Planning: Accommodating Producing

Forest Service Planning: AccommodatingUses, Producing Outputs, and Sustaining

Ecosystems

February 1992

OTA-F-505NTIS order #PB92-152560

Planning: Accommodating Uses. Producing

Outputs. and Sustaining

Ecosystems

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Recommended Citation:

U.S. Congress, Office of Technology Assessment, Forest Service Planning: AccommodatingUses, Producing Outputs, and Sustaining Ecosystems, OTA-F-505 (Washington, DC: U.S.Governrnent Printing Office, February 1992).

ForewordAmerica’s forests and rangelands provide valuable commodities and amenities for U.S.

citizens. Forests and rangelands account for two-thirds of all U.S. lands, and 40 percent ofthose lands are owned by the Federal Government. Forests and rangelands generate cleanwater, forage for livestock and wildlife, timber for construction, habitat for fish and wildlife,space for recreation, and pristine wilderness settings. The demands for these products andservices rises as the country’s population grows and leisure time increases. Thus, we are facedwith increasing conflicts over the use of forests and rangelands, especially the Federal lands,and concerns about their long-run protection.

Congress enacted the Forest and Rangeland Renewable Resources Planning Act (RPA)in 1974, to assure long-term sustainable management of our Nation’s renewable naturalresources and to increase public involvement in associated policy and budget debates. In 1976,Congress amended RPA in the National Forest Management Act (NFMA) to guaranteesustainable management for the national forests managed by the USDA Forest Service and toassure active public involvement in the forest planning process.

Congress questioned the effectiveness of planning at the forest level under NFMA andexpressed concern over the direction the process is headed. Most local forest plans have takenmuch longer to complete than anticipated, and frequently Congress has been asked to addresscontroversial issues that it expected to be resolved in the planning process. Numerousadministrative appeals and litigation of forest plans have come from environmentalists,business interests, and local governments.

In 1989, the House Committee on Agriculture, together with the House Interior andInsular Affairs Subcommittee on National Parks and Public Lands and the Senate Committeeon Agriculture, Nutrition, and Forestry, requested that the Office of Technology Assessmentexamine the Forest Service’s use of resource planning technologies. In Forest ServicePlanning: Setting Strategic Direction Under RPA, released in July of 1990, OTA evaluatedpast RPA efforts and identified options for improving RPA’s contribution to long-rangeplanning and to policy and budget deliberations. This second OTA report on forest planningevaluates technological, biological, social, economic, and organizational dimensions ofnational forest planning. It discusses the agency’s planning technologies, the appeals andlitigation processes, and the relationship between national planning under RPA andforest-level planning under NFMA. The assessment presents options for Congress that couldimprove forest planning under NFMA.

u JOHN H. GIBBONSDirector

.,!

M

Forest Service Planning: Advisory Panel

Hanna J. Cortner, ChairProfessor, Water Resources Research Center

Clark L. CollinsExecutive DirectorBlue Ribbon CoalitionPocatello, ID

Richard C. CollinsProfessor/Director of the Institute

of Environmental NegotiationsSchool of ArchitectureUniversity of VirginiaCharlottesville, VA

Dennis P. DykstraProfessor of ForestrySchool of ForestryNorthern Arizona UniversityFlagstaff, AZ

Paul V. EllefsonProfessor, Department of Forest

ResourcesUniversity of MinnesotaSt. Paul, MN

Jerry FranklinBloedel Professor of Ecosystem

AnalysisCollege of ForestryUniversity of WashingtonSeattle, WA

George T. HamiltonConsultantRecreation Resources

Management Co.Bow, NH

University of Arizona, Tucson, AZ

Willard I. Hamiltonl

Coordinator, Timber ResourcePolicy

Potlatch Corp.Lewiston, ID

Betty HuskinsVice PresidentRidgetop AssociationLinville Falls, NC

Andy KerrDirector of Conservation and

EducationOregon Natural Resource CouncilPortland, OR

Dennis C. LeMasterProfessor and HeadDepartment of Forestry

Natural ResourcesPurdue UniversityWest Lafayette, IN

William S. PlattsFisheries Consultant

and

Don Chapman Consultants, Inc.Boise, ID

Robert RagonExecutive Vice PresidentSun Studs, Inc..

Roseburg, OR

Gerald A. RoseDirector/State ForesterDivision of ForestryMinnesota Department of Natural

ResourcesSt. Paul, MN

IResj~~ from I-Watch Corp. Apr. 30, 1991, to go into private consulting iII FlitiY Hwbor, WA.

R. Neil SampsonExecutive Vice PresidentAmerican Forestry AssociationWashington, DC

Maitland S. SharpeConservation DirectorIzaak Walton League of AmericaArlington, VA

E. Maynard SmithRancherSmith 6-S LivestockGlen, MT

Gaylord L. StaveleyPresidentNational Forest Recreation

AssociationFlagstaff, AZ

A. Milton WhitingChairman and Chief Executive

OfficerKaibab Industries, Inc.Phoenix, AZ

Louisa L. WillcoxPolicy DirectorGreater Yellowstone CoalitionBozeman, MT

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel members. The panel doesnofi however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility for the report and the accuracy of itscontents.

iv

OTA Project Staff-Forest Service Planning

Roger C. Herdman, Assistant Director, OTAHealth and Life Sciences Division

Walter E. Parham Program ManagerFood and Renewable Resources Program

Ross W. Gorte,l Project Director

Analytical Staff

Robin P. White, Analyst

Daniel J. Whittle, Research Analyst2

Susan J. Wintsch, Contracted Editor

Administrative Staff

N. Ellis Lewis, Office Administrator

Nellie M. Hammond, Administrative Secretary

Carolyn M. Swam, P.C. Specialist

NOTE: OTA wishes to express its appreciation to the Congressional Research Service for the assistanceprovided in this report. CRS graciously granted Ross Gorte a 14-month detail to direct thisstudy, and to provide additional assistance before and after the completion of the assessment,to assure the purposes and tasks of the report were fulfilled. Thus, CRS's contributions to thisstudy were substantial.

I@ de~ ~m me co~siod Research Service.%orn November 1989 to May 1991.

Chapter

Chapter

Chapter

Chapter

Chapter

Chapter

Chapter

Chapter

Chapter

Chapter

ContentsPage

l: summary do . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2: Policy Options. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3: The Goals of National Forest Management and Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4: The Legal Framework for Forest Planning and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . .

S: Public Involvement in Forest Placing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6: Biological Dimensions of Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7: Technologies for National Forest Placing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

8: Economics in National Forest Planning.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

9: Organizational Factors in Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

IO: Relationship of Forest-Level NFMA Planning to National RPA Planning . . . . . . . . . . . . . . . .

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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vi

Chapter 1

Summary

ContentsPage

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . ● *................**””*”””” . *.”””””””””””””””””” 3Forest Planning as Strategic Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4Multiple Use and Sustained Yield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Public Involvement in Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Biological Dimensions of Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6F o r e s t Planning Technologies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Economics in National Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 7The Budgeting Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 8Organizational Factors in Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8NFMA Forest Planning in Relation to National RPA Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Role of Congress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....”.......””.” 10

BoxesBox Page

l-A. NFMA Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3l-B. Trust Fund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

TableTable Page

l-1. Major Findings on NFMA Forest Planning and Possible Options for Congress . . . . . . . . . . 10

Chapter 1

Summary

I N T R O D U C T I O N

The Forest Service is one of the major Federalland managing agencies. It has been part of theDepartment of Agriculture since 1905, and nowmanages some 191 million acres of land in 43 States.The Forest Service Organic Act of 1897 and theMultiple-Use Sustained-Yield Act of 1960 (MUSYA)guide the management of these lands, providing fora variety of uses and outputs---commodities (e.g.,timber, livestock forage, and fuels and minerals) andunmarketed values (e.g., recreation, wildlife habitat,and water flows)--and requiring management forsustained productivity.

The laws provide little guidance on how tobalance the various resource values and assuresustainability. Initially, conflicts were managed byseparating uses over space or time. However,demands on the resources have continued to climb,and unmarketed resources are now more widelyvalued by our society. Congress enacted the legalrequirement for national forest planning in theForest and Rangeland Renewable Resources Plan-ning Act of 1974 (RPA). The principal purpose ofRPA was to establish a national strategic planningprocess for meeting these conflicting demands whileassuring the sustainability of America’s renewableresources. RPA also directed the Forest Service toprepare integrated land and resource managementplans for units of the National Forest System. As partof the RPA Program, the Forest Service was todevelop the plans in accordance with MUSYA andthe National Environmental Policy Act of 1969(NEPA).

Congress amended RPA with the National ForestManagement Act of 1976 (NFMA). (See box l-A,)NFMA was largely a response to lawsuits that wouldhave substantially reduced Forest Service timbersales. The new law provided guidance for forestplanning by further emphasizing environmentalconsiderations and quality standards. Congress alsointended NFMA to aid in implementing MUSYA.Under NFMA the Forest Service retained much of itsdiscretion in managing the national forests, but was

required to involve the public in the planningprocess.

Significant administrative and legal challengeshave plagued national forest management and forestplans over the past 10 years. Congress has expressedconcern about potential impacts of appeals andlitigation on timber sales, employment, and budgets.Some of these challenges call for improving ForestService compliance with environmental require-ments. Others call for improving public involvementin the planning process. Still others blame FORPLAN—the planning technology the Forest Service has

Box 1-A—NFMA Planning

The National Forest Management Act of 1976(NFMA) was largely an amendment to the Forestand Rangeland Renewable Resources Planning Actof 1974 (RPA). RPA, as enacted, required theForest Service to prepare land and resource man-agement plans for units of the National ForestSystem. The agency was to use an interdisciplinaryapproach to integrate physical, biological, eco-nomic, and other sciences. NFMA added guidancefor public participation and for Forest Serviceconsiderations and standards in the planning proc-ess. These land and resource management plans areoften called forest plans, and the process is typicallycalled forest or NFMA planning.

chosen as its analytical tool—for a planning processthat is complex and insensitive to nonuse values,such as preserving endangered species.

This OTA report presents a comprehensive as-sessment of national forest planning by the ForestService. It evaluates technological, biological, so-cial, economic, and institutional dimensions offorest planning. The report discusses the appealsprocess and the merits and weaknesses of theagency’s planning technologies. It then presentsoptions for Congress that could improve forestplanning under NFMA.

- 3 -

4 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

FOREST PLANNING ASSTRATEGIC PLANNING

Strategic planning is a process for establishingmanagement direction. The 1897 Organic Act,MUSYA, NEPA, RPA, and NFMA implicitly re-quire a strategic planning process for the nationalforests. The Organic Act and MUSYA establish thebasis for the Forest Service to accommodate usesand provide outputs while sustaining forest ecosys-tems. MUSYA acknowledges that people’s needsdetermine the proper mix of uses and outputs, andthat the mix can change over time. NEPA providesa framework for reporting intended actions andpossible results of those actions to the public. RPArequires the Secretary of Agriculture to evaluate theNation’s renewable resources and to consider theirfuture use and sustainability. NFMA establishesmanagement considerations and environmental stand-ards and guidelines, and requires public involvementin developing and revising management plans.

Strategic planning goals must be specific enoughto provide clear direction for management activitiesand concrete enough to measure success. A forestplan should identify what kind of uses, outputs, andconditions are feasible and desirable. It should focuson issues of public concern, explaining how man-agement will affect key sites, produce importantoutputs, and protect vital resources and ecosystems.By focusing on issues and explaining managementchanges, a strategic forest plan can guide the agencyand inform the public.

M U L T I P L E U S E A N D

S U S T A I N E D Y I E L D

Multiple use, according to MUSYA, is the man-agement of renewable resources on the nationalforests to best meet the needs of the American peoplewithout impairing the productivity of the land. TheAct calls for forest management based on relativeresource values, not just on maximizing returns oroutputs.

Multiple-use management has come to meaneither joint production (using the same land forseveral uses simultaneously) or dominant use (usingdifferent parts of the land for different uses).Management based on joint production is difficultbecause of the lack of biological and social informa-tion on ecological interactions. Dominant-use man-

agement is complicated by the difficulty of deter-mining which lands to manage for which uses.

Multiple use, to some, implies use of commodityresources (e.g., timber, livestock forage, and miner-als). Areas where laws restrict commodity uses,however, such as recreation sites and wildernessareas, can still produce multiple values (e.g., recrea-tion, wildlife habitat, and water flows). As a concept,multiple use assures consideration of varied resourceuses and outputs, and seeks an appropriate balanceamong these. However, the concept provides littleguidance for managers on how to balance conflictinguses and outputs.

MUSYA represents the frost attempt by Congressto apply the goal of sustained yield broadly, to allrenewable resources. Sustained-yield managementrequires maintaining the productivity of the landwhile producing high levels of annual outputs.Sustained-yield management of the national forestshas been compromised by a lack of knowledge aboutecological and social relationships and by a techni-cal bias favoring production of individual resourcesover ecosystem management and protection. (Seebox l-B.)

PUBLIC INVOLVEMENT INFOREST PLANNING

The Forest Service has a long history of solicitingpublic input in its decisionmaking processes. BeforeNFMA, this was generally informal and sporadic.With the enactment of NFMA, Congress reinforcedthe public’s right to participate in agency planningand decisionmaking. NFMA embraces the notionthat conflicts can be addressed best by integratingthe public into the decisionmaking process early andoften.

Consensus today is that the Forest Service has notused public input efficiently or effectively in itsplanning process. Much current criticism is similarto that heard at least 20 years ago: the agency asksfor public input, but the input does not affect finaldecisions. Despite numerous opportunities for indi-viduals and interest groups to participate throughoutthe planning process, many final forest plans appearnot to accommodate public concerns.

The ineffective involvement of the public in theplanning process may result from several factors:use of incorrect models of public involvement, lackof information on how to involve the public,

Chapter 1--Summary ● 5

Box l-B—Trust Fund

The National Forest System is, in many respects,comparable to a trust fund established to providecontinuous and permanent natural resource bene-fits. The 1897 Forest Service Organic Act estab-lished forest protection, stable water flows, andcontinuous timber supplies as the purposes forforest reserves. The Multiple-Use Sustained-YieldAct of 1960 requires the Forest Service to maintainthe productivity of the land. Such direction showsCongress’ desire to maintain the resources of thenational forests, much as the assets of a trust fundare conserved. In the forests and the trust fund,managers are responsible for protecting the assets.Annual benefits are important, but preserving theproductive assets is paramount.

Two aspects of the National Forest Systemcomplicate the trust fund analogy. First, the annui-ties of the National Forest System include not onlyuses and outputs, but also nonuse values (e.g.,various aspects of relatively undisturbed ecosys-tems). Second, the Forest Service, as required bylaw, provides the public with opportunities toparticipate in the national forest planning process.Thus, the public both benefits from and influencesthe management of the National Forest System.This contrasts with traditional trust funds, where thebeneficiaries are relatively isolated from trustmanagement.

professional resistance to the public’s ideas, andinflexible conditions for managers. Most nationalforest managers still fail to recognize the purpose ofpublic involvement, believing public participation isprimarily an exercise in gathering information.

In fact, there are several reasons to involve thepublic in the planning process. First, the public mustagree to, or at least accept, the management activi-ties for the national forests and the overall directionmanagement takes. The public is more likely toaccept decisions if it has been involved in theprocess, understands the limits of the resources, andsees that consensus sometimes cannot be reached.Public participation also can serve as an earlywarning system. Public comments can alert agencyplanners to issues and concerns that are likely tocause significant controversy in the future. Byworking with the public, agency planners candevelop plans that address current and emergingconcerns and, thereby, avoid making decisions thatprompt appeals and delay implementation.

No one best way exists to facilitate publicparticipation in forest planning. The most effectivemeans vary with decisions to be made, geographicalsetting, and preferences of the local publics. Forexample, a town meeting might work well in NewEngland where town meetings have a rich history,but might fail in other parts of the country. Further-more, some people like public hearings while othersprefer personal interaction. Whatever procedures arechosen should encourage and stimulate debate, andmanagers should clearly respond to public desiresand concerns. Otherwise, citizens and interestgroups will seek other forums, such as Congress orthe courts, to influence forest policy and decision-making +

The administrative appeals process offered by theForest Service is best characterized as an extensionof public participation provided for under NEPA andNFMA. The process allows any individual to requestan agency review of forest plans or agency deci-sions. The administrative appeals process has helpedthe Forest Service to: 1) clarify planning decisions;2) set standards for environmental analyses requiredby NEPA; and 3) resolve various issues, such as useof management indicator species, protection ofbiological diversity, and adequacy of resource moni-toring plans. The appeals process has been costlyand time-consuming, because it has forced theagency to resolve complex questions under NEPAand NFMA. However, what has been learned fromthe frost round of plan development may make laterrevisions easier. The number of administrativeappeals is surprisingly small, given the level ofconcern, but may be locally significant, and theForest Service has often not met the deadlinesspecified in the regulations. Data on the number,location, rationale, significance, and effects ofadministrative appeals are not available, however,so it is impossible to evaluate the effectiveness of thecurrent system.

Litigation is the final recourse for individuals orgroups dissatisfied with Forest Service decisions.Judicial review assures that decisions are consistentwith legal direction. Despite the substantial contro-versy surrounding spotted owls and old-growthforests in the Pacific Northwest, few Forest Serviceplans or activities are litigated. Congressional effortsto change the judicial review process seem to beattempts to resolve substantive issues without ap-pearing to take sides. However, such changes areunlikely to improve forest planning or plan imple-


mentation, or to reduce conflict over national forestmanagement.

BIOLOGICAL DIMENSIONS OFFOREST PLANNING

Strategic planning depends on an analysis ofresource conditions and trends. Inventories providebaseline data on forest resources. Monitoring thenpermits an evaluation of trends in the quality andquantity of these resources. Forest inventory andmonitoring activities have long been criticized forfailing to support integrated, multiresource pro-grams. This failure is due largely to a historicalemphasis on timber resource inventories, inattentionto ecosystem processes, and insensitivity to the needfor statistically valid data analysis. These problemsare exacerbated by inadequate funding for theseexpensive but necessary activities.

The Forest Service is specifically criticized fornot following NFMA inventory and monitoringrequirements and for generating sparse, poor quality,and out-of-date information. It is also criticized forfailing to follow through with monitoring activitiesdescribed in the forest plans. Newly proposed 1991regulations may strengthen the role of monitoringand provide renewed emphasis on integrated, multi-resource programs. Lack of money for detailedmonitoring, however, will require the Forest Serviceto revise its monitoring plans to reflect moreaccurately what is possible and what is mostimportant to accomplish under staff and budgetconstraints and according to public interest.

Inadequate inventory data has made it particularlydifficult to address biological diversity comprehen-sively. Forest planning regulations require the ForestService to maintain diversity of plant and animalcommunities and to select and monitor a set ofmanagement indicator species. These species are toserve as surrogate measures of the health of bioticcommunities in relation to management activities.However, the Forest Service lacks guidelines, train-ing, and expertise to select and monitor indicatorspecies and some of the selected species have notbeen monitored. Use of indicators should focus onan improved selection process, and should provideinformation on the consequences of managementactivities as well as on current habitat conditions andecological processes.

FOREST PLANNINGTECHNOLOGIES

Technologies useful to forest management clarifyresource location, analyze resource availability overtime, and assess effects of decisions on ecosystemsand on human values. Computer models, as onetechnology to help with these evaluations, provideestimates of what might happen under variousmanagement options.

The most useful technologies for examiningspatial resource interactions are geographic informa-tion systems (GIS). These systems can superimposelocational data for two or more resources or activi-ties (e.g., timber stands over soil types). In so doing,GIS can contribute to resource management deci-sions and to public understanding of resourceinteractions. These systems, however, are veryexpensive to acquire and develop, and must be basedon reliable data. To date, the Forest Service has notused GIS extensively in forest planning, largelybecause of program and funding restrictions im-posed by Congress.

Linear programming is also a useful technologyfor analyzing resource use. Linear programmingmodels for land management try to maximizeresource uses and outputs over time within ecologi-cal limits. The models can provide the Forest Servicewith information on how to meet the requirements ofsustainable timber production and coordination oftimber harvesting with other uses. Linear program-ming, however, requires massive amounts of data todefine interrelationships among resources; excludesanalysis of risk and uncertainty; and necessarilyassumes direct, continuous, and reversible relation-ships among resources.

Resource simulation models are the principaltechnologies used by the Forest Service for estimat-ing ecological and environmental responses toactivities. These models try to quantify relationshipsamong resources and results of management actions.Simulations such as timber growth-and-yield mod-els and sediment yield models often examine conse-quences of management activities for a singleresource. The regional diversity of forest resourceshas led to many unique, local models rather thanuniversal models. Simulation models commonly areused as input to other models, such as linearprogramming models.


Economic and financial consequences of manage-ment must also be considered in planning. This canbe done, in part, by ex amining the benefits and costsof the proposed activities, the approach taken inFORPLAN. In addition, models are used to estimatethe local economic effects of management decisions.Input- output analysis is the traditional model used,and the Forest Service has developed variations ofsuch a model--IMPLAN--for forest planning.

The Forest Service designated FORPLAN asthe principal analytical tool for forest planning.FORPLAN is a linear programming model thatmaximizes the present net value of resource uses andoutputs (i.e., maximizes management efficiency)within specified constraints. The Forest Service usesFORPLAN because it performs certain tasks welland because it helps organize planning aroundselected issues. The strengths of FORPLAN includeits enormous analytical capacity; its focus onimportant issues (i.e., how much timber can be cutand from which areas); and its common language foranalysts.

FORPLAN is limited by its requirements formassive amounts of data on ecological interactionsand for market prices for all resource uses andoutputs. FORPLAN includes nonuse values-suchas protecting watersheds, preserving endangeredspecies, and improving aesthetics-only as con-straints rather than as goals. This implies thatsustaining ecosystems is a constraint on production,and not a goal for managing the national forests.Further, FORPLAN, and linear programming g gener-ally, has little capability to analyze spatial concerns.

Some resource managers and public interestsmistrust FORPLAN because of its large size andcomplexity, problems with documentation and veri-fication, and poor understanding of how to use theresults in decisionmaking. Nonetheless, FORPLANcan be a useful analytical tool if the Forest Serviceuses it with other technologies and to support publicunderstanding.

E C O N O M I C S I N N A T I O N A L

F O R E S T P L A N N I N G

Economic considerations in strategic planning fornational forest management involve determining thebalance among resource values and identifyingimpacts of national forest management on communi-ties. MUSYA calls for consideration of the relative

values of resources, while RPA and NFMA set uprequirements for economic analyses. Through theserequirements, Congress intended the Forest Serviceto determine the proper balance among resourceuses, outputs, and protection through interactionwith the public. Although Congress rejected eco-nomic efficiency as the principal consideration formanaging the national forests, it has been empha-sized in national forest planning.

The Forest Service uses FORPLAN as an eco-nomic efficiency model in national forest planning.In terms of achieving economic efficiency,FORPLAN is limited by uncertainties over thecomparability of market prices and other values,difficulty in balancing uses and outputs with nonusevalues, and inaccurate cost and value data.FORPLAN’s capability to assess efficiency of forestmanagement alternatives also is limited by the lackof knowledge of quantity and quality changes in allresource values that might result from the manage-ment activities.

Community stability is a common local concernin forest planning. The Forest Service is limited in itsability to assess and achieve community stabilitybecause of imprecise definitions, the lack of meas-ures of stability, the difficulty in measuring theacceptable pace and amount of change, and theagency’s inability to influence resource or productdemand.

The Forest Service uses IMPLAN, an input-output model adapted to each national forest, toassess employment and related impacts on commu-nities. However, the county-level data used canmask differences among communities within acounty. Furthermore, input-output models only pro-vide comparable analysis for certain resource-basedsectors. For example, the models define lumber andwood products as a single manufacturing industry,whereas recreation is scattered among several indus-tries in the retail trade and service sectors.

Restructuring payments to counties based ontimber sales may provide one way for the ForestService to avoid causing community instability. Atpresent, the Forest Service returns 25 percent of itsgross receipts to the States for use on roads andschools in counties that contain national forests.Forest Service payments account for a large portion,up to 80 percent, of operating budgets in somePacific Northwest counties. Timber typically ac-counts for most of the payments, usually 95 percent


of the total nationally, but the payments vary widelyfrom forest to forest and from year to year. Thus, thecounties have little certainty about annual payments,but are more likely to support Forest Service timbersales than other activities in the planning process.Fair and consistent compensation for the tax exemptstatus of national forest lands and activities couldstabilize county payments, regardless of how thelands are managed,

T H E B U D G E T I N G P R O C E S S

The annual Forest Service budget is the direct linkbetween Congress and national forest management.Budgets in some forest plans have been constrained,providing a picture of financially feasible opportuni-ties; in other forest plans, budgets have beenunconstrained, providing an examination of a widearray of alternatives. Unconstrained budgets proba-bly will not mesh with spending realities, and do notprovide information on priorities, but constrainedbudgets exclude possible opportunities. Because ofthe different budget assumptions, the forest planbudgets cannot be aggregated to a simple NationalForest System budget proposal.

The national Forest Service budget and appropria-tions are broken down by resource, in line itemappropriations. These appropriations must be trans-lated into integrated resource projects by resourcemanagers. The imprecision of this translation andthe difficulty of setting priorities among the lineitems has led to accounting data that may not reflectactual expenditures for managing the resources.Accountability is further complicated because targetaccomplishments for commodity resources, espe-cially timber, are readily measurable whereas targetaccomplishments for noncommodity resources arenot.

End-results budgeting, as proposed by the ForestService, would collapse line items for national forestmanagement into one operation and maintenanceaccount. The agency would record separate lineitems for investments, such as roads, trails, andreforestation. The effectiveness of this budgetingsystem depends on accurate measures for changes inconditions of all resources in response to manage-ment activities. Although the General AccountingOffice (GAO) reacted favorably to a test of end-results budgeting, the necessary measures of condi-tion to demonstrate the end results of managementare not sufficient at this time. Congress also may

perceive a loss in control over the budget for eachresource program. An alternative approach might becongressional appropriations by activity+. g., plan-ning, operations, maintenance and protection, in-vestments, and monitoring.

Fourteen permanently appropriated special ac-counts or trust funds account for nearly a third of theForest Service budget. Six of the largest are princi-pally related to the timber program. The ForestService has substantial discretion to determine theamount of money deposited in four of these funds—the Knutson-Vandenberg (K-V) Fund, the Sal-vage Fund, brush disposal, and other cooperativedeposits—which are to be used on the national forestwhere the money was collected. Despite the substan-tial discretion to determine local budgets throughtimber management activities, Congress has exer-cised little oversight or control over the specialaccounts and trust funds.

ORGANIZATIONAL FACTORSIN FOREST PLANNING

For at least half a century, the Forest Service wasviewed as a premier Federal agency. It was seen asa strong and independent manager of public re-sources for the public good. Professionalism withinthe Forest Service provided the basis for its longhistory of success; however, as it is dominated byprofessionals and technicians trained in forestry, theagency has given emphasis to the management anduse of trees. Although this emphasis has had merit inpast national forest planning, public perceptions ofthe relative values of forest resources have beenchanging. Social values today are less utilitarian andless accepting of traditional forestry practices thatmay harm nonuse values of the forests. The profes-sion and the agency have been changing, but manybelieve the change is too little too late.

The Forest Service, in accordance with NFMAand NEPA, has developed an interdisciplinaryapproach to forest planning. The agency uses teamsof specialists in wildlife, forestry, recreation, engi-neering, hydrology, soils, economics, range, andmany other fields. A diverse workforce brings abroader array of ideas, leading to increased creativ-ity and flexibility for the organization. Efforts todiversify have been overshadowed, however, by theagency’s traditional organizational structure by re-source function, especially at regional and nationaloffices. The emphasis on individual resources makes

.


integrated project planning and implementationdifficult.

Most Forest Service employees believe thattimber production is rewarded by the agency aboveother resource uses and values. More generally,agency employees believe that productivity (meet-ing targets, working hard, and being competent) andteam spirit (loyalty, teamwork, promoting the ForestService image, and getting along with peers) are themost rewarded organizational values. These organ-izational values differ from personal values held bymany Forest Service employees, who, regardless oftheir professional training or level in the agency,tend to value recreation over other uses, followed bywildlife and water. Many employees also believethat concern for healthy ecosystems should berewarded to the same degree as professional compe-tence, hard work, and teamwork.

The mismatch between apparent agency andemployee values may reflect several difficulties.These include changing established modes of opera-tion, external pressures, and a reward system thattypically measures the tangible outputs of commod-ity resources and ignores the intangible unmarketedand nonuse values.

To be implemented, the forest plans must betechnically and politically feasible, i.e., consistentwith scientific information, with public goals, andwith national decisions. Technical feasibility can beassessed annually by comparing outputs, changes inconditions, and unit costs with those in the forestplan. Political feasibility can be measured, in part, bythe number of administrative appeals and lawsuitsfiled against a plan. However, additional measuresof the effectiveness of public involvement andmanager responsiveness need to be developed toassure that managers are properly rewarded.

N F M A F O R E S T P L A N N I N G

I N R E L A T I O N T O N A T I O N A L

R P A P L A N N I N G

RPA establishes a strategic planning process atthe national level structured around four documents:the RPA Assessment, the RPA Program, the Presi-dential Statement of Policy, and the Annual Report.NFMA establishes a strategic planning process atthe local level, using an interdisciplinary approachand public involvement. The Forest Service regula-tions describe RPA-NFMA planning as iterative, in

that information from the forest level flows up to thenational level and information in the RPA Programflows back to the forests. The Forest Servicehistorically approached planning as a hierarchicalprocess, allocating resource targets from the RPAProgram to the regions, and from the regions to theforests. The 1990 process, however, was influencedby a more integrated approach using informationfrom the plans in the RPA Assessment and in theProgram strategies.

The national forest plans provide information onresource conditions and predicted results of pro-posed management actions. The RPA Assessmentprovides information on resource outputs, condi-tions, and trends on national forests, private, andother public lands. The RPA Assessment can serveas a source book for forest-level planners. Forestplanners can design inventory and monitoring activ-ities so data will be compatible with previousinventories and studies in progress. Data can then bemore easily aggregated and used in a comprehensiveanalysis in the RPA Assessment.

The forest plans also contribute to the RPAProgram, by identifying the public’s preferred man-agement alternatives. Issues and concerns that arewidespread at the local level should receive specialattention in the Program. As a strategic plan, theProgram needs to set direction for national forestplanning as well as for Research and for State andPrivate Forestry. The program, however, should notoverride local decisionmaking. Instead, it can aug-ment local planning by addressing regional, na-tional, and global issues not identified locally andprovide direction for forest plan revisions.

The forest plans can provide information to theAnnual Report on expenditures and results ofmanagement on each national forest. This informa-tion can be used to assure spending is balanced andefficient. Reporting on expenditures, outputs, andconditions should be consistent among forests andwith the RPA Assessment so data can be aggregatedand compared and trends assessed.

Target allocations from annual appropriations andthe RPA program are difficult to mesh with localplanning, primarily because targets are set only forcertain outputs. Forest managers lack measures forannual nontimber outputs and nonuse values and,thus, are generally ill-equipped to demonstratebalance in achieving stated goals. Strategic planningdoes not require eliminating national targets. In fact,


targets are critical for reaching stated goals forvarious resources at different times. Hard targets forselected outputs, however, do not encourage aninteractive flow of information from the local levelto the national level and, thus, run counter tofunctional strategic planning and the iterative proc-ess.

Resource capability information developed at thelocal level is a base for RPA planning, whereasnational objectives are essential to strategic planningand the setting of long-term goals. The process mustbe centralized to take a comprehensive look atoverall direction and to integrate budgeting andperformance appraisal. However, the process alsomust be decentralized to treat individual forestsappropriately and to assure that local plans aretechnically and politically feasible.

R O L E O F C O N G R E S S

OTA has identified four major findings on forestplanning:

1. Plan development emphasizes timber and otherphysical outputs.

2. Monitoring of forest management activities isinadequate.

3. Budget decisions overwhelm planning deci-sions.

4. National targets can nullify local decisions.

In view of these findings, OTA has identified 14options available to Congress to improve forestplanning under NFMA. These options are discussedbelow under the corresponding finding. (See tablel-l.)

Finding 1: Plan development emphasizes timberand other physical outputs.

The Forest Service emphasizes allocating landsand producing physical outputs, especially timber,in forest planning and gives little attention tosustaining ecosystems. MUSYA, NFMA, and theplanning technology FORPLAN encourage the em-phasis on timber and other physical outputs. Forestplan implementation, budgeting, and national direc-tion also emphasize land allocation and the quantita-tive, physical outputs of the national forests.

Option 1: Clarify legislative direction.

Congress could amend the laws guiding na-tional forest planning and management to recog-

Table l-l—Major Findings on NFMA Forest Planningand Possible Options for Congress

Findings Options

Plan development emphasizestimber and other physicaloutputs

Monitoring of forestmanagement activitiesis inadequate

Budget decisions overwhelmplanning decisions

National targets can nullify localdecisions

Clarify legislative directionBroaden the information base

Establish targets for allresources

Improve public involvement

Expand use of informationtechnologies

Separate the monitoringfunction

Require linkage betweenactions and results

Require public involvement inmonitoring

Eliminate appropriations byresource

Require realistic budgets inforest plans

Control special accounts andtrust funds

Compensate counties fairly andconsistently

Specify forest plans as thebaseline for RPA planning

Require RPA direction for allresources and all branches

SOURCE: Office of Technology Assessment, 1991,

nize the nonuse values of the national forests andto assure the protection of the ecosystems thatgenerate the use and nonuse values.

MUSYA could be amended to expand thepurpose of the National Forest System. The ex-panded purpose could include providing for all theuse and nonuse values of forests and rangelands.Multiple-use management could be expanded toinclude multiple values of the lands, and focus onsustaining national forest ecosystems. Amendmentsto NFMA could require a determination of landsuitability for all management activities and couldrequire forest plans that aim to sustain all values,including nonuse values.

Option 2: Broaden the information base.

Congress could require the Forest Service toexpand its forest planning inventory and analyti-cal base to include necessary information andmodels on all resources, on ecological interac-tions, and on social and economic impacts.

. .— —

Chapter l--Summary ● II

NFMA planning has initiated few resource inven-tories beyond those already used in forest planningand management before NFMA. Inventory data andmodels for the timber resource are more extensivethan those for other resources or for ecosystemconditions. Data and models for examining eco-nomic results of management activities are morecomplete for timber outputs than for other outputsand conditions. Congress could direct the ForestService to balance its forest planning informationbase and increase inventory funding, to assure thatanalysis responds to public concerns over nationalforest goals and management practices.

Option 3: Establish targets for all resources.

Congress could require forest plans to specifytargets for all resource uses and outputs, fornonuse values, and for ecosystem conditionsidentified as important by the public in itsparticipation in the planning process.

Congress intended forest plans to set the directionfor managing national forests. Current Forest Serv-ice databases and analytical tools, however, primar-ily measure physical outputs. Congress could re-quire the Forest Service to develop measures thatmore fully describe management direction for thenational forests. The Forest Service could thenidentify targets for all uses and outputs, for nonusevalues, and for ecosystem conditions in the forestplans and in RPA planning.

Option 4: Improve public involvement.

Congress could clarify the purposes for involv-ing the public in forest planning, and could directthe Forest Service to improve its public participa-tion processes.

Vague guidance in the forest planning laws hasled the Forest Service and the public to conflictingexpectations about how public comments are to beused in determining the future direction of nationalforest management. The Forest Service model ofpublic participation impedes effective participationbecause the public is viewed as an informationsource for identifying output goals, rather than asindividuals and groups interested in all aspects ofmanagement. Congress could amend NFMA todirect the Forest Service to use public involvementto build plans and decisions that are more acceptableto society. The Forest Service also could improve itspublic participation process by emphasizing the

importance of buildingtions or compromises.

Option 5: Expand usegies.

trust and acceptable solu-

of information technolo-

Congress could direct the Forest Service tobroaden the variety of technologies used forinformation collection, analysis, coordination,and presentation to assure that spatial andtemporal aspects of forest management are ade-quately addressed.

Current Forest Service planning technologies areimpeded by lack of information on resource interac-tions, have limited capacity for analyzing spatialconcerns, are difficult to understand, and emphasizeimpacts on the timber industry over other industries.Congress could direct the Forest Service to improveits use of planning technologies by integrating theirprincipal tool for forest planning--FORPLAN—with a GIS. The Forest Service also could be directedto emphasize research on more complete models ofeconomic impacts. Finally, the agency could im-prove the coordination of data collection and stor-age, build a historical record for forest planning, andcontribute to an integrated RPA Assessment.

Finding 2: Monitoring of forest managementactivities is inadequate.

An enormous amount of Forest Service and publictime and effort has gone into developing nationalforest plans. Monitoring, however, has been inade-quate to determine whether the plans are beingimplemented. The inadequate monitoring resultsfrom an inadequate database, insufficient funding,and lack of incentives to monitor. It is difficult tomonitor changes in ecosystem conditions withoutbaseline information on preexisting conditions. TheForest Service system, which includes few nontim-ber measures for evaluating managers, does notencourage monitoring.

Option 6: Separate the monitoring function.

Congress could establish monitoring of forestplans as a separate Forest Service activity, withspecified purposes and reporting.

Monitoring is important to determine whetherproposed and ongoing management activities areconsistent with planning goals. Currently no sanc-tions exist for incomplete or inadequate monitoring.

—


Congress could establish monitoring as a distinctForest Service responsibility. Congress could thenrequire an annual monitoring report, prepared by aninterdisciplinary team, with specific requirementsand with public participation or review. This wouldrecognize the importance of monitoring, and mightreduce the tendency to curtail or eliminate monitor-ing due to insufficient time or money.

Option 7: Require linkage between actions andresults.

Congress could require the Forest Service toidentify, in an annual report for each nationalforest, the results of activities in terms of outputsand conditions and in public participation in theplanning process.

An annual report from each forest could be anadded requirement under the NFMA planning proc-ess. This report could be used internally, forevaluating the performance of forest supervisors andstaff, and externally, for informing the public aboutthe results of management practices. The reportcould show how management activities meet outputand condition targets specified in the plans and couldalso include an evaluation of public participation.

Option 8: Require public involvement in moni-toring.

Congress could direct the Forest Service toinclude public participation in the monitoring ofnational forest plan activities.

Monitoring is expensive but essential in forestplanning. It assures that activities conform with plandirection and achieve the plan goals. Public involve-ment provides feedback to the agency on how thepublic interprets the plan’s direction. Public in-volvement also can help the agency focus on keyconcerns so that the most important outputs andconditions are measured carefully. Finally, publicinvolvement in monitoring can provide checks andbalances to assure that measurement is accurate.

Finding 3: Budget decisions overwhelm planningdecisions.

The annual Forest Service budget request andappropriations from Congress are inconsistent withthe budget levels and mixes assumed in nationalforest planning. This occurs, in part, because theforest plans set up an integrated approach to land and

resource management whereas the budget requestand appropriations are arranged by resource activity.Forest plan budgets and annual appropriations alsodiffer because budget assumptions vary in theamount of restrictions. When congressional appro-priations conflict with forest plan direction, theformer usually directs the course of action becauseForest Service employees are responsible for assur-ing that money is spent as directed. Special accountsand trust funds, which result largely from timberactivities, encourage the emphasis on timber outputsby providing counties and the agency with benefitsfrom increased timber sales. Many special accountsand trust funds are permanently appropriated, andreceive little attention from Congress.

Option 9: Eliminate appropriations by resource.

Congress could replace appropriations by re-source line item with appropriations by manage-ment activity. Congress could then direct theForest Service to develop its budget based on theactivities needed to implement the forest plans.

Forest Service budget requests and congressionalappropriations are now arranged in about 60 lineitems, specifying expenditures for resource activi-ties. Proposed funding for each activity is adjustedat each budget step-by the Washington Office ofthe Forest Service, the Secretary of Agriculture, theOffice of Management and Budget, and the Houseand Senate Committees on Appropriations. Resource-oriented appropriations encourage the administra-tion and Congress to specify output targets, espe-cially for timber, because such targets are easilyspecified and are controllable by Forest Servicemanagers. The Forest Service gives monitoring alow priority because monitoring does not providetangible outputs for which the managers can berewarded and because the agency lacks penalties forinadequate monitoring. Congress could replace re-source appropriations with appropriations for theactivities necessary for managing the national forests—planning, implementation, and monitoring.

Option 10: Require realistic budgets in forestplans.

Congress could direct the Forest Service toinclude a range of budget possibilities, from thecurrent forest budget to an unlimited increase, in thefinal plan for each national forest. The WashingtonOffice of the Forest Service provided no direction on


the budget assumptions to be used in national forestplanning. Some regions restricted budgets thatforests could assume in planning, whereas otherregions provided no restrictions. Budget restrictionsare more likely to result in forest plans that areimplementable but discourage identifying opportu-nities for improvement. Unrestricted budgets mayspecify opportunities for investments but may pro-duce plans that are not realistic and cannot beimplemented. Congress could require the ForestService to include both types of information in forestplans. The agency could then link the forest planswith opportunity analysis in the RPA process andprovide information on likely outputs and conditionsin the annual budget request.

Option 11: Control special accounts and trustfunds.

Congress could require more complete report-ing on the sources and uses of money in thevarious special accounts and trust funds, andcould clarify the purposes for which the fundscould be used.

The Forest Service presents little information onthe sources and uses of money in the various specialaccounts and trust funds that provide about one thirdof its budget annually. Thus, Congress is unable toexercise much control over their use. Congress couldrequire the Forest Service to present more completeinformation on the sources and uses of money in themajor special accounts and trust funds in the budgetrequest, the RPA Program, the forest plans, and theannual reports. Congress could examine the use ofspecial accounts and trusts funds and clarify thepurposes for which the funds could be used.

Option 12: Compensate counties fairly and con-sistently.

