know how they feel when they are sick, and so, by extension, ecosystem sickness must be a similar condition, which should be avoided. “Health” is a powerful metaphor in the world of competing policy alternatives.

For example, society may wish to manage a watershed to maximize opportunities for viewing the greatest possible diversity of birds, for the greatest sustained yield of timber, or for the greatest sustained yield of agricultural products. Achieving each goal would almost assuredly result in ecosystems that were very different, but equally “healthy.”
The debate is really over defining the “desired” state of the ecosystem, and secondarily, managing the ecosystem to achieve the desired state. Phrased another way: What kind of garden does society want (Regier, 1993)? There is no intrinsic definition of health without a benchmark of the desired condition. In ecosystem management, scientists should avoid value-laden terms such as “degradation, sick, destroy, safe, exploitation, collapse, and crisis” unless they are accompanied with an explicit definition of what the desired condition of the ecosystem is as defined by society. The word “society,” as used here, includes only humans.
In philosophical terms, the problem with “health” is how one links “is” and “ought.” For example, an ecosystem has certain characteristics — these are facts on which all analysts who study the ecosystem should be able to agree. Characteristics such as species diversity, productivity, and carbon cycling are examples. If the same definitions and the same methods are used, all analysts should come to the same answer within the range of system and analytical variability. The “ought” must involve human judgement — it cannot be determined by scientific or technical analysis (Shrader-Frechette and McCoy, 1993). The concept of “health” has a compelling appeal, but it has no operational meaning unless it is defined in terms of the desired state of the ecosystem.

Again, the 2012 Planning Rule says that “plans should promote ecological integrity”, yet we learn from the literature that “ecological integrity” is a flawed concept.

So,we might ask, how does the planning rule define ecological integrity?
We find it in 219.19

“The quality or condition of an ecosystem when its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity) occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

I couldn’t find “natural range of variation” in the rule, which seems odd because plans need to promote integrity, you tell if something has integrity because it’s within NRV.. so NRV becomes pretty crucial.

Conveniently, it is now defined in the Directives, in the Zero code chapter.

Natural range of variation (NRV). Spatial and temporal variation in ecosystem characteristics under historic disturbance regimes during a reference period. The reference period considered should be sufficiently long to include the full range of variation produced by dominant natural disturbance regimes, often several centuries, for such disturbances as fire and flooding and should also include short-term variation and cycles in climate. “Natural range of variation” (NRV) is a term used synonymously with historic range of variation or range of natural variation. The NRV is a tool for assessing ecological integrity, and does not necessarily constitute a management target or desired condition. The NRV can help identify key structural, functional, compositional, and connectivity characteristics, for which plan components may be important for either maintenance or restoration of such ecological conditions.

OK, so let’s get the logic here.
Plans are required to “promote” ecosystem integrity in a regulation.
Ecosystem integrity is defined in the regulation as equal to (dominant characteristics within NRV) AND (resilient to disturbance)
Yet, being with NRV is “not a target”. But based on these definitions you can’t have EI without being within NRV. And EI is a target. If I (integrity) is a target and I= (NRV) AND (Resilience) then isn’t NRV also a target implicitly?

If I want cookies that have nuts AND chocolate chips, then aren’t I saying that they need to have nuts?

It makes my few remaining (after trying to read the directives) neurons melt. But as during the COS debate on whether ecological sustainability should be “primary”, I still don’t understand what it means in practice. During the selected historic period, you may not have had roads on the Angeles NF; you didn’t have jet aircraft flying over Weminuche Wilderness. So we just start deleting activities until we get to those of some chosen “historic period?” Is this what the public wants from its public lands?

Plus now we have climate change, so in many cases returning to HRV with any distribution of any species may be impossible. Why would we want to put into regulation impossible implicit or explicit targets?

Warning: Fuzzy Concept in Regulation- “Ecological Integrity”- I

OK, well it’s not exactly a warning about “faulty concepts” but it was the best I could find in the time available..

It’s interesting that in procrastinating on working on reviewing the Planning Directives, I found and posted MUSYA. Let me quote it again here:

‘‘Multiple use’’ means: The management of all the various renewable surface resources of the national forests so that they are utilized in the combination that will best meet the needs of the American people; making the most judicious use of the land for some or all of these resources or related services over areas large enough to provide sufficient latitude for periodic adjustments in use to conform to changing needs and conditions; that some land will be used for less than all of the resources; and harmonious and coordinated management of the various resources, each with the other, without impairment of the productivity of the land, with consideration being given to the relative values of the various resources, and not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output.
(b) ‘‘Sustained yield of the several products and services’’means the achievement and maintenance in perpetuity of a high-level annual or regular periodic output of the various renewable resources of the national forests without impairment of the productivity of the land.

This seems to be what Congress intended the purpose of the national forests to be. So far, they seem to have added other environmental laws (which as Andy says, are not in conflict) so we would think that the primary purpose still stands.

Well, in the 2012 planning regulations, section 219.1 b states that it is consistent with MUSYA, and then 219.1 c says that “the purpose of this part is to “guide the …land management plans that promote the ecological integrity of national forests and grasslands.” It goes on to say that lands will be managed to be “ecologically sustainable” and “contribute to” social and economic sustainability.

So it seems like we have made a regulation for implementing NFMA, that at first, seems contrary to MUSYA.

Here’s MUSYA “harmonious and coordinated management of the various resources, each with the
other, without impairment of the productivity of the land”

whereas in the new NFMA regulation the goal is to “promote the ecological integrity” and “ecological sustainability” is first and no “harmonious coordination” seems to be required.

So, for those of you who didn’t follow the Committee of Scientist dynamics.. remember Roger Sedjo, of Resources for the Future said this..in his dissent from the COS report in 1998 (15 years ago and the discussion seems to be .. rather .. stuck). Here’s the link.. worth taking a look at.

I believe that the Report recommends measures, specifically the preeminence of an ecological sustainability focus together with the stringent viability regulations, that would have the effect of having the National Forest System operating primarily as a biological reserve. These recommendations go well beyond the Secretary’s charge to the Committee, which “is to provide scientific and technical advice to the Secretary of Agriculture and to the Chief of the Forest Service on improvements that can be made in the National Forest System Land and Resource Management planning process” and that this be done “within the established framework of environmental laws and within the statutory mission of the Forest Service.” The Report, however, recommends what is clearly a new mission for the FS that is in conflict with much of the statutory mission of the FS.

In selecting the new mission the Report uses definitions of sustainability that are considerably more narrow than those commonly used, and indeed more narrow than those used by the US Government in its international negotiations on sustainable forestry in the Montreal Process and Santiago Declaration. Furthermore, the Report justifies the new sustainability mission for the FS with assertions to the effect that the NFS is in jeopardy, but these assertions are not supported by evidence. In fact, evidence available strongly supports the view that forest sustainability is not in jeopardy, generally, although area specific problems do exist.

Additionally, most fundamental defects in the forest planning process cannot be corrected by the changes recommended in this Report. The Report recognizes the difficulties of meaningful implementation of planning without a basic reform to allow the budget and planning processes to operate in concert. Additionally, under the current planning system problems are exacerbated by frequent disruptions of planning via administrative orders from above, which often render the process meaningless. Also, the Report acknowledges, but does little to address, the problem of endless appeals that has plagued the forest plans and the planning process. Without these and other fundamental reforms, the changes recommended in the planning process are unlikely to alleviate most of the more serious problems experienced with forest planning.

Well, I’ve run out of room. Tomorrow we’ll discuss the “ecological integrity” definition in the rule and how it’s carried forward into the directives.