I read Randal O’Toole’s “Analysis Paralysis” article in the February issue of Environment & Climate News.
Forest Service Chief Dale Bosworth and other Forest Service officials certainly have some very real problems. However, I don’t believe it is the planning processes and the laws that are the problem, as much as it is the failure of the Forest Service to comply with the regulations, processes, policies, and plans that were developed by the agency in compliance with the laws.
I believe a very real problem has been the selection of people to lead the Forest Service who were never natural resource managers and were never expected to be.
Planning process worked … for a while
The Forest Service spent three years, from 1976 to 1979, developing regulations and processes for planning for the management of the national forests in compliance with the National Environmental Policy Act and the National Forest Management Act. The planning process was implemented and it took some eight years to complete most of the forest plans.
A small number of plans were never completed, because the environmental/preservation industry could not stand to allow the effort to succeed. In fact, the plans would not have taken so long to complete had the preservation industry not sued, in the middle of the forest planning process, to make the national forest planners consider each and every potential wilderness area in the forest planning process, rather than to accept the results of the Second Roadless Area Review and Evaluation (RARE II) for planning purposes. The preservationists have recently reversed their stand on this issue.
I believe the Forest Service did a reasonably good job, perhaps even an exceptionally good job, of planning under the regulations and policies that were in effect between 1979 and 1987. Public involvement was accomplished at the local and regional level, assuring the public was well informed and well heard. The science employed in the development of issues and their resolution was never really challenged. There were no surprises when the forest plans were approved. Everyone may not have been satisfied–obviously, the preservationists were not. But no one was really surprised; and they should not have been.
The real surprise and disappointment came when the Forest Service failed to implement the forest plans in compliance with the law. Within a couple of years following their approval, the Forest Service failed to implement the plans. The timber programs were not implemented in most national forests. And, when they weren’t implemented, the Forest Service failed to revise the forest plans, as required by law.
Planned timber harvests not met
As early as 1989, a number of national forests failed to meet the timber harvest volumes they committed to in their forest plans. Forest Service leadership hid behind what many of us believe is a misinterpretation of a rather obscure phrase contained in Section 13 of the National Forest Management Act:
Limitations on Timber Removal.–(a) The Secretary of Agriculture shall limit the sale of timber from each national forest to a quantity which can be removed from such forest annually in perpetuity on a sustained-yield basis: Provided, That, in order to meet over-all multiple-use objectives, the Secretary may establish an allowable sale quantity (ASQ) for any decade which departs from the projected long-term average sale quantity that would otherwise be established; Provided further, That, any such planned departure must be consistent with the multiple-use management objectives of the land management plan. Plans for variations in the ASQ must be made with public participation as required by Section 6(d) of this Act. In addition, within any decade, the Secretary may sell a quantity in excess of the ASQ established pursuant to this section in the case of any national forest so long as the average sale quantity of timber from such national forest over the decade covered by the plan do not exceed such quantity limitation.
The Forest Service leaders, apparently under some kind of political pressure, said the decadal volumes and the ASQs established in the planning process were nothing more than upper limits that could not be exceeded. I believe they based this on the first sentence in (a) above. They reasoned that, if the forests did not meet those volumes, it was no big deal and not worthy of a plan revision.
This was an extreme disappointment to many of us who had worked with the public in the development of as many as 12 alternatives, and the selection of one, during the planning process. A number of those alternatives could have exceeded the volumes in the selected alternative, on a long-term sustained-yield basis. But they were not selected because of multiple-use concerns. We had no idea the Forest Service leadership would take this unreasonable position. We had made a commitment.
Our assurance to the public was that if we did not implement the forest plans, we would revise the forest plans and again involve the public. The following is from Section 6(f)(5) of the NFMA:
6(f) Plans developed in accordance with this section shall–(5) be revised (A) from time to time when the secretary finds conditions in a unit have significantly changed, but at least every fifteen years, and (B) in accordance with the provisions of subsections (e) and (f) of this section and public involvement comparable to that required by subsection (d) of this section.
A voice of experience
It has been 14 years since the forest plans were approved in the Northern Region of the Forest Service. The annual timber sale volume has declined from about 1.1 billion board feet in 1987 to only 170.2 million board feet in 2001. That is on 25 million acres and 15 national forests.
On the Kootenai National Forest, the sale volume has declined from 232 million board feet of mostly green timber in 1989 to less than 70 million board feet in 2001. Also, well over 50 percent of the transportation system has been closed or restricted in some fashion on the Kootenai. How’s that for significant changes in conditions on a planning unit?
Still, the Forest Service has not found these “changes in conditions” on the Kootenai National Forest planning unit to be significant enough to warrant a plan revision. This seems rather incredible to me.