Congress could replace the current program ofreturning 25 percent of gross Forest Servicereceipts with a system to compensate countiesfairly for the tax exempt status of Federal landsand activities.

Since 1908, the Forest Service has returned 25percent of its receipts to the States for use on roadsand schools in counties where national forests arelocated. The Payments in Lieu of Taxes (PILT)program, administered by the Bureau of LandManagement, also compensates counties for the taxexempt status of Federal lands. It is unclear whether

the combination of Forest Service receipt-sharingand PILT payments is fair compensation. In someareas, the counties may receive payments thatexceed potential collections from a private owner ofundeveloped land. In other areas, the counties maybe undercompensated.

Many counties rely on Forest Service timberharvests for large portions of their budgets, buttimber receipts may vary by as much as 50 percentor more from year to year. Furthermore, PILTpayments require annual appropriations that couldface reductions with Federal budget cuts. Congresscould replace the current system of receipt-sharingand PILT payments with a system that fairly andconsistently compensates the counties for the taxexempt status of national forest lands. Congresscould require a study to devise the appropriatecompensation methods and levels, and then replacethe current system with the new tax-equivalencycompensation system.

Finding 4: National targets can nullify localdecisions.

RPA established a national strategic planningprocess for renewable resources. RPA also estab-lished a local planning process for preparing landand resource management plans for national forests.NFMA amended RPA to include considerations andrequirements for local planning. The Forest Servicedescribes the connection between RPA and NFMAas iterative, with information on capabilities andopportunities flowing from the local level to thenational level, and national targets being allocatedfrom the national level to the forests. The allocationof national RPA targets to the forests can negatelocal agreement about the proper managementdirection for a national forest. Nationally determinedtargets also can substantially alter national forestmanagement directions that have been determinedwith considerable local analysis and public involve-ment.

Option 13: Specify forest plans as the baseline forRPA planning.

Congress could require the Forest Service touse the management direction established in theforest plans as the baseline for National ForestSystem outputs and values in the RPA planningprocess.


National analyses of management options maynot account for site-specific interactions and con-straints and, thus, can overestimate productionpossibilities on the national forests. To correct this,Congress could direct the Forest Service to usenational forest plans as the baseline for outputs andvalues and specify that RPA Program direction beconsistent with the forest plans.

Option 14: Require RPA direction for all re-sources and all branches.

Congress could require the Forest Service toprovide targets and national direction for alloutputs and values and for all branches of theagency.

The RPA Program has traditionally establishedphysical output targets for the National ForestSystem, with only general direction for other valuesand other branches of the agency. Congress couldimprove the balance among resources and amongFederal and non-Federal lands by directing theForest Service to establish direction for agencyprograms to address all outputs and values on allforests and rangelands. Congress could require RPAProgram direction for all four branches ofthe Forest Service, to be defined in long-termgoals for productivity and ecosystem health and inshort-term targets for outputs and conditions ofconcern.

Chapter 2

Policy Options

. —.. - — - -. . - -- -— — -

ContentsPage

Forest Plan Development . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Plan Development Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Forest Plan Implementation. . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Plan Implementation Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .

Forest Service Budget Reconciliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Forest Service Budget Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Forest Planning Direction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Planning Direction Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .

171821212324272729

Chapter 2

Policy Options

The National Forest Management Act (NFMA)was enacted in 1976 primarily in response tosuccessful lawsuits challenging longstanding ForestService timber sale practices in West Virginia andelsewhere. Because these lawsuits indicated a grow-ing public dissatisfaction with clearcutting and otherForest Service activities, Congress chose to requirea public planning process for setting managementdirection for each national forest. Congress expectedthat a planning process based on sound information,environmental standards, and public involvementcould resolve many local controversies over nationalforest management.

Many are concerned that the NFMA planningprocess is not working as it was intended. Forestplanning has been controversial, and nearly all forestplans and many actions under those plans (especiallytimber sales) have been appealed. Litigation, nota-bly over red-cockaded woodpeckers in the South andover spotted owls and old-growth forests in thePacific Northwest, has focused nationwide attentionon national forest management.

The current controversies over national forestplanning and management have led some, includingMembers of Congress, to question the efficacy of theplanning process, and a few agency critics havesuggested repealing the requirement for forest plans.However, plans are necessary for coordinatingactivities, and the public is interested in nationalforest management. Repealing the requirement for apublic planning process probably would return theForest Service to a situation akin to that which led tothe Monongahela lawsuit, the Bitterroot contro-versy, and other conflicts that led to NFMA in thefirst place.

No simple means exist for ending the conflictsover national forest management, because peoplecare about the national forests and have differentopinions on how the forests should be managed.Nonetheless, the planning process could be modifiedto reduce the nationwide conflicts by improving theprocess for resolving local differences. OTA hasfound problems and potential for improvements inforest plan development, in forest plan implementa-tion, in Forest Service budgeting, and in forestplanning direction. Singly and in combinations,

these options could move national forest planningtoward the goal Congress envisioned in NFMA--astrategic planning process for developing and imple-menting publicly acceptable management directionfor the national forests.

F O R E S T P L A N D E V E L O P M E N T

Finding 1: Emphasis on Timber and Other Physi-cal Outputs

The Forest Service emphasizes allocating landsand producing physical outputs, especially timber,in national forest planning. Certainly outputs areimportant. The forest reserves (national forests)were established to provide stable water flows andcontinuous timber supplies while protecting thelands and resources. They are, in many ways,analogous to trust funds. (See box 3-C, p. 48.)Outputs are the annuity from the trust fund. How-ever, the ecosystems are the investment that generatethe annuities; and their sustainability is paramount.

Forest planning today gives relatively little atten-tion to sustaining ecosystems. Emphasis on measur-ing and producing physical outputs must be bal-anced with the nonphysical ‘‘outputs"—the nonusevalues of forests, such as spiritual appreciation orpreserving a legacy for future generations. Planninggenerally provides for nonuse values through landallocations-recommendations for wilderness andidentification of lands not suited for timber production--but such allocations are indirect measures that divideinterests and ignore mutual benefits. The relativeinattention to sustaining ecosystems and to provid-ing nonuse values, the increasing demand for allresources, and conflicting social values are at leastsome of the reasons for the acrimony over nationalforest planning.

The emphasis on timber and other physicaloutputs results from a wide variety of factorsthroughout the Forest Service’s planning and man-agement systems. (This is not to say that timberdominates the management of all national forests,but that the agency’s structure and programs system-atically accentuate timber and other physical outputsover other values.) The Multiple-Use Sustained-Yield Act of 1960 (MUSYA) implied such a focuson outputs. Likewise, NFMA focused more on

–17–


regulating timber management than other activities.It is easier to inventory timber than to inventoryother resource conditions and values. In addition, theprincipal planning technology--FORPLAN--wasdeveloped from a timber harvesting schedulingmodel, and the goal (objective function) of themodel is to maximize those outputs that can bequantified. Other aspects of planning and management—implementation, budgeting, and national direction—also emphasize the quantitative, physical outputs ofthe national forests.

Plan Development Options

Implementable national forest plans will neces-sarily include a balance of uses, outputs, and nonusevalues, with management that is sensitive to ecosys-tems and acceptable to the public. The currentsystematic emphasis on timber and other physicaloutputs makes the development of acceptable forestplans difficult, at best, as suggested by the difficul-ties the Forest Service encountered in preparing thefirst round of forest plans. A number of steps couldbe taken to assist in achieving the balance necessaryto develop acceptable plans.

Option 1: Clarify the legislative direction.

Congress could amend the laws guidingnational forest planning and management torecognize the nonuse values of the nationalforests and to assure the long-run productivityof the ecosystems that generate the use andnonuse values.

Several laws guiding planning and managementof the national forests contribute to emphasis onphysical outputs. The 1897 Forest Service OrganicAct notably is not a problem. The frost purpose itidentified for the forest reserves was to improve andprotect the forests, and the second was to securefavorable water flows--a nonuse value of the forests(although water also has value in use). The OrganicAct also authorized regulation of the occupancy anduse of the forests ‘‘to preserve the forests . . . fromdestruction. Thus, the Organic Act is fully consist-ent with the trust-fired concept of the nationalforests—to provide use and nonuse values and toprotect the ecosystem base.

The Multiple-Use Sustained-Yield Act of 1960,however, does contribute to the physical outputfocus. MUSYA promotes the utilitarian view ofnational forests, listing as purposes either direct,

on-site activities (e.g., recreation and timber) orsurrogates for such activities (e.g., range, watershed,and wildlife and fish). Nonuse values, such asaesthetics, spiritual appeal, and future legacies are,at most, implicit in the act. Furthermore, sustainedyield contributes to this focus on the direct, on-siteuses and outputs by emphasizing their continuedproduction, rather than emphasizing the manage-ment of the ecosystems that generate all forestvalues. Amendments to MUSYA could; 1) expandthe purposes of the National Forest System to that ofproviding all the use and nonuse values of forestsand rangelands; 2) expand multiple-use manage-ment to include the multiple values of the lands; and3) focus on the sustainability of the ecosystems thatcomprise the national forests.

NFMA has also contributed to the timber focus byproviding additional regulatory guidance for contin-ued timber production while protecting other values.Section 6(k) requires the Forest Service to identifylands not suited for producing timber, “consideringphysical, economic, and other pertinent factors tothe extent feasible.’ Section 6(l)(1) requires repre-sentative information comparing timber sale, refor-estation, and stand improvement costs with returnsto the Treasury. Section 13(a) requires the ForestService to identify the allowable sale quantity fortimber, such that the production can be sustained inperpetuity. However, other resource managementactivities are not subject to comparably restrictiveprovisions. Amendments to NFMA could require:1) equivalent determinations of land suitability forall management activities; 2) revenue-cost compari-sons for each resource; and 3) goals for sustaining alloutputs (including nonuse values) at levels whichwill not decline.

Option 2: Broaden the information base.

Congress could require the Forest Service toexpand its inventory and analytical base forforest planning to include necessary informa-tion and models on all resources, on ecologicalinteractions, and on social and economic im-pacts.

NFMA planning has been conducted with fewsupplemental inventories, beyond those already inuse in forest planning and management prior toNFMA. For example, the northern spotted owl wasidentified as a management indicator species forforest planning in western Washington and Oregon

Chapter 2-Policy Options . 19

in the early 1980s. However, the comprehensiveinventory of owl populations and habitat was notbegun until 1989, after the owl had been proposedfor listing under the Endangered Species Act andafter draft plans had been completed for many of theforests. The Forest Service has been conductingtimber inventories for many years, with substantialstatistical validity, and has numerous models forexamining future stand conditions and related out-puts based on current or proposed managementactivities. However, inventories for other resourcesand for ecosystem conditions are less complete andmodels are less fully developed. Similarly, the dataand models for examining the economic conse-quences of management activities are more com-plete for timber outputs than for other outputs andconditions.

This is not to suggest that better data on resources,conditions, and trends will allow for correct, scien-tific management of the national forests. Forestplanning is necessarily political, because the deci-sions and choices are about the future and what itshould look like. Furthermore, information is expen-sive, and some data will always be imprecise.However, improved information and models canmore accurately describe the current situation andhow actions are likely to affect future outputs andconditions. This is as true for the economic andsocial effects of decisions as it is for the ecologicalaspects of land management. Information and mod-els should also focus on public values-on outputs,conditions, jobs, the legacy we leave to the future,etc. Thus, public participation should help definewhat should be measured and what analytical toolsare needed for forest planning.

Congress has provided little direction to theForest Service on the kind of information requiredfor forest planning and how to obtain it. NFMAestablished a number of analytical requirements,such as identifying lands not suited for timberproduction and determining the allowable timbersale level that could be sustained in perpetuity,which dictate certain analytical tools. However,NFMA contained no specific requirements on inven-tories; it only required the regulations to ‘‘providefor obtaining inventory data. ” Some analyses areimplied by the various requirements, such as provid-ing for biological diversity and prohibiting irreversi-ble watershed damage. Congress has protected theForest Service from judicial challenge to plansdeveloped using inadequate, outdated information

through a rider on the Forest Service appropriationsfor fiscal years 1988 and 1989.

Congress could direct the Forest Service toimprove its inventory and analytical base for forestplanning, to assure that the information and analysisresponds to the public’s concerns in terms ofnational forest goals and direction, of opportunitiesand tradeoffs, and of management practices. Con-gress might also recognize the cost of acquiringadditional information, since new inventories andtools can be expensive to develop, and a simplerequirement for ‘‘adequate’ information could besubject to widely disparate interpretations. Somecongressional guidance on the nature and purpose ofinformation and analysis could assist the agency indetermining, and the courts in assessing, the ade-quacy of the inventory and analytical base.

Option 3: Establish targets for all resources.

Congress could require the forest plans tospecify targets for all resource uses and out-puts, nonuse values, and ecosystem conditionsidentified as important by the public in itsparticipation in the planning process.

Congress intended the forest plans to set thedirection for managing the national forests. Direc-tion is, in part, described by the established short-and long-term goals. However, as discussed above,the information base and analytical tools emphasizephysical outputs, and are fragmentary at best fornonuse values and for ecosystem conditions. Whilethe public is interested in physical outputs, it is alsoconcerned about nonuse values and about thelong-term health of ecosystems. The emphasis onoutputs contributes to conflicts over national forestplanning, because the public wants goals establishedfor all the uses and values of the forests andrangelands,

Congress could require the Forest Service todescribe more fully the management direction forthe national forests by identifying targets for usesand outputs, for nonuse values, and for ecosystemconditions in the forest plans. Identifying suchtargets will require development of relevant meas-ures, especially for nonuse values and ecosystemconditions. Such an expanded information basemight not be immediately implementable. Nonethe-less, a broad array of targets is necessary to respondto the desires and interests of the American people.

20 ● Forest Service planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Option 4: Improve public participation.

Congress could clarify the purposes forinvolving the public in forest planning, andcould direct the Forest Service to improve itspublic participation processes.

Effective public participation in forest planningdemands that the agency and the participants under-stand why participation is required. NFMA and theNational Environmental Policy Act of 1969 (NEPA)helped to establish public involvement in agencyplanning and decisionmaking. However, the lan-guage in the laws requiring public participation inforest planning is ambiguous as to why the publicshould be involved. Therefore the agency and thepublic have differing and even opposing expecta-tions about how public comments are to be consid-ered and used in determining the future direction ofnational forest management. The imprecise guid-ance and contrasting expectations have heightenedthe conflict over national forest planning and man-agement.

The Forest Service model of public participationalso has hindered effective public involvement inforest planning. Many Forest Service managersapproach public participation as an ‘‘inform andeducate’ exercise--to learn what the various inter-ests want and to inform them of what is feasible. Thisapproach impedes effective participation, becausethe public is viewed merely as a source for establish-ing output goals, rather than as individuals andgroups interested in all aspects of management. Italso suppresses understanding and trust, because theindividuals and groups are supposed to accept whatthe Forest Service determines is feasible, eventhough the information presented is often incom-plete or too technical for many to comprehend.Furthermore, the agency often addresses the inter-ests separately, which can lead to mistrust aboutwhat agreements have already been reached. Thus,the ‘inform-and-educate model and meetings withseparate groups hamper effective public participa-tion in forest planning.

Congress could clarify the purpose for publicparticipation in forest planning. NFMA could beamended to direct the Forest Service to use publicinvolvement to build plans and decisions that areacceptable. Various tools could be employed, toassure effective involvement by the variety ofindividuals and groups interested in forest planningand management, including but not limited to formal

and informal public gatherings, personal contacts,and alternative dispute resolution techniques. Con-gress could also strengthen the direction in section14 of the Forest and Rangeland Renewable Re-sources Planning Act (RPA), as amended by NFMA,for using advisory committees, including an exemp-tion from the Federal Advisory Committee Act, ifdeemed appropriate.

The Forest Service could also improve its publicparticipation process by stressing the importance ofbuilding trust and consensus (or at least not opposi-tion) among the various interests. The Forest Servicerecognizes the widespread dissatisfaction with thecurrent process, and currently has an employeetraining course that seems to build on this concept ofpublic involvement. Nonetheless, the Forest Servicemust assure the public and its employees that theprocess is intended to build local agreement on howthe national forests should be managed.

Option 5: Expand use of information technolo-gies.

Congress could direct the Forest Service tobroaden the variety of technologies used forinformation collection, analysis, coordination,and presentation to be sure that both spatialand temporal aspects of forest managementare adequately addressed.

The Forest Service, in 1979, designatedFORPLAN as its principal tool for national forestplanning. FORPLAN (and linear programming ingeneral) is useful for organizing data and analyz-ing the temporal aspects of forest outputs, butFORPLAN: 1) typically requires information onresource interactions that exceed the state-of-the-knowledge, 2) has limited capacity for analyzingspatial concerns, and 3) was built to be compre-h e n s i v e - - answer all relevant questions in one model—and thus often defies understanding by the publicand even planners. IMPLAN (and input-outputmodels in general) is useful for ex amining theeconomic consequences of plan alternatives, but thenature of the data and the model lead to a fullerpicture of the impacts on the timber industry than onother industries.

Congress could direct the Forest Service toimprove its use of various planning technologies.FORPLAN, or a comparable tool, is probablynecessary to address temporal concerns, such assustainable output levels, but could be simplified by

Chapter 2-Policy Options ● 21

separating distinct issues for analysis with differentversions of the model. Despite the extreme cost ofgeographic information systems, such a spatial toolis probably necessary to address spatial concerns,and would be most useful if linked to FORPLAN.The Forest Service could also be directed to empha-size research on models for spatial and temporalresource interactions and on more complete modelsof economic and social impacts. The Forest Servicecould be directed to improve the coordination of datacollection and storage, to build a historical record forforest planning and to contribute to an integratedRenewable Resource Assessment. Finally, the For-est Service must recognize that the various technolo-gies are intended to support and assist in buildingacceptable plans and decisions, not to provide adefinitive answer that must simply be accepted.

F O R E S T P L A N

I M P L E M E N T A T I O N

Finding 2: Monitoring of Forest ManagementActivities Is Inadequate

National forest plans have been developed withenormous expenditures of Federal and public timeand effort, but it is uncertain how effectively thoseplans are being implemented. To date, monitoringhas been inadequate to evaluate national forestplanning and management.

The inadequate monitoring results, in part, fromthe inadequate base of information on resource usesand outputs and ecosystem conditions of forests andrangelands. For example, it is impossible to monitorchanges in ecosystem conditions that result fromforest planning direction or from management activ-ities without baseline information on preexistingconditions. On the other hand, monitoring couldhelp establish baseline data needed for forest plan-ning. Thus, inadequate inventories and inadequatemonitoring are part-and-parcel of the same problem,and both must be improved to provide an adequatepicture of the forest and rangeland resources andecosystems.

Inadequate monitoring also results from the lackof incentives to monitor, or more precisely, from thelack of penalties for not monitoring. Forest supervi-sors are evaluated largely on achieving the easilymeasurable annual outputs specified for their forests—the “hard’ targets, such as timber sale targets-andon spending money as appropriated. Timber sale

outputs and expenditures are important, but the lackof monitoring of other plan objectives permitsachieving other activities and goals to be postponedand could allow resource and ecosystem conditionsto deteriorate. Monitoring that shows degradingconditions or unbalanced achievement of plan ob-jectives would not only reflect poorly on the agencyand its managers, but would also provide the publicwith information that could be used to challengeactivities and practices. Thus, the agency has adistinct disincentive to monitor the implementationof the forest plans.

Plan Implementation Options

Monitoring is an essential part of strategic plan-ning for the national forests. Monitoring serves threepurposes. First, monitoring demonstrates whetherthe management activities on the ground are consist-ent with the direction established in the forest plan.Second, monitoring demonstrates if the results ofthose activities achieve the goals identified in theplan. And third, monitoring demonstrates the accu-racy of the assumptions and values used in the plan.Through such demonstrations, monitoring providesthe feedback needed to revise the plans and manage-ment activities and to assure that the national forestsare being managed to meet the needs of theAmerican people. Several options could improvemonitoring of forest plan implementation.

Option 6: Separate the monitoring function.

Congress could establish monitoring of for-est plans as a separate Forest Service activity,with specified purposes and reporting.

Current Forest Service planning regulations (36CFR 219.1 l(d)) specify that the forest plans mustidentify the monitoring and evaluation requirementsneeded to evaluate management activities. While theplans all appear to contain monitoring sections, nosanctions exist for incomplete or inadequate moni-toring. Furthermore, monitoring and reporting mightdemonstrate that activities are inconsistent with thedirection established in the plan, that the outputsvary from the planned goals, or that the assumptionsupon which the plan is based are incorrect. Inaddition, monitoring must compete for funding withother activities, such as planning and output produc-tion. Thus, monitoring is generally the first activityto be eliminated or reduced when funding is less thanthe level specified in the forest plan.


Congress could establish monitoring and report-ing as a distinct Forest Service responsibility, muchas it did with integrated land and resource manage-ment planning. The Forest Service had conductedplanning before the enactment of RPA and NFMA,but Congress specified standards for national forestplanning, such as an interdisciplinary approach,periodic revisions, specific considerations, and pub-lic participation. Congress similarly could require anannual monitoring report, prepared by an interdisci-plinary team, with specific requirements and publicparticipation. (The following options discuss theselatter aspects.) This would recognize the importanceof monitoring, and might reduce the likelihood ofCurtailing“ “ or eliminating monitoring due to insuffi-cient time or money.

Option 7: Require linkage between actions andresults.

Congress could require the Forest Service toidentify, in an annual report for each nationalforest, the results of activities in terms of theoutputs and conditions identified as goals inthe national forest plans, and in terms of publicparticipation in the planning process.

The Forest Service currently is required to preparea national annual report on its activities as part of theRPA planning process. However, as described in theOTA study, Forest Service Planning: Setting Strate-gic Direction Under RPA, the agency’s annualreport provides an incomplete picture of outputs andcondition changes in the national forests. Timbersales and harvests, recreation use, and other uses andoutputs are often identified, but the measures forsome resources are merely rough estimates. Thereport more typically identifies management activi-ties, but the activities are not related to the condi-tions supposedly being managed; for example,range, watershed, and wildlife habitat improvementefforts are reported, but the agency lacks measures(quantitative or qualitative) to show the resultingimprovements in range condition, watershed condi-tion, or wildlife habitat condition.

Comparable annual reports are not required aspart of NFMA planning, although many forestsproduce them and the Forest Service has recentlyproposed annual reports for each national forest. Anannual report could be useful internally, for evaluat-ing the performance of forest supervisors and theirstaffs, and externally, for informing the public about

the results of management. However, to be effectivefor such uses, an annual report must demonstratehow on-the-ground activities meet the output andcondition targets specified in the forest plans.Because of concerns about the community impactsof national forest management, an annua1 reportmight also identify relevant changes in local em-ployment that result from management activities.

An annual report on national forest managementcould also include an evaluation of public participa-tion. Some have suggested that managers should berewarded for resolving administrative appeals andlawsuits over forest plans and over activities toimplement the plans. Resolving issues locally isgenerally desirable, and a declining number ofappeals and lawsuits would indicate success in suchefforts. However, some conflicts cannot be resolvedlocally, while others may be reduced by postponingdecisions or by directing the decision to anotherforum. Thus, additional measures of effective localpublic involvement in forest planning and manage-ment are needed to evaluate fully managerial per-formance in public participation responsibilities.

Congress could require an annual report fromeach national forest to provide relevant informationfor internal and external reviews that would com-plete the feedback necessary for strategic nationalforest planning under NFMA. Measures for compar-ing annual performance with output and conditiontargets identified in the plan could be required, andreporting on the local economic impacts of manage-ment and on public involvement could also bespecified.

Option 8: Require public involvement in moni-toring.

Congress could direct the Forest Service toinclude public participation in the monitoringof forest plan activities.

The public is interested in national forest manage-ment, is involved in national forest planning, and isconcerned about the results of management activi-ties. Simply reporting on results is feasible, butplaces the public on the outside, rather than makingthem participants in planning and management.Congress could specify that the Forest Serviceinclude public participation in the monitoring offorest plan activities.

Chapter 2--Policy Options . 23

Including the public in monitoring could fulfillseveral purposes. As described above, monitoringassures that activities conform with the direction inthe plan. However, different individuals can read thesame statements describing direction, and reachdifferent conclusions about what activities are con-sistent with that direction. Public involvement inmonitoring provides feedback to the agency on howthe public interprets the plan’s direction. Significantdifferences in interpretation would suggest that aplan needs to specify the management directionmore clearly.

Monitoring is also intended to assess whether theresults of activities achieve the goals identified in theplan. Public participation in monitoring can helpassure that the Forest Service focuses on the outputs,sites, and other values that are important to variousinterests. Monitoring all results of managementactivities on all sites is expensive, time-consuming,and probably impossible in a practical sense. Thus,monitoring is necessarily limited. Involving thepublic can assist the agency to focus on the keyconcerns, to guarantee that the most importantoutputs and conditions are measured most carefully.

Finally, public involvement in monitoring canalso save money. Many individuals and groups whoparticipate in planning have expertise that could beused to conduct some monitoring activities. Havinga variety of interests involved can provide a balanceof views and checks to assure that measurements arecomprehensive and accurate. In this way, the ForestService can build trust between the employees andthe public, and among the disparate stakeholders innational forest planning and management. However,Forest Service managers must still be responsible formeasuring the results of activities in the nationalforests and for implementing the forest plans.

F O R E S T S E R V I C E B U D G E T

R E C O N C I L I A T I O N

Finding 3: Budget Decisions Overwhelm PlanningDecisions

The annual Forest Service budget request and thesubsequent appropriations from Congress are incon-sistent with the budget levels and mixes assumed innational forest planning. This occurs, in part, be-cause the forest plans establish an integrated,coordinated approach to land and resource manage-ment, but the budget request and appropriations are

arranged by resource activity. Budgets for multiple-use management at the forests must be translatedinto resource-oriented budgets, and these resourcebudgets are then modified by the Washington Officeof the Forest Service, the Secretary of Agriculture,the Office of Management and Budget, and theHouse and Senate Committees on Appropriations tomeet their political needs and responsibilities. Theresult is congressional appropriations that bear littleresemblance to the coordinated budgets needed toimplement the integrated land and resource manage-ment plans.

The difference between forest plan budgets andannual appropriations also results from the variety ofbudget assumptions used in forest planning. Oneregional office restricted the budget increases whichcould be assumed in forest planning, but otherspermitted unrestricted and often unrealistic budgetincreases to achieve all the goals desired by thepublic. Such plans can seem ideal to the public, solong as no one is clearly responsible for paying forthe plan. The differences in budget assumptions inforest planning prevent the Forest Service fromdeveloping a budget request directly from the forestplans.

When congressional appropriations conflict withforest plan directions, the budget decision is invaria-bly followed, because Forest Service employees areresponsible (some are personally liable) for assuringthat money is spent as Congress directs. Thus,appropriations by resource activity-not the forestplans-essentially control the management activi-ties in the national forests. Furthermore, the annualappropriations have specified Forest Service timbersale targets, typically in excess of the administra-tion’s request (although below the potential identi-fied in forest plans with unrestricted budgets), andthese congressional timber targets determine na-tional, and ultimately local, management priorities.The appropriations have not included targets forother resource outputs or for resource conditionsand, thus, have contributed to the Forest Service’semphasis on timber outputs. (See ‘‘Finding 1:Emphasis on Timber and Other Physical Outputs. ’

Finally, the Forest Service has a number of specialaccounts and trust funds, comprising about a third ofthe Forest Service budget. The largest is ForestService receipt-sharing payments to counties, withpayments often exceeding $300 million annually.However, the Knutson-Vandenberg (K-V) Fund, the


Timber Salvage Sale Fund, brush disposal, and otherspecial accounts and trust funds generate at least$500 million annually for Forest Service activities.These funds result mostly from timber harvests, butthe expenditures commonly are not limited to timbersales or investments. Thus, the counties (through thereceipt-sharing payments) and the managers of mostresource programs (through available budgets) ben-efit from increasing timber sales, again contributingto the emphasis on timber outputs. Furthermore,many of these special accounts and trust funds arepermanently appropriated, with the money automat-ically available unless Congress halts or restricts theexpenditures. Congress has given relatively littleattention to these funding sources, and their use hasbecome increasingly important as the Federal budgetproblems have mounted.

Forest Service Budget Options

If the forest plans are to be implemented, theplanning process must be integrated with the budgetand appropriations process. The budget processmust provide balanced consideration of all theresource output and condition goals of the forestplans. Congress needs information on the opportuni-ties for improving management with additionalfunding, but Congress and the public also need toknow how the forests will be managed if the desiredfunds are not available. Furthermore, the ForestService needs flexibility to implement the forestplans, but Congress needs to exercise its control toassure that national forest management fits withinthe overall spending and taxing priorities demandedby the public. Congress has several options forintegrating and balancing the planning and budget-ing processes and for providing the necessaryflexibility while retaining appropriate control.

Option 9: Eliminate appropriations by resource.

Congress could appropriate funds by man-agement activity, rather than by resource lineitems, and direct the Forest Service to developits budget accordingly, based on the activitiesneeded for implementing the forest plans.

Forest Service budget requests and congressionalappropriations are currently arranged in about 60line items, specifying expenditures for variousresource activities, such as timber sale preparationand administration, wildlife habitat improvement,and trail maintenance. Proposed funding for each

resource activity is adjusted at each step in thebudget process—by the Washington Office of theForest Service, the Secretary of Agriculture, theOffice of Management and Budget, and the Houseand Senate Committees on Appropriations-to meettheir own needs and responsibilities. The eventualappropriations by resource rarely mesh with thefunding needed for integrated, multiple-use manage-ment under the forest plans. Furthermore, theresource-oriented appropriations also encourage theadministration and Congress to specify output tar-gets, especially for timber, since timber targets areeasily specified and are more controllable by ForestService managers.

A related problem is that, under resource-orientedappropriations, other necessary activities are eitherunfunded or must be conducted with funds intendedfor resource management. Planning, and the requi-site training and software development and acquisi-tion, has been funded largely by resource-specificappropriations. Monitoring is typically conductedby the resource specialists for the resource beingmonitored, but does not provide tangible results forwhich the resource managers can be rewarded.When combined with the lack of penalties forinadequate monitoring, it is not surprising thatmonitoring has a low priority within the agency.Thus, although planning and monitoring are essen-tial to effective national forest management, fundingfor these activities must be diverted from the variousresource activity appropriations.

Congress could replace the resource-orientedappropriations with appropriations for the activitiesnecessary for managing the national forests—planning, implementing, and monitoring. Thesemajor categories could be further subdivided, toprovide Congress with more control over the agency’sbudget. For example, planning could be divided intoinventories and data management, technology ac-quisition and development, personnel development,public involvement, and plan preparation (writingand reproducing). Similarly, monitoring could bedivided into on-site measurement, equipment pur-chases, personnel development, public involvement,and report preparation. Implementation could besubdivided into ongoing activities and investments,with ongoing activities including use and outputproduction and control, and maintaining currentresource, ecosystem, and facility conditions. Invest-ment categories could include roads, trails, andfacilities to increase or control uses and outputs, and

—— .

Chapter 2----Policy Options ● 25

administrative facilities. Resource, ecosystem, andfacility rehabilitation to improve current conditions,such as reforestation or trail reconstruction, could beidentified as either ongoing activities or as invest-ments.

Reorganizing the Forest Service budget would noteliminate the agency’s responsibility to provideinformation on the anticipated uses and outputs andon the likely changes in resource, ecosystem, andfacility conditions at the requested budget level (andwith increases or decreases in the budget). TheForest Service could also be required to provide unitcost information for important activities, such assuccessful reforestation, road construction, and rec-reation facility operation. Nonetheless, such reor-ganization of the budget and appropriations struc-ture could allow Congress to retain control overimportant decisions (e.g., the level and location ofinvestments), could assure adequate funding fornecessary activities (e.g., planning and monitoring),and could provide the Forest Service with theflexibility to implement the forest plans,

Option 10: Require realistic budgets in forestplans.

Congress could direct the Forest Service toinclude a range of budget possibilities, fromthe current forest budget to an unlimitedincrease, in the final plan for each nationalforest.

The Washington Office of the Forest Serviceprovided no direction on the budget assumptions tobe used in national forest planning. One regionrestricted the budgets that forests could assume inplanning but most did not. Budget restrictions aremore likely to result in forest plans that areimplementable, i.e., within the realities of Federalbudget limitations. However, such restrictions alsoprevent the forests from identifying opportunities forimproving national forest management and forgenerating additional revenues through increasedbudgets. This has placed forests with restrictedbudget assumptions at a disadvantage in annualinternal budget negotiations.

While unrestricted budget assumptions have al-lowed forest and regional personnel to identifyopportunities for investments under increased budg-ets and are more acceptable to the public (becausemore uses and outputs can be accommodated whilemaintaining or improving resource and ecosystem

conditions), such forest plans may be unimple-mentable. Conditions may deteriorate and/or theuses and outputs must be at lower levels thanplanned, increasing the likelihood of challenges inadministrative appeals or litigation.

Both types of information---+pportunities withunrestricted budgets and likely management withbudget limitations-are necessary in forest plan-ning. Unrestricted budget opportunities are impor-tant to demonstrate how management could beimproved, and an analysis of opportunities is re-quired in the RPA Assessment. However, theadministration and Congress are facing increasingpressures to reduce the Federal budget and, thus,substantial budget increases are unlikely. Congressand the public need to know how the forests arelikely to be managed under limited budgets. Con-gress could require the Forest Service to includeboth types of information in forest plans, therebylinking the forest plans with opportunity analysis inthe RPA process and providing information on thelikely management direction and the near-termoutputs and conditions in the national forests.

Option 11: Control special accounts and trustfunds.

Congress could require more complete re-porting on the sources and uses of money in thevarious special accounts and trust funds, andcould clarify the purposes for which the fundscould be used.

The Forest Service presents little information onthe sources and uses of money in the various specialaccounts and trust funds. The budget request con-tains aggregate information on the expected receiptsand expenditures from each fund, but with little or nodiscussion of the purposes or locations of theexpenditures. The annual Report of the ForestService presents information on reforestation andtimber stand improvement under the K-V Fund andon road construction and reconstruction using pur-chaser road credits, but not on revenue-sharingpayments, the Timber Salvage Fund, the WorkingCapital Fund, brush disposal, or other permanentappropriations. The Timber Sale Program Informa-tion Reporting System (TSPIRS) also includes K-VFunds and purchaser road credits, and adds theTimber Salvage Fund, but excludes brush disposaland road maintenance deposits from timber purchas-ers. The forest plans, and the RPA Program, do not


distinguish funding and activities under any specialaccounts or trust funds.

The special accounts and trust funds provideabout a third of the Forest Service budget annually,but with the sparse information available, Congressis unable to exercise much oversight and controlover their use. Some have specified funding levels:revenue-sharing is 25 percent of gross receipts, andthe Reforestation Trust Fund receives up to $30million annually from tariffs on wood productimports. However, deposits to most of the accountsare at the discretion of the Forest Service at the locallevel. An unlimited portion of timber receipts can bedeposited in the K-V Fund. If the Forest Servicedesignates a sale as a salvage sale, because itcontains some (unspecified) volume of dead, dying,or threatened timber, the remaining timber receiptscan be deposited in the Timber Salvage Fund. Thelevel of brush disposal and other cooperative depos-its is also at the discretion of the Forest Service.Thus, the Forest Service has substantial localauthority to determine the amount of money depos-ited in the various special accounts and trust fundsif the forest has timber to sell.

The Forest Service also has substantial discretionover the use of the special accounts and trust finds.Several accounts (K-V, salvage, brush disposal, andother cooperative deposits) are to be used on thenational forest that generated the deposits, althoughsome funds are used for regional and WashingtonOffice staff. Most accounts have specified purposes:salvage funds are to prepare and administer newsalvage sales; the Reforestation Trust Fund is forreforestation and timber stand improvement; brushdisposal and other cooperative deposits are for thepurposes specified in the contractor agreement. TheForest Service has relatively broad discretion overthe use of the K-V Fund-it can be used forreforesting cutover sites, for improving timberstands, or for mitigating and enhancing other re-sources within the timber sale area. To date, nostudies have examined whether the level or use ofthe special accounts and trust funds are consistentwith congressional intent.

Congress could require the Forest Service topresent more information on the sources and uses ofmonies in the major special accounts and trust fundsin the budget request, the RPA program, the forestplans, and the annual reports. Congress could alsoexamine the use of special accounts and trust funds,

through oversight hearings and/or review by theGeneral Accounting Office, to assess whether theuse of the funds is consistent with the original intentand with forest planning. Congress could also clarifythe purposes for which the funds could be used, toassure that the special accounts and trust funds areused in a manner that is consistent with the directionset forth in the forest plans.

Option 12: Compensate counties equitably.

Congress could replace the current programof returning 25 percent of gross Forest Servicereceipts with a system to compensate countiesfairly for the tax exempt status of Federallands and activities.

Since 1908, the Forest Service has returned 25percent of its receipts to the States for use on theroads and schools in the counties where the nationalforests are located. The payments were clearlyintended to compensate the counties for the taxexempt status of the national forest lands, but thelegislative history provides no explanation of whycompensation of 25 percent of receipts was deemedappropriate. In 1976, NFMA expanded the defini-tion to include K-V Fund deposits and timberpurchaser road credits as gross receipts, because theForest Service had been diverting an increasingshare of receipts to “internal management pur-poses” (reforestation and road construction), andthereby reducing the basis for county payments.Receipt-sharing is akin to an ad valorem severanceor yield tax, which some jurisdictions use to taxprivate timberland owners. However, it is unclearwhether Forest Service receipt-sharing approxi-mates common severance or yield tax systems, andin some States, purchasers also pay yield taxes ontheir harvests of Federal timber.

A second program, enacted in 1976, compensatescounties for the tax exempt status of Federal lands.The Payments in Lieu of Taxes (PILT) program,administered by the Bureau of Land Management,generally provides an annual payment of $0.75 peracre for entitlement lands (which include mostNational Forest System lands), although the totalpayments are limited by the population in thecounty. PILT payments are also reduced by compen-sation under other programs, such as Forest Servicereceipt-sharing payments, to a minimum of $0.10per acre per year. Thus, in areas where Forest Servicepayments exceed $0.65 per acre, the counties receive

Chapter 2--Policy Options ● 27

$0.10 per acre under PILT and the full Forest Servicepayments. In areas where Forest Service paymentsare less than $0.65 per acre, the counties receive$0.75 per acre on average under the two programs.(The offset to PILT payments lags behind changes inForest Service payments, and thus county compen-sation could be above or below $0.75 per acre in anygiven year, but will average $0.75 per acre.) ThePILT payments have not changed since the programwas created, and thus compensation in real dollars iscurrently less than half of what Congress enacted in1976.

It is unclear whether the combination of ForestService receipt-sharing and Bureau of Land Man-agement PILT payments is equitable compensationfor the tax exempt status of national forest lands. Insome areas, the counties may receive payments thatexceed what collections from a private owner ofundeveloped land might be, but in other areas, thecounties might be undercompensated. Timber gen-erally accounts for at least 90 percent of ForestService receipts, and in heavily timbered areas,Forest Service payments can be substantial. Manycounties rely on Forest Service payments for sub-stantial portions of their budgets, but the agencydoes not regulate the timing of harvests, and, thus,receipts and county payments vary as timber har-vests fluctuate. Timber receipts fluctuate widely,rising or falling by 50 percent or more from year toyear because of changing market condition. Further-more, PILT payments require annual appropriationsfrom Congress, and while Congress has not failed toappropriate the full authorization, Federal budgetconstraints could force reductions in PILT pay-ments. Counties, therefore, must depend on unpre-dictable sources that might be compensating themless than a private landowner would.

Congress could replace the current system ofreceipt-sharing and PILT payments with a systemthat fairly and consistently compensates the countiesfor the tax exempt status of national forest lands.Such compensation would reimburse States andcounties for lost property taxes, sales taxes, incometaxes, and/or yield taxes, depending on existing taxstructures, and the basis could vary by county or byState. Congress could require a study, by the GeneralAccounting Office or some other agency, to devisethe appropriate compensation methods and levels,and then could replace the current system with thenew tax-equivalency compensation system.

F O R E S T P L A N N I N G D I R E C T I O N

Finding 4: National Targets Can Nullify LocalDecisions

RPA established a national strategic planningprocess for renewable resources under which theForest Service is to assess opportunities and capabil-ities, develop a long-term agency program, coordi-nate that program with annual budgets, and reportannually on progress in implementing that program.RPA also established a local planning process forpreparing land and resource management plans forthe national forests, and NFMA amended RPA toprovide substantial guidance on considerations andrequirements for the local planning process. Con-gress may not have envisioned a close unionbetween the local and national plannin g processes,but they have evolved toward closer coordination.The Forest Service describes the connection as aniterative process, with information on capabilitiesand opportunities flowing into the RPA Assessment,and quantitative national targets from the RPAProgram being allocated to the forests.

Allocating national RPA targets to the nationalforests can negate local agreement about the appro-priate management direction for a national forest.Allocated targets may be technically infeasible,because a comprehensive, national analysis neces-sarily aggregates information on local capabilities,and loses the site-specific interactions and con-straints. Furthermore, the RPA Program is subject tonational political pressures, from within the admin-istration and from Congress and the many interestgroups, that may be insensitive to local demands andcapabilities. Thus, national goals can be infeasible toachieve on the ground. In addition, because ofexisting inventories and analytical tools, targetsfocus on annual physical outputs, especially timberoutputs. Allocated timber targets from RPA (or fromthe annual appropriations), even if technically feasi-ble, can substantially alter the national forest man-agement direction, determined with considerablelocal analysis and public involvement.

Planning Direction Options

To implement national forest plansacceptable to the public, the NFMA

that areplanning

process must be coordinated with the RPA planningprocess by maintaining a continuous, multidimen-sional exchange of information on current situations,

297-904 0 - 92 - 2


capabilities, and opportunities-including physicaland political potentials and limitations. Nationaldirection for forest planning is needed to assureadequate consideration of regional, national, andglobal problems and concerns. However, only localanalysis can determine physically and politicallyfeasible solutions.

Option 13: Specify forest plans as the baseline forRPA planning.

Congress could require the Forest Service touse the management direction established inthe forest plans as the baseline for NationalForest System outputs and values in the RPAplanning process.

The Forest Service envisions an iterative NFMAplanning-RPA planning process, with the forestplans providing information for the RPA Assess-ment and the RPA Program establishing targets forthe National Forest System. Clearly, the forest planscan contribute data on the current situation, and onthe capabilities and opportunities for the forests toprovide outputs and other values-data which areessential to an assessment of the renewable resourcesituation in the United States. However, nationalanalyses of management options can overestimateproduction possibilities, because site-specific inter-actions and constraints cannot be maintained in suchanalyses. Therefore, national output targets allo-cated to the forests may be technically infeasible toimplement.

Alternatively, Congress could direct the ForestService to use national forest plans as a technicallyand politically feasible baseline for outputs andvalues from the National Forest System, particularlyif a consistent range of budget possibilities isrequired in forest planning. Then, in RPA planning,the Forest Service could compare the baselineNational Forest System production and the expectedprivate and other public production with the demandprojections, to determine likely shortfalls, unaccept-able price increases, and/or deteriorating conditions.The RPA Program could examine alternatives toaddress these identified problems—by increasingNational Forest System budgets, by expandingresearch, and/or by bolstering financial and techni-cal assistance to States and to private landowners. Ifregional, national, or global concerns cannot beadequately addressed under such alternatives, theRPA Program could provide direction for additional

issues to be considered as forest plans are revised. Ifthe problems are near term, the Program could directimmediate analyses of potential plan amendments orrevisions to address the problems. However, Con-gress could specify that any RPA Program directionfor the National Forest System be consistent withlocally developed forest plans and with public par-ticipation to assure that the direction is acceptable.

Option 14: Require RPA direction for all re-sources and all branches.

Congress could require the Forest Service toprovide targets and/or national direction forall outputs and values and for all branches ofthe agency.

The RPA Program has traditionally establishedphysical output targets, principally because theavailable information and analytical tools focus onphysical outputs. It is admittedly difficult to estab-lish goals for values other than annual physicaloutputs, particularly when the inventories and analy-tical models concentrate on outputs. Nonetheless,the emphasis on physical outputs from the nationalforests has impeded consideration of ecosystemsustainability.

The RPA Program has also focused on theNational Forest System. The Program typically setsthe direction for Research and State and PrivateForestry by simply extending and expanding the sizeand structure of current activities. In contrast, targetsfor the National Forest System are driven by thedesire to alleviate demand-supply imbalances for thevarious resources through national forest manage-ment. This focus largely reflects the ability to holdforest supervisors and other line managers accounta-ble for achieving physical output targets, whereasresearchers and employees providing financial andtechnical assistance are not clearly responsible forproducing outputs. However, this focus has led to anemphasis on the National Forest System lands andoutputs, which exceeds their importance in theNation’s land and renewable resource base.

Congress could improve the balance amongresources and among Federal and non-Federal landsby directing the Forest Service to establish directionfor agency programs to address all the outputs andvalues on all forests and rangelands. The ForestService could be directed to emphasize financial andtechnical assistance to alleviate regional demand-supply imbalances for marketed outputs and values,

Chapter 2-Policy Options . 29

and to focus on Federal and other government landsfor demand-supply imbalances of unmarketed out-puts and values. Congress could require RPAProgram direction, for all the branches of the ForestService, to be defined in long-term goals forproductivity and ecosystem health and in short-termtargets for outputs and conditions of concern.

S U M M A R Y A N D C O N C L U S I O N S

Congress, in enacting NFMA, envisioned an openplanning process for establishing national forestmanagement direction acceptable to the public. Todate, national forest planning has not fulfilled thisvision, and national forest management seems to beas controversial now as when NFMA was enacted.Most plans and many actions under those plans havebeen appealed, and lawsuits have focused nationalattention on Forest Service land and resourcemanagement. Some argue that the planning processhas become so controversial and burdensome thatNFMA should be repealed, while others haveproposed modifications emphasizing various as-pects of plan implementation.

OTA found a number of problems in nationalforest planning. The plans focus on producingtimber and other physical annual outputs, because ofan emphasis on outputs in the legislative guidance,in the inventories, and in the analytical technologies.Outputs from the national forests are clearly impor-tant, but sustaining the ecological health of thenational forests is paramount. The national forestsare, in many ways, comparable to a trust fund,intended to produce annuities from assets. Annuitiesare desirable, but maintaining and enhancing theassets is crucial to perpetuating the annuities. Innational forest planning, inventories, analyses, andtargets too often emphasize the outputs (the annui-ties) and discount the ecosystems (the assets).

The focus on physical outputs could be overcome,if the environmental and economic consequences ofplanning and management were assiduously moni-tored. However, monitoring has been insufficient toevaluate national forest plans and management.Efforts to produce outputs or, in some cases, theagency’s failure to act could be degrading the nonusevalues and the productive assets of the nationalforests, but the monitoring needed to assess suchchanges is not being done. Monitoring can deter-mine: 1 ) if the activities are consistent with thedirection established in the plans; 2) if the results

accomplish the plan’s objectives; and 3) if theassumptions and models used in the planningprocess are accurate. To date, monitoring of nationalforest plans and their implementation has notachieved these purposes. The lack of monitoringresults, in part, from the inadequate informationbase. More importantly, however, monitoring isfragmentary because there are no incentives tomonitor, and no penalties for managers for notmonitoring.

Direction-setting at the national level has alsoemphasized annual timber and other outputs, al-though better integration of forest plans in the RPAplanning process could help to protect nonuse valuesand long-run ecosystem health. The resource-oriented budget process and the numerous specialaccounts and trust funds (which are funded princi-pally through timber sales) contribute to the focus ontimber and other outputs. Furthermore, RPA plan-ning was intended to be a strategic process for allrenewable forest and rangeland resources, but hasemphasized timber and other outputs from thenational forests, again because better informationand analytical tools exist for timber and other annualoutputs than for ecosystem conditions. Unless closelycoordinated with the forest plans, national outputtargets from the annual appropriations or from theRPA planning process can overwhelm the techni-cally and politically feasible decisions producedlocally, through substantial analysis and publicparticipation.

Despite these problems, NFMA planning canfulfill the strategic process envisioned by Congress.Clearer legislative direction, a broader informationbase, targets for ecosystem health as well as forannual outputs, more effective public participation,and a variety of analytical technologies could lead totechnically and politically feasible national forestplans and management. Distinguishing and organiz-ing monitoring, linking activities to results, andinvolving the public in monitoring can assure thatforest plans are implemented. Appropriations bymanagement activity, realistic budget assumptionsin forest plans, better accounting for special ac-counts and trust funds, and fair compensation tocounties for the tax exempt status of Federal landscould lead to Federal financing consistent with theforest plans and overall Federal budget constraints.Finally, a more interactive RPA-NFMA planningprocess, with forest plans as the baseline for theNational Forest System and with long- and short-

. . —-. . .


term direction for all resource values and all These changes can complete the strategic planningbranches of the agency, can result in a national process for the national forests that was begun withdirection that can be achieved through national NFMA and has been evolving under Forest Serviceforest planning and other Forest Service activities. leadership.

Chapter 3

The Goals of National ForestManagement and Planning

ContentsPage

Purpose and organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33National Forest Goals: Multiple Use and Sustained Yield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Historical Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34Philosophical Basis for Government Ownership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42What Is Multiple Use? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43What Is Sustained Yield? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

National Forest Planning: Achieving the Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49Planning Direction and Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .49Strategic Planning for the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

. Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .53

BoxesBox Page

3-A. Livestock Grazing, Recreation Use, and Timber Production Trendsin the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

3-B. Privatization of Federal Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .443-C. The National Forest System as a Natural Resource Trust Fund . . . . . . . . . . . . . . . . . . . . . . . . 48

FiguresFigure Page3-l. Grazing in the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 363-2. Recreation Use of the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 373-3. Forest Service Timber Sale Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 383-4. U.S. Lumber and Plywood Production

. . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

TableTable Page3-l. Uses, Outputs, and Resources Corresponding to the Purposes Listed

in the Multiple-Use Sustained-Yield Act of 1960 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ● ,... 46

Chapter 3

The Goals of National Forest Management and Planning

Beginning in 1975, Forest Service timber salepractices were successfully challenged in severallawsuits (the first and best known being the "Monon-gahela Decision’ ), on the grounds that the agencywas violating specific provisions of the 1897 ForestService Organic Act. The Forest Service argued thatscientific evidence and 70 years of experiencejustified their practices, but the court held that onlyCongress could change the legal restrictions onselling timber. In the National Forest ManagementAct of 1976 (NFMA), Congress eliminated therestrictive provisions of the 1897 Organic Act,provided substantial guidance to the Forest Servicefor preparing land and resource management plansfor units of the National Forest System, and requiredpublic participation in determin ing managementdirection. It was hoped that an open planning processcould resolve local controversies at the local level,and get Congress and the courts out of local, detailednational forest management.

To date, Forest Service planning under NFMAhas not fulfilled this vision. Controversy, litigation,and congressional involvement abound in manage-ment of the national forests. In the South, clearcut-ting is prohibited near red-cockaded woodpeckercolony sites in the national forests. Administrativeappeals in the northern Rocky Mountains havedelayed enough timber sales to cause a timbersupply squeeze for some sawmills. A Wyomingsawmill sued to try to guarantee minimum ForestService timber supplies under a timber managementplan, but lost and was subsequently closed. Contro-versy over road construction has led Congress toconsider, and sometimes to enact, substantial changesin road construction appropriations (292).

The current forest management controversy withthe greatest impact is over the national forests of thePacific Northwest—how much timber to sell, and/orhow much ancient forest to reserve from harvestingfor the protection of the northern spotted owl and theold-growth Douglas-fir ecosystem. As plans for thenational forests in western Washington and Oregonwere being developed (long after the target date

specified in NFMA), courts enjoined timber saleswhich might threaten the owl’s existence. Congressacted to continue the timber sale program while theU.S. Fish and Wildlife Service considered protect-ing the owl under the Endangered Species Act. (Theowl was subsequently determined to be threatened,according to the provisions of that act.) Courts havesince ruled portions of the congressional interven-tion to be unconstitutional.

Some have characterized these problems as re-gional battles over the control of resources. In placeswhere commodity production is being curtailed,some users, Members of Congress, and agencyemployees assert that national forest management isgridlocked. Congress has been asked to considerlegislation to overhaul the system. Some proposalswould prohibit clearcutting, others would add guid-ance on forest plan implementation, still otherswould prevent judicial review of Forest Servicedecisions. Some observers have suggested that manyof the problems result primarily from the belief thatNFMA planning could resolve controversies, andthat repealing NFMA would resolve at least some ofthe current difficulties (18). Others go further,suggesting that the experiment in public land andresource ownership is a failure, and that radicalreform of the system is the only solution (41).Nonetheless, many believe that the current planningprocess, with improvements, is still appropriate.

P U R P O S E A N D O R G A N I Z A T I O N

These problems and proposals led Congress to askOTA for an assessment of the technological, biolog-ical, social, and economic dimensions of the forestplanning process established under NFMA. Toassess these aspects of the NFMA planning process,one must first examine the purposes of nationalforest management: multiple use and sustainedyield, as defined in law. These goals are examinedfrom their historical development, from their phil-osophical basis, and from their implications formanagement.

Iwe~t Vlrglnla D1vi~io~ of (he I~~k Walton ~ague, Inc. V. Butz, 367 F. SUpp. 422; 522 F. 2d 945 (4UI Cti. 1975).

-33-

—


After examining the management goals, thischapter describes the strategic nature of the NFMAplanning process. Strategic planning is a usefulstandard for examin ing the NFMA planning processfor two reasons. First, although Congress did notexpressly create a strategic planning process for thenational forests, national forest planning is part ofthe strategic planning process created in the Forestand Rangeland Renewable Resources Planning Actof 1974 (RPA).2 Congress clearly intended the RPAprocess to be strategic planning (259), and thusimplicitly intended strategic NFMA planning bymaking the land and resource management plans forthe national forests a part of the RPA Program(section 6(a)).

Second, a public strategic planning process is aneffective approach for identifying organizationalgoals for a government agency. NFMA establishedan open, public process for setting managementdirection for the national forests. Forest plans are todescribe that direction by identifying goals forconditions and outputs, together with: 1) the stand-ards and guidelines for management activities, 2) theproposed and possible actions, and 3) the financialresources necessary to fulfill those goals. Strategicplanning is an appropriate criterion for assessingnational forest land and resource management plan-ning under NFMA.

The subsequent chapters of this report assessspecific aspects of the planning process—legalcontext, social dimensions, biological aspects, plan-ning technologies, economic considerations, andorganizational characteristics. The principal crite-rion for examining these aspects is how theycontribute to strategic national forest planning, bothin theory and in practice. The last chapter concludesthis assessment by reviewing the relationship be-tween strategic NFMA planning and the ForestService’s national planning effort under RPA.

N A T I O N A L F O R E S T G O A L S :

M U L T I P L E U S E A N D

S U S T A I N E D Y I E L D

Historical Development

Creation of the National Forests

Numerous devastating natural disasters, often inconjunction with extensive logging, occurred in theUnited States during the late 1800s. Huge wildfiresswept through logged-over lands in New Englandand in the Lake States in 1871, 1881, and 1891; the1871 Peshtigo fire killed 1,500 people in Wisconsin(32, 200). Timber cutting on public lands was illegal,but the timber protection laws were routinely flouted(291). Furthermore, major floods of the late 1880swere blamed on widespread deforestation (190).These events led Congress, in 1891, to grant thePresident authority to reserve important publicdomain lands, but Congress did not authorize effortsto protect the reserves.

In 1897, in response to President Grover Cleve-land’s substantial forest reservations, Congress in-directly guided management of the forest reserves(renamed the national forests in 1907) by limitingthe purposes for which the President could reserveforest lands. Reserves were to exclude lands morevaluable for mineral extraction or for agriculture,and could only be established:

. . . to improve and protect the forest within theboundaries, or for the purpose of securing favorableconditions of water flows, and to furnish a continu-ous supply of timber for the use and necessities ofcitizens of the United States , . .

This was the principal congressional direction forthe purposes of reserving lands and managingreserved lands, and has come to be known as theForest Service Organic Act. The act also authorizedthe agency to regulate the “occupancy and use [ofthe reserved lands] and to preserve the foreststhereon from destruction. ’

%JFMA was substantially an amendment to the Forest and Rangeland Renewable Resources Planning Act of 1974 (RPA-Act of Aug. 17, 1974;Public Law 93-378, 88 Stat. 476; 16 U.S.C. 16001614). RPA, as enacted, required the Forest Semice to prepare land and resource management plansfor units of the Nationat Forest System using an interdisciplinary approach to integrate physical, biological, economic, and other sciences. NFMA addedsubstantial guidance for public participation and for relevant considerations in the planning process. These land and resource management plans are oftenealted forest plans, and the process is typically called forest or NFMA ptanning.

J~ section ad&esses he ~storic~ development of legislation providi~ tie ~agement gods for tie MtiOIXd fOreSL1. Ch. 4 Will eXiiIllkle tiedetailed legal requirements of these laws.

Chapter 3-The Goals of National Forest Management and Planning ● 35

The floor debate over this act strongly indicatesthat the primary intent was to protect the forests andthe downstream water flows.4 Wood was to be madeavailable to settlers and to miners who needed thetimber locally, but providing wood for loggers wasnot a consideration in establishing forest reserves.Senator John Lockwood Wilson of Washingtonnoted:

, . . the timber lands withdrawn [that are more than25 miles from Puget Sound] do not contain mer-chantable timber. They have only their value, if any,for mining purposes (326).

Senator George Laird Shoup of Idaho, in arguing forpermission to sell timber from the reserves, added:

. . . We do want to protect and will protect our timberif the reserves are only established in the right place.But, Mr. President, our farmers and our miners areentitled to a sufficient quantity of timber for domes-tic purposes (233).

Thus, Congress was clearly concerned about thelocal community impacts of reserving Federal forestlands. In the subsequent century, the national forestshave become an important source of wood for thelumber and plywood needed in home building andother uses. Nonetheless, the principal concerns inestablishing the forest reserves were for protectingthe lands and waters while making a continuoussupply of timber available.

Following the transfer of the reserves to theDepartment of Agriculture in 1905, the managementactivities of the new Forest Service (created whenthe Forestry Division of the Department of theInterior’s General Land Office was merged with theDepartment of Agriculture’s Bureau of Forestry)generally focused on land and resource protection.The first efforts were to protect the forests fromwildfires and from trespass (illegal timber cuttingand homesteading), and to control grazing, whichhad been unregulated by the Department of theInterior (329). The Forest Service based its efforts onthe broad, general provision in the 1897 Organic Actpermitting the Secretary of Agriculture ‘‘to regulatetheir [the forest reserves’] occupancy and use and topreserve the forests thereon from destruction . . .“The livestock industry challenged the Forest Serv-ice’s right to regulate use and charge fees, but the

agency’s position was upheld by the U.S. SupremeCourt in 1911 (240).

In 1911, Congress also authorized the ForestService to acquire lands for the National ForestSystem. The Weeks Law authorized land acquisitionto protect water flows; acquiring land to providetimber was not authorized until the Clarke-McNaryAct of 1924. Many of the national forest lands in theeastern half of the country were acquired under theWeeks Law, and, unlike those in the west, many hadbeen denuded or severely degraded before theFederal Government acquired them. Thus, in originsand biological and cultural histories, the easternnational forests are quite different from the nationalforests in the west.

I n summary, the concept of using the nationalforests in many ways was implicit from the verybeginning. When use levels were low, conflictsamong users were minor and could be managed byseparating uses. Public discussion of the compatibil-ity of uses did not begin until after the National ParkService was created in 1916. In the following years,the Park Service tried, sometimes successfully, togain control of prime Federal recreation sites. TheForest Service countered Park Service efforts byarguing that proper management of the various landuses could provide both recreation and commodityextraction, that ‘‘multiple use’ was preferable to‘‘single use. ’

The Multiple-Use Sustained-Yield Act of 1960

The debate with the Park Service and disagree-ments with ranchers continued to simmer until about1950. Then, during the next decade, several condi-tions and events led the Forest Service to believe inthe need for legislative sanction to define thepurposes of the national forests and to preserveForest Service discretion in managing those lands.

The demand for the goods and services providedby the national forests began to change after WorldWar II. Livestock grazing had been the major use ofthe reserves when the Forest Service began manag-ing the lands, but livestock use of the national forestspeaked in 1920 and has slowly declined since (298).In contrast, recreation and timber harvesting beganslowly, then accelerated after World War II. (Seebox 3-A.) While timber harvesting increases some

4T~p1c~ly, ~omlttm ~ewfl~ ~W more weight ~5 indicators of the intent of Congess ~an does the floor debate, but no cotittee reports werefiled on the 1897 act, because it was an amendment to an appropriations bill. This was a common practice at that time, because the appropriationscommittees did not exist until the 1920s. Appropriations bills were developed by what are now known as authorizing committees.


BOX 3-A—Livestock Grazing, Recreation Use, and Timber Production Trends in the National Forests

Livestock grazing was the most important use of the forest reserves when the lands were transferred in 1905from the Department of the Interior to the Forest Service in the Department of Agriculture. Livestock grazingcontinued to increase for the next 15 years, but has slowly declined since 1920. (See figure 3-l.)

Recreation in America has undoubtedly increased since World War II. (General recreation data are unavailableto show the magnitude or consistency of the increase.) National forest recreation use was generally below 10 millionvisitors annually prior to 1946, but climbed to about 25 million in 1950, and rose to more than 100 millionvisitor-days by 1961.1 Recreation use has continued to climb, exceeding 250 million visitor-days in 1989. (Seefigure 3-2.) This is not to suggest that all uses have increased equally. Motorized recreation, travel to destinationresorts, and backcountry hiking increased as the Nation’s transportation system improved, as leisure time increased,and as the Wilderness System expanded. However, demographic and other changes have shifted recreation usestoward shorter but more frequent and less strenuous activities (199, 235).

Timber harvesting in the national forests also increased substantially after 1950. Before World War II, nationalforest timber harvests averaged less than 1 billion board feet (BBF) annually. In 1950,3.5 BBF were harvested, andthis rose annually, reaching 12.1 BBF by 1966. (See figure 3-3.) In contrast to the continued growth in recreationuse, national forest timber sales and harvests have generally ranged between 9 and 13 BBF annually since 1960,with no discernible long-term trend. Lumber and plywood production has increased slowly over this period (seefigure 3-4), suggesting that national forest timber displaced private and other public timber in the 1950s. Since 1960,harvests of private and other public timber may have fueled the increased production, but improved tech-nology-greater product output from the same amount of timber input-has also contributed to the increasedlumber and plywood production.

IR=~m ~ ~ m=- ~ visits ptior to 1%5, ~ has beenmessurd invisitordays since 1%5. Howevtx, the c-e k measureis apparently insignifkant for mportmg“ the treads ill recreation q Ss * in figure 3-2 (74).

10

8

6

4

2

0<

Figure 3-l-Grazing in the National Forests

Million permitted to graze

I I I I I 1 I I f

1 1920 1929 1938 1947 1956 1965 1974 1983 1992

Year

SOURCE: U.S. Department of Agriculture, Forest Service, Report ot the Forest Service (Washington, DC: U.S.Government Printing Office, annual series).

—

Chapter 3-The Goals of National Forest Management and Planning ● 37

Figure 3-2—Recreation Use of the National Forests

Million recreation visitor-days300 –

2 5 0 -

200-

150-

1 0 0 -

5 0 –

10 r 1 I I r I r1944 1950 1956 1962 1968 1974 1980 1986 1992

Year

SOURCE: U.S. Department of Agriculture, Forest Service, Report of the Fores! Service (Washington, DC: U.S.Government Printing O~fice, annual series),

recreation opportunities it limits other opportunitiesand values. The simultaneous increase in the ForestService timber program and in national forestrecreation use in the 1950s and early 1960s probablymagnified the conflicts over national forest manage-ment.

Ranchers tried to increase their influence in de-termining livestock permit numbers, fees, and othermatters, and convinced Senator Frank Barrett ofWyoming to introduce a bill to this effect in 1953(329). In the same Congress, the timber industrypushed for industry selection of public timberland ascompensation for private timberland flooded byFederal dam projects (329). Although these effortswere unsuccessful, they indicated an interest inpartitioning the national forests among interestgroups.

Another effort to reduce Forest Service discretionbegan in 1955: the first bill to establish a wildernesssystem was introduced. The Forest Service wassurprised by the bill, because it had administrativelyestablished a system of wilderness, wild, and primi-

tive areas in the National Forest System, beginningin 1924. However, administrative boundary modifi-cations and pressures to expand national foresttimber harvests led some to believe that statutoryprotection was necessary to preserve undevelopedareas in the national forests. (See the followingsection on the Wilderness Act.)

Then, in 1956, the Park Service launched Mission’66 to increase the size of the National Park Systemsubstantially. This was seen as a threat to thenational forests, since many parks had been createdfrom national forest lands. Furthermore, PresidentDwight D. Eisenhower supported Mission ’66, butthe Forest Service was unable to obtain financialsupport for its countermeasure, Operation Outdoors.

Taken together, these events and conditions ledthe Forest Service to believe in the need forlegislative blessing of their existing managementdirection. The multiple-use legislation proposed bythe Forest Service won only lukewarm support. Fewoutside the agency believed it was necessary,although several conservation groups endorsed it.

—


Figure 3-3-Forest Service Timber Sale Program

14

12

10

8

6

4

2

Billion board feet

w I ‘- T imber so ld I

1 + Timber cut

o 1I I 1 I I I I 1

1944 1950 1956 1962 1968 1974 1980 1986 1992

Year

SOURCE: U.S. Department of Agriculture, Forest Service, Reoort of the Eorest S8fvkx (Washington, DC: U.S.Government Printing Mm, annual series). ‘

However, opposition was also muted. The timberindustry initially opposed new legislation, believingthe Forest Service Organic Act gave timber produc-tion more prominence than the multiple-use bill. Theindustry offered a substitute directing strongerfinancial considerations in national forest manage-ment. Other potential opponents, such as the SierraClub and The Wilderness Society, generally stayedclear of the debate, focusing their attentions onstatutory wilderness protection. Thus, after a rela-tively brief and mild struggle, the Forest Service wasrewarded with the Multiple-Use Sustained-YieldAct of 1%0 (MUSYA), stating that:

. . . the national forests are established and shall beadministered for outdoor recreation, range, timber,watershed, and wildlife and fish purposes. Thepurposes of this Act are declared to be supplementalto, but not in derogation of, the purposes for whichthe national forests were established as set forth inthe Act of June 4, 1897 . . .

. . . The establishment and maintenance of areas ofwilderness are consistent with the purposes andprovisions of this Act.

In enacting MUSYA, Congress essentially sanc-tioned Forest Service management to provide abroad array of natural resource uses and outputs,while protecting the land and resource base of thoseuses and outputs. Congress accepted the agency’slegislative proposal, because the proposal did notchange national forest management direction orcongressional oversight or authority. MUSYA ex-panded upon the national forest purposes set forth inthe Organic Act and together they provide broaddirection and substantial agency discretion formanaging the National Forest System.

The Wilderness Act

The Forest Service had long recognized the valueof keeping some lands undeveloped. In 1924, underits general adminis. trative authority, the agency setaside the Gila Wilderness in New Mexico, andsubsequently established a system of wilderness,wild, and primitive areas. However, some observerswere concerned about the administrative authority tomodify area boundaries and about increasing pres-sures to expand national forest timber harvests, andproposed statutory protection for specific undevel-oped lands in the national forests.

Chapter 3—The Goals of National Forest Management and Planning . 39

Figure 3-4—U.S. Lumber and Plywood Production

Billion cubic feet

3

H

21

1

01 9 5 0 1 9 5 6 1 9 6 2 1 9 6 8 1974 1 9 8 0 1 9 8 6

Year

SOURCE: U.S. Department of Agriculture, Forest Service, An Analysis of the 7imber Situation in the United States:1989-2040, Part 7: The Current Resource and Use Situation. draft [bv Havnes, R.W.1 (Washington, DC: U.S.Government Printing Office, 1989), p. A-67.

Events in the Boundary Waters Canoe Area ofnorthern Minnesota illustrate the concerns. AfterWorld War H, the Forest Service proposed severallarge, long-term timber sales in the area, overlong-standing local opposition. This led local con-servationists —and eventually Senator HubertHumphrey of Minnesota-to believe that timberfrom all national forest lands would be harvested,except where harvesting was prohibited by law(329). Comparable situations elsewhere led conser-vation groups, which had supported the ForestService against the ranchers and loggers, to supportthe idea of statutory wilderness protection.

The Forest Service included a provision in theMultiple-Use Sustained-Yield Act of 1960, notingthat ‘‘the establishment and maintenance of areas ofwilderness are consistent with the purposes andprovisions of this Act. However, wilderness propo-nents were still not satisfied, and the Wilderness Actcreating the National Wilderness Preservation Sys-tem was enacted in 1964.

The Wilderness Act provides more explicit guid-ance for managing the designated areas than the

Organic Act and MUSYA do for the other NationalForest System lands. The Wilderness Act generallyprohibits commercial activities and road and facilityconstruction in the designated areas. Compatiblecommercial activities (e.g., outfitter services) wereexempted, and grazing and other nonconforminguses (especially motorized access) were generallyallowed to continue, if those uses had been estab-lished before the area was designated as wilderness.Furthermore, valid existing mineral rights wereprotected, and the act permitted new rights to beestablished for about 20 years (specifically, untilDec. 31, 1983). In essence, the Wilderness Actprohibited timber harvesting, new recreation facili-ties, and new motorized access in the areas desig-nated as wilderness by Congress.

The Forest and Rangeland RenewableResources Planning Act of 1974

RPA was enacted because of concerns aboutshort-sighted, political decisions for the Nation’srenewable resources. At that time, public trust ingovernment was deteriorating-the Watergate scan-dal was breaking and Vietnam War protests were


expanding. Congress was reasserting control overthe Executive Branch—for example, the Congres-sional Budget and Impoundment Control Act (whichpreceded RPA by a month) reestablished congres-sional control of the budget, following impound-ments (nonspending of appropriations) by the NixonAdministration. Senator Hubert Humphrey, the prin-cipal sponsor of RPA, asserted that the administra-tion’s short-term spending priorities were short-changing renewable resource management.

RPA established an open, strategic planningprocess by which the Forest Service would addressthe long-range renewable resource situation in fourdocuments. First, an Assessment produced every 10years would examine resource conditions, trends insupply and demand, and opportunities to invest inresource production. Then, every 5 years, a programwould establish the direction for all Forest Serviceactivities, to respond to the trends and opportunitiesidentified in the Assessment. The Program was to beconsistent with the principles set forth in MUSYAand in the National Environmental Policy Act of1969 (NEPA). Thus, Forest Service activities underthe RPA Program are to provide for multiple usesand sustained yields, and the Forest Service is toinclude users and other interested parties in settingnational direction for Forest Service activities. APresidential Statement of Policy, which accompa-nies each Program, would then be used to guide theannual budget requests. Finally, an Annual Reportwould assess Forest Service accomplishments andprogress in implementing the program.

RPA also required the Forest Service to prepare“land and resource management plans for units ofthe National Forest System. These plans were to becoordinated with other Federal, State, and localplanning processes, and were to be developed using‘‘a systematic interdisciplinary approach to achieveintegrated consideration of physical, biological,economic, and other sciences. ’ The plans wereconsidered part of the RPA Program, and thus wereto be consistent with MUSYA and NEPA. Thus,RPA confirmed MUSYA as the management princi-ple for the national forests, and essentially estab-lished the requirement for public participation innational forest planning.

The National Forest Management Act of 1976

NFMA was enacted primarily in response toseveral lawsuits. The initial suits successfully ar-gued that clearcutting in the Monongahela NationalForest violated the Forest Service timber saleauthority in the 1897 Organic Act. The lower courtdecision was upheld by the 4th Circuit Court ofAppeals in August 1975. Then, in December, theFederal District Court of Alaska extended thisdecision to the long-term timber sale contracts inAlaska. 6 In July 1976, a preliminary injunctionfollowed the same logic to halt clearcutting in theNational Forests in Texas.7 Several other lawsuitswere filed in late 1975 and in 1976 to stopclearcutting in the national forests. The timberindustry and the Forest Service argued that clearcut-ting was a sound timber management tool, and thata ban would devastate the timber economy. If all thelitigation were successful, Forest Service timbersales would probably have fallen by half (261).However, in the Monongahela case, the Court ofAppeals stated that it could only apply the existinglaw; if the law was an anachronism, it was up toCongress, not the courts, to remedy the situation.

The lawsuits challenging clearcutting were onlyone expression of growing public dissatisfactionwith national forest management. The 1970 BelleReport (264) described problems on the BitterrootNational Forest in western Montana. The SenateCommittee on Interior and Insular Affairs heldextensive hearings on clearcutting around the coun-try in 1971, and issued recommendations for ForestService clearcutting in a committee report, com-monly known as the Church Clearcutting Guidelines(265). In 1970, the Forest Service had on its owninitiative begun a review of the wilderness potentialof many national forest roadless areas (RARE I), butthis review was halted in 1972 because of litigationcharging the Forest Service had been arbitrary inselecting the areas to be reviewed (294). ForestService management was, in essence, being chal-lenged in many ways and places.

Bills were introduced to make a simple, technicalcorrection to the Organic Act, making it legal toclearcut timber in the national forests. However,Congress chose to respond to the full range of public

Swest Virginia Division Of ftw IZUUA Walton League, Inc. V. Butz, 367 F. SUpp. 422; 522 F.2d. 945 (L$ti CU. 1975).

ezies~ V. Butz, 406 F.supp. 258.

7T~as Cominee on Natural Resources V. Butz, Civil Action No. ‘H-76-268-CA

Chapter 3--The Goals of National Forest Management and Planning ● 41

concerns about national forest management, ratherthan just address the immediate problem. Uponintroducing NFMA, Senator Hubert Humphrey ofMinnesota stated that:

Time has demonstrated that we need more than anew prescription for selling timber. We need afundamental reform in managing all of the resourcesassociated with forested land of the national forestsystem . . .

To me it is not enough that we modernize themethods by which timber is sold. This bill does muchmore. Its basic purpose is to assure that the multipleuses are realized and their yields are sustained. Thisbill seeks to strengthen resource management so thatit is ecologically effective (120).

Because RPA required land and resource manage-ment plans for units of the National Forest System,Congress chose to guide the local planning processby amending RPA. This option also fit with Con-gress’ intent to retain the basic direction for theNational Forest System, as set forth in the OrganicAct and MUSYA. NFMA was intended to assurebalanced use and protection of all the resources,today and tomorrow. As noted in the SenateCommittee Report:

The role of the Forest Service in the managementof the National Forest System is to act as a stewardof the land . . .

Timber production and sale are important aspectsof the overall management of the National ForestSystem lands, However, they are not the soleobjectives of management planning . . .

The other resources of the forests, wildlife and fishhabitats, water, air, esthetics, wilderness must beprotected and improved. Consideration of these re-sources is an integral part of the planning process. . .

It is, therefore, time for Congress to act in order toinsure that the resources found in our NationalForests can be used and enjoyed by the Americanpublic, now and in the future (261).

Senator Humphrey described the relationship amongNFMA, RPA, and MUSYA by noting that “TheForest and Rangeland Renewable Resources Plan-ning Act and these amendments are intended to befully compatible with the principles of the Multiple-Use Sustained-Yield Act, and, in fact, to providefurther direction in the implementation of that act”(120).

Much of NFMA is an amendment to the land andresource planning requirement of RPA. Some amend-

ments provide considerations for management. Forexample, section 6(k) specifies consideration ofphysical, economic, and other pertinent factors indetermining the suitability of land for timber pro-duction. NFMA also establishes standards andguidelines for planning. For example, section 6(f)(2)requires the plan to reflect proposed and possibleactions, including the planned timber sale program,and section 6(g)(2)(A) directs the Forest Service toidentify lands suitable for resource management.Section 6(g)(3) directs guidelines to achieve thegoals of the RPA Program, while subsection (A)specifies the consideration of the economic andenvironmental aspects of resource managementsystems, and subsection (F)(ii) requires an assess-ment of potential environmental, biological, es-thetic, engineering, and economic impacts of eachtimber sale. In addition, section 6(1) requires esti-mates of long-term benefits and costs and a represen-tative sample of government returns and expendi-tures associated with the sale of timber.

NFMA also establishes standards and guidelinesfor assuring protection of the resources of thenational forests. Examples include providing for adiversity of plant and animal communities (section6(g)(3)(B)); prohibiting irreversible soil, slope, andwatershed damage (section 6(g)(3)(E)(i)); assuringadequate reforestation within 5 years (section 6(g)(a)); protecting waters, wetlands, and riparianareas (section 6(g)(3) (E)(iii)); limiting the size ofclearcuts (section 6(g)(3) (F)(iv)); revegetating roadsunless the need for a permanent road is specified ina road plan (section IO(b)); and generally limitingtimber sales to a quantity that can be harvestedannually in perpetuity on a sustained-yield basis(section 13(a)). Thus, NFMA requires many consid-erations, standards, and guidelines in planning forthe management of the national forests underMUSYA.

While the Organic Act and MUSYA define theparameters of management, and NFMA detailsconsiderations, standards, and guidelines, NFMA isnot a set of prescriptions for national forest manage-ment. RPA and NFMA establish a planning processthat leaves substantial management discretion withthe agency. Furthermore, NFMA clearly intendedthat management, as set forth in the forest plans,respond to the desires and concerns of the people, asexpressed locally and through the national strategicplanning process under RPA. NFMA explicitlyrequires “public participation in the development,

42 ● Forest Service planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

review, and revision of land management plans . . .’RPA and NFMA planning are also to be conductedin accordance with NEPA, and NEPA also requiresthat Federal agencies consider public input indecisionmaking.

In sum, NFMA emerged in response to lawsuitsthat would have substantially reduced Forest Servicetimber sales. However, Congress chose to provideguidance for the required forest management plans,rather than enact only management prescriptions ora technical correction to the timber sale authority.The guidance is mostly in the form of planningconsiderations and standards and guidelines foranalyzing, reporting, and protecting the quality ofresources and the environment. NFMA was alsointended to assist in producing the high-level ofsustainable outputs required under MUSYA. NFMAleaves the Forest Service with substantial ForestService discretion in managing the national forests,but requires the agency to consider public interestsand concerns, and directs that the forest plans beprepared in accordance with NEPA. Thus, theOrganic Act and MUSYA provide a framework formanaging the national forests, while NFMA andNEPA essentially direct that local resource condi-tions and public desires and concerns be consideredin determining the details,

Philosophical Basis forGovernment Ownership

There are two, interrelated reasons for govern-ment ownership and management of forests andrangelands and of renewable resources: 1) theproduction of one resource output can affect otherresources, and 2) many resource uses are notcurrently marketed. Forests and rangelands clearlyproduce more than just one output or value; a forest,for example, can simultaneously grow timber, pro-vide food and cover for wildlife and livestock, andyield water for human use, land animals, and fish.Activities to modify one aspect of the forest willaffect other uses and values. For example, thinninga timber stand to increase timber growth might alsoincrease water yields and forage production, butmight decrease wildlife cover and water quality.This interrelationship among outputs is generallyknown as joint production.

Joint production can be a problem for naturalresource management, because many resource val-ues are not marketed. (See box 3-B.) Timber is theonly national forest output priced in a competitivemarket, 8 and even for timber, the Forest Serv ice doesnot respond to market signals in traditional ways(increasing sales when prices and/or profits rise, anddecreasing sales when prices and/or profits fall). Forother national forest resources, markets are not usedto set prices or to signal appropriate operations andinvestments.

While markets can improve production effi-ciency, efficiency was explicitly rejected as theguiding principle for managing the national forests.In debating MUSYA, the House Committee onAgriculture did not even consider a timber industryproposal to base management direction on financialconsiderations (329); instead, MUSYA directed thatmanagement need not be ‘‘the combination of usesthat will give the greatest dollar return or the greatestunit output. ’ Implicitly, Congress recognized thelimitations of markets in providing a balanced mixof resource values, and accepted the Forest Servicebill making multiple use and sustained yield theappropriate directions for national forest manage-ment.

Congress maintained this philosophy in enactingNFMA. As a result of the Belle Report (264) andother evidence of uneconomical timber investments,the Senate included a financial standard (productioncosts less than economic returns) for lands withtimber production as a management goal. A similarprovision was considered and rejected by the HouseCommittee on Agriculture and on the floor of theHouse. The substitute, agreed upon by the confer-ence committee and accepted by both Houses,requires consideration of economic (and other)factors in determining lands not suited for timberproduction, and then allows timber salvage sales andsales to protect multiple-use values on lands notsuited for timber production. Section 6(l)(1) ofNFMA also requires the Forest Service:

. . . to provide information on a representativesample basis of estimated expenditures associatedwith reforestation, timber stand improvement, andsale of timber from the National Forest System, andshall provide a comparison of these expenditures to

8pJot dl ~atlo~ forat ~~r is sold ~ ~mpetitive ~ets. From 1973 to 1979, 25 percent of timber sales (incIuding more t.bI hdf of all SaleSin the central and southern Roe& Mountains) received only one bid (288). (Such data are not published regularly, and more recent data are not available.)In areas where one-bid sales are common, Forest Service timber sale appraisals, rather than competition, determine timber prices.

—.

Chapter 3—The Goals of National Forest Management and Planning ● 43

the return to the Government resulting from the saleof timber . . .

However, NFMA does not proscribe agencyactions or require responses based on the compari-son of costs and revenues.

What Is Multiple Use?

MUSYA defines multiple use as:

. . the management of all the various renewablesurface resources of the national forests so that theyare utilized in the combination that will best meet theneeds of the American people; making the mostjudicious use of the land for some or all of theseresources or related services over areas large enoughto provide sufficient latitude for periodic adjust-ments in use to conform to changing needs andconditions; that some land will be used for less thanall of the resources; and harmonious and coordinatedmanagement of the various resources, each with theother, without impairment of the productivity of theland, with consideration being given to the relativevalues of the various resources, and not necessarilythe combination of uses that will give the greatestdollar return or the greatest unit output.

This definition of multiple use is not very usefulfor determin ing the proper management of thenational forests. The only goal is to meet the needsof the people, while the only limitation is to protectthe productivity of the land. In addition, multiple-use management is to consider relative resourcevalues, but maximizing returns or outputs is not to bethe sole basis for determining management. (Thislast provision was apparently a response to thetimber industry’s proposal for the multiple-use billto emphasize financial considerations in ForestService management decisions.)

Joint Production or aDominant-Use Patchwork?

The concept of multiple use encompasses twodistinct views about managing to produce outputsand uses: joint production and patchwork of domi-nant uses. As noted above, joint production recog-nizes that forests and rangelands are ecosystems thatcan produce more than just one use or output ofvalue-they provide wildlife habitat, yield water,can be used for recreation, and produce timber and

forage for livestock.9 Management of one use orvalue will affect the others; for example, a clearcutyields timber, generally increases water flows,augments forage for livestock and wildlife, andprovides access to new areas for some types ofrecreation, but may also degrade water quality andeliminate wildlife cover and certain recreation op-portunities, at least temporarily.

While joint production is clearly an accurate viewof the ecological interactions on forests and range-lands, it is difficult to apply the concept to landmanagement. Despite the long-standing recognitionof joint production, our understanding of the rela-tionships among resource values is incomplete. Thebiological and social sciences have, to date, pro-vided only a fragmentary picture of the ecologicalinteractions for a given site. Furthermore, seeminglyminor variations in activities or locations can causesubstantially different interactions among resourcesdepending on soil types, the nature and condition ofsurrounding sites, and other factors. Finally, noobjective way exists to determine whether the netresult of management actions on all of the currentand future uses and outputs is desirable. Economics(usually benefit-cost analysis) is often used toevaluate the results, but the limits of economicanalysis combined with the limits of our knowledgeof biological and social interactions make such anevaluation incomplete, at best. (See ch. 8.)

Another view of multiple-use management, apatchwork of dominant uses, provides clearer direc-tion for land managers. Under this approach, landsare divided into management units, and each unit ismanaged to produce more (or higher quality) of thedominant use(s) or output(s) while maintainingenvironmental and resource quality standards. De-spite the visceral reaction of many to the concept ofdominant-use management, this approach to achiev-ing multiple use is clearly consistent with MUSYA.The phrases “judicious use of the land for some orall of these resources’ and ‘‘some land will be usedfor less than all of the resources” suggest that theForest Service (which drafted the definition) be-lieved that multiple use could be achieved byseparating conflicts in space. Furthermore, someuses must be separated, because they are incom-

91t should be noted tha~ in different situations, multiple use may mean something other than the broad variety of uses and outputs commonlyassociated with forests and rangelands. In the mineral industries, for example, multiple use means allowing more than one type of mineral extractionfrom a site, with no reference to otlm uses, Thus, in certain circles, oil drilling on a hardrock mining claim is multiple use, even if no other uses occur(329).


Box 3-B—Privatization of Federal Lands

Since the late 1970s, some have questioned the validity of the historic justification for Federal land andresource ownership. Classical economics, dating back to a century before Adam Smith, asserts that governmentsshould minimize their interference with private land allocation and production decisions, because governmentinterference necessarily reduces optimal output (21 1). Citing this theoretical base, “sagebrush rebels” and othershave argued for privatization--the disposal of the national forests (and other Federal lands) by selling or transferringthe land to individuals and organizations in the private sector (45, 180). This approach would end or at least limitFederal land ownership, and rely principally on private market responses to consumer demands for determiningresource use and protection. A less draconian form of market responsiveness, called marketization, would retainFederal ownership, but seek to reap the benefits of private markets by rewarding Forest Service managers forresponding to consumer demands (187). This would require establishing markets for many uses and outputs thatare not currently marketed or that are subsidized.

Benefits of Market-Based DecisionsMarkets have two principal strengths for guiding land and resource management decisions. First, markets

provide unmistakable signals of individual consumer demands. Market prices of goods and services fluctuate tobalance supply and demand by allocating available supplies among consumers. High prices reflect strong demand,while low prices show weak demand. Similarly, price changes show changing demands, with prices rising whendemand is increasing (or supply is falling) and prices falling when demand is decreasing (or supply is rising).

The second strength of markets results from the clarity of the signals about supplies and demands: markets leadto efficient production among the marketed resources. Prices and production costs determine the most profitableoperations and investments. Assuming that managers respond to profits, actions will be shifted to producing themost profitable goods and services-those with high prices (strong demand) relative to the cost of production. Theseshifts to greater production of the most profitable resources will increase supplies and thus eventually reduce prices.Ultimately, managers responding to the price and profit information will achieve the most profitable balance amongall the marketed resources.

Limitations of Market-Based DecisionsThe primary limitation to using markets for land and resource management decisions is that many uses and

values are not marketed. Sometimes, pricing decisions have intentionally been made outside markets. For example,as a society, the American people have generally chosen not to charge a market price for the right to fish or hunt.Similarly, the established fee for grazing livestock on Federal lands is substantially below the calculated fair market

patible; few people want to picnic or camp in a tion, wildlife production, etc. Furthermore, somerecent clearcut, for example. Thus, a dominant-usepatchwork is, in some cases, necessary.

Applying a dominant-use patchwork for manag-ing the national forests is not without difficulties.Our incomplete knowledge of ecological and socialinteractions also restricts multiple-use managementunder this view, although less detailed understand-ing is needed for setting environmental and resourcequality standards and for monitoring results toassure that standards are met. However, determiningstandards is not a technical process. It is a socialprocess, with the affected and interested individualsand groups defining the minimum acceptable stand-ards. Defining the patches--which lands are man-aged for which uses—is also not a purely technicalprocess. Most lands can be managed for varioususes, emphasizing timber production, water produc-

lands that are highly effective at producing one value(e.g., timber) might also be highly effective atproducing another (e.g., wildlife), and joint manage-ment of the values might produce more of both thanwould be produced in a dominant-use patchwork.The ability of sites to produce conflicting values—e.g., wood and undisturbed ecosystems—is the heartof the controversy over preserving old-growthDouglas-fir forests in western Washington andOregon. Thus, although technical production is animportant consideration in determiningg the domi-nant use for a patch of forest or rangeland, thedemands and desires of the affected and interestedindividuals and groups must also be considered.

In reality, multiple-use management is morecomplicated than either joint production or a dominant-use patchwork suggests, and ‘multiple-use manage-


value of grazing(181, 281). Often, uses are subsidized to ensure availability to all, particularly for recreation. Marketproponents argue that subsidies will lead to overuse, and that price can be used to efficiently allocate the suppliesamong potential consumers. However, price uses wealth and income for allocating use, while other allocationmechanisms, such as lotteries and first-come-first-sewed, may be more equitable (61). Thus, for some resource uses,society (through its elected representatives) has chosen subsidies and alternative allocation schemes.

High transaction costs limit the effectiveness of some resource markets (31). For some resources, the cost toenforce market transactions is quite high; for example, the current easy access to national forests makes it difficultto ensure payment of the fair market value for dispersed recreation. Furthermore, the numerous highways andinholdings bring in many visitors whose primary purpose is not visiting the national forest. A similar difficulty isbeing able to relate increased outputs to management activities. For example, increased water flow may result frommanagerial efforts, but it also may simply result from additional precipitation; such uncertainty (together withexisting water rights law) may make it difficult for the Forest Service to charge for the increased water flow. Thus,difficulties in collecting market prices for the resource outputs produced may limit the use of markets for guidingmanagement of the national forests.

In addition, the collective-goods nature of some resources may prevent the creation of markets (31). Collectivegoods are provided for everybody, if they are provided at all, because people cannot be excluded from receivingthe benefits. Such benefits usually result not from the use of the goods or services, but simply from their existence;thus, collective goods are also called nonuse values and it is impossible to establish markets for them. For example,endangered species are collective goods, because much of their value is derived from knowing they exist, rather thanfrom using them. This is not to say that everybody wants the collective good; some people undoubtedly get littlepersonal benefit from knowing spotted owls exist. However, markets work because each buyer can choose theamount of the specific goods or services bought, whereas the collective nature of nonuse values prevents eachAmerican from choosing the amount of the collective good bought. Moreover the benefits of collection goods(existence) cannot be withheld from those who don’t pay.

Externalities are a third limitation to using markets for land and resource management decisions. Marketsinvolve transactions between buyers and sellers, but occasionally transactions harm people who are not involvedin the transaction. For example, when a landowner sells timber, the buyer and the seller are involved in thetransaction, but others--recreationists, sightseers, downstream water users, etc.—may be affected by the timbersale. If all resource uses and outputs were sold in equally efficient markets, the externalities would be resolvedwithin the marketplace. However, the high transactions costs for some resources and the collective-goods natureof other resources prevent establishing equally efficient markets for all resources. Therefore, externalities wouldplague purely market-based guidance for land and resource management.

ment” has come to mean either approach or a activities for a given site. The phrase, ‘‘multiple-usecombination of the two. Early Forest ‘Service man-agement apparently focused on the dominant-usepatchwork approach—use levels were relativelylow, and conflicts were managed simply by separat-ing users. As timber harvesting and recreation useincreased after World War II, managing the conflictsbecame increasingly important and increasinglydifficult. While the Forest Service still managessome conflicts by separating users in space and time,it also attempts to accommodate other values bymodifying dominant-use management. Such modifi-cations to dominant use may reflect the joint-production nature of forest and rangeland outputsand values, but they are only assumed to approxi-mate joint production.

In practice, joint production and dominant-usepatchwork can lead to quite different management

management, therefore, provides little guidancefor land management, and can be very misleadingwhen used to describe management direction. Asrecently as 1989, Henry Vaux noted the lack ofagreement on the meaning of multiple use:

Why such an apparent conflict in meanings?Because the symbol [multiple use] has at least somevalidity in describing these disparate forms of forestmanagement . . .

Even in an economic context, multiple use maybeinterpreted in more than one way.

Thus, ‘‘multiple use’ has multiple interpreta-tions, meaning different things to different people.To some, multiple use necessarily includes use ofcommodity resources (timber, livestock forage,minerals). Areas where such uses are proscribed,such as recreation sites and wilderness areas, there-


fore are not considered multiple-use areas. However,others have noted that such areas still yield water andare used for recreation and by wildlife (99), whileclearcuts effectively eliminate recreation use of theharvest site, at least temporarily. It is unclear whichuses or how many uses are necessary for an area tobe managed under multiple use.

Thus, although multiple use assures considerationof the various resource values and suggests that abalance among the values is appropriate, its multiplemeanings and various interpretations, together withthe technical difficulties of estimating joint produc-tion relationships, limit its usefulness for explainingor defending alternative management practices.

Confusion in the Act

One source of confusion in practicing multiple-use management is the list of purposes for admini-stering the national forests under MUSYA—‘‘outdoor recreation, range, timber, watershed, andwildlife and fish purposes. This list combines uses,outputs, resources, and land classes as the purposesfor administering the national forests. (See table3-l.)

This combination of purposes was not accidental.The terms were selected to assure a particular orderin an alphabetical (and therefore neutral) listing (56,329). Recreation had to come first, to combat ParkService efforts to obtain national forest lands and toshow that commodity production was not the firstand foremost purpose of national forest manage-ment. Then, a land classification-range-was usedinstead of livestock g-razing or forage, to assure thatthis commodity use was not listed frost. Timber wasselected to achieve centrality (and implicitly neutral-ity), although forestry has been (and sometimes still

is) used to describe timber production (53), andwood products are the end use; however, forestry orwood products would have meant listing this pur-pose first (emphasizing it) or last (denigrating it),neither of which was desired. Watershed waschosen, both to include soil resources implicitly andbecause other Federal agencies (e.g., the Bureau ofReclamation and the Army Corps of Engineers) areresponsible for providing water. Finally, wildlifeand fish-rather than the more natural phrase, fishand wildlife, or the more comprehensive term,animals-was used to assure last place in the listing,because States have primary jurisdiction over ani-mal management and because the U.S. Fish andWildlife Service shares Federal responsibility foranimal management. Thus, although the listing ofpurposes used in MUSYA was a hodgepodge ofuses, outputs, resources, and lands, it was politicallyexpedient.

The odd mixture of uses, outputs, resources, andland classes in MUSYA has contributed to theconfusion over what multiple-use management is.Multiple use suggests an emphasis on uses, orperhaps on outputs. However, the definition focuseson managing resources and protecting the productiv-ity of the land, and specifically prohibits selectingthe combination of uses that would maximizereturns or outputs. A focus on managing resourcessuggests a more integrated, ecological approach tomanagement than would result from a focus onproducing uses and outputs (17). MUSYA does notclearly define the proper focus for Forest Serviceefforts, and the resulting management thus mixesresource protection with use and output productionwithout defining the balance among resource values.

Table 3-l—Uses, Outputs, and Resources Corresponding to the Purposes Listed inthe Multiple-Use Sustained-Yield Act of 1960 (MUSYA)

Purpose in MUSYA Human use Resource output Resource base

Outdoor recreation , . . . . . . . . . . Leisure activities None Facilities, access, and acceptableland

Range . . . . . . . . . . . . . . . . . . . . . . Animal products Forage Forage-producing plants andgrazable land

Timber. . . . . . . . . . . . . . . . . . . . . . Wood products Timber Trees and harvestable landWatershed . . . . . . . . . . . . . . . . . . Water, hydro power Water Precipitation, soil, and protective

vegetationWildlife and fish . . . . . . . . . . . . . . Hunting, fishing, birdwatching, etc. Animals Animals and their habitat

(i.e., recreation) requirements (food, cover, etc.)SOURCE: Office of Technology Assessment, 1991.

— ———.


What Is Sustained Yield?

MUSYA defines sustained yield as:

. . . the achievement and maintenance in perpetuityof a high-level annual or regular periodic output ofthe various renewable resources of the nationalforests without impairment of the productivity of theland.

This definition is much more useful than thedefinition of multiple use for determining nationalforest management. Goals are defined more clearly:the productivity of the land is to be maintained,while producing a high level of annual (or periodic)outputs forever. As with a trust fund (see box 3-C),this implies producing a high annuity while protect-ing and enhancing the fired’s assets. This definitionis also consistent with the original managementdirection for the national forests enacted in the 1897Organic Act-that the lands are protected, that waterflows are secure, and that timber supplies arecontinuous.

Historically, sustained yield has been appliedmostly to timber. Providing a sustained timbersupply was a European forestry tradition imported toAmerica at the turn of the century (188). Inparticular, Gifford Pinchot wanted to show thattimberlands could be managed profitably for contin-uous production, demonstrating that the cut-and-runpractices of the timber industry were unnecessary(188, 327). Congress has, at various times, givendirection to provide continuous timber supplies-inthe 1897 Organic Act for the forest reserves, in the1937 0 & C Act10 for managing certain Federaltimberlands in western Oregon, and in the 1944Sustained Yield Actll authorizing special units ofFederal timberland to be managed to provide timberfor specific local communities.

Sustained yield has also been applied to managingrangelands and fisheries. The Wilderness Act im-plies sustainability for natural processes in describ-ing wilderness as “an enduring resource” and inprohibiting most developments. Nonetheless, MUSYAappears to be the first time that sustained yield wasbroadly applied to all renewable resource values,and this was probably done in part to counter ParkService efforts to become the premier Federalrecreation agency. Regardless of why it was pro-

posed, the concept of sustained yield of all resourcesmay have been the most persuasive reason forcongressional support for MUSYA (56).

There are three limitations to implementing sus-tained-yield management in the national forests: 1)the physical/biological bias of the approach, 2) thelimits of knowledge, and 3) the resource focus. First,sustained yields are determined by the physical andbiological productivity of the sites, with little or noregard for the relative value of those yields. Essen-tially, this view assumes that producing more mustbe better, regardless of the costs and the impacts onother values. Bowes and Krutilla(31) noted that theForest Service has an ‘‘institutional focus on thestability of harvest levels and on biological criteriafor timber treatments . . .“ NFMA perpetuates thisview in section 6(m) by identifying the “culmina-tion of mean annual increment’—the age of maxi-mum average physical production-as the standardfor harvesting timber. Thus, sustained yield focuseson perpetuating supplies by restricting uses andoutputs to growth or carrying capacity.

Furthermore, as discussed above, the biologicaland social sciences have provided an incompletepicture of the relationship between outputs (yields)and the resource base. Current resource outputs canbe used to estimate productivity, but current produc-tivity is an imperfect predictor of permanentlysustainable production levels. For example, currenttimber growth rates can be estimated and used todetermine appropriate harvest levels, but timberharvests probably alter growth rates by changinghydrologic patterns and soil nutrients and micro-fauna. Furthermore, using one resource affects thecurrent and future productivity of other resources.Timber harvests, for example, can alter (increasingor decreasing) both short-term and long-term wateryields, forage production, and animal populations.The limits of knowledge about ecological and socialrelationships make it difficult, if not impossible, toguarantee the sustained yield of all the resources atthis time.

Finally, the supply and production emphasisnecessarily focuses on the uses and outputs ofindividual resources (17). This focus has two effects.First, it inhibits ecosystem management. Managerstend to focus on producing and protecting individual

Im & c At of 1937, %t of Aug. 28, 1937, ch. 876 (50 Stat. 874; 43 U. S.C.1 181a).Ilsmti Yield F~re~t -=ent ~~ At of ~. 29, 1944, ch. 146 (58 stat. 132; 16 U.S.C 583).


Box 3-C-The National Forest System as a Natural Resource Trust Fund

The National Forest System was established to provide continuous and permanent natural resource benefits.In the Forest Reserve Act of 1891 and the Organic Act of 1897, Congress authorized reserving lands from thelarge-scale clearcutting that allegedly caused downstream flooding and destructive wildfires. The term reserve hasa double meaning. In addition to meaning something saved for future use or special purpose, a reserve is also‘‘capital held back from investment by a bank or company in order to meet probable or possible demands. Thus,reserve can also suggest capital assets held to provide for future needs. It is possible that Congress chose the termreserve to convey both meanings: saving the land from timber cutting to preserve water quality and establishing thecapital needed to provide for future demands.

Regardless of congressional intent in choosing the term reserve, the National Forest System is, in some ways,comparable to a trust fund. The Organic Act established continuous timber supplies as one of the purposes for forestreserves. The Multiple-Use Sustained-Yield Act of 1960 requires the Forest Service to maintain the productivityof the land Such direction indicates Congress' desire that the productivity of the national forests be protected, muchas the assets of a trust fired are maintained

The eastern national forests complicate the view of national forests as a trust fund. In contrast to the westernnational forests, with their substantial reserves of timber and expanses of lands, the eastern national forests wereacquired largely from cut-over lands, without enormous capital assets to be reserved Subsequent management ofthese lands has enhanced the asset value of the eastern national forests, and illustrates the possibilities formanagement to improve the asset base. Thus, the history of the eastern national forests can also be seen as a ForestService success in natural resource trust management.

Managing a trust fund illustrates the dilemma posed for managing the national forests. A trust fund is togenerate annuities for the beneficiaries, but the assets must be protected and enhanced, to assure future annuities.Similarly, the national forests are to provide for today’s uses and outputs, but the productive base (the lands,resources, and ecosystems) must be managed to assure that the uses and outputs can be sustained in the future. Inboth cases, managers are responsible for maintaining and enhancing the assets. Annual benefits are important, butpreserving the productive assets is paramount.

In both the National Forest System and trust funds, moreover, professional managers are responsible forprotecting the assets and producing the annuities and must also be responsive to the needs of the beneficiaries. Attimes, the beneficiaries may choose to forgo some annuities, to increase future annuities or for some moral or ethicalreason. For example, a trust fired’s beneficiaries may instruct the fund’s managers to terminate certain investments,even though the managers may believe them to be desirable assets. Thus, while the managers are responsibleprofessionals, the beneficiaries may prefer a mix of assets and annuities that is less than optimal, as defined by theprofessional.

The “annuities” of the National Forest System include not only uses and outputs, some of which are difficultto quantify (see box 8-A, p. 145), but also some nonuse values. Many people, for example, cherish various aspectsof relatively undisturbed ecosystems. Furthermore, different balances of uses, outputs, and nonuse values yielddifferent distributions of benefits. For example, building and/or maintaining campgrounds provides little directbenefit to the timber industry (although the workers may use the campgrounds) or to backpackers; wilderness maybenefit backpackers, but provides little value for loggers or for snowmobiles. In contrast to a traditional trust fund,with its financial annuities, no simple, technical measure exists to determine the optimum level and mix of valuesprovided from forests and rangelands.

Finally, the Forest Service is required by law, to provide the public with opportunities to participate in thenational forest planning process. Thus, the public both benefits from and influences the management of the NationalForest System. This contrasts with traditional trust funds, where the beneficiaries are relatively isolated from trustmanagement. Nonetheless, trustees are to be prudent managers of the assets, and for a government agency withassets and annuities that are difficult to quantify, prudence dictates that the beneficiaries be directly involved indeciding about the annuities to be provided and the assets to be maintained and improved.

~The~riCanHeri~geD~~~ of the En@sh Lunguage (BostoI.L MA: AIIIIuican Hdw Publidhg CO. & Hou@ton - CO.,1969), p. 1106.

Chapter 3-The Goals of National Forest Management and Planning . 49

resources, rather than on integrating the protectionand use of ecosystems. Under this focus, multipleuse will more likely be a dominant-use patchwork,rather than joint production, with coordinated man-agement of individual resources rather than trulyintegrated resource management.

When MUSYA was enacted, protection wasconsidered necessary only to ensure that uses andoutputs could be sustained. However, people todayalso value naturalness, and many wish to see naturalecosystems protected. The recognition of suchnonuse values is at least part of the controversy overnational forest management in the Pacific Northwestand elsewhere.

NATIONAL FOREST PLANNING:ACHIEVING THE GOALS

Planning Direction and Framework

What, then, are the goals for managing thenational forests and how can they be achieved? TheOrganic Act and MUSYA frame the goals effec-tively. National forest management is to accommo-date uses, produce outputs, and sustain ecosystems,with uses and outputs constrained to sustainablelevels. Furthermore, as stated in MUSYA, manage-ment is to provide “the combination that will bestmeet the needs of the American people . . .’ Thus,the proper mix of values is, essentially, determinedby the 1) the physical and biological capabilities ofthe lands, and 2) the economic, social, and personalinterests of affected and concerned individuals andgroups.

Planning for the management of the nationalforests is the means of achieving those goals.Planning is done whenever activities are proposed.The first Forest Service “plans” were simple landallocation decisions to separate conflicting uses.More formal planning began after World War I, andexpanded following World War II, especially toorganize and coordinate the expanding timber pro-gram. By about 1960, the Forest Service recognizedthe need for integrated planning to coordinate themultiple uses of the various resources. However,planning efforts were still primarily internal, techni-cal approaches to resolving problems and determin-ing direction.

The first legal requirement for national forestplanning was enacted in RPA. The principal purpose

of RPA was to establish a national strategic planningprocess for America’s renewable resources (259).RPA also directed the Forest Service to prepareintegrated land and resource management plans forunits of the National Forest System. Because theseplans were deemed part of the RPA program, theywere to be developed in accordance with MUSYAand NEPA.

NFMA substantially amended the RPA directionfor forest planning by adding numerous considera-tions and requirements to be met in the planningprocess. However, NFMA provided no additionalguidance on how to determine the mix of resourceuses, outputs, and protection.

Strategic Planning for the National Forests

Taken together, the Organic Act, MUSYA, NEPA,RPA, and NFMA provide the framework for manag-ing the national forests. The Organic Act andMUSYA established the foundation-that the For-est Service is to accommodate uses and produceoutputs while sustaining the ecosystems upon whichthe uses and outputs are based—but they did notidentify the mix or balance of uses, outputs, andprotection. Instead, MUSYA implicitly acknowl-edged that the proper mix is determined by people’sneeds, as expressed through public participation andthrough legal requirements, and that the mix canchange over time. NEPA provided a framework fordisclosing intended actions and the possible conse-quences of those actions to the public. RPA requiredintegrated land and resource management plans, andNFMA then established several management con-siderations and requirements, and specified publicinvolvement in developing, amending, and revisingmanagement plans.

These laws implicitly direct strategic planning forthe national forests. Forest planning is an openprocess to set goals for the conditions of and outputsfrom the national forests, to identify standards andguidelines for activities, and to describe the actionsand funding needed to achieve the goals. The publicis to participate in setting technically and politicallyfeasible condition and output goals for ForestService managers. However, forest plans must alsobe consistent with the strategic direction set in RPAplanning.


Setting Direction

Strategic planning is a process for establishingmanagement direction for an organization. In busi-ness, it defines the concept of the firm, and reflectsthe social, economic, and political setting withinwhich it operates. For a Federal agency, strategicplanning begins with a clear statement of theagency’s mission, defining what service the agencyprovides and who the clients/beneficiaries are. TheForest Service’s current motto-Caring for the Landand Serving People—is an overgeneralized direc-tion to accommodate uses and produce outputs whileprotecting lands and sustaining ecosystems.

The most widespread problem in strategic plan-ning is vague goals (101). Goals must be specificenough to provide real direction for managers andconcrete enough to measure success. A broad,imprecise goal, such as “optimize the balance ofresource values,’ is subject to widely differentinterpretations. It gives managers no objective basisfor evaluating the impacts and tradeoffs of theirvarious options; different managers could conceiva-bly undertake diametrically opposed actions undersuch general, unspecific guidance. The concretegoals in a forest plan would identify the quality,quantity, cost, and time of the uses, outputs, andconditions that are feasible and desirable, establish-ing a clear direction for managing the resources andecosystems of the national forest and specificmeasures to evaluate performance.

Forest plans generally have not provided such adescription of forest management goals. The sizeand complexity of a national forest may make itvirtually impossible to provide a comprehensive,detailed description of the quality, quantity, cost andtiming of all uses, outputs, and conditions. Rather, amanageable set of goals could be established byfocusing on key issues and concerns, explaining howmanagement will affect pivotal sites, produce im-portant outputs, and protect critical lands, resources,and ecosystems. Furthermore, the forest plan coulddescribe how management is likely to be differentfrom what was occurring before the plan wasadopted. The Forest Service has recognized thispoint, and the 1981 Advanced Notice of ProposedRulemaking (287) proposes incremental (rather thanzero-based) revisions for forest plannin g. Nonethe-less, by focusing on issues as well as on managementchanges, strategic forest plans can both guide theagency and inform the public.

The Irrationality of Strategic Planning

Strategic planning is messy and imprecise, ratherthan rational and scientific (241). It necessarilyinvolves considering many feasible directions andselecting the one that best fits the organization’scharacter and clientele. No precise, rational, scien-tific systems exist for making the selection, nocalculus of inputs and outputs can determine theright choice. Rather, strategic planning means se-lecting the mission that will work best for aparticular organization, with its current mix ofemployees and customers; for a different organiza-tion or at a different time, a different option might bepreferable. Furthermore, because the public is boththe “owner” of government assets and the client ofagency programs, a government agency must con-sider public and political needs and desires instrategic planning.

The imprecision of strategic planning contrastswith early expectations about NFMA planning.Many, inside and outside the agency, believed thatNFMA planning “would essentially be a scientificprocess” (276)-that enough facts and the rightcomputer model would lead to the “right’ answersfor how to manage the national forests. The ForestService has recognized the limitations of a rational,scientific process for forest planning in its recentinternal critique of NFMA planning (276). However,even from the outset, some observers have noted thatnational forest planning was inherently political, andthat a technical, scientific process could not lead toacceptable plans (3, 49, 79). Despite these earlywarnings, the Forest Service is only now acknowl-edging that forest planning is dominated by publicconcerns and interests.

In forest planning, some form of public agreement—working consensus, informed consent, etc.—is nec-essary, if the plans are to be implemented. At times,consensus and the middle-ground are not feasible,and the Forest Service must make a decision thatnecessarily favors one group or another. Regardless,the decisions and the rationale for those decisionsmust be explained in plain, nontechnical English.Decisions are also more likely to be accepted, if thepublic and the line managers have been involved inthe process, understand the limits of the resources,and see that consensus cannot be reached. Onecommon objection to forest planning is that thepublic doesn’t understand how and why decisionswere made (277).


To participate fully and constructively, peopleneed to know what will be decided in the plan, whatdecisions will be postponed, and where and whenthose decisions will be made (277). Public involve-ment in strategic forest planning is necessarily anongoing process, throughout the preparation andimplementation of the plans. The planning regula-tions should specify how plan decisions are to betreated during implementation, and under whatconditions plans are to be amended.

Furthermore, the discussions among the ForestService and the public should focus on the importantissues and desires. Needs and desires may beexpressed as concern over particular sites, interest inachieving certain output levels, or desire to haveareas or resources protected or preserved. The ForestService has recently noted that plans are moresuccessful if the full range of needs is considered—emotional and symbolic needs, as well as economicand community needs and organizational needs(276). Regardless of how they are expressed thepublic’s needs, desires, concerns, issues, and inter-ests must all be addressed in every step of preparingand implementing strategic forest plans.

The Information Base

Planning for a desired future requires someunderstanding of the present, including the peculiar-ities of an organization-its structure, its personnel,its customers, and its owners or board of directors,Strategic forest planning would take stock of thenational forest lands and resources, the ForestService workforce, the interested publics, and theAmerican people and Congress.

Inadequate information is a common problem instrategic planning (101). Complete data will not‘‘solve’ forest planning problems, because strategicplanning is not scientific, with data and computers toget the “right’ answers. In addition, measures forsome outputs and conditions will always be impre-cise. Nonetheless, strategic planning depends on ananalysis of the current situation-the resource con-ditions and trends and the public’s concerns anddesires. Knowing the starting point is essential todetermining the actions necessary to achieve thegoals. An inadequate ‘‘situation audit’ would re-strict the value of the forest plan as a guide to presentand future Forest Service actions, because thestarting point is uncertain.

The incomplete data on ecosystem conditions,especially the lack of information on resourcequality, in the RPA Assessment has been notedelsewhere (259), Data inadequacies in nationalforest planning are described in ch. 6 of this report.Data must not only be complete, they must also betimely. Outdated resource information in NFMAplanning has been described as a serious problem(1), and Congress has provided temporary protectionfrom judicial review to forest management decisionsbased on outdated information (28). Furthermore,sometimes even the issues being considered in forestplanning are out of date, and no longer reflect thecurrent concerns (1). The outdated information onresources and concerns principally results from thelong timeframe required to develop the first round offorest plans, and might not be a continuing problemif the plans can be revised more expeditiously.Nonetheless, the timeliness of information, as wellas its completeness and accuracy, must be addressedexplicitly in the planning process.

The assessment of the current situation is anecessary precursor to examining options and op-portunities in forest planning. Inventories mustrespond to the issues and concerns for each forest, toassure that relevant data are collected, and that timeand money are not spent gathering unnecessaryinformation. The Forest Service has not been con-sistently successful in identifying relevant dataneeds early in the planning process; for example,although the northern spotted owl was identified asan indicator species for old-growth Douglas-firhabitats in the early 1980s, the inventory of spottedowls and their habitat was not begun until 1989. Inaddition, although relevant data are determined bylocal concerns and issues, collection methods andmeasurements for information that is needed com-monly or nationally should be standardized, to allowfor aggregation of data from numerous forests.

Examining options and opportunities is a majorpart of the NFMA planning process. The process isoften highly technical, as when land and resourcecapabilities are determined, tradeoffs are analyzed,and management prescriptions are developed. How-ever, the public is affected by and interested in theresults of the analyses, and the users, not technicalstandards, determine the compatibility or incompati-bility among various uses and outputs of a given siteor adjoining areas. Similarly, while the efficiency ofmanagement prescriptions can be technically evalu-ated, the prescriptions must be acceptable to the


public. Thus, examining options and opportunities isboth a technical and a social process.

Implementation

The strategic plan guides an organization’s ac-tions. Although a strategic plan must be imple-mented, it is neither a long-term budget plan nor anironclad commitment (241). This is particularly truefor government agencies, since managers do notcontrol all the variables that determine implementa-tion (particularly budgets). Instead, the strategicplan identifies goals for the action plans used tobuild annual budgets and to determine activities.Forest plans should define condition and outputtargets for the national forests, which can then be thebasis for budget proposals and for subsequentactions. They cannot be guaranteed commitments,because Congress enacts Forest Service appropria-tions annually. This contrasts with the view of forestplans as social contracts. Nonetheless, forest plansare agreements between the agency and the publicabout the goals of national forest management, andshould therefore guide budgets and subsequentactions.

It is unclear whether forest plans are guidingbudget proposals and management activities. Imple-mentation difficulties arise from the complexity ofenvironmental laws (206), but the agency believesthat the plans are guiding national forest manage-ment (276). Others disagree, suggesting that theagency has backed away from implementing someforest plan decisions (205) or that the actions don’tmatch the promises of the plans (76), Perhaps moreimportantly, the monitoring and evaluation of activi-ties and results has been inadequate to determinewhether forest plans are being implemented (i.e.,whether budgets and actions are consistent with theplan) and whether the results match the expectations.(See ch. 6.)

A further problem in strategic planning is that linemanagers often do not realize that planning is amanagerial function, that ‘ ‘planning and doing areseparate parts of the same job; they are not separatejobs” (101, 241). Managers who have not beeninvolved in strategic planning commonly perceiveplans as a burden imposed on them, rather than as abetter way of doing business. The Forest Service hasfound that forest plans are likely to work best—beacceptable to the public and implemented by theagency—if the forest supervisors were directlyinvolved in their development (276). However, the

forest planning process is complex and manypressures compete for a manager’s time. Thus,managers are often only marginally involved in theplanning process. Nonetheless, forest planning andmanagement must become integrated, and the ForestService is now providing training for forest supervi-sors and other employees on forest plan implementa-tion.

Feedback and Control

Strategic planning is a continuous process, ratherthan a discrete act. Because it directs an organiza-tion’s future, the strategic plan must be flexibleenough to respond to economic and political changes.The Forest Service must also respond to naturaldisasters—fires, floods, hurricanes, volcanic erup-tions, etc. Thus, one should not expect NFMAplanning to be “done’ it is an ongoing process ofsetting direction, of responding to feedback and tochanging conditions, and of guiding actions andbudget proposals. This is consistent with the NFMArequirements to amend plans as needed and to reviseplans periodically.

Strategic planning requires that results—sales andprofits in business; outputs, uses, and conditions forthe national forests—be monitored to determine ifthe actions meet the organization’s mission (241). Ifthe results are unexpected and undesirable-if allthe goals are not being achieved—actions can bemodified to achieve the defined goals, or the planamended to revise the goals, if necessary. Withoutperiodic evaluation, the organization could continuein an unacceptable direction until litigation or someother unanticipated event forces a change. Thus,monitoring and feedback are essential to fulfillingthe strategic planning process. However, as dis-cussed in chapter 6, the Forest Service has done verylittle monitoring of forest plan activities.

Finally, strategic planning must be both central-ized and decentralized in nature (101). It is central-ized because the organization takes a comprehensivelook at its situation and overall direction. Further-more, the control systems—such as budgeting andperformance appraisal-must be integrated andcoordinated, to assure that the various units can betreated equitably. However, strategic plans mustalso be decentralized, so that individual units areappropriately distinguished and so that the managershave the flexibility to respond to local situations andare rewarded appropriately. The national strategicplanning process under RPA sets the overall direc-

Chapter 3—The Goals of National Forest Management and Planning ● 53—— ——

tion for the agency, and provides the centralizedguidance for the agency. However, national produc-tion targets allocated to the national forests constrainflexibility to respond to local physical, biological,economic, and social conditions. Thus, forest plan-ning must be consistent with the centralized guid-ance from RPA planning, but condition and outputtargets and plan implementation and evaluationmust be decentralized, with each forest respondingto its local situation.

Poor coordination among units is a commonproblem of strategic planning by corporations ( 101).The Forest Service is basically organized func-tionally—by resource. This structure has served theagency well for decades, but it inhibits integratedresource management. For example, the first roundof forest plans was often reviewed in Forest Serviceregional offices and the Washington headquarters byresource staff specialists, who typically forced theplans “back in line with the traditional single-resource’ approach (276,). Reorganizing the staffand budget structures for integrated resource man-agement was one of the future challenges identifiedin the agency’s recent critique of its forest planningprocess (276).

Another common strategic planning problem isinadequate links to control systems, such as budgetsand incentives (101). Control systems guide per-formance. If the controls are inconsistent with thestrategic direction, they can slow or even preventsuccessful implementation. In business, bonuses andpromotions are often based on specific accomplish-ments, outputs, or programs. If these targets do notconform to the strategic goals, managers are morelikely to ignore the strategic goals than theirindividual performance targets (241). Similarly,budgets that are not consistent with the strategicdirection can shift management emphasis away fromthat direction.

The Forest Service has addressed part of thebudget problem by calling for an integrated resourcebudget process (276), but creating a link betweenforest plans and annual budgets will require morethan a new budget structure (215, 217). (See ch. 8.)Some critics of the agency have suggested that thecurrent budget system encourages timber harvestingat the expense of other resources (187). Incentivesand rewards related to the forest plan are equallyimportant. Timber outputs have allegedly become soimportant that many past and current employees

have expressed concern that the timber targetsoverride other resource considerations (66, 90, 136).As discussed in chapter 9, strategic forest planningrequires that the Forest Service reward systems beexplicitly tied to preparing effective forest plans andto implementing those plans.

SUMMARY AND CONCLUSIONSControversy has always surrounded the national

forests, The 1897 Forest Service Organic Act wasenacted principally to limit presidential authority toestablish reserves, and the authority to sell timberwas a subject of debate. In 1911, the U.S. SupremeCourt ruled that the Forest Service did have theauthority to regulate and charge for grazing in thenational forests. The Multiple-Use Sustained-YieldAct of 1960 (MUSYA) was enacted at ForestService request, because of various efforts to reducediscretion over managing the national forests. TheNational Forest Management Act of 1976 (NFMA)was enacted because litigation threatened to haltclearcutting in the national forests, and therebyreduce Forest Service timber sales by half. Today,the controversies include debates about red-cockaded woodpeckers, about spotted owls andold-growth Douglas-fir forests, about below-costtimber sales, and about the level of administrativeappeals and litigation. Controversies will probablyalways exist, because people care about the landsand resources of the National Forest System.

The national forests have always been managed toprovide multiple uses and sustained yields. MUSYAfurther articulated the purposes for national forestmanagement, but did not establish unambiguousgoals for the national forests. The act presents a mixof uses, outputs, resources, and land classes as‘‘purposes, ’ without giving much guidance on howto manage for the many uses and outputs. Multipleuse is to ‘‘meet the needs of the American people, ’while sustained yield suggests limiting use tosustainable levels. Taken together, the 1897 OrganicAct and MUSYA direct management of the nationalforests to accommodate resource uses and produceresource outputs in the mix that people want, whileprotecting the lands and resources, and sustainingthe ecosystems. NFMA added considerations formanagement and regulations for developing, amend-ing, and revising the plans and for managementstandards and guidelines, while requiring publicparticipation in defining the mix of resource valuesfor each national forest.

54 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

RPA established a strategic planning process forthe Nation’s natural resources. RPA, as amended bythe NFMA, also required the agency to prepare andrevise land and resource management plans for thenational forests. These plans can also be seen asstrategic plans, consistent with the guidance in RPAand NFMA, with the purposes outlined in theOrganic Act and MUSYA, and with the publicdisclosure required by the National EnvironmentalPolicy Act of 1969 (NEPA).

Strategic planning establishes the direction for anorganization. Goals are measured in concrete termsso that everyone (managers, employees, and thepublic) understands the direction. As directed byMUSYA, NFMA, and other laws, the nationalforests are to accommodate uses and produceoutputs, while protecting lands and sustainin g eco-systems. (See ch. 4.) Forest plans must, therefore,identify the quantity, quality, and timing of thesegoals. A document that presents such a comprehen-sive picture of all uses, outputs, conditions, and sitescould be overwhelming to produce and to under-stand. Rather, the agency could present the manage-ment direction by describing how managementunder the plan will change for key sites, importantoutputs, and critical resources and ecosystems. Inessence, quantity and quality goals must be set forthe outputs and conditions people are concernedabout.

Strategic planning for the national forests must bebased on sound information and analysis, but is nota precise, rational, scientific process. A ForestService review of criticisms concluded that nationalforest planning is essentially political in nature (10),and in its recent internal critique, the agency notedthat ‘‘technical answers to social and political issuesalienate many people’ (276). Technical answersfrom computer programs were unlikely to be moreacceptable for directing national forest managementthan was the professional expertise which had beenrejected in the early 1970s in the Bitterroot contro-versy, the Monongahela lawsuit, and the enactmentof NFMA. Strategic planning for government activi-ties is rooted in public agreement-or workingconsensus, informed consent, or whatever term youchoose to indicate that the management must beacceptable to the public. (See ch. 5.) Public involve-ment can be most effective, if: 1) the decisions to bemade in the plan (and those to be postponed toanother time or forum) are specified when planningis begun, and 2) the discussions and decisions focus

on the needs and concerns of the interested andaffected individuals and groups.

A strategic forest plan begins with an assessmentof the current situation-what people want and areconcerned about, and the land and resource condi-tions and trends that are relevant to those desires andinterests. More and better data will not ‘‘solve’forest planning problems, because strategic planningis not a rational, scientific process, but charting acourse to the desired destination (the goals) dependson knowing the starting point. Inadequate datahamper strategic planning by restricting understand-ing of current conditions and direction. Furthermore,unless the data limitations are well known, technicalanalyses based on poor data provide apparentlyprecise estimates of the consequences of variousoptions and opportunities. (See ch. 7.) The incom-plete and outdated information used in the forestplans, particularly on conditions- and impacts ofconcern to the public, has impeded strategic forestplanning. (See chs. 6 and 8.)

If strategic planning is to have any value, theforest plans must be implemented. The plans areneither budget proposals nor ironclad commitmentsto actions or results, particularly since governmentagencies must request funds from a legislature. (Seech. 8.) Strategic plans must allow for the flexibilityto respond to changing conditions, whether due tobudget restrictions, political changes, or naturaldisasters. Nonetheless, the plans should guide budgetrequests and management activities. It is unclear,however, whether the forest plans are being imple-mented, because monitoring and evaluation ofactivities and results has generally been inadequate.(See ch. 6.) Plans are most likely to be implementedif managers recognize that planning is part of the jobof managing a national forest, and are thereforeclosely involved in the planning process. (See ch. 9.)

Finally, strategic planning is a continuous proc-ess, with feedback to assess plan implementation. Ifthe results differ unacceptably from those antici-pated, the actions can be adjusted to achieve thedesired goals, or the plan can be amended to modifythe goals, if necessary. Without adequate monitor-ing, management could continue in an undesirabledirection until forced to change by unexpectedproblems or litigation. (See chs. 5 and 6.)

A strategic planning process for the nationalforests is both centralized and decentralized—centralized for control and coordination, but decen-


tralized for flexibility to adapt to local physical,biological, social, and economic conditions. Direc-tion for national forest planning from the RPAProgram can provide the centralized coordination,but should not impose rigid requirements thathamper local flexibility. (See ch. 10.) Furthermore,the agency’s traditional fictional organizationstructure has inhibited the integrated, interdiscipli-nary approach required in planning and appropriatein managing the lands and ecosystems, in assessingplans and activities, and in dealing with the public.(See ch. 9.) In addition, budgets and incentives mustbe linked to the goals set forth in the plan; the currentbudget system and performance appraisals empha-size commodity outputs over other use and conditiongoals, but managers must be held accountable for

achieving all condition and output goals. (See chs.8 and 9.)

Ultimately, managing the national forests is akinto managing a trust fund. A trust fund is to provideannuities for the beneficiaries, but the assets of thetrust are to be protected and enhanced. Similarly,national forests are to be managed to provide thevalues that people want-the uses, outputs, andprotection of special sites and resources. The assetsof the national forests—the lands, resources, andecosystems—are to be conserved and improved, toassure that the values they provide can be sustained.Strategic planning is an approach, consistent withthe laws governing the management of the nationalforests, that can achieve these goals.

Chapter 4

The Legal Framework for ForestPlanning and Management

. . . . . .

ContentsPage

Setting Direction for Managing the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 60The Forest Service Organic Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60The Multiple-Use Sustained-Yield Act of 1960 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61The National Environmental Policy Act of 1%9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61The Forest and Rangeland Renewable Resources Planning Act of 1974 . . . . . . . . . . . . . . . . . . 63The National Forest Management Act of 1976 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Additional Legal Constraints on the Forest Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66The Wilderness Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66The Wild and Scenic Rivers Act of 1%8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67The Clean Water Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .70The Endangered Species Act of 1973 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .72

BoxesBox Page4-A. Special Congressional Attention for the Tongass National Forest . . . . . . . . . . . . . . . . . . . . . 664-B. Release Language and Management of Roadless Areas Not Included in the

National Wilderness Preservation System ● . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

Chapter 4

The Legal Framework for Forest Planning and Management

During congressional oversight hearings in Octo-ber 1989, Forest Service Chief Dale Robertsonasserted that forest management had become in-creasingly ‘‘complicated’ by the series of laws thatgovern forest planning and plan implementation.Chief Robertson stated that, while each law serves aparticular worthwhile purpose, taken together theyimpose serious burdens on planning and implemen-tation:

[T]rying to implement all of these laws does getto be an extremely difficult situation . . .

Sometimes we feel like we are almost in animpossible situation because when we face theselegal requirements of National Forest ManagementAct, NEPA, Endangered Species Act, Archaeologi-cal Resource Protection Act, the Clean Water Act,Clean Air Act, and all of these other laws,. . . peoplecan pick our weakest link, and challenge us on ourdecisions, and delay or stop the best laid plans(206).

Some critics question the utility and efficacy offorest planning laws, believing these laws have notcontributed to solving problems related to resourcemanagement, and even suggesting that the laws berepealed (18, 187). They further charge that thecomplex legal requirements have imposed a cumber-some and costly burden on the agency, subjecting itto increased threat of appeals and litigation stiflingresource management, and accomplishing few of theobjectives it was designed to achieve (79). “Docu-mentation, consistency, and correct procedure be-come far more important than a land manager’ssolid, experienced judgment” (16).

Others defend the current legal framework asnecessary to sustain the forest and rangeland ecosys-tems while accommodating uses and producingoutputs. Some argue that the current problems existbecause planning laws preserve too much agencydiscretion, and urge Congress to mandate more

prescriptive management laws (76). The agency’scurrent difficulties, they argue, result because theagency has failed to follow the spirit and intent of theexisting environmental protection laws. Still otherssuggest that numerous administrative appeals andlawsuits result because the agency is not reallylistening to the public (277); the legal requirementsmight not seem so cumbersome, if the agency weremore responsive to local public input and workedmore closely with interested publics to solve conflictthrough deliberation and negotiation.

This chapter examines the general framework oflaws governing land and resource management inthe national forests and the implications of each onforest planning.1 First, it examines the laws thatprimarily govern planning and management-theForest Service Organic Act of 1897, the Multiple-Use Sustained-Yield Act of 1960, the NationalEnvironmental Policy Act of 1969, the Forest andRangeland Renewable Resources Planning Act of1974, and the National Forest Management Act of1976. Then, it reviews certain laws that restrictactivities to protect various resource values2--the1964 Wilderness Act, the Wild and Scenic RiversAct of 1968, the 1972 Clean Water Act, and theEndangered Species Act of 1973.

The chapter also briefly discusses the concernover the ‘‘cumulative impact’ of these laws onForest Service planning and management. Thecomplex web of laws may make forest planning andactivities slower, costlier, and less efficient thannecessary to produce and protect the various re-source values. Moreover, some laws guide thesetting of management direction based on localconditions and public participation, while other lawsestablish requirements or standards for specificresources, values, or sites. The difficulties posed bythis legal web will be examined, but the thoroughlegal analysis needed to evaluate whether alternative

]A host of ~w~ apply t. some deWe t. forest management, including, but not limited to: he Gened Wing IAW of 1872, the 1911 WCXkS bW,the Migratory Bird Treaty Act of 1918, the Mineral basing Act of 1920, the Taylor Grazing Act of 1934, the 1%5 Land and Water Conservation FundAct, the Archaeological Resource Protection Act, the Federal Land Policy and Management Act of 1976, the Clean Air Act Amendments of 1977, the1978 American Indian Religious Freedom Act, the Public Rangelands Improvement Act of 1978, the 1980 Alaska National Interest Lands ConsemationAct, and the 1987 Federal Onshore Oil and Gas Leasing Act. More thorough listings, with copies of the laws, can be found in The Pnncipaf Luws Relaringto Forest Service Activities (270) and Wildlands Management Law (232).

Zsome of the phumin@nanagement laws, notably NFMA, also establish restrictions on planning and management. However, they are included asdirection-setting laws, because management guidance is their primary purpose.

–59–297-904 0 - 92 - 3


structures could provide comparable protection moreefficiently is beyond the scope of this study.

S E T T I N G D I R E C T I O N

F O R M A N A G I N G

T H E N A T I O N A L F O R E S T S

Forest Service administration of the nationalforests is authorized and governed by severalstatutes that establish the agency’s mission andgenerally define the scope of its regulatory andmanagement authority. These laws include the 1897Organic Act, the Multiple-Use Sustained-Yield Actof 1960 (MUSYA), the Forest and RangelandRenewable Resources Planning Act of 1974 (RPA),and the National Forest Management Act of 1976(NFMA). The following discussion examines howeach of these statutes has shaped the Forest Service’smission, the extent to which each directs thesubstance and procedure of planning and decision-making, and the extent to which each has broadenedor narrowed the agency management authority anddiscretion. In addition, because of its importantprocedural requirements for forest planning, theNational Environmental Policy Act of 1969 (NEPA)is also examined in this section.

The Forest Service Organic Act

In 1891, Congress gave the President the authorityto reserve by proclamation any public domain lands“wholly or in part covered with timber or under-growth, whether of commercial value or not . . ."3

This authority was narrowed in 1897 when Congressdefined the purposes for which such public landscould be reserved. This act, which has becomeknown as the Forest Service Organic Act, providedthat:

No public forest reservation shall be established,except to improve and protect the forest within thereservation, or for the purpose of securing favorableconditions of water flows, and to furnish a continu-ous supply of timber for the use and necessities ofcitizens of the United States . . .

The forest reserves were created from public landsunder the jurisdiction of the General Land Office inthe Department of the Interior. Congress alsoauthorized the Secretary of the Interior to manageand protect the lands by “mak[ing] such rules and

regulations and establishing] such service as willinsure the objects of such reservations, namely, toregulate their occupancy and use and to preserve theforests thereon from destruction” (89).

Early forest management focused primarily on thetimber and range resources. Management planningfor the forest reserves began in 1899, when theDepartment of the Interior began developing work-ing plans” for timber harvesting in each of theestablished reserves (324). After the reserves andmanagement agency were merged into the Bureau ofForestry in the Department of Agriculture in 1905,the chief of the newly created Forest Service, GiffordPinchot, directed that working plans be developedfor every timber sale, in part to facilitate timberharvesting, but also to avoid overcutting (324).

Forest Service planning and management of therange resources began largely in response to theperception that the public rangelands were beingovergrazed by sheep. Thus, while the early timberplanning efforts were to make timber available, theearly range management efforts were more regula-tory in nature, designed to protect water and othernatural resources from the consequences of over-grazing (324). The agency charged fees for grazingrights to reduce overgrazing on some lands andwithdrew certain other lands from grazing useentirely. The Organic Act and these early resourceworking plans firmly established both a utilitarianand protective tradition for resource managementwithin the Forest Service, consistent with ChiefPinchot’s views of proper resource management(196, 324).

The agency’s authority to regulate the use andoccupancy of the national forests was first chal-lenged by ranchers who objected to Federal controlover and fees for grazing livestock on traditionallygrazed lands. However, in 1911, the U.S. SupremeCourt upheld the agency’s authority to regulategrazing through the imposition of “reasonable”user fees (240). Of greater importance, the courtrecognized that under the Organic Act the agencypossesses broad regulatory authority over the “oc-cupancy and use” of the forest reserves. The courtheld that the Secretary of Agriculture is required tomake rules and regulations to protect the forestreserves ‘from depredations and harmful uses, ’ and

3Fore.t Ra=e At, ~t of ~. 3, 1891, Ch. 561 (26 s~t. 1103; 16 U.s.c. 471). Repealed by section 704(a) of the Federal Land Policy and

Management Act of 1976 (Act of Oct. 21, 1976, Public Law 94-579 (90 Stat. 2743)).

Chapter 4--The Legal Framework for Forest Planning and Management . 61

concluded that the Secretary is authorized ‘‘toregulate the occupancy and use and to preserve theforests from destruction.”4

Since 1911, courts have consistently interpretedthe occupancy-and-use language of the 1897 Or-ganic Act as providing the agency with broadregulatory and management authority over thenational forest lands. Courts have recognized thatthis authority includes, but is not limited to, the rightto issue land use permits for large areas,5 to regulatemotorized recreation use,6 and to regulate wildlifewithin the national forests7 (324).


MUSYA expanded the express regulatory andmanagement authority of the Forest Service. MUSYAdirected the Forest Service to administer the nationalforests for “outdoor recreation, range, timber, wa-tershed, and wildlife and fish purposes. ” (For adiscussion of these purposes, see ch. 3.) MUSYAwas intended to be consistent with the 1897 OrganicAct, and thus reflects and perpetuates the utilitarianand protective visions embodied in the agency’straditions. In addition to recognizing principles ofmultiple use and sustained yield, MUSYA provideda clearer agency mission and established for the firsttime a statutory basis for the concept of integratedresource management. Nevertheless, MUSYA pro-vided general guidance for national forest manage-ment without providing any specific substantivedirection on how to balance the various resources ordetermine the appropriate mix of values generatedby the national forests.

Courts have consistently recognized that MUSYApreserves the agency’s already broad regulatoryauthority and wide discretion over the occupancy,use, and protection of the forests. The Ninth CircuitCourt of Appeals has held that the language of theMUSYA “breathe[s] discretion at every pore.”8

With MUSYA (and under the 1897 Organic Act),it was difficult to challenge Forest Service manage-ment decisions successfully. The Monongahelalawsuit successfully challenged long-standing For-est Service timber sale practices as violating specificrequirements in the Organic Act for selling timber.However, agency discretion over management di-rection and the mix of resources values werevirtually unchallengeable.

The National Environmental PolicyAct of 1969

NEPA significantly altered the Forest Service’splanning and management discretion. NEPA seeksto assure that all Federal agencies will incorporateenvironmental concerns into their decisionmakingProcesses.9 NEPA has been called ‘the first compre-hensive commitment of any modern state toward theresponsible custody of the environment” (39).

Section 102(2)(C) of NEPA specifically requiresthat all Federal agencies evaluate and prepare adetailed written statement on the environmentalimpact of all proposals “for legislation or othermajor Federal actions significantly affecting thequality of the human environment.” In 1978,pursuant to an Executive order from PresidentJimmy Carter, the Council on Environmental Qual-ity promulgated regulations (40 CFR 1500-1508)setting more specific standards and guidelines gov-erning the “NEPA process. ” The regulations guidewhen environmental impact analyses and statementsare required, direct that alternatives to the proposedaction be evaluated, and set forth general standardsfor those processes.

The U.S. Supreme Court has held that NEPA hastwo objectives: 1) to obligate agencies to considerthe environmental impacts of any proposed action,and 2) to require that the public be shown that the

4um-ted ~t~~~S v. Grirnaud, 220 Us. 506.522(1911).51111915, con-s granted the Forest Semice the authority to issue land use permits for ~ up to 80 acres and for terms of up to 30 years (Act

of Mar. 4, 1915, ch. 144 (38 Stat. 1101; 16 U.S.C. 493). Courts have recognized the agency’s authority to issue permits for larger land areas under thisact in conjunction with the 1897 Organic Act; see Wilson v. Block, 708 F. 2d 735 (D.C. Cir. 1983).

6McMichael v. United States, 355 F. ~ 283 (~ CU. 1%5).

THunt v. United States, 278 U.S. 96 (1~8)”

~pfl~”~ v. B~~la~, 608 F. u 8(JS (~ Ck. 1979). see also sierra Club v. Butz, 3 ELR 20, 292 (!M Cir. 1973); Hi-Ridge L@er co. v. UnitedStares, 443 F. 2d 452 (9th Cir 1971).

gsection 2 of MA specitles that the purposes of the aCt me: “To declare a national policy which will encourage productive and enjoyable harmonybetween man and his environment to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the healthand welfare of maw [and] to enrich the understanding of the ecological systems and natural resources important to the Nation . . .’

IOBa/timre Gas & Elecm”c Co. v. N~C, Iw, 4.62 U.S. at 97 (1982); Weinberger V. Catho[ic Action Of Hawaii, 454 U.S. 139, 143 (1982).


agency has considered an action’s environmentalconsequences.

10 The Court has also held that NEPAis a procedural rather than a substantive law, i.e., thatit does not mandate certain outcomes or decisions. Ifan agency fully complies with the law’s proceduralrequirements, the agency cannot be forced to modifyits decision based on likely environmental effects orto mitigate those environmental impacts.11 Theprocedural nature of NEPA has complicated itsimplementation, however, because the detailed NEPArequirements have largely evolved as “commonlaw” in the Federal courts. To ensure that planningand decisionmaking procedures comply with NEPAstandards, agencies must frequently consult anextensive and growing body of case law.

NEPA has had an extensive, though indirect,effect on national forest management. NEPA doesnot alter the Forest Service’s mission, nor specifi-cally narrow the agency’s management and regula-tory authority and discretion. It neither mandatescertain mixes or combinations of resource values,nor requires the agency to select the most environ-mentally sound alternatives to proposed actions.Nonetheless, the impact of the extensive and com-plex NEPA procedures on agency decisionmakingshould not be underestimated. NEPA has affectedForest Service planning and decisionmaking in twobasic ways, consistent with the objectives of the act:consideration of environmental impacts, and fullpublic disclosure.

The Forest Service has long considered thebalance among resource uses in its planning anddecisionmaking; MUSYA merely confined a long-standing Forest Service tradition of consideringresource tradeoffs. However, by requiring an assess-ment of environmental impacts, rather than just abalance among uses, NEPA added environmentalprotection (over and above the MUSYA requirementto maintain the productivity of the land) as aconsideration in national forest management. NEPAserved as a catalyst for the integrated planning andmanagement contemplated 10 years earlier by MUSYA(1, 324). Section 102(2)(a) of NEPA directs the useof an interdisciplinary approach in Federal planning

and decisionmaking. This direction (together withsimilar direction in NFMA) has changed the agency’sdecisionmaking processes at all levels, and hasprompted the agency to replace its traditionalresource planning with planning for coordinatedresource management (l). The requirements forinterdisciplinary planning have also brought a morediverse collection of professionals to the agency.

The other significant impact on Forest Serviceplanning and management is the full disclosurerequirement. In response to NEPA, the ForestService began to expand its public information andparticipation programs drastically (1, 231), and this,in turn, has meant closer public scrutiny. Further-more, the agency’s compliance with NEPA proce-dures are subject to closer judicial scrutiny than aredecisions under management guidance. In 1976, theU.S. Supreme Court noted that courts will take a“hard look’ at agency consideration of environ-mental impacts under NEPA, to assure that thedecisions are not arbitrary and capricious.12 Thus,through the closer public and judicial scrutiny ofagency decisionmaking, NEPA has effectively re-quired the Forest Service to keep a detailed andthorough record of its decisionmaking processes.

Finally, NEPA requires that environmental analy-ses be site-specific. This is difficult in forestplanning, because the plans do not set forth specificactivities and sites; such details are determined inproject (or implementation) planning. Nonetheless,forest plans are required to be consistent with NEPA.The Forest Service now views the environmentalimpact statement accompanying the plans as ‘‘pro-

grammatic," assessing the impacts of the programs(the plans). Site-specific environmental analysesconducted for specific projects are ‘‘tiered’ to theprogrammatic environmental impact analyses, with-out repeating the programmatic analyses.13 In partbecause programmatic analyses can be several yearsold, agencies must supplement them when signifi-cant new information becomes available. Thus,forest and project planning and NEPA analyses areparts of a ‘‘never-ending’ interactive process (1,280).

IOBaltimre Gas & E1ecrn’~ c~ ~, N~C, [nC., 462 U.S. at 97 (1982); Weinberger V. Catholic Action of Hawaii, 454 IJ.S. 139, 143 (1982).

llstTcker’~ Bay Neighborhood council, Inc. v. Karlen, 444 U.S. 223 (1980); Robertson V . hfethow valley citizens council, 19 ELR ZOT43 ~SFSmy 1, 1989).

lz~/eppa V. sierra Club, 427 U.S. 390 (1976).

Is~~ view ~s evolv~ over tie Pmt few Yws, and ~us my forest p~s and accompanying environmental statements may not fit thk description

of the intertwined forest and project planning and environmental analysis.


The Forest and Rangeland RenewableResources Planning Act of 1974

Congress enacted RPA to reassert its authorityover Forest Service planning and decisionmaking.RPA applies to all four branches of the agency—theNational Forest System, State and Private Forestry,Research, and International Forestry-and directsthe agency to develop a long-term strategic planningprocess (259). As part of this strategic planningprocess, RPA required land and resource manage-ment plans for units of the National Forest System.However, except for requiring a “systematic inter-disciplinary approach ‘‘ in developing these plans,RPA provided no substantive or procedural stand-ards and guidelines for their development, until itwas amended by NFMA in 1976.


NFMA established a complex series of proceduraland substantive requirements for developing thelong-term land and resource management plans(forest plans) required by RPA. Although NFMAneither modifies the principles of MUSYA nordirects any particular balance or mix of resourcevalues, the extensive planning requirements have ledsome to dub it the agency’s ‘‘new Organic Act’(324). By setting forth a host of procedural andsubstantive standards and guidelines for planningand implementation, NFMA significantly affectsForest Service management and to some extentnarrows the agency’s regulatory and managementdiscretion.

NFMA does not mandate specific output levels,determine the mix of values produced, or attempt toset priorities for resource managers. While embrac-ing MUSYA, NFMA provides more substance to theprinciples of multiple use and sustained yield, andconsequently offers additional guidance to theagency on forest planning. NFMA establishes aplanning process to set goals and objectives fornational forest management and to identify: 1)standards and guidelines for management, 2) pro-posed and possible activities, and 3) the necessaryfinancial resources.

NFMA serves three basic functions. First, itdirects the agency to prepare long-term integratedforest plans for each national forest, to be amendedor revised as needed, but revised at least every 15years. Next, it requires regulations establishingsubstantive standards and guidelines for timber

management and for the protection of water andother renewable resources. And finally, it expresslyprovides for active public involvement in the plan-ning process. The following discussion examinesthese functions, and discusses their implications formanagers.

Developing National Forest Plans

The forest planning process is comprised of threecomponents: development, approval, and imple-mentation. Section 6(f)(5) of NFMA directed theForest Service to attempt to complete the initialround of forest plans by September 30, 1985, and torevise each plan at least every 15 years. Whendeveloping forest plans, the agency is required toadhere to the principles of MUSYA and to follow theprocedural requirements of NEPA. NFMA embracesthe concept of integrated planning through interdis-ciplinary analysis; each national forest shall employan interdisciplinary planning team (section 6(f)(3))to use a “systematic interdisciplinary approach toachieve integrated consideration of physical, biolog-ical, economic, and other sciences’ (section 6(b)).Plans must be based on “inventory data on thevarious renewable resources’ of the forest (section6(g)(2)(B)). NFMA also directs that implementingregulations specify guidelines for forest plans toensure that plans achieve the goals of the RPAprogram (section 6(g)(3)).

Once a plan has been developed (with publicinvolvement), it must be approved by the regionalforester who, after reviewing the plan, must submita Record of Decision. If approved, the plan becomesfinal and implementation can begin. Under ForestService regulations (36 CFR 217), final forest plansare subject to administrative appeals—an additionaladministrative review initiated by members of thepublic. (See ch. 5.) Plans are also subject to legalchallenge, under the Administrative Procedures Act,since NFMA contains no specific provision forjudicial review of forest plans.

Forest plans are developed using the principles ofstrategic planning-setting direction, developingtargets for outputs and conditions, and establishingstandards and guidelines for implementation. (Seech. 3.) Plans are generally programmatic in nature;rather than making site-specific decisions on usesand outputs, plans set general goals and guidelines,which direct activities on the ground. Nonetheless,section 6(f)(2) of NFMA also requires the plans toreflect ‘‘proposed and possible actions, including


the planned timber sale program . . . necessary tofulfill the plan.” The plan does not make suchproject decisions, but does set goals and objectives,establish management standards and guidelines, andidentify management prescriptions (scheduled com-binations of activities for management areas), andsubsequent project decisions must be consistent withthe plan.

Until they are amended or revised, final forestplans are the primary guidance for Forest Serviceactions on the ground. NFMA provides that if anamendment would result in a‘‘signiilcant change, ’the agency must provide for public involvementcomparable to that allowed for plan development(section 6(f)(4)). Entire plans shall be revised whenthe agency finds that conditions on a forest ‘‘havesignificantly changed, ” but at least every 15 years(section 6(f)(5)). Whether such changes are “signifi-cant ‘‘ is to be determined at the discretion of theagency. Pursuant to NFMA, the Secretary of Agri-culture promulgated regulations in 1979 (revised in1982), which set forth specific procedures forresource inventorying and monitoring, and for plandevelopment and implementation. The Forest Serv-ice has begun the process of revising the planningregulations, with the ‘Advanced Notice of ProposedRulemaking" published in the Federal Register onFebruary 15, 1991.

Guidelines for Timber Management and forResource Protection

Although NFMA is primarily a procedural law, itdoes require regulations setting forth substantivestandards and guidelines. Most of the substantiverequirements apply to timber management practices,while the others generally provide guidance forprotecting water, plant, and animal resources. Manyof these provisions narrow the agency’s manage-ment discretion to various degrees.

Because NFMA was passed largely in response tolitigation over the agency’s timber managementpractices, it is no surprise that much of the law isfocused upon regulating those practices. NFMAincludes provisions that limit the location, methods,and amount of timber production that may take placewithin the national forests. NFMA requires regula-tions that specify that:

1. increases in harvest levels are based on intensi-fied management practices, only if such prac-tices can be done in accordance with MUSYA

2.

3.

4.

5.

6.

7.

and are successfully implemented (section6(g)(3)(D));timber harvesting is allowed only on thoselands where “soil, slope, or other watershedconditions will not be irreversibly damaged”(section 6(g)(3)(E)(i));timber harvesting is allowed only where thereis ‘assurance that such lands can be adequatelyrestocked within 5 years” (section 6(g)(3) (E)(ii));“protection is provided for streams, lakes,shorelines, and other wetlands from detrimen-tal changes” from timber harvesting (section6(g)(3) (E)(iii));the harvesting system ‘‘is not selected primar-ily because it will give the greatest dollar returnor the greatest unit output of timber’ (section6(g)(3) (E)(iv));clearcutting is used where “it is determined tobe the optimum method . . . to meet theobjectives and requirements of the relevantland management plan” (section 6(g)(3)(F)(i);and‘‘maximum size limits for areas to be cut in oneharvest operation” are established (section6(g)(3) (F)(iv).

NFMA also generally prohibits the sale of timberfrom lands identified as not suited for timberproduction and generally limits sales to sustainablelevels. Specifically, section 6(k) prohibits timberharvesting on lands identified as:

. . . not suited for timber production, consideringphysical, economic, and other pertinent factors to theextent feasible . . . except for salvage sales or salesnecessitated to protect other multiple-use values . . .

Section 14(a) directs the Secretary to:

. . . limit the sale of timber from each national forestto a quantity equal to or less than a quantity whichcan be removed from such forest annually inperpetuity on a sustained-yield basis . . .

The annual sale quantity is allowed to fluctuateabove and below the average for each decade. A plancan also depart from this ‘non-declining even flow’level of timber harvesting, if the departure is‘‘consistent with the multiple-use management ob-jectives . . . [and] made with public participation. ’

Many of the evaluations and determinationsadmittedly require the professional judgment ofagency personnel, and thus are substantially discre-tionary in nature. Nevertheless, these provisions


establish a mandatory framework for making deci-sions on timber harvesting, and consequently limitto some degree the traditional discretion of theagency to regulate and manage timber harvesting.

The various provisions that constrain timbermanagement were enacted to limit the impacts oftimber harvesting on other forest resources. Con-gress appeared especially concerned about the po-tential impacts of logging practices on water andfisheries. NFMA contains other provisions aimed atprotecting resources from impacts of timber harvest-ing, mineral development, recreation, and other useson forest resources. Section 6(g)(3)(B), for example,directs that forest plans should protect biologicaldiversity within the national forests. 14 Specifically,the regulations for forest planning should includeguidelines to:

. . . provide for diversity of plant and animalcommunities based on the suitability and capabilityof the specific land area in order to meet overallmultiple-use objectives . , .

Section 6(g)(3)(C) essentially requires researchand evaluation, through continuous monitoring andfield assessment of the effects of management, toensure that the productivity of the land is not sub-stantially and permanently impaired.

Public Involvement

The third basic function of NFMA is to providefor active public involvement. NFMA (in conjunc-tion with NEPA) seeks to assure that before proceed-ing with certain actions and programs, the agencyinforms and involves the public in decisionmaking.By opening up the agency’s decisionmaking proc-esses to closer public and congressional scrutiny,NFMA has increased agency accountability anddecreased discretion. (See ch. 5).

Implications for Managers

NFMA and the other direction-setting laws pro-vide guidance for establishing output and conditiontargets for the national forests and standards andguidelines for management with public participa-tion. In forest planning, the agency must consider

alternative approaches for managing the lands andresources, and must evaluate the potential site-specific and cumulative impacts of managementoptions. Failure to comply with NFMA procedurescan prevent the agency from proceeding with aparticular action. NEPA seeks to assure that environ-mental considerations become an integral part ofdecisionmaking, and NFMA adds the requirementthat actions be implemented in a manner that doesnot seriously impair the forest lands, resources, orproductivity.

The actual impacts of NFMA on Forest Servicemanagement discretion cannot be known precisely.While the law requires regulations constraining theuse of certain practices that might have significantadverse impacts, the determin ation of significance islargely a matter of agency discretion. In addition,courts remain relatively deferential to the agency’smanagement discretion under NFMA. In one exam-ple, the court acknowledged that soil erosion from aproposed road construction would have major con-sequences on the water of a nearby stream, butupheld the agency’s decision to proceed with theproject as planned, stating that, “[l]ike the MultipleUse, Sustained Yield Act [sic], the NFMA requiresthat national forest lands be managed with dueconsideration given to environmental values . . .Here, the balancing of competing values struck bythe Forest Service . . . was not so insensitive toenvironmental concerns that it violates the NFMA."15

Relatively few court decisions have interpretedagency discretion under NFMA since the initialforest plans have been completed. Thus, it may bepremature to speculate on the degree to which courtswill defer to agency management discretion in thefuture. However, the numerous procedural andsubstantive NFMA requirements for forest planningmake more agency decisions subject to administra-tive and judicial review. It is possible that theadministrative and judicial challenges to agencyplans and decisions will be unprecedented. Theprecise impacts of the threat of appeals and litigationon agency decisionmakers is unknown, but it isindisputable that increased accountability under

14~e [em “biologic~ diversity’ hasb~omerelatively Commonsince theemctmentof NFMA, and often encompasses diversity at a variety of levels,such as genetic diversity, species diversity, and ecosystem diversity. NFMA’s term---d‘versity of plant and animal communities-is akin to ecosystemdiversity for the natiorud forests. The regulations go further, su~esting species diversity by requiring that “fish and wildlife habitat shall be managedto maintain viable populations of existing native and desired non-native vertebrate species” (36 CFR 219.19). In this report, biological diversity innational forest mamgement is used as a synonym for the diversity of plant and animal communities.

ISNo~hWe~~l~ian ccmre~ Prorecrive A~$ociafion v. Peterson, 565 F. Supp. 586, 606 @.D. Cal. 1983), modified, 764 F.2d 581 (9th Cir. 1985),rev’d in part sub nom, Lyng v. Northwest Indian Cemetary Protective Association, 485 U.S. 439 (1988).


NEPA and NFMA has lead to a greater emphasis on or site protection laws affecting Forest Servicedocumenting decisions.

ADDITIONAL LEGALCONSTRAINTS ON THE

FOREST SERVICEThe laws examined above set out the general

planning and management framework for the ForestService. Most of these laws are procedural in natureand provide only general guidance to the agency onhow to balance resource management. In addition tothese laws, numerous statutes not specifically writ-ten for the national forests circumscribe forestplanning and management. The purposes of theselaws are typically to protect particular resources orsites, and thus the laws frequently impose substan-tive constraints or limitations on activities. (See box4-A.) This section describes the four major resource

management. 16

The Wilderness Act

The Wilderness Act, enacted in 1964, maybe themost law most restrictive to Forest Service manage-ment discretion, because it prohibits or restrictsvarious uses in particular areas of the nationalforests. The purpose of the act is to preserve naturalareas for recreation and other purposes. Lands areincluded in the National Wilderness PreservationSystem by act of Congress from those Federal landswhere:

. . . the earth and its community of life are untram-meled by man, where man himself is a visitor whodoes not remain. An area of. . . undeveloped Federalland retaining its primeval character and influence,without permanent improvements or human habita-

]~ ~o~ forests ~ont~ o~y N. systas of sw~ ~mgement ~~ — tie Natio~ Wildern=s Preservation System and the National Wildand Scenic Rivers System. The national forests also contain numerous other special management areas, typically designated by Congress individuallyand with ptiCUkiI management guidance for each area. For more on these areas, see Special Management Areas in the National Forest System (296).

Chapter 4--The Legal Framework for Forest Planning and Management ● 67

tion, which is protected and managed so as topreserve its natural conditions (section 2(c)).

Congress did not view designated wildernessareas within national forests as conflicting with thegeneral direction for national forest management.Section 4(a)(1) of the Wilderness Act specificallystates that:

. . . [n]othing in this Act shall be deemed to be ininterference with the purpose for which the nationalforests are established as set forth in the Act of June4, 1897 [the Forest Service Organic Act], and theMultiple-Use Sustained-Yield Act of 1960.

Despite such statements, the Wilderness Acteffectively limits Forest Service discretion for man-aging designated wilderness areas within the na-tional forests. Section 4(b) states that:

. . . each agency administering any area designatedas wilderness shall be responsible for preserving thewilderness character of the area and . . . wildernessareas shall be devoted to the public purposes ofrecreational, scenic, scientific, educational, conser-vation, and historical uses.

To achieve these purposes, section 4(c) expresslyprohibits commercial enterprise, permanent or tem-porary roads, motorized and mechanical transport,and structures and installations in wilderness areas,except for existing private rights and minimumadministrative requirements. However, the Wilder-ness Act also provides numerous exemptions tothese restrictions:

1.

2.

3.

4.

motorboat and aircraft access “may be permit-ted to continue, ’ where such use existed priorto designation (section 4(d)(l));measures may be taken for ‘‘the control of fire,insects, and diseases” (section 4(d)(l));mineral prospecting and information gatheringon other resources is permitted ‘if such activityis carried on in a manner compatible with thepreservation of the wilderness environment”(section 4(d)(2));activities under valid existing mineral rights(which could be established on or beforeDecember 31, 1983) ‘‘necessary in exploring,drilling, producing, mining, and processingoperations’ are permitted, ‘‘subject to suchreasonable regulations governing ingress andegress as maybe prescribed” (section 4(d)(3));

5. the President may authorize water and powerprojects, and associated activities, “needed inthe public interest” (section 4(d)(4)(l));

6. livestock grazing ‘‘shall be permitted to con-tinue subject to such reasonable regulations asare deemed necessary’ (section 4(d)(4)(2));and

7. “commercial services may be performed . . .for activities which are proper for realizing therecreational or other wilderness purposes of theareas” (section 4(d)(6)).

In addition, many of the subsequent statutesadding areas to the National Wilderness Preserva-tion System have established similar exceptions forparticular sites and activities, typically to permitexisting uses to continue after the areas have beendesignated.

Nonetheless, the Wilderness Act clearly limitsagency activities in planning and managing thedesignated areas. (See box 4-B.) Despite the numer-ous exemptions from the general restrictions, certainuses—most notably timber harvesting and devel-oped recreation—are prohibited in wilderness areas.Furthermore, even for the exemptions, the agency isrestricted as to the location and extent of permissibleactivities. Thus, the Wilderness Act significantlynarrows Forest Service management discretion, andlimits choices available in national forest planningfor designated areas.

The Wild and Scenic Rivers Act of 1968

The Wild and Scenic Rivers Act of 1968 isintended to preserve and protect the unique values ofcertain rivers and their surrounding lands. Specifi-cally, section l(b) of the act directs that selectedrivers with ‘‘outstandingly remarkable scenic, rec-reation, geologic, fish and wildlife, historic, cultural,or other similar values, be preserved in free-flowingcondition, and that they and their immediate envi-ronments shall be protected for the benefits andenjoyment of present and future generations. ’ Theact requires agencies (including the Forest Service)to report to the President on the suitability ornonsuitability of rivers within their jurisdiction foraddition to the National Wild and Scenic RiversSystem, and the President makes recommendationsto Congress. Congress then designates components


ITIW porest service had administratively created a system of wildeme% VVML ti ptitive m ~ in 1924. The WildernessAct established the National Wilderness Preservation System with the existing 9.1 million ams of administratively designated wilderness andwild areas, and direeted the evaluation of wilderness suitability of the primitive areas.

2Cafifirniav.Bergland,483F. Supp. 46S @.D.Cal. 1980), afdinparf, rev’dinpart, Ctdiforniav.Block, 690F. 2d753 (91hCir. 1982).3Akernativeversions would baveprohibited sub-nwim Of d~

- d~elwm~t of deasd ~.suitability, forever or until a speeified date, and may have

of the System, based on, but not limited to, agency around the selected river (within the limits specifiedand Presidential recommendations.17 in the act), and to develop a management plan for

protecting the area. In particular, section 10 specifies

The Wild and Scenic Rivers Act establishes that:

guidelines for managing the lands surrounding (a) Each component of the national wild anddesignated rivers. The agency charged with admini- scenic rivers system shall be administered in suchstering the river is directed to establish boundaries reamer as to protect and enhance the values which

17~ ~n~t t. he Natio~ Wilderness ~eservation system where ody Congress can designate areas, State legislatures can designate dditiOnS tOthe National Wild and Scenic Rivers Systeu with the approval of the U.S. Secretary of the Interior.


caused it to be included in said system without, such areas . . . as may be necessary to protect suchinsofar as is consistent therewith, limiting other uses rivers in accordance with the purposes of this Act. . .that do not substantially interfere with public use and Particular attention shall be given to scheduledenjoyment of these values. In such administration timber harvesting, road construction, and similarprimary emphasis shall be given to protecting its activities which might be contrary to the purposes ofesthetic, scenic, historic, archaeological, and scien- this Act.tific features. Management plans for any suchcomponent may establish varying degrees of inten- In contrast to the Wilderness Act, the Wild and

sity for its protection and development, based on the Scenic Rivers Act is neither prescriptive nor pro-special attributes of the area. scriptive; rather it allows the Forest Service to

determine what management goals and activities areSection 12(a) then adds that each agency: consistent with the purposes of the act. Nonetheless,

shall take such action respecting management the act does emphasize management for esthetic,0..policies, regulations, contracts, [and] plans, affecting scenic, historic, archaeological, and scientific val-


ues, and requires protecting and enhancing thevalues that led to the river being designated.Consequently, Forest Service discretion in planningfor the management of these areas is narrowedsignificantly.

The Clean Water Act

Congress established stricter standards for pro-tecting the Nation’s water resources in 1972 when itrevised the Federal Water Pollution Control Act,also known as the Clean Water Act.18 The purposeof the Clean Water Act is to enhance water qualityby imposing limitations on sources of pollution. Theact allows States to set their own water qualitystandards, equal to or more restrictive than theFederal standards, and requires Federal agencies tocomply with the State standards.

The Clean Water Act provisions having thegreatest impact on Forest Service management arethose regulating nonpoint source pollution. Unlikepoint source pollution, which originates from adiscrete, identifiable source such as a ditch or pipe,nonpoint source pollution refers to pollution origi-nating over a widespread land area, such as fromagricultural, mining, or silvicultural activities. Na-tional forest activities that might generate nonpointsource pollution include, but are not limited to,timber harvesting, livestock grazing, off-road vehi-cle use, and road and trail construction and mainte-nance.

The Clean Water Act was amended in the WaterQuality Act of 198719 to require the States to developstandards for regulating nonpoint source pollution.When combined with the requirement for Federalagencies to comply with State water quality stand-ards, the State standards for nonpoint source pollu-tion become a critical consideration for the ForestService (6). While NEPA only requires the ForestService to evaluate and consider the impacts ofmanagement activities on watersheds and waterquality, the Clean Water Act prohibits the agencyfrom engaging in activities that would cause impactsin excess of Federal or State water quality standards.Thus, Federal and State water quality laws impose

substantive, enforceable limits on national forestmanagement—the State water quality standardsrepresent a minimum level of protection, which theForest Service must observe. Consequently, in forestplanning, the Forest Service is not allowed thediscretion simply to weigh the impacts on waterquality against the anticipated benefits from aparticular use.

The Forest Service has attempted to meet Statewater quality standards by requiring forest plans toinclude Best Management Practices (BMPs) forprotecting water quality. However, courts have ruledthat, even when the U.S. Environmental ProtectionAgency and the relevant State agency approve theBMPs, the use of BMPs does not guarantee compli-ance with State water quality standards .20 BMPs areonly a means to achieve those standards, not areplacement for the standards (6, 7). The ForestService must not only plan to use BMPs, but mustalso show that their practices comply with Statewater quality standards. Thus, the Clean Water Actsubstantially narrows agency discretion.

The Endangered Species Act of 1973

The Endangered Species Act of 1973 (ESA) isanother environmental protection law with poten-tially serious implications for forest planning andmanagement. As is apparent in the current contro-versies over the northern spotted owl in the PacificNorthwest and the red-cockaded woodpecker in theSoutheast, the designation of a plant or animalspecies as threatened or endangered under ESA canalter Forest Service planning considerations andmanagement discretion.

ESA recognizes that various species of fish,wildlife, and plants “have been so depleted innumbers that they are in danger of or threatened withextinction” (section 2(a)(2)), but they are of “es-thetic, ecological, educational, historical, recrea-tional, and scientific value” (section 2(a)(3)). Thepurposes of the act are to provide: 1) a mechanismfor conserving ‘‘the ecosystems upon which endan-gered species or threatened species depend,’ and 2)a program for conserving those species (section

18~e Feder~ water pollution con~ol fit had b~n erected ~ 194* (~t of J~e 30, 19@, Ch. 75* (62 stat. 1155)) and amended numerous timeSprior to its complete revision in the Federal Water Poilution Control Aet Amendments of 1972. This revision was subsequently amended in the CleanWater Act of 1977, and the combination is commonly referred to as the Clean Water Act.

lg~t of Feb. 4, 1987, public IAW 100-4 (101 Stat. 7; 33 U.S.C. 1251 et Sq.).

2flNorfhweSt/~ia~ cemereVprofectiVe ASS~~i~fion v, Peterson, s(js F.supp. 586,606 @J.D.c~. 19s3), mdified, 764 F.2d 581 (9th CiS. 1985), rev’din part sub nom. Lyng v. Northwest Indian Cemetary Protective Association, 485 U.S. 439 (1988).

Chapter 4-The Legal Framework for Forest Planning and Management . 71

2(b)). ESA also defines conserving the species asbringing “any endangered species or threatenedspecies to the point at which the measures providedpursuant to this act are no longer necessary’ (section3(3)). Thus, for ESA, conservation is synonymouswith recovery of the species.

ESA is administered by the U.S. Fish and WildlifeService (USFWS) and the National Marine FisheriesService (NMFS). Section 4(a)(1) of the act requiresUSFWS and NMFS to determine if species arethreatened or endangered by: 1) destruction ormodification of habitat, 2) overutilization, 3) diseaseor predation, 4) inadequate regulatory mechanisms,or 5) other natural or human factors. The determina-tion is to be based ‘‘solely on the best scientific andcommercial data available” (section 4(b)(l)(A)).Congress gave specific directions not to includeeconomic effects in determin ing if species arethreatened or endangered; the report on the 1982ESA amendments from the House Committee onMerchant Marine and Fisheries states:

The addition of the word “solely” is intended toremove from the process of the listing or delisting ofspecies any factor not related to the biological statusof the species. The Committee strongly believes thateconomic considerations have no relevance to deter-minations regarding the status of species and intendsthat economic analysis requirements . . . not apply(258).

Section 4(a)(3)(A) requires the designation of“any habitat of such species which is then consid-ered to be critical habitat. Critical habitat is also tobe based on the best scientific data available, but incontrast to the listing decision, the USFWS orNMFS is to consider ‘the economic impact, and anyother relevant impact, of specifying any particulararea as critical habitat” (section 4(b)(2)).

ESA establishes three considerations of endan-gered or threatened species for national forestplanning and management. First, a recovery plan isto be developed for endangered and threatenedspecies (section 4(f)), focusing on species that‘‘conflict with construction or other developmentalprojects or other forms of economic activity. ” Theservices of ‘appropriate public and private agenciesand institutions, and other qualified individuals’ areto be procured, but recovery teams are exempt fromthe Federal Advisory Committee Act (FACA).When national forest lands are involved, ForestService employees are likely to be included in

recovery planning teams, and thus, recovery plansand national forest planning can be coordinated.

The second ESA consideration in forest planning,in section 9 of the act, is a prohibition on the“taking” of any species which has been designatedas endangered. “Taking” is defined to mean “toharass, harm, pursue, hunt, shoot, wound, kill, trap,capture, or collect, or to attempt to engage in anysuch conduct” (section 3(18)). Section 10 definesconditions under which the taking of an endangeredspecies would be permitted.

Finally, section 7(a)(2) of ESA directly affectsFederal agency actions by specifying that:

Each Federal agency shall, in consultation withand with the assistance of the Secretary [of Interiorand of Commerce], insure that any action authorized,funded, or carried out by such agency. . . is not likelyto jeopardize the continued existence of any endan-gered species or threatened species or result in thedestruction or adverse modification of [critical]habitat . . .

Following the consultation, the Secretary is toissue an opinion on whether the actions willjeopardize the endangered or threatened species orwill adversely modify the designated critical habitat.If jeopardy or adverse modification is identified, theSecretary must then suggest a reasonable alternativefor achieving the results without jeopardizing thespecies or adversely modifying its critical habitat.Specifically, section 7(b)(3)(A) states that:

Promptly after conclusion of the consultation , . . .the Secretary shall provide . . . a written statementsetting forth the Secretary’s opinion, and a summaryof the information on which the opinion is based,detailing how the agency action affects the species orits critical habitat. If jeopardy or adverse modifica-tion is found, the Secretary shall suggest . . .reasonable and prudent alternatives . . .

The Endangered Species Act could have seriousimplications for Forest Service management andplanning. Recovery plans can affect national forestplans, since NFMA requires forest plans to be‘‘coordinated with the land and resource manage-ment planning processes of . . . other Federal agen-cies” (section 6(a)). Furthermore, any action thatconstitutes a‘ ‘taking’ under ESA is strictly prohib-ited. Finally, the Forest Service is required to consultwith the Fish and Wildlife Service on plans andactivities that might jeopardize threatened or endan-gered species or that might adversely modify critical


habitat. Because of the programmatic and strategicnature of forest planning, it is virtually impossible todetermine in advance whether particular manage-ment activities under the plan will lead to a findingof jeopardy or adverse modification. Thus, thesection 7 consultation process is an ongoing one. Tothe extent that national forest plans and activitiesconflict with ESA’s requirements, amendmentsand/or revisions to the plans may be necessary.

SUMMARY AND CONCLUSIONSThe legal framework for national forest planning

and management consists of two types of laws:direction-setting laws and protection-standards laws.The direction-setting laws include the 1897 ForestService Organic Act, the Multiple-Use Sustained-Yield Act of 1960, the Forest and RangelandRenewable Resources Planning Act of 1974, and theNational Forest Management Act of 1976. Theselaws essentially create an open planning processthrough which values are balanced and tradeoffs areevaluated in national forest management. The Na-tional Environmental Policy Act of 1969 augmentsthese direction-setting laws by requiring the ForestService to consider environmental impacts and toshow the public how those impacts were considered.

The protection-standards laws typically apply tomuch more than just the Forest Service, andestablish standards for protecting particular re-sources or sites. Some of the most important ones fornational forest planning and management includethe Wilderness Act, the Wild and Scenic Rivers Actof 1968, the Clean Water Act, and the EndangeredSpecies Act of 1973. These statutes differ from thedirection-setting laws, because they are not prem-ised on balancing resource values, but on main-taining minimum standards for resource or siteprotection. Furthermore, these laws were passed atdifferent times over the past few decades, and servedifferent, sometimes overlapping or even contradic-tory, purposes. Nonetheless, because these lawsestablish specific standards or restrictions, the ForestService must comply with their legal requirements.

The complex web of laws, some requiring abalancing of values and others establishing stand-ards or restrictions, has raised two concerns. Thefrost, articulated by Forest Service Chief DaleRobertson, is that the numerous compounding andpossibly conflicting requirements make nationalforest planning and management an exceedingly

complicated task. At the extreme, the sum total ofthe various protection standards and restrictions maymake any on-the-ground management actions in-feasible.

To date, the “cumulative impact” of the variouslaws on Forest Service management has not beenextensively analyzed, nor is it known whether thecollective purposes of these laws can be realisticallyachieved while maintaining historic levels of national forest uses and outputs. However, such legalanalyses are beyond the scope of this study. Con-gress could consider commissioning such analysesby an independent organization with the necessarylegal expertise. Congress could even consider modi-fying the protection-standards laws for nationalforest management, to allow the goals of these lawsto be balanced with other values in national forestplanning. Again, however, analyzing the implica-tions of such an option is beyond the scope of thisstudy and of OTA’s mandate.

The second concern is that the complexity of thelegal framework, and especially of the process lawssuch as NFMA and NEPA, lead agency managers tofocus on "bomb-proofing" their management plans.Planning must follow correct procedures and bethoroughly documented, and decisions must beconsistent—regardless of the validity, appropriate-ness, or acceptability of the plans and decisions—because proper procedure, documentation, and con-sistency are necessary to demonstrate that thedecisions are not arbitrary and capricious (16).

This concern is predicated on two assumptions.The first is that the judicial system examines onlywhether the agency has followed the letter of thelaw. When agencies are sued, the courts do rule onwhether agencies have fulfilled their legal require-ments, especially for laws with specific standards orconstraints. For example, the Forest Service mustmeet State water quality standards, and it mustconsult with the Fish and Wildlife Service (orNMFS) when its actions might affect an endangeredspecies. However, courts also grant substantialdeference to an agency when the laws grant discre-tion to the agency. For example, the Forest Servicemust consider the relative values of the variousresources, and must consider physical and economicfactors in identifying lands not suited for timberproduction. For forest planning, the Forest Serviceshould identify the legal requirements that must be


fulfilled, prior to considering alternative manage-ment direction for the national forests.

The second assumption underlying the perceivedneed for bomb-proofing is that various interests willsue if their desires are not met in forest planning.However, this assumption is inaccurate, in tworespects. First, the Forest Service is facing relativelyfew lawsuits. In fiscal year 1989, only 11 ofapproximately 500 forest plan appeals and only 32of 525,000 timber sales were litigated (300). (See ch.

5.) Second, and more importantly, people typicallysue only if they believe the agency is being arbitraryor unfair. Such beliefs can generally be overcomethrough an open, honest exchange of desires andconcerns among the agency and the various inter-ested and affected individuals and groups, leading tounderstanding and acceptance of the possibilitiesand limitations for managing the national forests.This is the purpose behind NFMA’s requirement forpublic participation in national forest planning.

Chapter 5

Public Involvementin Forest Planning

ContentsPage

public Participation in Forest Service Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ’77Legal Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77Forest Service Efforts in Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81Reducing Conflict Through Cooperation and Collaboration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

Administrative Appeals and Litigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .95Administrative Appeals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . 95Litigation of Plans and Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99

State, Tribal, and Local Government Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .State Legal Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Cooperation With Other Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Local Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Appeals and Litigation . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .State and Local Government Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Box

101101102103103104105105

Box Page

5-A. Opportunities and Limitations With Alternative Dispute Resolution . . . . . . . . . . . . . . . . . . . 92

—. . —.

Chapter

—

5

Public Involvement in Forest Planning

The National Forest Management Act of 1976(NFMA) established a more direct and substantialrole for the public in forest planning than hadpreviously existed. Its public participation require-ments complemented those already in place underthe National Environmental Policy Act of 1969(NEPA). Congress assumed that a more participa-tory planning process would lead to better, moreacceptable management of the national forests, andthat early and continual public involvement couldhelp the agency resolve controversies in a moreorganized and timely fashion.

Despite NFMA, many conflicts and controversiesover the management of the national forests remain.In October 1989, the Senate Committees on Agricul-ture, Nutrition, and Forestry and on Energy andNatural Resources convened a joint oversight hear-ing to review the planning process under NFMA.Several senators expressed frustration over thecontinuing controversies, and concern that manywere being resolved outside of the planning process—in annual appropriations or in administrative appealsor litigation. In his introductory remarks, SenatorPatrick Leahy (Vermont) stated:

I have been very concerned with the process inwhich forest controversies in the Northwest arebeing resolved; not in the planning process; not inthe courts, but through the appropriations process bymeans of limiting judicial review (143).

Senators Mark Hatfield (Oregon) and JamesMcClure (Idaho) concluded that the planning proc-ess had ‘‘broken down. ’ Prescriptions for reformingthe current system vary widely, but the problem iscommonly attributed to Forest Service failure toinvolve the public effectively in forest planning.

The legal and regulatory framework for publicparticipation in forest planning is designed toencourage public involvement in three generalstages of the process: 1) in plan development,review, and implementation; 2) through requests foradministrative review of plans and decisions; and3) through judicial review. In addition, NFMAinstructs the agency to coordinate its planningprocess with those of other Federal agencies andState, tribal, and local governments. Taken together,these charnels for public participation are intended

to expand and elevate the public’s historic role inForest Service decisionmaking and to assure thatpublic values, needs, and desires are reflected inforest plans.

This chapter will ex amine public involvement inforest planning at the stages referred to above. Thefirst part examines public participation at the plandevelopment and implementation stage. Specifi-cally, it discusses the legal framework for publicparticipation and Forest Service efforts to integratethe public in its decisionmaking. It also addresseswhy those efforts seem inadequate, and reviewsalternative approaches to public involvement inForest Service decisionmaking. The second partdiscusses the role that administrative appeals play inthe planning process, and analyzes current issuesand concerns surrounding the use of the appealssystem. It also discusses the role of the judiciary inforest planning, and specifically addresses issues ofjudicial review. Finally, the third part of the chapterexamines the additional requirements for coordinat-ing Forest Service planning with other governmentactivities.

PUBLIC PARTICIPATION INFOREST SERVICE PLANNING

Legal Requirements

Forest Service land and resource planning andmanagement is guided primarily by three laws: theMultiple-Use Sustained-Yield Act of 1960 (MUSYA),NEPA, and NFMA. (See ch. 4 for a more thoroughdiscussion of the legal framework for Forest Serviceplanning and management.) Taken together, thesestatutes provide both a conceptual basis and a firmlegal mandate for public involvement in the forestplanning process. Common among these laws is theimplicit recognition that planning and managingpublic resources is not solely a function of technicalexpertise and scientific decisionmaking. It is inher-ently a subjective process, dominated by social,political, and cultural questions (49, 51, 330). (Seealso ch. 3.) The Forest Service must involve theinterested publics in a meaningful way, if theresulting plans are to respond to changing publicneeds and values (3, 49, 51, 231, 330).

-77–



The passage of MUSYA in 1960 and severalFederal statutes in the 1970s significantly opened upadministrative agency procedures to closer publicscrutiny and more active public involvement. UnderMUSYA, the Forest Service retained primary au-thority and significant discretion over the manage-ment of the forest resources. Nevertheless, byexpanding the number of public resources overwhich the agency had express management andregulatory authority, the act provided a strongerconceptual basis for agency responsiveness to plu-ralistic, public values than had previously existed.

MUSYA directs that, in managing the nationalforests, the Forest Service shall give “due consider-ation . . . to the relative values of the variousresources, and shall assure that resources are‘‘utilized in the combination that will best meet theneeds of the American people. ” As discussed inchapter 3, the act embraced the concept that thepublic’s interest is best served by managing thenational forests for many values. However, the actprovided only the most general guidance to agencymanagers as to how to do this. (See ch. 4.)

MUSYA provided a theoretical framework forpublic participation by focusing agency attention onmultiple resource management. This mandateplaced the agency in a more visible position ofweighing and balancing resource values and usesand of reconciling conflicts. And because planningand management decisions were supposed to beguided by the ‘‘needs of the American people, ’MUSYA began a trend toward external, as opposedto bureaucratic, standards of accountability (231).However, it did not provide the general public withany legal right to participate in forest planning.

The National Environmental Policy Act of 1969

Throughout its history, the Forest Service hadsolicited public input into its decisionmaking proc-esses, but often informally and infrequently (208).With the enactment of NEPA in 1970, the agencywas expressly required to establish procedures forpublic involvement in planning and management.

Congress enacted NEPA at a time when the publicwas demanding more access to administrative deci-sionmaking. NEPA requires Federal agencies toassess the environmental effects of any proposedmajor Federal action that would significantly affectthe human environment. NEPA emphasizes “full

disclosure’ of agency decisions—findings fromenvironmental assessments and impact statements.An examination of alternatives to the proposedaction, and comments from reviewing State andFederal agencies, must also be made available to thepublic.

NEPA does not provide standards and guidelinesfor public involvement, nor does it specify thatpublic meetings must be convened. It treats thepublic principally as a recipient of information,rather than a participant in decisionmaking (231).Under the law as written, Federal agencies have aduty to make environmental impact statementsavailable for review, but are not required to solicitfeedback from the public.

Nonetheless, public awareness of potential envi-ronmental consequences of proposed programs oractions makes agencies more accountable to publicconcerns and more sensitive to the environment(231). President Richard Nixon made it clear thatFederal agencies were to actively seek public viewsbefore making final decisions. His Executive orderto implement NEPA directed agencies to:

Develop procedures to ensure the fullest practica-ble provision of timely public information andunderstanding of Federal plans and programs withenvironmental impact in order to obtain the views ofinterested parties. These procedures shall include,whenever appropriate, provision for public hearings,and shall provide the public with relevant informa-tion, including information on alternative courses ofaction (183) (emphasis added).

President Nixon had instructed the Council onEnvironmental Quality (CEQ) to issue guidelines toFederal agencies for preparing Environmental Im-pact Statements rather than regulations. Regulationsto implement NEPA were subsequently issued underPresident Carter in 1978. These regulations provideclearer guidance to agencies on the purpose of publicinvolvement, and give the public a more participa-tory, consultative role than the vague “inform andeducate’ language of the law had done. Theregulations provide that:

Federal agencies shall to the fullest extent possi-ble. . . [encourage and facilitate public involvementin decisions which affect the quality of the humanenvironment (40 CFR 1500.2(d)).

Agencies shall (40 CFR 1506.6):(a) Make diligent efforts to involve the public in

preparing and implementing their NEPA procedures.

——

Chapter 5-Public Involvement in Forest Planning ● 79

(b) Provide public notice of NEPA-related hear-ings, public meetings, and the availability of envi-ronmental documents . . .

(c) Hold or sponsor public hearings or publicmeetings whenever appropriate . . .

(d) Solicit appropriate information from the public. . .

(e) Explain . . . where interested persons can getinformation or status reports on environmentalimpact statements . . . and

(f) Make environmental impact statements, thecomments received, and any underlying documentsavailable to the public . . .

under the regulations, agencies are thus responsiblefor involving the public in decisions affecting thehuman environment.

NEPA regulations also direct a process to facili-tate decisionmaking, not to justify predetermineddecisions. “NEPA procedures must insure thatenvironmental information is available to publicofficials and citizens before decisions are made andbefore actions are taken” (40 CFR 1500. l(b))(emphasis added). The regulations also require thatagencies solicit public input early in planning anddecisionmaking through ‘‘ scoping’ ‘—’ ‘an early andopen process for determining the scope of issues tobe addressed and for identifying the significantissues related to a proposed action’ (40 CFR1501 .7). Furthermore, NEPA regulations direct agen-cies to ‘ ‘integrate the NEPA process with otherplanning at the earliest possible time to insure thatplanning and decisions reflect environmental values,to avoid delays later in the process, and to head offpotential conflicts” (40 CFR 1501.2).

While the regulations set forth clearer guidance toagencies on why to involve the public in planningand decisionmaking, standards for public participa-tion in forest planning are evolving largely throughcase law. (See ch. 4.) Courts have provided someguidance as to NEPA’s public participation require-ments. In California v. Block,l the court noted that:1) the Forest Service was required to present a broadrange of alternatives to allow full public participa-tion in decisionmaking, and 2) information from thepublic was not only to be collected, but was also tobe considered in decisionmaking (92). Nonetheless,two important questions regarding public participa-

tion in forest planning under NEPA remain largelyunanswered:

1. What is the role of the public (vis-a-vis agencyresponsibility) in Forest Service decisionmak-ing?

2. How must the Forest Service demonstrate itsresponse to public comments in its final forestplans and decisions?


With the passage of NFMA in 1976, Congressreinforced the public’s right to participate in ForestService planning and decisionmaking. Enactment ofthe law was largely triggered by the Monongaheladecision2 and other court decisions that threatened tohalt certain timber harvesting practices in thenational forests. (See ch. 3.) However, the contro-versy in the Monongahela National Forest of WestVirginia was not unique, but rather an indication ofwidespread public dissatisfaction with Forest Serv-ice Management practices (80). Lawsuits were filedin Alaska, Texas, and several other States. Disputesabout management of the Bitterroot National Forestin Montana led Congress to commission an inde-pendent evaluation of Forest Service practices (264).

The Monongahela and Bitterroot controversiesinvolved not only the legitimacy of timber manage-ment practices under the 1897 Forest ServiceOrganic Act, but also questioned the agency’sinterpretation of its multiple-use and sustained-yieldmandates. The uproar over clearcutting was ‘‘but thefocal point for groups with a broad range of interestsin reforming national forest management’ (80).These conflicts demonstrated public perceptions ofthe agency as insensitive to nontimber values, andpublic demands for greater agency accountability inupholding its multiple-use mandate.

NFMA embraces the notion set forth in the NEPAregulations—that many conflicts can be reconciledby integrating the public into the decisionmakingprocess early and continuously. Upon submitting theconference report on NFMA to the Senate, HubertHumphrey, the chief sponsor of the bill, character-ized the public as ‘‘advisers’ to agency planners anddecisionmakers:

Icul@TnlQ v. BqIIufl~, 483 F.supp, 465 (E. D.Cal. 1980), aff d in Part, re~”d in Part, ca[if~rni~ Block, 690 F.2d 753 (9th Cir. 1982).

‘West Virginia Di)’ision of the Izaak Walton League, Inc. v. Butz, 367 F. Supp. 422; 522 F. 2d 945 (4th Cir. 1975).


This is an act that assures that our public forestsare managed with advice from the several publics,and managed in a framework that makes ecologicaland environmental sense . . .

It creates the policy machinery for making certainthat professional expertise and public desires arebrought together in the public interest (120).

President Gerald Ford echoed the Senator’s remarks:“Emphasis throughout the act is on a balancedconsideration of all resources in the land manage-ment process. Of equal importance, this act guaran-tees the full opportunity to participate in NationalForest land and resource planning” (87).

NFMA directs the Secretary of Agriculture topromulgate regulations specifying procedures toensure that forest plans are developed in accordancewith NEPA, although such regulations have neverbeen promulgated. The conference report on NFMAemphasized that the purpose of this provision wasnot to amend or mod@ NEPA, but to assure“uniform guidance . . . as to what constitutes amajor Federal action for which an environmentalimpact statement is required” (266).

In addition, rather than just referring to NEPA forguidance on public participation, section 6(d) ofNFMA specifically requires public participation ‘inthe development, review, and revision” of forestplans. This provision directs the Secretary at least tomake the documents available at convenient loca-tions and to “hold public meetings or comparableprocesses . . . that foster public participation in thereview of such plans or revisions. ’ Furthermore,Congress conferred an additional opportunity for thepublic to influence the regulations implementingNFMA in section 6(h), by providing for advice andcounsel from an independent committee of scientists“to assure that an effective interdisciplinary ap-proach is proposed and adopted. ”

Finally, section 14 authorizes and encourages theuse of advisory boards in planning and managing thenational forests. Section 14(b) specifies:

In providing for public participation in the plan-ning for and management of the National ForestSystem, the Secretary. . . shall establish and consultsuch advisory boards as he deems necessary tosecure full information and advice on the executionof his responsibilities. The membership of suchboards shall be representative of a cross section ofgroups interested in the planning for and manage-

ment of the National Forests System and the varioustypes of use and enjoyment of the lands thereof.

Despite such direction, the Forest Service has notused any formally designated advisory boards fornational forest planning or management since thelate 1970s. In one case, the White MountainNational Forest in New Hampshire, an existingadvisory board that was officially disbanded in thelate 1970s has continued meeting without explicitForest Service coordination and assistance as an AdHoc Advisory Committee. The Forest Service hasstated that the requirement to conform with theFederal Advisory Committee Act (FACA) inhibitstheir use of advisory boards, but how and whyFACA inhibits advisory board use has not beenexplained or demonstrated.

Taken together, these several sections of NFMAproject the public as an integral component of forestplanning and implementation. While the law pre-serves agency decisionmaking authority, it casts thepublic in the role of advisers and consultants to theplanning and decisionmaking processes.

NFMA Regulations

In the fall of 1979, the Secretary of Agriculturepromulgated regulations to govern the implementa-tion of NFMA. These regulations provide substan-tial guidance on public participation, and furtheredCongress’ intent that public involvement shouldconstitute more than a mere exchange of informa-tion. Section 219.7(a) sets forth the intent of publicparticipation to:

(1) ensure that the Forest Service understands theneeds and concerns of the public;(2) inform the public of Forest Service land andresource planning activities;(3) provide the public with an understanding ofForest Service programs and proposed actions;(4) broaden the information base upon which landand resource management planning decisions aremade; and(5) demonstrate that public issues and inputs areconsidered and evaluated in reaching planning deci-sions.

Section 219.7(e) provides further that “conclusionsabout [public] comments will be used to the extentpracticable in decisions that are made. ” This consti-tutes the first time that the agency was explicitlyrequired to reflect public input in forest managementplans and decisions.

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Chapter 5--Public Involvement in Forest Planning ● 81

The regulations provide reasonably clear guid-ance to agency managers on the purposes andobjectives of public involvement, but also providethe agency with significant discretion in choosingthe best methods for public participation. Section219.7(c) states, “Public participation, as deemedappropriate by the responsible official, will be usedearly and often throughout the development, revi-sion, and significant amendment of the plans(emphasis added). Nonetheless, the Forest Servicemust demonstrate that it has considered public inputin reaching its final decisions. Thus, section 219.7(a)(5)was of special significance, because it forced actionin response to public comments-the agency wasspecifically required to be “responsive” to publicparticipation.

The NFMA regulations were significantlychanged in 1982, as part of the sweeping changesrecommended by President Ronald Reagan’s TaskForce on Regulatory Reform. The Task Forcerecommended that much of section 219.7 be elimi-nated or changed (269). Section 2 19.7(a) would havebeen reduced to a single, broad statement of purpose:‘‘public participation throughout the planning proc-ess is encouraged. ” Because of strong publiccriticism, however, the Forest Service retained mostof the original language (92). Nonetheless, thesections that most strongly required Forest Serviceresponsiveness to the public—section 219.7(a)(5) todemonstrate consideration of public issues andinputs, and section 219.7(e) to use conclusions aboutpublic comments to the extent practicable-weredeleted.

The Forest Service has defended the deletion,arguing that the sections were unnecessary, inaccu-rate, and nonregulatory, and thus inappropriate forNFMA regulations (92). However, several observershave criticized the Forest Service for eliminatingthose particular provisions which most clearlyforced the agency to respond to public comment.These 1982 changes have significantly increasedagency discretion of how to use public commentsand have contributed to ‘‘erosion of the role of thepublic as participant in the planning and decisionprocess . . .“ (emphasis in original) (231).

Forest Service Efforts in Public Participation

It is widely held—by Members of Congress,members of the general public, academicians, andmany agency personnel-that the Forest Service has

not efficiently or effectively used public input in itsplanning process (27, 91,231, 277,281, 330). Thisinefficiency is manifested, in part, by the risingnumber of appeals and lawsuits over forest plans andproposed activities. It is important to note that theissue surrounding public participation is not solelya question of whether the Forest Service hastechnically complied with the letter of the law, butalso whether the agency has fulfilled the spirit andintent of the laws.

The Forest Service acknowledges that publicparticipation is an important objective of its plan-ning process, and provides numerous opportunitiesfor the public to participate throughout the planningprocess. Nevertheless, the Forest Service has notdemonstrated much success in achieving effectivepublic participation; few forest plans show thedegree to which public concerns have been accom-modated or how managers have considered andresponded to public issues and concerns. Somenational forests have succeeded at involving thepublic in planning and decisionmaking, but for themost part, forest supervisors apparently lack suffi-cient training, guidance, and flexibility to respondadequately to public input.

Integrating the public into forest planning, imple-mentation, and monitoring is admittedly difficult.The Forest Service is required to solicit publicinvolvement in at least ten distinct points in theplanning process (330). In addition, a large numberof specific decisions affect the ‘‘public interest, ’and this number has grown enormously since thepassage of the MUSYA in 1960. Furthermore,agency leaders, observers, and participants differ onthe public’s role in planning and decisionmaking.NEPA and NFMA both contemplate that publicconcerns and issues will be reflected in the planningprocess, but neither specifies how and to what extentplans and decisions should accommodate theseconcerns. Because the Forest Service has not clearlydefined the role of the public in the planning process,both agency managers and the public have differentexpectations and perceptions of the extent to whichpublic input should influence final decisions.

Historical Development

Forest Service planning and management havebeen increasingly attacked since the 1960s. Becauseof the wide discretion of the Forest Service to makeand implement forest policy, several interest groupsfelt that their views were systematically underrepre-


sented in plans and decisions (330). Though seldomfaulting the professionalism of the agency’s workforce per se, some critics have charged that theagency simply has been inclined toward certaininterests, while others have asserted that the agencywas ‘captured’ by outside interests (202,250, 330).

The Bitterroot and Monongahela debates demon-strated the controversial and political nature ofpublic land and resource management and high-lighted the public’s growing expectation for agreater role in Forest Service decisionmakin g. Theperceived lack of responsiveness to public needs andvalues led to calls for agency reform. In 1970, theBelle Report concluded in part that “the staff of theBitterroot National Forest finds itself unable tochange its course, to give anything but tokenrecognition to related values, or to involve most ofthe local public in any way but as antagonists” andrecommended agency reorganization so that publicinvolvement would “naturally take place” (264).The 1971 Forest Service policy statement on publicparticipation was not followed in practice (29). In1972, Cutler recommended five reforms aimed atimproving agency responsiveness to public con-cerns: 1) active recruitment of diverse professionalsfor a‘ ‘multidisciplinary’ staff; 2) early involvementof all interests in decisionmaking; 3) use of ‘ ‘inde-pendent hearing officers and semi-independent citi-zens’ committees’ to review plans and decisions; 4)more and broader alternatives for public review andcomment; and 5) adequate time to review alterna-tives (330)0

Current Conditions and Trends

Criticism of Forest Service decisionmaking hashardly fallen on deaf ears. Since 1970, the agencyhas adopted scores of procedural reforms aimed atpromoting public involvement in its policymakingprocesses. NEPA documents are widely distributed,public meetings are now commonplace, alternativesare routinely reviewed by interested publics, and theagency has used a growing number of citizenworking groups to avoid plan appeals.

Despite Forest Service reforms, public dissatis-faction with final plans and decisions remains high,indicating that many still believe that the agency isunreceptive and unresponsive to their concerns andpriorities. A recent survey of forest planning partici-pants shows 43 percent were “somewhat to verydissatisfied” with the planning process in whichthey had participated, and 55 percent voiced frustra-

tion with the Forest Service planning process as awhole (68). In addition, 72 percent believed that theForest Service unfairly favored some interests overothers when preparing forest plans (68).

The Forest Service undertook its own internalreview of the planning process under NFMA. Mostof the employees surveyed indicated that the agencyhad technically complied with public participationrequirements contained in the law and the regula-tions. However, the public was seen as dissatisfiedwith Forest Service attempts to involve them. Only3 percent of the employees believed that publicparticipation had affected final forest plans (279).

A 1990 report, which solicited comments andideas about the forest planning process from a hostof persons representing various interests, academia,State and local governments, and the general public,likewise reported a widely held feeling that ForestService officials ‘do not welcome proactive partici-pation . . . but prefer to accept information only ontheir own terms and in forums organized by theForest Service” (277). The participants felt that theagency’s public hearings, arranged to invite viewson issues, forced groups into taking hard, polarizedpositions at the outset. ‘‘The planners then retreatedto their offices, emerging sometime later with adraft, followed by another public hearing-andincreased polarization” (277). The report attributedpart of the problem to the lack of a clear agreementand understanding within the agency on the role ofthe public in reaching decisions (277).

While acknowledging shortcomings in publicinvolvement, other observers maintain that theForest Service has been relatively successful inpromoting public participation, given the extensiveand complex requirements of NEPA and NFMA. Asthe planning process continues to evolve and mature,public participation efforts will likely improve,assuming that agency leadership acknowledges theimportance of public participation and activelyencourages and is receptive to public input. InOctober 1989, Forest Service Chief Dale Robertson(207) stated, “In preparing these forest plans, wehave worked with the public. We have come downon what we believe is the best balance after taking allthe factors into account. ” The 1990 internal critiqueof land management planning echoed the Chief’sremarks:

Great strides have been made in Forest Serviceplanning. Citizens were involved to an unprece-


dented extent. . . Many important relationships, withcitizens, local officials, other agencies, and Indiantribes, have been formed . . . There was frustration,but there is a general feeling that individuals insideand outside the agency did the very best they knewhow . . . [P]ublic participation methods changed asthe planning process matured and as results indicatedthe need for changes. Such change will continue aswe enter the next phase of forest planning (276)(emphasis in original).

Many questions concerning the legal adequacy ofpublic involvement methods have been resolvedthrough the administrative appeals process (155).According to the Forest Service, appeals haveplayed an important role in “testing the soundnessof the agency’s day-to-day decisions, current policyand use of discretion. Thus, appeals can and do helprefine and clarify Forest Service policies and proce-dures” (155). The agency’s critique, which includesa series of recommendations designed to promotegreater responsiveness to public input, is furtherevidence that the agency is learning from itsexperiences and attempting to improve public par-ticipation. This critique also prompted the agency toupdate its training course on plan development andimplementation to ensure that needed changes arecommunicated to staff in the field.

Public participation probably will continue toimprove as the agency becomes more experiencedwith the NEPA and NFMA processes. Nonetheless,there still appears to be a substantial gap betweenstated policy and the actual practice. Much of thecriticism heard today echoes of that heard more than20 years ago-that although the agency solicitspublic input, few participants perceive that theirinput has a noticeable impact on plans or decisions.The failure of Forest Service efforts to meet publicexpectations about being included in decisionmak-ing is common to Federal agencies (4). The promiseof citizen participation in policy formulation anddecisionmaking is seldom fulfilled, because for themost part, effective techniques of involvement andparticipation have not been widely adopted (231).

Reasons for Difficulties

Critics who charge that changes in the ForestService’s public involvement strategy and approachhave been minimal, question the extent to which theagency has learned from past experiences (92, 230,231, 330). The most common explanations forForest Service difficulties in effectively involving

the public in planning and decisionmaking are theuse of incorrect models of public involvement, thelack of information on how to involve the public,professional resistance to public ideas, and inflexi-ble conditions for managers.

incorrect Models--One explanation for why theForest Service has failed to meet public expectationsfor participation is that the agency has not developedan appropriate model for encouraging and usingpublic input. Likewise, the Forest Service managershave been unable to provide the public with a clearunderstanding of the purpose of their involvement orhow their input would be used. “People did notknow the level of specificity they were expected tomake in their comments because they did notunderstand the decisions that were going to bemade” (277).

Typically, the Forest Service convenes a meetingof various individuals and interests to discuss a setof issues determined by the Forest Service (277).This ‘has led to issue-airing and venting, but has notaffected decision-making” (277). By asking forinterests and preferences, the agency encourages thepublic to act individually and separately (231). Thisapproach suggests that the agency views the publicnarrowly, as a “gaggle of consumers,” i.e. asindividuals and groups with predetermined andstatic values and preferences (231).

This “model” of public participation is premisedon the assumption that due process is the appropriatemeans to guarantee public access to agency planningand decisionmaking (231). The publics are givensufficient opportunities to present their views, andall views are considered, but the agency is the soledecisionmaker and final arbiter. The publics are thusplaced in the position of having to advocate the“rightness” of their position and the “wrongness”of the positions of others (330).

This divisiveness promotes adversarial behaviorand inhibits the ability of affected groups andindividuals to find mutually acceptable alternatives(330). Citizens have no collaborative forum in whichto learn about one another, to revise their opinions,or to discover common interests and mutuallybeneficial solutions (23 1, 330). Rather than promot-ing a dialogue among the agency and the publics,current models and approaches reduce the purposeof public input to mere information gathering;communication typically flows only one way—fromthe public to the agency (92, 231, 277, 330). The


process neither convinces nor informs the public,because it “does not provide the opportunity formutual inquiry to better understand the issuesinvolved and the merit of a variety of differentalternatives; . . . affected groups are not given theopportunity to amend, support, or reject their earlynotions’ (330). Thus, many are not convinced thatfinal decisions are the most acceptable ones thatcould have been reached.

The adversarial model of public participation alsopromotes distrust of the agency, because those whodisagree with the decisions tend to view agencymanagers as the agents of the opposing interests(330). Furthermore, the public strongly perceivesthat forest planning has been used to justify predeter-mined decisions (277). Decisions disappoint manyparticipants, because they have not been convincedby the decisionmaking process “that the decisionreached is right’ (330). Participants ‘wanted a clearand credible rationale for the decision that showedthat their comments had been heard, understood andconsidered, and evidence that the Forest Service hadacted on the best information available” (277). Alltoo often this rationale has not been forthcoming infinal plans and written decisions.

For want of a clear understanding of the role of thepublic, managers tend to measure the adequacy ofpublic involvement practices in terms of simpleprocess or interest representation (231)--how manypublic hearings were held; how many differentinterest groups were present at these meetings; howmany comments were collected; etc. Because agencyofficials lack explicit formulas for decisionmaking,they seek to compensate by being “systematic andthorough” in their approach to public involvement(330). This ensures that virtually every affected orinterested group and individual has an opportunity topresent their views, but provides no guidance tomanagers on how to integrate the public into theprocess of weighing alternatives, evaluating trade-offs, and making final decisions. This approach failsto distinguish between ‘‘interest airing’ and ‘‘inter-est accommodation ’’-concepts with significantlydifferent implications (330). The current ForestService approach tends to be based on interest airingalone, and is not designed “to accommodate [thepublics’] concerns in a way that satisfies them thatthey have indeed been accommodated as well aspossible” (330). “Issue airing,” without involve-ment in the decisionmaking, encourages participants

to argue positions rather than to discuss the largerinterests and issues at stake (83).

Insufficient Data—Some observers attribute theagency’s failure to engage the public in the planningprocess to the lack of data available on the mosteffective and efficient public participation tech-niques and methods. “Little empirical research isavailable to help forest managers understand publicparticipation . . . [and] empirical data in socialscience literature that analyze the most appropriatemethods to involve the public in resource decision-making are scarce’ (86). A survey of forest planningparticipants in Idaho and Washington identified fiveparticipation methods preferred by the public: 1)citizen representatives on Forest Service policymak-ing bodies, 2) formal public hearings, 3) surveys ofcitizen attitudes and opinions, 4) open public meet-ings, and 5) meetings held for residents of specificcommunities (325). However, none of these fivemethods were used by any of the national forests inthe survey area (325). Arguably, information onpublic preferences could assist managers in stimu-lating better local public participation.

The Forest Service also lacks empirical evidenceon the people who tend to participate in forestplanning (86). No research has identified or exam-ined demographic, sociological, or other characteris-tics of the people who participate. It is difficult todesign effective involvement programs withoutunderstanding the characteristics and interests of theparticipants. ‘‘Empirically derived information canhelp forest managers understand the public moreaccurately and can help participation officers designprograms for the population in general and forspecific groups” (86).

Resistance to Public Involvement—The mandatefor more extensive public participation in the forestplanning process was imposed upon an agency thathad traditionally operated relatively autonomously.While agency leaders were receptive to the chargefor greater public involvement, both NEPA andNFMA required major changes in the reamer inwhich the agency operated. Field managers were notexperienced or trained in integrating the public intothe decisionmaking process, and little guidance wasprovided on how and why to accommodate thepublic; consequently, public participation methodshave evolved slowly.

Numerous critics assert that the agency leadershipdoes not welcome proactive participation, because it

Chapter 5-Public Involvement in Forest Planning . 85

can be counterproductive-sometimes the publicwants decisions that are inappropriate, infeasible, orinconsistent with agency policies (92, 159,229,231,277). Forest supervisors often believe that ‘proper’decisions must be internally consistent (“loyalty tothe party line’ ‘); responding to local interests is thusirresponsible, unless the decision is unequivocallyfaithful to agency policies and decisions (229, 231).Consequently, the agency has preferred to acceptpublic input only on its terms and in forums it hasorganized (277).

Another allegation is that the Forest Serviceresists meaningful public participation to preserveits decisionmaking autonomy and discretion. Beingresponsive to the public may restrict certain agencyactivities or options. Forest Service employees havebeen described as reluctant public servants, who“still seem to regard their work as the strictapplication of natural science to the managementand protection of the environment’ (159). Profes-sional resource managers believe that their trainingand experience equips them to make decisions andthat, by and large, the public is uninformed and toodiversely opinionated for useful input and sounddecisionmaking (227).

Natural resource personnel surveyed from severalagencies felt that the public, even the interest groups,had little knowledge of land and resource manage-ment issues (237). Thus, managers work to ‘ ‘edu-cate’ the public and change people’s minds aboutthe agency policies and practices rather than explorealternatives to satisfy the public’s goals and objec-tives. “Information programs are undertaken morefrom a desire to shape public opinion than toincorporate public opinion into policy decisions’(159). The Forest Service typically develops anddefines public issues internally and then invites thepublic to review and comment (77). This approachperpetuates the notion that public participation isnothing more than a forum in which to ‘‘inform andeducate’ the public.

This attitude impedes listening to the public. TheForest Service employs many professionals, withdiverse backgrounds. However, resource expertise isalso employed by State agencies, by other Federalagencies, by universities and consultants, and bymany interest groups. Even the uninformed can haveintelligent ideas about land and resource manage-ment. Sometimes the most innovative suggestionscome from those whose thinking has not been

narrowed by professional training. Furthermore,education is most likely to occur, not when thepublic is told what is feasible, but when it is guidedto reach its own conclusions. Finally, professionalsoften do not realize that their technical decisionsmay intrude on public values, and only publicparticipation can define which decisions are techni-cal and which are public (3).

The emphasis on retaining autonomy and discre-tion has prevented the agency from using effectivemodels of participation in forest planning and fromresolving basic issues such as the identity of thepublics, the roles of the agency and the public in theplanning process, and the degree of influence thepublic should exercise over final decisions (231).The unwillingness to allow the public to play agreater role in planning and decisionmaking hasstifled the agency’s capacity to learn-to carefullyevaluate and reflect on past programs and policycommitments, to examine a wider range of alterna-tives to proposed actions, and to respond to changingpublic values and priorities (203, 231).

Inflexible Conditions—The 1970 Belle Reportfound that Forest Service managers in the fieldlacked the flexibility needed to respond effectivelyto public needs:

In order to maximize local community supportthose persons in the Forest Service most intimatelyassociated with local community interests [i.e., thedistrict rangers] must be free to act . . . yet his [sic]authority is severely limited and all too frequentlyhis decisions and answers are bureaucratically deter-mined . . , He is therefore denied the flexibility tomeet issues and problems on an ad hoc basis. It mightalso be said that his decisions are always predeter-mined, at least with respect to major issues andproblems (244).

Furthermore, the Forest Service does not rewardmanagers or other employees for accommodatingthe public:

Unless there is freedom to solve resource relatedproblems on a situational basis, there are no groundsfor public participation . . .[but] public participationis the key in determining the particular expression ofpublic interest to particular problems (29).

Evidence suggests that the inflexibility describedin the Belle Report 20 years ago remains. Forestsupervisors and district rangers are often constrainedfrom responding to public issues by a host of factorsbeyond their control. For example, allocated na-


tional goals and objectives, set in the RPA Programand through annual budgets, frequently contradictthose derived at the local level, effectively preempt-ing forest plans. Control systems-rewards, incen-tives, and budgets—are not linked to the plans.Local forums designed to encourage deliberationand debate among the most interested publics are fornaught, if they are systematically overruled bynational policies that are insensitive to local con-cerns.

Even agency employees note that local planningand response to local publics are being overridden.In an open letter to the Forest Service Chief, forestsupervisors from the Rocky Mountain areas stated:

The emphasis of National Forest programs doesnot reflect the land stewardship values embodied inforest plans, nor does it reflect the values of manyForest Service employees and the public. , . Program/budget testimony is constrained by Administrationobjectives. Program shifts contained in forest plansand public opinion are not expressed . . . in annualbudgets and agency policies (90).

In their recent recommendations to the Chief, theseforest supervisors echoed the conclusions of theBelle Report:

Field line officers should become more effectivein working with local, State and National key publicsand elected leaders to build support for ForestService programs generally, and to discourage spe-cific earmarking (90).

Finally, the functional organization of the ForestService employees and resource-oriented budgetsimpair a manager’s ability to implement integratedresource plans. Many interests and employees be-lieve that functionalism has led to funding for someresources and not for others (276, 277). It is arguedthat the differences between funding called for in theplans and actual appropriations prevent the agencyfrom meeting the intent of NFMA, because the trulyinterdisciplinary and integrated plans cannot beimplemented as planned (149).

Reducing Conflict ThroughCooperation and Collaboration

The preceding discussion of problems in involv-ing the public is not to suggest that agency efforts atpublic participation have been a total failure onevery national forest. Despite the lack of agreed-upon criteria to evaluate the success or effectivenessof public involvement, observers cite a number of

forests that have achieved “viable plans” (330).Typically, these forests brought diverse groupstogether to identify issues and discuss alternatives;these informal citizen working groups and forumsencouraged debate, dialogue, and deliberation amongthe groups and with the agency. According to severalobservers, success largely depended on the initiativeof particular forest supervisors (or in some casesregional foresters), rather than on guidance fromagency leadership (229, 231).

Typically, where a forest plan was deemed asuccess, there was a forest supervisor who under-stood the social and political environment, was ableto read the forest constituency well, and personallynavigated the plan through the reefs of publiccontroversy (277).

Other forests seem to have committed themselvesto meaningful participation in their final forest plans.For example, in the Ochoco National Forest:

Incorporation of public involvement into deci-sions being reached in the final Forest and Grass-lands Plans has been an integral step in progressingfrom the draft documents . . . Significant steps weretaken during the last four months of final documentpreparation to insure that direction in the final plansresponded accurately to comments received on thedraft. In response to public comment, new informa-tion and legislation, significant changes were madein the preferred alternative between Draft and Final.Concurrently, with the alternative modification, theForest Service worked closely with the public inattempting to validate and/or seek ‘consent’ for theFinal Plan (274).

Although this statement alone does not prove thatpublic participation was effective on the Ochoco, itdoes indicate that the agency recognizes the impor-tance of public participation in the planning process,and acknowledges that public input should bereflected in final plans and decisions.

These successes and commitments are a valuablebeginning to effective involvement of the public inforest planning and decisionmaking. However, ifpublic participation in forest planning is to fulfill thepurposes of NEPA and NFMA, the Forest Servicemust provide consistent and organized direction forimproving public participation. Effective participa-tion is not solely a function of process and proce-dures; managers must have a clear idea of why thepublic is being consulted for particular decisions,and how they should consider and respond to publicinput.

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Chapter S-Public Involvement in Forest Planning ● 87

Why Involve the Public in Forest Planning

The decisionmaking responsibilities of Federaladministrative agencies, including the Forest Serv-ice, contain duties best described as ‘‘quasi-legislative’ in nature. This is true whenever Con-gress vests substantial discretion in an agency toexecute broad or general legislation, such as MUSYA.Reich (203) noted the ‘practical necessity’ of broadadministrative discretion, due to the growth in theadministrative state in the last 50 to 60 years.However, broad grants of administrative discretioncan also be inconsistent with a ‘‘pluralist vision ofsociety, because broad discretion creates “thepossibility that unelected bureaucrats could imposetheir own ideas on the public” (203). Concern overthe legitimate role of the public administrator led tothe creation of the administrative process; “Admin-istrators, in theory, became managers of neutralprocesses designed to discover optimal public poli-cies” (203).

Agency planning activities have been character-ized as falling somewhere between rulemaking andadjudication. Planning activities prior to NFMA,however, were generally considered exempt fromthe requirements to involve the public under theAdministrative Procedures Act (APA) (208), andNFMA did not directly alter this situation. TheForest Service’s broad mandate in MUSYA neces-sarily requires agency managers to allocate scarcepublic resources, and NFMA preserves broad agencydiscretion in planning. Thus, the concerns aboutrepresentation and agency accountability to thepublic have grown steadily. For example, theBitterroot and Monongahela controversies erupted,in part, because some members of the publicbelieved that Forest Service policies were unrespon-sive to and inconsistent with public demands.Increasingly over the past two decades, the publichas demanded and expected the right to participatein Forest Service planning and decisionmaking.

Given the nature of Forest Service responsibilities—allocating scarce public resources through long-range, integrated resource planning and manage-ment—the call for greater public representation andinvolvement in agency decisions seems perfectlylogical (202). While a strictly democratic approachto agency decisionmaking might be too cumbersomeand costly, only public participation can assure thatthe allocation of forest resources best satisfies the‘ ‘public’s interest.’ In 1962, Reich wrote:

. . . [it] can be argued that in a democracy the ‘publicinterest” has no objective meaning except insofar asthe people have defined it; the question cannot bewhat is “best” for the people, but what the people,adequately informed, decide they want.

Failure to involve interested publics in planningcan lead those publics to choose other forums-suchas Congress and the courts-to press their demands,and may result in final plans that cannot beimplemented (49, 203, 231).

Affected and interested individuals and groupscan contribute to agency decisionmaking processesin several ways. Public involvement is most com-monly viewed as a means to provide agencies withgreater insight into values, needs, and priorities thanwould be available without such input. Perhaps moreimportantly, however, public participation can serveto define the important decisions and relevantinformation for decisionmaking (92). Public in-volvement can lead agency managers to consider awider range of issues and to articulate concerns moreclearly (92, 203, 330).

Public participation can also serve as an “earlydistant warning system, ” alerting agency plannersand managers to resource issues that are likely tocause significant controversy in the future. Withmore direct insight into public values and priorities,the agency can develop plans that address new andemerging concerns and, in theory, avoid makingdecisions that prompt appeals and litigation and thatdelay implementation (49, 306). If used effectively,public input can help agency managers detect andaddress problems early, thereby leading to moreefficient and expeditious implementation of theplans on the ground.

Finally, public participation can also improveagency accountability. Several observers argue thatpublic involvement is needed as a representativecheck on agency activities (92, 203):

Administrative agencies . . . have been makingdecisions in a temporary political vacuum. Thus, ina sense, the present day participatory emphasisrepresents a restoration of the political balance in ourdemocracy-a balance that was temporarily lostbecause the complexity of problems developedfaster than the institutional capacity to deal withthem through representative procedure (186).

Including the public in the decisionmaking proc-esses helps to ensure that agencies accuratelydetermin e the ‘‘public interest’ in a given situation


and respond appropriately; public participation canhelp to bridge the gap between actual public valuesand those perceived by the agency.

The Forest Service has a distinguished history ofmanaging the public forests and rangelands. Theagency’s professionals have traditionally been edu-cated in a variety of professional and scientificdisciplines and have historically maintained virtu-ally exclusive decisionmaking authority over theallocation and management of national forest re-sources (202, 208, 324). However, as noted inchapter 3, conflicts over resource use have intensi-fied since the 1950s and the agency’s statutorymandate has been broadened to include expressconsideration of more noncommodity values. Con-sequently, the number of subjective, value-ladenquestions confronting managers has increased sig-nificantly, limiting the ability of professionals todetermine and represent the “public interest” (202,330).

“Goodness” and “badness” in our society arecollective value judgments, and land expertise is nobetter qualification than many others for makingthem (15).

While education, training, and open-mindedness areimportant characteristics of land and resource pro-fessionals, these characteristics do not give manag-ers any special ability or authority to represent thevalues of others (15, 202, 330). To the extentinterested members of the public are allowed torepresent their own concerns and values, publicparticipation can inform and guide final plans anddecisions (330).

This is not to suggest that all battles over forestmanagement can be avoided by involving the publicin planning and decisionmaking; mutually satisfac-tory decisions simply cannot be reached on someissues (203, 330). Also, the agency should not berelieved of management authority and responsibil-ity.

[T]he issue is not whether the public or experts areto manage, but whether, and to what degree, theexperts should be made aware of, and responsive to,public opinion (202).

Forest Service managers are, ultimately, responsiblefor making decisions. Nonetheless, public involve-ment can help managers: 1) determine importantpublic values and priorities, 2) define critical issuesand the relevant information to address them, 3)

identify emerging issues and possibly avoid crises,and 4) assess how well they have fulfilled the“public interest.”

Models of Effectiveness

Administrative procedures developed to promotepublic participation are frequently flawed, becausepublic wants are often assumed to be predeterminedand static. The primary purpose of public participa-tion, therefore, is presumed to be gathering from thepublic.

People’s preferences are assumed to exist apartfrom any process designed to discover and respondto them, that is, outside any social or politicalexperience in defining the nature of the problem andattempting to resolve it. . . Individual preferences donot arise outside and apart from their social context,but are influenced by both the process and thesubstance of public policy making (203).

Public participation in Forest Service decisionmak-ing is valuable, not just because it offers interestedgroups and individuals a forum for conveying andadvocating certain positions, but because it providesindividuals and groups the opportunity to under-stand the values and preferences of others and achance to refine their own.

Five distinct concepts of the public, each portray-ing the public in a different capacity, have beendescribed (239). One concept is the public as marketplayers-as individuals and their individual prefer-ences. Another is the public as clients—as organizedinterests that “lobby” decisionmakers. The thirdconcept is the public as patients—as persons orgroups who are affected by policies and decisions.The public can also be viewed as consumers-aspersons interested in using goods and services (incontrast to simply expressing their preferences).Finally, the public can be viewed as functionaries—as the interests of producers (owners and laborers) inmaking and selling resource-based goods and serv-ices.

Distinguishing among these concepts can beinstructive to administrators considering how toinvolve the public in planning, but there are twolimitations to this approach. First, various individu-als and groups may fit within different concepts atdifferent times-acting, for example, as a client onone day or in one setting, and as a consumer onanother day or in another setting. In addition, all ofthese concepts divide individuals from one another;


none include the political identity of the public as awhole-the public as citizens (239). Nonetheless,viewing the public with these distinct concepts,portraying the public in various roles, can helpdecisionmakers understand the interests and motiva-tion of the individuals and groups who participate inforest planning.

Forest Service administrators commonly use a“market imagery’ model of the public (141). Thepublic is typically viewed narrowly, as individualcompeting and conflicting interests, as ‘‘a gaggle ofconsumers shopping for policies from shelvesstocked by government experts” (141). Thus, publicparticipation emphasizes: 1) the need to “inform andeducate” the public about agency programs andactivities, and 2) the collection of opinions from awide variety of interests, to be sure all views arerepresented. Those opinions are then weighed againstresource management concepts, costs, and legalconstraints, with agency decisionmakers choosingalternatives they believe best meet the expressedinterests (49, 203, 330). Such an approach isgenerally insufficient because it emphasizes ‘ ‘repre-sentation’ rather than ‘ ‘accommodation’ of multi-ple interests (49, 330). The incomplete or inaccuratepicture of the publics, which can result from relyingprincipally on the market imagery model, may leadagency planners to miscalculate the political feasi-bility of final plans and decisions.

A broader view of the public, on the other hand,can encourage mutual understanding. Public in-volvement in planning and decisionmaking not onlyoffers a forum for conveying concerns and advocat-ing positions, but also provides an opportunity tounderstand the values and preferences of others anda chance to build on common bonds. Open discus-sions and joint fact-finding can also improve under-standing of the issues and conflicts underlyingdecisions, and thus produce insights into how andwhy specific decisions are made (330). Understand-ing is essential to building trust among the partici-pants (the public and the agency employees). Effec-tive public involvement can, therefore, encouragetrust, and thus acceptance of the final plans anddecisions (49, 203, 330). An appreciation of thesignificance of effective public involvement indeveloping implementable plans can lead agencymanagers to develop effective procedures to involvethe public.

Open Decisionmaking or Decision Building—An ongoing interchange among diverse interests andthe agency is needed to reflect informed publicopinion and/or consent in the goals and objectivesfor land and resource management (306). Planningand decisionmaking is a learning process, andmodels of participation should, therefore, encouragetwo-way communication, which allows the agencyand the general public to learn from each other (203,231). The agency and the public should each beviewed as contributors to the process, with differentresponsibilities.

Problems in public management of natural re-sources and environmental quality necessarily in-volve technical, biophysical questions-e.g., what isfeasible, what results from specific practices, whatvarious practices cost. They also involve human,socioeconomic questions, as well—e.g., whatshould be the goals, what values are important, whatpractices are acceptable (29, 306). The latter arequestions of value, and ‘‘only the public is able toprovide adequate insights into the social or humanaspects’ (29) (emphasis in original). Professionalshave no special training for determining what issocially desirable (15). One major objective andchallenge of the planning process is to balance‘‘traditional democratic notions of citizen involve-ment in government with the countervailing need fortechnical competency and efficiency of the techno-cratic society” (92, 306). Thus, on those issuesinvolving inherently value-laden questions, morepolitically acceptable decisions could be madethrough a more collective, collaborative decision-making process.

Public participation can lead to more collectiveplanning and decisionmaking, if conducted in amanner that encourages dialogue or deliberationamong the agency and interested individuals andgroups (203, 231, 330). Public deliberation overpublic issues is the “foundation of democracy”(203).

Such deliberation can lead individuals to reviseopinions (about both facts and values), alter prem-ises, and discover common interests. Disagreementsand inconsistencies encourage individuals to balanceand rank their wants. The discovery that solelypersonal concerns are shared empowers people to actupon them (203).

Furthermore, socioeconomic considerations entereach stage of the decision process (3, 330). Thus,


public involvement should aim for sustained interac-tion among the agency and the interested publicsthroughout planning and implementation (29, 306).

More collective decisionmaking that welcomespublic views and considers them seriously is “opendecisionmaking” (228, 277). It encompasses manyof the concepts described above--sustained interac-tion among the agency and public interests, honestsharing of information and opinions, and cleardescription of how decisions were reached. Thus,open decisionmaking effectively leads to the “pub-lic dialogue” that is the essence of collaborativedecisionmaking.

Shannon (231) suggests that the Forest Servicereplace the vision of “decisionmaking’ with “deci-sion building. ” The sole decisionmaker is replacedwith a leader who helps the agency and the publicjointly build acceptable decisions. Thus, the man-ager becomes responsible for organizing people(employees and the publics) and information, todevelop the knowledge and commitment necessaryto choose a course of action (52). This model ofdecision building recognizes that decisions requireconsiderable effort by all interests, and that theprocess must be coordinated so that the “pieces fittogether” (231).

Clearly, decision building, open decisionmaking,or collaborative planning would require a change inForest Service planning and decisionmaking.3 Greaterpublic involvement in plannin g and decisionmakinglikely will impose greater duties and responsibilitieson the managers, many of whom are alreadystretched to their capacity to perform their requiredduties. However, if people are involved-if theyhelp build the decisions and understand why deci-sions are made-they will not only be more likely toaccept the decision, they will also contribute to itsimplementation. If the agency is to get out of thecourts, public participation must effectively involvethe public.

Manager Responsibilities-A change from deci-sionmaker to decision builder does not eliminatemanagers’ responsibility for their decisions. How-ever, the focus of efforts is altered. Rather thanfunctioning as an arbiter, managers would functionmore like brokers. They would solicit, organize, andfacilitate public participation and debate and seeking

mutually beneficial tradeoffs and compromisesthrough discussions with and negotiated settlementsamong the various interests (49). Discussions ofinterests, as opposed to declarations of positions,lend a less adversarial and more collaborativeatmosphere to the planning process (83, 330). Thus,an administrator would ‘‘fimction less like . . . [a]‘neutral’ manager . . . [and more like a] teacher andguide” (203).

The professional has the responsibility to providethe public with the basic information required tounderstand problems and to recognize what isinvolved in the decisions that are made. Once thepublic has set its goals, the professional can help byapplying technical skills in the attainment of thosegoals (29).

Agency managers can also advise on the physical,technical, and practical feasibility of whether theexpectations and goals can be achieved. Managersthus lead in the debate, as well as provide technicalexpertise (49).

Managers reevaluating the public’s role in deci-sionmaking must ask three initial questions (216): 1)who should be involved in the decision process, 2)what role should they play, and 3) what degree ofinfluence should they possess. By addressing thesequestions, the agency can provide its managers withdirection on the purposes and objectives of publicinvolvement, and the public with a clearer indicationof how its input will be used in making finaldecisions. This, in turn, would provide the publicwith a greater incentive to become involved.

A modified organizational structure may be re-quired to involve the public effectively. The resource-oriented structure may inhibit the open, wide-ranging discussions inherent in open decisionmak-ing. Furthermore, periodic reevaluation to determinewhether the current structure supports successfulplanning and implementation is fundamental toeffective strategic planning (70, 101). Thus, reexam-ining the roles of agency managers and the public inthe decisionmaking process might prompt the agencyto revise its internal structure and adopt newtechniques that better promote public involvement.

Once administrators determine when and why toinvolve the public, they should focus on effectivelypromoting public participation. This requires more

Throughout the remainder of this cbapter, the term decisio nmaking is used generically to refer to making decisions, whether by opem collaborative,decision building or by more traditional processes.

Chapter 5--Public Involvement in Forest Planning . 91

than providing ample notice of decisions to poten-tially interested individuals and groups. Incentivesto participate in a particular forum are also needed(231). Forest policy is made in a variety of forums—in Congress, in the Forest Service planning andappeals processes, and in the court--each open tovarious degrees of public involvement. Understand-ably, persons and groups will be more inclined toparticipate in the forums where they believe thattheir participation will have the greatest impact (80,230).

Finding the right formula for facilitating publicparticipation is admittedly difficult. The suitabilityof methods and procedures varies with the nature ofthe decisions, the geographical setting, and thepreferences of the local publics. For example, a townmeeting might work well for public involvement inparts of New England, where town meetings have arich history, but might not work at all in other partsof the country; similarly, some individuals areuncomfortable participating in public hearings, pre-ferring letters or personal interaction. Whateverprocedures are chosen, managers should encouragethe public to participate by responding clearly totheir concerns, and stimulate deliberation and de-bate. Without incentives to participate in agencyplanning and decisionmaking processes, citizensand interest groups often seek out other forums, suchas Congress or the courts, to influence forest policyand decisionmaking (203, 231, 330).

Forest Service Efforts To Improve Public Par-ticipation--The Forest Service has recognized theimportance of public participation in national forestplanning and management. The agency recentlyreviewed its public participation practices (amongother things), and the review team made a series ofrecommendations to improve the effectiveness ofpublic participation (277). They emphasized theimportance of achieving consensus among inter-ested publics and the need to train agency personnelin communication, mediation, and facilitation skills.They also noted that the traditional resource-oriented approach to funding is inhibiting integratedplanning and management (276).

Pursuant to this review, the Forest Service hasbegun the process of revising its regulations to guidethe implementation and revision of forest plans(287), and has revised its forest plan implementationtraining course. In the proposed revisions of theregulations, the agency has embraced the findings

297-904 0 - 92 - 4

and recommendations of the review and has an-nounced its commitment to strengthen the role ofpublic participation in agency planning and deci-sionmaking. Public participation processes are rec-ognized as attempting to achieve “informed con-sent’ among the interested publics, and the proposalthus casts the public in a more specific, direct, andactive role in planning and decisionmaking. Inaddition, the proposed regulations encourage thepractice of “conflict resolution” as a tool for publicinvolvement. (See box 5-A.) This suggests that morecollaborative public participation activities maybecome more commonplace.

Furthermore, observers have cited several na-tional forests where public participation efforts areconsidered relatively successful, and suggest thattheir experiences can serve as models for otherforests (149, 330). Wondolleck (330) cites sevennational forests where managers have successfullyestablished collaborative public participation proc-esses to develop final forest plans or to avoidadministrative appeals of those plans. Shands (228)described open decisionmaking as applied in NorthCarolina. Thus, the Forest Service has successstories to show that public involvement in nationalforest planning and decisionmaking can work.

Measuring the Effectiveness of PublicInvolvement in Forest Planning

Developing criteria by which to measure theeffectiveness of public involvement is important forat least two reasons. First, measures of effectivenesscan provide clearer direction to managers in the fieldon the goals and objectives of public involvementand on the role of the public in planning anddecisions. With a clearer picture of the goals andobjectives of public participation, managers couldhave abetter idea of how to respond to public input.Second, public participants would have clearer andmore realistic expectations of how their input wouldbe used, providing an incentive to participate inplanning and in building decisions.

Because of the intensely political nature of forestplanning, measuring the effectiveness of publicparticipation activities in forest planning and deci-sionmaking can be elusive (203). Neither NEPA norNFMA contain measures by which to gauge theeffectiveness of public participation efforts. Thereare no substantive guidelines for how the agencyshould consider and respond to public input. Inaddition, courts are generally deferential to agency


Box 5-A--Opportunities and Limitations With Alternative Dispute Resolution

Involving the public in a collaborative manner can lead to plans and decisions that are accepted by the public,but not all conflicts can be resolved, even through the best collaboration or open decisionmaking. Often, theindividuals or groups who are dissatisfied with the plans or decisions will turn to administrative appeals or litigationto modify those plans or decisions. Sometimes, such disputes can be resolved through a number of techniques,collectively known as alternative dispute resolution (ADR).1

ADR is a voluntary process involving some form of consensus building, joint problemsolving, and/ornegotiation aimed at producing mutually acceptable solutions to disputes or controversies (21, 171). ADRencompasses several different types of problemsolving practices, the most common of which are negotiation,mediation, and arbitration (21, 171). Negotiation brings the parties together to bargain, compromise, or otherwisesolve problems and settle disputes. Mediation involves a neutral third-party mediator or facilitator to assist theparties in resolving their differences, but the mediator has no authority to impose a settlement. Arbitration is similarto mediation, but the third-party arbitrator does have the authority to impose a settlement A fourth type of ADR,similar in many respects to mediation, is termed joint problemsolving. This technique brings interested partiestogether (possibly with a neutral facilitator) to collaboratively solve problems, typically related to proposed rules,plans, or actions, and thus is especially useful in administrative rulemaking and in planning (37, 231).The Use and Benefits of ADR

The use of ADR by State and Federal agencies is becoming more common. ADR has been used successfullyto resolve disputes involving a wide variety of environmental and natural resource issues, such as land use, waterresources, air quality, energy, forest land and resource planning and management, and toxics (21). Negotiatedrulemaking and Superfund mediation by the U.S. Environmental Protection Agency (EPA) are perhaps the bestknown examples of the use of ADR by a Federal agency (21, 203, 204), and legal challenges to EPA rules havedeclined considerably since they began negotiated rulemaking (300). In addition, the Administrative Conferenceof the United States has encouraged the use of ADR in Federal rulemaking to reduce subsequent litigation (21).

The Forest Service is encouraging the use of ADR, especially mediation, for developing final forest plans andfor resolving administrative appeals of plan and projects. The 1989 revision of the administrative appeal regulationsencourages the use of ADR to settle appeals (36 CFR 217.12(a)), and the proposed revision of the forest planningregulations encourage conflict resolution at all stages in the forest planning process (287). Furthermore, ChiefRobertson has publicly endorsed and encouraged the use of ADR by the national forests (1 16).

The Forest Service has responded to such encouragement. Bingham and DeLong (22) identified 21 nationalforests that had relied on ADR techniques to develop final plans or to resolve administrative appeals. Wondolleck(330) cites seven national forests where agency managers established collaborative public participation processesto develop final forest plans or to avoid administrative appeals of those plans. For example, the draft forest plan forthe Monongahela National Forest in West Virginia received widespread public criticism. In anticipation ofadministrative and legal challenges, agency planners invited interested groups and individuals to work closely withthem to redevelop plan alternatives; the result was a final plan that was substantially different than the draft plan(330). On the other six national forests-the Jefferson, the Cibola, the Chugach, the Rio Grande, the Chatta-hoochee/Oconee, and the Nebraska--agency managers also used ADR techniques to resolve contentiousadministrative appeals.

Negotiation at the planning and appeals stages can be a valuable tool for bringing diverse interests togetherto resolve complex disputes (21, 22, 243, 330). Bingham and DeLong (22) noted that the use of ADR techniquesin forest planning can:

1. promote better communication;2. promote more creative solutions;3. promote more lasting decisions;4. reduce the time to complete a plan; and5. be used in combination with other processes.

lsme of these tochniqucs are also useful in decision buMQJ. m ~“w hcnvevor, fOcuso8 on techniques used to resolveadministrative appeals and litigation after plans bave bccm completed or decisions made.


The promise of ADR in forest plan development is that voluntary negotiated agreements can reduce thelikelihood of administrative or legal challenges and increase the ability of the agency to implement the plans (22,330). Past approaches to public participation have involved the public reactively-agency managers are unable toaccommodate all interests, and then must defend their plans and decisions from administrative and legal challengesby dissatisfied interests (330). A more cooperative and interactive process for plan development and implementationcan engage the publics proactively--managers invite forest users and other interested groups and individuals tojointly develop a plan that is acceptable to all (330). A mediator or facilitator can coordinate the process and helpparties to develop final decisions that are more defensible (and less likely to need defense) than those made withoutdirect public consultation and collaboration (330). The neutral third party is particularly useful when trust amongthe participants is low. The principle underlying ADR can serve as a foundation for building these proactive andcollaborative processes (21, 22, 330).

ADR is an additional problemsolving tool, not a substitute for more traditional processes such as litigation (5,21, 330). ADR may not always be appropriate for the dispute or acceptable to all the parties involved. But whentraditional methods are unsatisfactory, ADR is an effective alternative means by which to avoid stalemate,polarization, or protracted litigation (21, 204). In some instances, ADR is less expensive and time-consuming thanmore traditional mechanisms, although research has not fully documented the savings (21). Nonetheless, ADR hasprovided parties with a greater feeling of control over the decisions being made and a greater sense of satisfaction,and has led to consideration of a wider range of alternatives and more creative options (84). Participants generallybelieve that ADR increases their input to planning and decisionmaking, and believe that it is fair and efficient (21).Using ADR in Forest Planning

To date, the choice of whether to use ADR in forest planning has generally been made regionally or locally,on a case-by-case basis (21). The use of ADR techniques is clearly authorized, but not mandated. Because ADRcan resolve many disputes over national forest planning and management, Congress and the Forest Service haveconsidered how to institutionalize ADR in forest planning, but no specific requirements have been enacted.

Clearer direction and better-defined procedures for Forest Service use of ADR could create incentives to useADR by providing greater predictability on how public participation might affect final decisions, and mightencourage the participants to initiate negotiations themselves (22). Clearer direction on the use of ADR could alsobenefit managers by providing clearer standards and guidelines on when and how to use ADR, whether to engagea mediator, and how to convene all the necessary parties. By building a certain measure of consistency in ADRprocedures, such standards and guidelines might reduce the likelihood that the process will be misused. Clearerdirection might also make enforcement of negotiated agreements easier (21).

Proponents of institutionalizing ADR stress that the objectives should be to: 1) achieve some consistency inprocedures, and 2) preserve the flexibility of the agency and the parties to shape the process to meet the needs ofthe particular circumstances (21, 22, 330). Achieving both objectives is admittedly a difficult task. Severalsuggestions for institutionalizing ADR have been proposed (22):1. The negotiation process should be voluntary. The strength of ADR lies in the parties’ willingness to work

cooperatively to find mutually acceptable solutions to common problems (21, 22, 330). Mandating the use ofADR would inhibit the necessary cooperation.

2. ADR is particularly useful for resolving specific disputes. The process has worked well on administrative appeals,because the interested parties are easily identifiable and the issues tend to be narrow and well-defined (22, 330).And, parties have an incentive to negotiate when a lawsuit is filed, because litigation is the final forum in whichto affect the decision (22). Nonetheless, by negotiating early in the planning process, the Forest Service candiscourage polarization and avoid subsequent challenges and delays to implementation (22).

3. The process should be initiated only when the disagreement is amenable to negotiation. The agency or a mediatorcan assess the appropriateness of convening negotiations, and identify potential issues and procedural concerns(22, 330). ADR is most useful if the parties have the flexibility to determine which issues are ripe for resolutionand which should be deferred (21, 22, 330).

4. The process should include all relevant parties, who can be identified by the agency or a mediator. Excludingcritical interests will lead to controversy later, and could result in appeals or litigation. Thus, negotiations mustaccommodate a balanced and fully representative body of interests (22, 330). Furthermore, under NEPA andNFMA, all interested individuals and groups have an equal right to participate in the forest planning process.

(continusdon fh9xtp4u81


Box S-A-Opportunities and Limitations With Alternative Dispute Resolution-Continued

5. A neutral mediator is often useful. Because the agency is not neutral-it represents statutory and regulatoryanizational interests, and may have an interest m Particular outcomes (22, 50)-amandates, promotes certain org

mediator can be particularly useful and lend some perceived fairness to the process. A mediator may not benecessary, however, in cases where there are only a few parties, the issues are well-defined, and all the partiesbelieve that they can reach an agreement without the aid of a mediator (22).

6. Time should be allowed for the process to work In many instances, ADR has been less costly and lesstime-consuming than appeals and litigation, but observers caution that ADR is not necessarily more expeditiousthan litigation or other decisionmaking processes. Furthermore, some stress that deadlines are important andshould be established at the outset, considering the number of parties involved, the type and number of issuesin question, the stage of the decisionmaking process, and any other relevant circumstances (22). To preserveflexibility, deadline extensions could be allowed (22). However, other interests may be affected by delays indecisions, and these impacts should also be considered

7. Agreements should be implemented. A potential benefit of ADR is that plans and decisions are less likely to bechallenged and thus are more likely to be implemented. But since such processes are time-consuming andpotentially costly, some assurance that the agreement will be implemented may be a necessary incentive to obtaincooperation (22). However, providing sufficient assurance maybe difficult, because the agency must still complywith the requirements of NEPA, NFMA, and the other laws that apply to forest planning and management.

Limitations of ADRNot all decisions are amenable to successful resolution through negotiation and mediation. For example, if the

parties’ fundamentalvalues or interests are at odds, ADR may only result in further delay (25, 330). ADR is unlikelyto be successful unless the issues in dispute are well-defined. ADR can be useful for specific, narrowly definedissues, but often the most contentious issues must be resolved through other means (22, 330).

The success of ADR also depends on the participation. It maybe difficult to gather a balanced group ofparticipants, but excluding some critical interests could lead to litigation (25, 198). Furthermore, the parties mayhave significant differences in expertise and/or power, leaving some at a dative disadvantage (5, 25). Thoseperceiving their relative disadvantage might compensate for it by abandoning the ADR process and turning toCongress or the courts where they may have relatively greater power (201). Because of these potentialdisadvantages, the question of whether ADR is appropriate for resolving of a particular dispute or conflict is bestdetermined by the parties themselves.

Finally, the use of ADR does not always lead to solutions. First, ADR is not free, and only saves time andmoney if the dispute could not have been resolved earlier and if ADR avoids more costly and time-consuming. .administrative appeals and litigation. Second, while voluntary negotiated agreements are more likely to beimplemented (22), they confront the same technical, financial, and administrative difficulties faced by other plansand decisions (21). Thus, ADR is not a panacea, but simply one more useful tool in the planning and managementof the national forests.

decisionmakers. Discretionary decisions, such as resolution (279). The critique also identified severalhow to balance competing public interests, are reasons for improving the effectiveness of publictypically upheld by the courts unless the decisions participation in the planning process (276):are clearly “arbitrary and capricious’ or the resultof an “abuse of discretion. ’ In such cases, the plans 1.

may withstand administrative appeals and legalchallenges, but not satisfy the participants, who may 2.in turn seek legislative redress for the concerns.

The 1990 internal critique identified three criteria 3.

for measuring the effectiveness of public participa-tion: 1) whether public participation had affected the 4.decision, 2) whether the public and the ForestService were committed to the plan, and 3) whether 5.appeals could be avoided through negotiation andcontinued intensive public participation or conflict

involving more people leads to better, moreacceptable decisions;challenges to the decisions can be avoidedthrough informed consent;challenges (appeals or litigation) can be with-drawn by resolving the dispute;decisions are more defensible if the public hasbeen involved; andtrust and credibility lead to general commit-ment to the decision, and eliminate ‘‘fatal”challenges to implementation.

—


Two assumptions are implicit in these statements.First, public participation is assumed to be moreeffective if all or most of the interested and affectedgroups and individuals are involved. This traditionalForest Service view is a useful but incomplete viewof the public’s role in planning and decisionmaking.The second assumption is that public participation isprimarily intended to achieve the “informed con-sent’ of the participants to the forest plans. Whilethe latter assumption casts the public in a morecollaborative role, the former still emphasizes repre-sentation over accommodation.

Wondolleck (330) identified five factors leadingto successful public participation: 1) building trustamong participants; 2) promoting understanding ofthe issues and conflicts and of the reasons forunderlying decisions; 3) incorporating conflictingvalues; 4) providing opportunities for joint fact-finding; and 5) encouraging cooperation and collab-oration. These factors could provide a tangibleframework with which to measure the success ofpublic participation activities for particular deci-sions. Another observer suggests that plan anddecision effectiveness should be measured by politi-cal feasibility, social acceptability, economic justifi-ability, environmental efficacy, and the technicalcompetency to implement the decisions made (231).

Even the best and most effective public involve-ment cannot resolve all conflicts. Individuals andgroups will continue to differ over the importantvalues to be produced through national forestmanagement. Effective involvement can build trustand promote understanding, but some participantswill be unwilling to compromise or accommodateother values.

Such disputes necessarily lead to alternativemeans—traditionally, administrative appeals andlitigation—for solutions. The Forest Service hasincreasingly used a variety of techniques, collec-tively known as alternative dispute resolution (ADR),to settle disputes outside these traditional avenues.(See box 5-A.) ADR is not a substitute for decisionbuilding or collaborative planning, but can be aneffective tool for some challenges, because theissues and participants tend to be more narrowlydefined in administrative appeals and litigation.

ADMINISTRATIVE APPEALSAND LITIGATION

In recent years, Members of Congress haveexpressed concern that the number of administrativeand legal challenges to forest plans and activitiesindicate that forest planning has “broken down”(262, 263). Congress has been especially concernedover the effects on forest plan implementation—particularly on timber sales-of delays caused byappeals and litigation. These concerns have promptedcalls to modify or streamline the systems foradministrative and judicial review. In an effort toexpedite the administrative appeals process, theForest Service revised its appeals regulations in1989. Others contend that delays because of appealsand lawsuits do not result from flaws in the systems,but rather are symptoms of interest in and concernsover national forest planning and management.Proponents of this argument believe that problemsshould be corrected: 1) through improved agencycompliance with NEPA and NFMA, 2) throughimproved public involvement during plan develop-ment and implementation, and 3) through an end tocongressional management direction (output targetsand resource-specific funding) in annual appropria-tions.

This discussion examines the role of administra-tive appeals and litigation in forest planning andimplementation, assesses the nature of problemsattributed to appeals and litigation, and considersoptions for reform. Administrative appeals will bediscussed separately from litigation, as the problemsassociated with each are different in nature.

Administrative Appeals

The Forest Service is not required by law to offeran administrative appeals process. Nonetheless, theagency has maintained various systems for adminis-trative appeals of agency decisions since 1906(1 16).The systems have varied in formality and complex-ity; some processes have had standing requirementsand have confined the right to appeal to those in acontractual relationship with the agency, whileothers have permitted any person having a grievancewith particular agency decisions to request addi-tional administrative review (155).


The Current Administrative Appeals System

The Forest Service currently has three sets ofprocedures for administrative reviews of agencyplans and decisions. One set, 36CFR251.82, is usedonly for reviews of occupancy and use decisions,and is available only for the affected party. A secondset, 36 CFR 211.16, provides an expedited systemfor requesting review of rehabilitation decisionsfollowing natural catastrophes, such as salvage salesfollowing forest frees. However, most appeals, andconcerns over the appeals process, are under theregulations, 36 CFR 217, governing the appeal ofNEPA-related decisions (including forest plans andactivities under those plans). The following discus-sion focuses solely on this appeals process.

The current system of administrative appealswithin the Forest Service is relatively informal innature. In contrast to the appeals systems in someFederal agencies, the Forest Service appeals processis not adjudicatory in nature-no administrative lawjudges or independent hearing officers review ad-ministrative decisions. The Forest Service’s processis better characterized as an extension of publicparticipation under NEPA and NFMA than as anadjudicatory process, because any interested partycan file an administrative appeal on a forest plan ora NEPA-based decision on a specific project oractivity that flows from a plan.

Appeals are made to reviewing officers, the directsupervisors of the decisionmakers. A second level ofreview can be requested, but the second review isdiscretionary, not a right of the appellant. Forexample, since forest plans must be approved byregional foresters, appeals challenging those plansare reviewed by the Chief of the Forest Service, withdiscretionary review by the Secretary of Agriculture.Likewise, decisions made by the forest supervisorsare appealable to the regional forester, with discre-tionary review by the Chief. The reviewing officerscan fully or partially affirm or reverse the originaldecisions, or may, under certain circumstances,dismiss appeals without review. The reviewingofficers may also request that the deciding officerattempt to resolve or settle the issues in dispute withthe appellants. (See box 5-A.)

Not all decisions are subject to review under 36CFR 217. Only decisions recorded in a NEPAdocument (i.e., a Record of Decision, a DecisionNotice, or a Decision Memo, and the relatedenvironmental disclosures) are subject to appeal

under these regulations. Consequently, appealabledecisions include timber sales, road and facilityconstruction, forest pest management activities,measures to improve wildlife and fisheries habitat,and so forth. However, policy directives, agencyhandbooks, and other guidance for forest planningand management that do not require NEPA docu-ments are not appealable. The regulations also settime limits on filing and processing appeals. How-ever, the review period can be extended, to allow forthe disagreement to be resolved through other meansand for other reasons. Following a fina1 decision onan appeal, an appellant can seek judicial review ofthat decision in Federal district court under theAdministrative Procedures Act.

The Current Appeals Situation

Many members of the public and of Congress areconcerned over the number of administrative ap-peals, and the time and expense involved in process-ing them. In 1989, the General Accounting Office(GAO) reported that the total number of administra-tive appeals filed annually had more than doubledbetween 1983 and 1988, from 584 to 1,298 (252).Much of the increase can be attributed to thecompletion of forest plans; in 1983, forest planappeals accounted for less than 1 percent of theappeals, but in 1988 they accounted for more than aquarter of the total appeals of NEPA-related deci-sions (252). However, appeals of timber sales alsoincreased during this period (252). The total numberof new appeals fell in 1989, but rose again in 1990and increased substantially in 1991 (although 60percent of the increase was attributed to onedecision) (111,285).

The time needed to process appeals also rosesignificantly during the 1980s. The average process-ing time increased from 201 days in 1986 to 363days by 1988, an increase of more than 75 percent,and more than 250 percent longer than is provided inthe regulations (252). Appeals of forest plansgenerally require more processing time than otherappeals (252), and thus some of the increase in timeis the result of the increase in appeals of plans. Inaddition, the backlog of unresolved appeals hasincreased from 64 at the end of 1983 to 830 at the endof 1988, with forest plan appeals accounting for 44percent of the backlogs in 1988, and to more than1440 at the end of 1990 (1 11).

The cost of handling and processing appeals hasalso generally risen. The Forest Service reports that

..—


servicewide costs for appeals (excluding costsincurred by the U.S. Department of Agriculture’sOffice of General Counsel) increased from approxi-mately $2.8 million in 1983 to $10.1 million in 1988(285, 300). Cost data for fiscal years 1989 and 1990indicate that annual costs have decreased to approxi-mately $7.8 million (285).

The increases in appeals appear to be due both toconcerns over the emerging forest plans and toincreasing concerns over timber sales in some areas.Although many appeals are described as harassment,especially when many timber sales on a forest areappealed, most appeals appear to be justified,because 90 percent have been reversed or remanded(300), with additional appeals reversed or remandedat the second-level, discretionary review (285). Themajority of the reversals was because of NEPA-related problems (1 16).

The increase in processing times appears to be dueto problems in complying with the appeals system,rather than with the system itself. GAO (252) foundthat, nationwide, the Forest Service was responsiblefor 94 percent of the total time overruns beyond thebasic time provided for appeals in the regulations.

These problems have resulted primarily from thedifficulties in responding to the growing number ofsophisticated challenges to the environmental analy-ses by the Forest Service (252). Because NEPA haslargely been interpreted through litigation, the For-est Service often must incorporate new standardsand requirements into its pending appeal decisions,causing added delays. Nevertheless, the Congres-sional Research Service (CRS) echoed GAO’sfinding that the appeals system is not necessarily aproblem in and of itself (300).

The administrative appeals process has been avaluable tool for the Forest Service. It has providedan internal mechanism for clarifying the legalrequirements and for testing the soundness ofdecisions and the appropriateness of current policiesand procedures (155). In addition, the appealsprocess can lead to better and more consistentdecisions by encouraging more responsibility andaccountability on the part of deciding officers (1 16).Through appeals decisions, the agency has clarified:1) what decisions are to be made in forest plans, 2)the relationship between decisions made in the plansand those made during implementation, and 3) thestandards for the environmental analyses required byNEPA (155). Appeals have also helped the agency

establish uniform policies to address various issues,such as the nontimber benefits of below-cost sales;the adequacy of a plan’s timber demand analysis;and the appropriateness of the plan’s allowable salequantity (155). Other issues addressed in administra-tive appeals have included guidance on managementindicator species and biological diversity, and ade-quacy of resource monitoring plans (155). Becausethe appeals process has forced the agency to addressand resolve novel and complex questions underNEPA and NFMA in this frost round of plandevelopment, revising forest plans may be easierthan preparing the initial plans (155).

The Forest Service revised its appeals regulationsin 1989 in response to concerns over the growingnumber of appeals filed against final forest plans andto the significant increase in the amount of timeneeded to resolve those appeals, In addition, theForest Service has recently initiated new efforts torectify deficiencies. In January 1991, the agencybegan using its revised forest plan implementationtraining course. The course is designed to addressvarious shortcomings, especially compliance withthe analysis and documentation requirements ofNFMA and NEPA. It is too early to tell whetherthese changes will ameliorate the conflicts surround-ing forest management, and thus reduce the numberof appeals and /or their impacts.

Implications and Consequences of Appeals

The implications of the growing number ofappeals, and of the delays and costs they cause, arenot precisely known. Some speculate that the delaysin processing significantly reduce the amount oftimber available for sale, causing serious economicimpacts for local communities (252). Consequencesfor other resource uses and values are far lesswell-known, and are rarely debated, but should notbe ignored. Nevertheless, the following discussionfocuses on the impact of appeals on timber availablefor sale.

The available evidence does not support theassertion that administrative appeals have signifi-cantly decreased the volume of timber available forsale. GAO (252) concluded that, although impactson timber availability vary by region, appeals offorest plans and activities have not significantlyaffected or delayed timber sale volume nationwide.In fiscal years 1986 and 1987, appeals were filed ononly 6 percent of the total volume of timber offeredfor sale, and less than 1 percent of the total offered


volume was delayed by those appeals (252). Further-more, less than 6 percent of timber volume sold ineach region, and less than 2 percent nationally, wasdelayed in fiscal year 1988 (295). However, thesedata exclude appeals resolved relatively quickly (inthe same year they were filed) and meritoriousappeals, where the agency’s decision was deter-mined to be inadequate. Finally, an analysis of theForest Service timber program from 1969 through1988 showed no significant decline in timberavailability that could be attributed to administrativeappeals (301).

Nonetheless, administrative appeals can affect thetimber sale program. The agency attempts to main-tain an inventory or “pipeline” of approved timbersales that are available as substitutes for appealedsales, thus preventing serious gaps in timber flow.But, for a number of reasons, the inventory ofplanned timber sales with approved environmentalanalyses has declined in recent years (252, 300).According to the Forest Service, this “pipeline”problem has been more acute in some regions-suchas the Northern Region (Montana and northernIdaho)--than in others (252). Appeals, in conjunc-tion with inadequate environmental analyses and areduction in the number of timber sales for which therequisite environmental analyses have been pre-pared, can reduce the flow of timber from thenational forests (301). Furthermore, shortcomings inthe agency timber program data may disguise thereal impacts of appeals on timber availability.

Alternatives to Appealing Plans and Activities

Some have attributed the growth in the number ofappeals and in the processing time to the currentsystem of administrative appeals. It is argued that,because any activity can be appealed, the appealssystem is used to force a reevaluation of forest plandecisions, and to harass authorized uses of thenational forests. However, only NEPA-related deci-sions can be appealed, and thus policy directives andguidelines that can affect forest planning and man-agement are not subject to appeals.

Some have suggested replacing the current ForestService appeals process. One proposal is to establisha more formal, quasi-judicial appeals process, simi-lar to that of the Interior Board of Land Appeals inthe Department of the Interior. This system relies onan administrative law judge (or an independenthearing officer) to review the record on appeal, andarbitrate the solution (300). Another suggestion is to

create a ‘‘super board’ to hear appeals of decisionsmade by the Forest Service, the Bureau of LandManagement, and possibly other land managingagencies, such as the National Park Service and U.S.Fish and Wildlife Service (300).

More typical proposals would change the currentsystem of administrative appeals practiced by theForest Service, rather than revise it wholesale (262).One suggestion is to require appellants to haveparticipated in the planning process or to demon-strate that they would be directly harmed by thedecision. Another proposal, to assure that theappellant is serious about the challenge, is to requirea filing fee for appeals. A third approach is to shortenthe time allowed for filing and processing, therebyreducing the delays caused by appeals. Anothersuggestion is to restrict appeals of activities toconsistency with the plans, although how this fitswith tiering of site-specific activity documentationand programmatic forest plans is unclear. (See ch. 4.)A fifth recommendation is to require negotiationsbefore the reviewing officer examines the appeal.This might eliminate some appeals, particularlythose resulting from misunderstandings, but isinconsistent with successful use of alternative dis-pute resolution. (See box 5-A.) In general, theseproposals restrict access and/or expedite the process,and therefore attempt to eliminate “unnecessary”appeals and accelerate implementation of forestplans and activities.

Changing the current administrative appeals sys-tem might not yield the desired results, however.The GAO findings suggest that the problems are notprincipally due to the system; the delays and timeoverruns were mostly attributable to the agency’sinability to meet the deadlines (252). Furthermore,the agency reversed or modified its decisions in 40percent of the timber sale appeals resolved inWashington, Oregon, Montana, and northern Idahobetween 1985 and 1988 (252). Thus, appeals haveapparently played a significant role in exposinginadequate environmental analyses and documenta-tion. If the current system is modified to reduceaccess or expedite processing, it may simply lead tomore litigation by dissatisfied parties.

The Forest Service revised the appeals regulationsin 1989 to expedite appeals processing. The impactof the changes is not yet fully known, but thesecond-level “discretionary review procedure doesnot appear to be working’ (285). To the extent the


changes do not reduce the number or processing timeof appeals, additional changes may be warranted.The Forest Service is also encouraging the use ofalternative dispute resolution to avoid and/or settleappeals (116). Such a technique can be effective forsettling disputes, and thus is a valuable alternative toadministrative and legal challenges. More effectivepublic participation and more widespread use ofalternative dispute resolution in planning and imple-mentation may result in fewer appeals of plans andprojects.

Ultimately, forest planning and implementationinvolve a host of complex political and technicalquestions. Administrative appeals constitute a valu-able check on Forest Service decisio nmaking byproviding additional admini strative review of some-times highly controversial plans and projects. Ap-peals provide the public with a final administrativeopportunity to question the appropriateness of deci-sions on land use, resource allocation, and standardsand guidelines. As NEPA has been interpreted by thecourts, administrative appeals have helped the agencyto assure that decisions are modified when necessaryto comply with NEPA requirements. Appeals havealso encouraged consistency and accountabilitythroughout the National Forest System. Thus, manyof the features of the current system should beretained. Modifications could expedite the processwhile preserving the general purposes and structureof the system. Solutions that focus on correctingmanagement problems responsible for some of theappeals can improve plan implementation.

Litigation of Plans and Activities

Many in Congress are also concerned that litiga-tion of forest plans and activities has led tointolerable delays in implementing those plans andactivities (263). Some even suggest that appeals andlitigation are often used “offensively” to delayimplementation of the plans for as long as possible(28). This section briefly examines the role of thecourts in the Federal forest planning process, de-scribes the impacts of litigation on forest planimplementation, and discusses some options forreform.

Judicial Review

Neither NEPA nor NFMA expressly provide forjudicial review of forest plans and activities. None-theless, since the passage of these two laws, thecourts have played an increasingly significant role inforest planning and implementation.4 Federal courtsexercise jurisdiction over forest planning under theAdministrative Procedures Act.5 APA authorizesFederal courts to review Federal agency actions,except when a statute precludes judicial review of aparticular action or commits the decision to agencydiscretion. Standing requirements are fairly broad:any person ‘‘suffering a legal wrong because ofagency action, or adversely affected or aggrieved byagency action within the meaning of a relevantstatute, is entitled to judicial review thereof” (5U.S.C. 702). The law once required persons todemonstrate pecuniary damage to obtain judicialreview of agency actions, but such direct financialinterests are no longer necessary.

The 1897 Organic Act and MUSYA vestedsignificant management authority in the ForestService, with relatively few constraints on theagency’s discretion to allocate resources or toregulate the occupancy and use of the nationalforests. Consequently, prior to NEPA and NFMA,most agency actions were essentially immune fromclose judicial review (324). However, NEPA andNFMA contain a number of procedural and substan-tive requirements for forest planning and manage-ment, and thus subject agency decisions to closerscrutiny by the courts. In addition, several environ-mental laws, including the Endangered Species Act,contain provisions authorizing private citizens tochallenge agency actions in court.

Courts can prohibit the Forest Service fromimplementing a plan or pursuing a particular actionif the agency fails to comply with procedural orsubstantive requirements of NEPA and NFMA.However, except for clear violations of statutoryprocedure or substance, courts remain relativelydeferential to agency expertise and discretion, andwill generally uphold agency actions unless they areshown to be arbitrary and capricious or an abuse ofdiscretion. This broad deference is tempered some-

+IFIVIA was passed in an attempt to “get the Forest Service out of the courts and back in the woods,’ but it seems not to have been eff=tive infilifiihng this purpose.

SDis~ct ~o~ j~lction is es~blished ~der tie “FederaJ Question” statute (Act of June 25, 1948, ch- 646 (62 Stat. 930), as amended; 28 U.S.C.1331).


what by the ‘‘hard look’ standard of judicial review.(See ch. 4.)

Implications and Consequences of Litigation

In contrast to the substantial and growing numberof administrative appeals, relatively few ForestService plans and activities are litigated. Of theroughly 500 forest plan appeals finalized in fiscalyear 1989, only 11 ended up in Federal court (300).Furthermore, only 32 timber sales were litigated infiscal year 1989 (300), out of about 500 timber saleappeals and 525,000 timber sales. As of March 1,1991, 6 cases were litigating regional guides (re-gional direction for forest planning), 15 cases werelitigating forest plans, and 7 other cases were basedon NFMA (289). A total of 66 lawsuits challengingtimber sales were pending as of April 17, 1991,including 21 challenges in California and 35 inWashington and Oregon (1 11). Thus, despite claimsthat the growing number of legal challenges to forestplans and activities threatens efficient and effectiveforest management, the existing evidence suggeststhat the Forest Service is rarely sued over its plansand activities.

This is not to suggest that the few lawsuits do nothave substantial economic impacts, particularly incertain regions, such as the Pacific Northwest.Litigation can often be complex and lengthy, and thesubsequent delays may have a significant impact onthe planning and management of the national forestsat any given time. For example, several lawsuits arechallenging the Regional Guide Amendments onSpotted Owls, but at least two6 have been stayedpending resolution of the principal challenge--Seattle Audubon Society v. Robertson, No. C89-160(W.D. Wash.). While the exact impact of the spottedowl litigation is highly debatable, most estimatessuggest that tens of thousands of timber industryjobs could be affected by the decision. On the otherhand, the plaintiffs obviously believe that thelitigation is needed to protect existing values associ-ated with the old-growth forests. What is clear fromthis example is that, while few agency plans anddecisions are litigated, such litigation can haveimmense consequences on agency activities over anextended period.

Possible Reforms for Judicial Review ofForest Service Plans and Decisions

In an effort to curb some of the impacts oflitigation of Forest Service (and Bureau of LandManagement) timber sales, Congress has enacted anumber of riders to appropriations laws that precludejudicial review of certain decisions. Between 1985and 1989, these riders have exempted a broad rangeof management decisions from judicial scrutiny.Riders have been used: 1) to exempt decisions toresell timber returned under the Federal TimberContract Payment Modification Act of 1984 fromjudicial review; 2) to proclaim that environmentalimpact statements for certain timber sales, roads, andother activities “shall be treated as satisfying’ therequirements of NEPA and NFMA and conse-quently not subject to administrative appeal orjudicial review7; and 3) to preclude judicial reviewof challenges to existing plans solely because theplans are outdated or fail to incorporate newinformation (28). Opponents of such provisionscontend that appropriations bill riders circumventthe legal direction for forest planning in NEPA andNFMA, and that solutions to forest planning andmanagement controversies should be made onlyafter careful review by the authorizing committees(143).

Other, more comprehensive reforms have alsobeen suggested (300). One proposal is to legisla-tively encourage, or even to require, the use ofalternative dispute resolution techniques to avoid orresolve administrative appeals and litigation. (Seebox 5-A.) A second option is to eliminate one levelof judicial review; cases that have completed theadministrative review process would be heard di-rectly in Federal appeals courts, possibly with appealdirectly to the U.S. Supreme Court. Another sugges-tion is to develop a bifurcated system, wherebycertain issues (e.g., those involving activities underthe plans) go to the district courts, and others (e.g.,those involving forest plans) go directly to the courtsof appeals. A fourth option is to establish a newFederal Lands Court to hear legal challenges to landand resource management plans and activities forboth the Forest Service and other Federal land

6fVorthwest Forest Resource Coumil V. Robe~son, NO. 89-136FR (D. Oregon), consolidated with WeStern Washington Comercial Forest ~fJ”onCom”ttee v. U.SF.S., No. 89-139 (D. Oregon).

7~e N~& c~c~t Coti of Ap@s held tit pm of ~s rider w~ ~constitutio~. me co~ IBX@Zd co~ess’s ge!sld COIIStitUtiOrd dhOlity

to exempt certain decisions from NEPA and NFMA, but held that the language of the rider was unconstitutional, because it violated the sepamtion ofpowers doctrine by dictating judicial findings as to the sufficiency of the environmental impact statements.


managing agencies. The opportunities and limita-tions of such measures were the subjects of a 2-dayworkshop sponsored by the Congressional ResearchService in 1989, and a more detailed analysis can befound in the CRS Report, Appeals of Federal LundManagement Plans and Activities: A Report on aCRS Research Workshop (300).

To the extent that plaintiffs are successful on themerits of their legal claims, and to the extent thatother lawsuits filed have not generally been frivo-lous or otherwise unwarranted, the current system ofjudicial review seems to be serving its intendedpurpose. Citizens are allowed an opportunity tochallenge the legal basis for agency plans anddecisions. Thus, judicial review provides a valuableindependent check on the agency’s compliance withits legal requirements. At least some Members ofCongress seem committed to preserving citizens’rights to judicial review of forest planning andmanagement decisions:

The rights of our citizens to use the courts toprotect our forests should not be abridged. We mustfind a way to protect our citizens’ rights and ourforests (143).

The available information suggests that the law-suits filed against the Forest Service generally can beattributed to the agency’s inadequate compliancewith NEPA, NFMA, and other laws, such as theEndangered Species Act and the Clean Water Act.Improved compliance with applicable law is likelyto reduce the successful legal challenges to ForestService plans and decisions. Thus, the immediatechallenge is to make the planning process work moreeffectively and efficiently, while preserving thebasic function of the courts.

Much of the current controversy over administra-tive appeals and litigation has arisen because of oneissue—the protection of spotted owls and old-growth forests in the Pacific Northwest. It seemspremature to revise the nationwide judicial reviewprocess for forest planning and management becauseof one admittedly calamitous clash of values.Changing the judicial review process appears to bean attempt to resolve the substantive debate aboutthe fate of old-growth forests, without forcingCongress to choose between forest protection andtimber production. Further study and analysis ofways to expedite forest management-related litiga-tion may be warranted. In the meantime, however, itmay be more pressing to address management-

related problems that have led to agency failures tocomply with planning and environmental laws.

S T A T E , T R I B A L , A N D L O C A L

G O V E R N M E N T P A R T I C I P A T I O N

Other Federal agencies and non-Federal govern-ment organizations have additional requirementsand opportunities to participate in Forest Serviceplanning. The requirements generally revolve aroundState jurisdiction over water and wildlife. In addi-tion, MUSYA and NFMA provide for Forest Servicecoordination with State, tribal, and local govern-ments and other Federal agencies in the planning andmanagement of the national forests. Finally, Statesand local governments have interests in nationalforest management, which may go beyond thetraditional consideration of direct employment andincome generated by national forest outputs.

State Legal Responsibilities

The legal framework governing national forestplanning and management generally recognizesState responsibility for water rights and for fish andwildlife. The 1897 Organic Act specifies that:

All waters within the boundaries of forest reservesmay be used . . . under the laws of the State whereinsuch reserves are situated . . .

State jurisdiction over national forest waters isimplicit in MUSYA, since MUSYA is to be ‘‘sup-plemental to, but not in derogation of, the purposesfor which the national forests were established as setforth in the Act of June 4, 1897.” Furthermore, Stateauthority over fish and wildlife is expressly providedin section 1 of MUSYA:

Nothing herein shall be construed as affecting thejurisdiction or responsibilities of the several Stateswith respect to wildlife and fish on the nationalforests.

Since NFMA directs that land and resource manage-ment planning for the national forests is to beconsistent with MUSYA, NFMA also implicitlyendorses State authority over the waters and thewildlife of the national forests.

In addition to these directions in the 1897 OrganicAct and in MUSYA, the Wilderness Act and theWild and Scenic Rivers Act of 1%8 expresslyprovide for State jurisdiction over water rights andwild animals. Section 4(d) of the Wilderness Actspecifies that:


(7) Nothing in this Act shall constitute an expressor implied claim or denial on the part of the FederalGovernment as to exemption from State water laws.

(8) Nothing in this Act shall be construed asaffecting the jurisdiction or responsibilities of theseveral States with respect to wildlife and fish in thenational forests.

The Wild and Scenic Rivers Act of 1968 providessimilar language for State authority over fish andwildlife, and then provides much more explicitguidance on the relationships between State waterrights and efforts to preserve the wild and scenicqualities of the designated rivers.

In addition to the traditional State authority overwater rights and wild animals, the States set andenforce water and air quality standards, under theClean Water Act and Clean Air Act, respectively. Asnoted in chapter 4, States are authorized to establishstandards more stringent than those imposed by theFederal laws, and Federal agencies must complywith State standards. Thus, Forest Service practicesmust meet the State standards for water and airquality.

Most States also regulate forest practices--silvi-cultural techniques, the percentage of a watershedthat can be clearcut within a specified period, and soforth (114). Since many of these regulations areimposed to achieve water and air quality standards,they may be applicable to national forests as well.Even if the Forest Service is not subject to Staterequirements, however, the Forest Service must, ata minimum, be aware of State forest practiceregulations and their implication for management ofnational forests and adjoining lands.

Cooperation With Other Agencies

Direction for Forest Service cooperation withother government agencies was frost expressed insection 3 of MUSYA:

. . . the Secretary of Agriculture is authorized tocooperate with interested State and local governmen-tal agencies and others in the development andmanagement of the national forests.

RPA reinforced this direction in its requirement toprepare land and resource management plans forunits of the National Forest System; such plans areto be:

. . . coordinated with the land and resource manage-ment planning processes of State and local govern-ments and other Federal agencies.

Section 12 of NFMA adds that “information anddata available from other Federal, State, and privateorganizations’ shall be used in forest planning.And, State, tribal, and local governments can alsoparticipate in national forest planning through thepublic participation provisions of section 6(d),

As with public participation, agency participationand coordination is not guaranteed to influencenational forest decisionmaking:

The opportunity to comment on a proposedfederal action does not necessarily give state andlocal government any meaningful leverage overfederal land use decisions (55).

Furthermore, the 1982 revision of the NFMAregulations reduced the emphasis on Forest Servicecooperation with State and local governments (20).

A complicating factor in intergovernmental coor-dination in forest planning is the variety of Stateagencies with an interest in national forest manage-ment. At a minimum, States typically have oneagency administering water rights and possiblyenforcing water quality standards, another agencyresponsible for fish and wildlife, and a third agencyto manage State forest lands and to regulate forestpractices. These separate agencies often have differ-ent, potentially conflicting interests in nationalforest planning and management, and it can be quitedifficult for the Forest Service to coordinate with theState when the State presents conflicting views.

The State of Oregon recognized this difficulty,and believed that a unified State response wouldhave greater influence on the plans for the nationalforests in the State (20). The State was fortunate tobe able to assemble a small team of experiencedexperts, with ready access to the Governor’s office,to achieve a unified response. In addition, the StateForestry Department and Oregon State Universityhad already begun a cooperative assessment of thetimber resources on all timberlands in the State.Subsequently, the Governor and the Oregon con-gressional delegation were able to forge a short-termlegislative compromise between timber interests andenvironmentalists for continuing timber sales de-spite the ongoing litigation over spotted owl protec-tion. Finally, the ongoing concern about spotted owlprotection had led to a study of timber management

—.


options for all landowners. The State’s wealth ofnew data on timber resources and timber manage-ment, and its ability to reach a compromise amonginterests, greatly contributed to its success in influ-encing the forest plans for the national forests inOregon (20).

While the State of Oregon benefited from uniquecircumstances, its experience illustrates that a uni-fied response among State agencies provides clearerinput, and thus makes a direct Forest Serviceresponse more feasible. If other States wish toinfluence national forest planning, coordinating thepositions of the various agencies and providing aharmonious stance may be necessary.

Local Concerns

State and local governments also have directinterests in the management of the national forests.First, the Forest Service returns 25 percent of itsgross revenues to the States for use on schools androads in the counties where the national forests arelocated. Thus, State and especially local govern-ments have a financial interest in national forestmanagement that generates revenues. (For a morethorough discussion of this concern, see ch. 8.)

In addition, elected State and local officials arerepresentatives of the people, and thus are surrogatesfor the public acting collectively. The public ascitizens is an important role (231, 239), but theForest Service typically views the public as individ-ual interests. State and local government participa-tion in forest planning provides one means forincluding this important aspect of the public’sinterests. (See ch. 5.)

Finally, State and local governments have a stakein maintaining the employment and income of theircitizens. Activities in the national forests supportlocal jobs, and debate over community stabilityreflects this interest. (Again, see ch. 8.)

The Federal Government may also have aninterest in maintaining the economic stability oflocalities. Under the “fabric-of-government” the-ory, the multiple levels of government work cooper-atively to support the interests at all levels (312).This position is based on the vision that local andregional economic health and vigor is in the nationalinterest, and the Federal Government is, therefore, apartner in influencing State and local economies. If

one accepts the fabric-of-government theory, thenthe Forest Service has a direct interest in cooperatingwith State and local governments to maintain theireconomies. (The alternative view, the ‘‘assignment-of-powers’ theory, asserts that each level of govern-ment has separate and distinct responsibilities. Stateand local economies are viewed as State and localresponsibilities; national interests pertain only tobenefits for all Americans or at least multi-Stateregions.)

The joint management of forest ecosystems alsogenerates State and local interest in national forestmanagement. National forests are part of theseecosystems, and their management should be coor-dinated with the management of other forested landsto protect ecosystem health and productivity. Someecosystem requirements, such as wildlife migrationcorridors, particularly need some form of coordina-tion among landowners.

States not only have an interest in coordinatedforest management, they also have some responsi-bility for, and some expertise in, such management(20). As discussed above, many States regulateforest practices on at least State and private lands,Many States also have statewide forest resourceplanning programs, funded in part through the ForestService’s Cooperative Forestry Assistance Program(in the State and Private Forestry Branch of theagency) (102, 103). These State forestry activities—forestry regulation and statewide resource planning—implicitly recognize that forests are ecosystems.Therefore, States have some particular expertise andinterest in coordinating forest management, andsuch expertise should be given a full hearing innational forest planning and management.

SUMMARY AND CONCLUSIONS

Public participation is essential to developingforest plans that the public will accept as appropriatemanagement direction for the national forests. Pub-lic participation operates at several stages of plan-ning and implementation: during the developmentand revision of forest plans; in implementing thoseplans; and when requesting administrative and/orjudicial review of agency plans and decisions.Finally, the public participates through the coordina-tion of Forest Service planning and decisionmakingwith State, tribal, and local governments.


Public Participation

Public participation in Forest Service planningand decisionmaking is required bylaw. The Multiple-Use Sustained-Yield Act of 1960 (MUSYA) re-quires that management ‘best meet the needs of theAmerican people,” which can only be determinedby identifying the public’s values and desires. TheNational Environmental Policy Act of 1969 (NEPA)requires agencies to inform the public about thepossible environmental impacts of their decisions,including the public as a participant in decisionmak-ing rather than as a mere recipient of information.

Congress reinforced the public’s right to partici-pate in Forest Service planning and decisionmakingin the National Forest Management Act of 1976(NFMA). Senator Humphrey, the chief sponsor,described the public as advisors to agency plannersand decisionmakers. NFMA also authorized the useof advisory boards in planning and managing thenational forests, but the Forest Service has not usedthis authority.

Although the Forest Service has long included thepublic in its planning and decisionmaking, thepublic remains critical of agency efforts. Recentstudies have shown that the public does not under-stand why the agency makes the decisions it does,and believes it has little influence on the agency.Thus, the public perceives that the Forest Service hasfailed in its public participation responsibilities.

One explanation for the perceived failure is thatthe Forest Service model of participation is based ondue process, on receiving full and equal representa-tion of various views and values. Thus, each interestis forced to argue the ‘‘rightness’ of their positionand the ‘‘wrongness’ of other positions. Thisprocess is divisive and promotes conflict and distrustamong the interests and with the agency. It alsomeans that “success’ is measured in numbers ofviews, participants, and opportunities. Forest Serv-ice failures are also blamed on insufficient data onwho the participants are and how they prefer toparticipate. Others suggest that the agency resistsmeaningful participation because its traditional au-tonomy and professionalism inhibit listening to‘‘nonexperts. Finally, some observers have notedthat public participation is limited by the focus onresource outputs and budgeting and the lack ofmanagerial incentives for effective participation.

The Forest Service has had numerous successes ininvolving the public in national forest planning.Typically, successful managers have a clear idea ofwhy the public is to be involved-to determine whatis truly in the publics’ interests. Furthermore, theyoften understand the goals of public participation—to gain insights into the public’s values, to providean early warning of potential problems, and to beaccountable to the public. However, the ForestService also needs a model of public involvementthat recognizes the various roles of the public: asindividuals, as organizations, as producers, as con-sumers, and as citizens. This broader view of thepublic can lead to open discussions and joint under-standing of situations, limitations, and possibilities.

Such a model of public participation leads to aquite different approach to planning and decision-making. Under this approach, sometimes referred toas open decisionmaking or as decision building, theagency and the public are both contributors to deci-sions. Decisions are reached through dialogue andmutual deliberation, with sustained interaction tofind the common ground and to build acceptabledecisions. This model also suggests that, instead ofbalancing interests and adjudicating conflicts, For-est Service managers become leaders in organizingand facilitating debate and public analysis. Thisapproach not only involves the public in decision-making, it helps the participants to understand whycertain decisions are reached. There is no simpleformula or technique for open decisionmaking ordecision building. The best means of involving thediverse publics will vary regionally and amonginterests.

The Forest Service has recognized the need forcriteria of successful participation, and has sug-gested that success includes decisions affected bythe public, public and agency commitment toimplementing the plan, and fewer administrativeappeals. Others have suggested that key elements ofsuccess are mutual trust and understanding.

It will not always be possible to develop plans anddecisions that are acceptable to all parties. Alterna-tive dispute resolution techniques can help to resolvesome differences. Such techniques, used in conjunc-tion with open decisionmaking/decision building,could reduce the conflicts over national forestmanagement. Nonetheless, the traditional techniquesof administrative appeals and litigation will still be


used occasionally, when differences cannot beresolved satisfactorily.

Appeals and [litigation

Many members of the public and of Congressbelieve that administrative appeals and litigation arepreventing the implementation of national forestplans, and that this indicates the failure of theplanning system. The number of administrativeappeals-internal, relatively informal reviews at therequest of a member of the public—more thandoubled between 1983 and 1988, and the averageprocessing time also increased substantially. Muchof the increase can be directly attributed to thecompletion of forest plans, although the number oftimber sales being appealed has also risen, and theForest Service has not been meeting the regulatorydeadlines for processing appeals. However, theappeals system has been useful for helping theagency to cope with evolving standards for meetingthe requirements of NEPA and NFMA.

The increasing number and processing time ofappeals has been described as a problem, particu-larly by delaying the sale and harvest of timber.Although evidence of significant delays is lacking,the aggregate data available could be maskingserious local problems.

Various proposals have been offered to addressthe apparent problems of Forest Service administra-tive appeals. Some would overhaul the systemcompletely, replacing the current, informal systemwith a more structured, formal system akin to that ofthe Department of the Interior’s Board of LandAppeals. Most suggestions would alter the currentsystem less radically, typically either by restrictingaccess to appeals through standing requirements ora filing fee, or by expediting processing throughshorter deadlines or required negotiations. However,such options could be counterproductive, if theresult is fewer appeals but more litigation.

Litigation—judicial review of agency decisions—can lead courts to prevent the agency from imple-menting plans or pursuing actions, if the decision-making did not comply with the procedural andsubstantive requirements of NEPA and NFMA.Relatively few administrative appeals of ForestService plans or decisions actually lead to litigation.Currently, only 28 cases are pending over NFMA

decisions, and only 66 cases are pending over timbersales. Nonetheless, few lawsuits can have immenseconsequences. The largest and best known exampleis the case over the spotted owl supplement to thePacific Northwest Regional Guide, for NFMAplanning in Washington and Oregon. This casecould affect tens of thousands of jobs in the PacificNorthwest, but the plaintiffs assert that the guidecould allow the extinction of the owl and theelimination of other values associated with theold-growth forests the owls inhabit.

Some problems resulting from litigation of ForestService planning and decisionmaking have beenaddressed with riders on the annual Forest Serviceappropriations to preclude judicial review of spe-cific decisions or on certain bases. Such riders havebecome increasingly controversial, as the authoriz-ing committees recognize the increasing use ofappropriations to establish management directionfor the national forests. Other reforms have beensuggested, such as requiring the use of alternativedispute resolution techniques, eliminating one levelof judicial review, developing a bifurcated system(with some decisions reviewed by district courts andothers reviewed initially by appellate courts), orestablishing a new Federal Lands Court.

However, one must be careful in revising thecurrent system of judicial review for Forest Serviceplanning and decisionmaking. Successful litigationsuggests that the Forest Service is not complyingwith its legal requirements. If the requirementscannot be met, Congress should consider changingthe laws, not simply preventing the laws from beingenforced. Furthermore, much of the current contro-versy is over the spotted owl. Some have suggestedthat Congress is attempting to avoid the appearanceof choosing sides in the debate, and is attempting toresolve the substantive issue by altering the systemof judicial review. It maybe inappropriate to changethe system because of one, albeit monumental,lawsuit.

State and Local Government Participation

State, tribal, and local governments have particu-lar interests in national forest planning and manage-ment. States have jurisdiction over and responsibil-ity for certain resources, such as water rights and fishand wildlife management, and the laws governing


Forest Service planning and decisionmaking pre-serve these State rights. Furthermore, many Statesregulate forest management practices, at least onState and private lands. Thus, cooperation betweenthe Forest Service and the relevant State agencies isan important part of national forest planning.

MUSYA and NFMA require the Forest Service tocooperate with State and other government agencies.However, cooperation does not provide the States orother governments with any meaningful leverage toinfluence plans or decisions. The State of Oregon,through a fortunate combination of people andcircumstances, was relatively successful at influenc-ing national forest plans. The State coordinated itsvarious agencies for water quality, forest practices,fish and wildlife management, etc., and thus pro-vided harmonized responses to the forest plans. Thesuccess of their efforts strongly suggests that con-

sistent, coordinated State responses to Forest Serv-ice plans and decisions are more likely to beinfluential than independent agency responses.

Finally, State and local governments have addi-tional interests in maintaining their economies andin sustaining ecosystems. The fabric-of-governmenttheory suggests that the Forest Service is a partner insupporting regional and local economies. Further-more, State and local governments represent thepublic acting as citizens, and thus represent particu-lar interests that are relevant to land and resourcemanagement planning. Finally, coordination amongthe various landowners is necessary to sustainecosystems. States, through their forest practiceregulations and their State forest resource planning,have expertise and knowledge to offer in coordinat-ing management of multiple landowners.

Chapter 6

Biological Dimensionsof Forest Planning

ContentsPage

Inventory and Monitoring in a Strategic Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Resource Inventory and Monitoring in the Forest Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Resource Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Inventory Requirements in NFMA and the Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Problems With Inventory Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Summary and Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Resource Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Monitoring Requirements in NFMA and the Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Problems With Monitoring Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Summary and Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Special Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. .. .. .. O.. ... ....O..Biological Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Biological Diversity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Indicators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Box

109109111111112114115115115117117117119121123

Box Page6-A. Example of Levels of Monitoring on a Nationa1 Forest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116

TableTable Page6-1. National Forest Plans Sampled for Inventory and Monitoring Reviews . . . . . . . . . . . . . . . . 112

Chapter 6

Biological Dimensions of Forest Planning

INVENTORY AND MONITORINGIN A STRATEGIC PLAN

Strategic planning requires systematic monitoringof resources to assess trends and manage accordingto public desires. An inventory of resources isnecessary to provide baseline data on what exists onthe forests. Monitoring leads to a continuous recordof information on the quality and quantity ofresources and permits an evaluation of trends.Monitoring activities can be adjusted to respond totrends, changing interests, and emerging issues.

The Forest and Rangeland Renewable ResourcesPlanning Act of 1976 (RPA) and the National ForestManagement Act of 1976 (NFMA) call for anintegrated approach to resource management:

In the development and maintenance of landmanagement plans . , . the Secretary shall use asystematic interdisciplinary approach to achieveintegrated consideration of physical, biological,economic, and other sciences (section 6(b)).

The integrated approach was to minimize duplica-tion of data gathering and to facilitate consideringinteractions among resources in developing forestplans (174). Some researchers consider inventoriesaimed at collecting data on one resource, such as atimber survey, to be multiresource inventories,because some of the collected information might beuseful to an analysis of other resources, such aswildlife habitat. Lund (156), however, limits mul-tiresource inventories to those with planned integra-tion. He defines an integrated inventory system withsix characteristics: 1) adaptable to a wide range ofecological conditions; 2) easy to use at differentlevels of management; 3) replicable and suitable forstatistical analyses; 4) flexible enough to fulfilldifferent information needs; 5) adaptable to amonitoring program; and 6) suitable for use withautomated data processing. An integrated resourceinventory also includes a multiresource componentthat emphasizes interactions among variables (174).

Because planning under NFMA calls for anintegrated approach to resource management, theForest Service must structure inventory and moni-toring programs around integrated multiresourcecharacteristics. This is not an easy task. An inven-tory and monitoring system that exhibits integratedmultiresource characteristics will result, by its verydesign, in compromises in the gathering and analysisof data (174). For example, rangelands are definedby several physical features (topography and soilconditions) as well as a suitability factor for grazingby domestic livestock or wildlife. To inventory andmonitor adequately the range-forage resource, theForest Service must make specific decisions regard-ing which elements or combination of elements(interactions) to address, including specific methodsof inventory, data analysis, and model development(174). The many decisions required to define theresource characteristics and ensure an integrateddesign make it extremely difficult to strive for anintegrated multiresource inventory and monitoringprogram.

R E S O U R C E I N V E N T O R Y

A N D M O N I T O R I N G I N

T H E F O R E S T P L A N S1

Inventory and monitoring require the collection ofinformation. When data collection is planned effi-ciently, inventory information can also be used inmonitoring, and monitoring can be used to updateand improve inventories (137). The primary differ-ence between the two activities is that inventoriesare used to guide plan development, while monitor-ing is used to measure plan implementation andeffects. An inventory might include collecting dataon sizes and types of trees, or number of eagle nestswith young. Monitoring would then include main-taining the records of tree size and type, or numberof eggs hatched over time, to permit a determinationof trends-in annual growth rates or hatchingsuccess. Both resource inventory and monitoring areessential to the evaluation of resource conditions on

10TA did not ~ t. revlcw all Plain for mtio~ forests. ~ ~dition to tie traditio~ pubfish~ ~ormation ~d discussions ad interviews, however,

OTA did contract for background papers that reviewed plans for 11 national forests in depth and several others in less detail. Eight of the indepth planswere chosen randomly to represent each of the eight Forest Service regions ( 137). Three additional case studies were conducted, one each in the eastern(238), southwestern (166) and northern (42) regions. The selection of these forests was not to point to particularly good or bad plans, but to illustrateproblems that are inherent in many of the plans.

–lo9–


the national forests and to the proper implementationof management activities.

Since NFMA was enacted and the regulationshave been in effect, several problems have surfacedin relation to inventory and monitoring activitiesconducted by the Forest Service. Problems commonto both inventory and monitoring are discussedbelow. Problems unique to data gathering or tomonitoring programs are then addressed in separatesections.

Forest inventory and monitoring have been criti-cized for failing to produce an integrated, multi-resource program. The scientific community, whichhas participated in long-term discussions on whatconstitutes appropriate inventory and monitoring, isas much to blame for this failure as the ForestService (174). Although there is general agreementon the need for rigorous application of propersampling design and statistical analyses, ‘‘few clearguides exist in the scientific literature on howspecific resources should be inventoried and moni-tored” (174). Advanced academic training andextensive research experience are required to designinventories, analyze inventory data, and establishmonitoring programs that will achieve an appropri-ate standard. The scientific community, however,has not agreed on the makeup of a “rigorous andproper’ sampling design. And, the Forest Servicehas not been quick to institute an integrated multi-resource program, because specific designs andanalytical techniques have not been established, andbecause the agency has not had enough experts todesign such programs.

Slowness in developing an integrated multi-resource inventory and monitoring system also canbe blamed on the Forest Service’s historical empha-sis on inventory of the timber resource. Beforepassage of RPA and NFMA, inventorying by theagency concentrated primarily on ways to maximizetimber production (162, 174). Inventory and moni-toring programs used by the Forest Service todayattempt to include integrated, multiresource invento-ries but are designed largely by retrofitting timber-oriented programs (174).

Even in 1986, in the absence of final Forest Plans,functional timber management plans were stillprepared and were still the basis of most day-to-daymanagement activities (122).

Retrofitting a timber-focused program to includeintegrated, multiresource inventories has persistedin forest planning for three reasons. First, agencypersonnel have training and experience in specifictechniques and are slow to change (174). Second,substantial changes in sampling design may impedethe use of previously collected data. Finally, theoriginal version of FORPLAN, the primary forestplanning model, was not designed to address forestmultiresource interactions. (See also ch. 7.)

Another shortcoming of forest inventory andmonitoring programs has been the failure to addressecosystem processes, and the lack of attention toappropriate spatial and temporal scales for examin-ing ecosystems. The enormous complexities ofnature-soil formation, plant growth and succes-sion, decomposition by fungi and bacteria, modifi-cations by invertebrates and vertebrates, and naturalcatastrophes, especially forest frees-should be ac-counted for in an inventory and monitoring program(174). In the past, many ongoing resource invento-ries were designed to furnish information about thecondition of a single resource for a small land area,such as a timber sale or a report on range orwatershed improvement needs (166). In contrast,inventory data for a forest plan must provideinformation on a forestwide basis, often a millionacres or more, for decisions that need to be made inthe planning process. An inventory of timber standsdoes not address ecosystem elements. Aggregationof timber stands into larger units will also notaddress interactions that go beyond the stand bound-aries, such as water flows and wildlife movements.In addition, appropriate temporal scale must beadopted for evaluating ecological systems. Forexample, sampling wildlife in only one season (e.g.,summer only or winter only) will bias data collectionto breeding or wintering requirements. Data for aforest plan must, therefore, be collected at theappropriate scale (in time and space) and be moreorganized-by resource as well as by site, date ofinformation, and possible interrelated effects-thandata collected under a nonintegrated approach forsmall areas (166)0

Data collection and monitoring by the ForestService has also been criticized for not beingsensitive to statistical requirements for effective dataanalysis. Critics have pointed to several key compo-nents for statistical evaluation of data: clear identifi-cation of variables to be evaluated; accuracy andprecision of variable estimates; and adequacy of

Chapter 6--Biological Dimensions of Forest Planning ● 111

sample sizes (174). The weaknesses in statisticalvalidity of Forest Service inventories and monitor-ing have been attributed to the lack of biometricianson the planning teams. 2 This lack of expertise hasresulted in the inability to improve data collectionand analysis for accurate reporting of resourceconditions and trends (174).

Problems with inventory and monitoring activi-ties of the Forest Service are made worse by the lackof adequate funding (166). Monitoring is expensiveand funding has not been provided for the systematiccompletion of forestwide inventories for most re-sources. For example, range managers on a nationalforest may use a variety of range inventories.Analysis of some allotments may have been com-pleted recently and include field measurement offorage use. Other allotments may have been invento-ried many years ago, using different inventorytechniques. Some allotments may never have beeninventoried (166).

Verner (304) provided a worst case scenario inresponse to the question, ‘‘Can we afford reliablemonitoring systems?” He used the pileated wood-pecker (Dryocopus pileatus) to illustrate that thecost of monitoring annual changes in abundance ona particular forest for this species could exceed $1million per year. The potentially high costs ofmonitoring activities, and the lack of adequatefunding, require managers to analyze costs carefullyas the monitoring plans are being developed.

RESOURCE INVENTORY

Inventory Requirements in NFMAand the Regulations

NFMA directs the Forest Service to obtain‘‘inventory data on the various renewable resources,and soil and water’ (section 6(g)(2)(B)) and to basethe forest plans on those inventories (section 6(f)(3)).NFMA contains several planning requirements thatimply the need for resource inventories. For exam-ple, plans are required to provide ‘sustained yield ofproducts and services” (section 6(e)(l)) by gener-ally limiting timber harvests to ‘‘a quantity whichcan be removed . . . annually in perpetuity’ (section13(a)). To meet this requirement, a national forest

must have inventory information on the stocks andgrowth rates of its trees.

Other planning requirements that depend on datafrom resource inventories are associated with landcapabilities. Plans are required to ensure that timberis harvested only under certain conditions: lands thatare suited for timber production considering physi-cal, economic, and other pertinent factors (section6(k)); lands where adequate reforestation can beassured within 5 years after harvest (section 6(g)(3)(E)(ii)); and lands where soil, slope, or otherwatershed conditions will not be irreversibly dam-aged (section 6(g)(3)(E)(i)). In developing the tim-ber program, the forest must provide for the protec-tion of water bodies ‘‘where harvests are likely toseriously and adversely affect water conditions orfish habitat” (section 6(g)(3) (E)(iii)). Plans mustalso provide for the diversity of plant and animalcommunities based on the suitability and capabilityof the specific land area (section 6(g)(3)(B)). NFMAalso requires the plans to be revised when conditionshave significantly changed. Again, developing andmaintaining resource inventories can facilitate ful-filling these requirements.

NFMA’s requirements for resource inventoriesare reiterated and expanded in the regulationsgoverning forest planning issued by the ForestService in 1979 and revised in 1982:

Each Forest Supervisor shall obtain and keepcurrent inventory data appropriate for planning andmanaging the resources under his or her administra-tive jurisdiction. The Supervisor will assure that theinterdisciplinary team has access to the best avail-able data. This may require that special inventoriesor studies be prepared. The interdisciplinary teamshall collect, assemble, and use data, maps, graphicmaterial, and explanatory aids, of a kind, character,and quality, and to the detail appropriate for themanagement decisions to be made. Data and infor-mation needs may vary as planning problemsdevelop from identification of public issues, man-agement concerns, and resources use and develop-ment opportunities. Data shall be stored for readyretrieval and comparison and periodically shall beevaluated for accuracy and effectiveness (36 CFR219.12 (d)).

The regulations require: specific inventories ofroadless areas (36 CFR 219.17); fish and wildlife

2J. Vemer, us. D~~rn~~t of Agri~~e, Forest se~i~, Fores&y Sciences hbomtory, Fresno, CA, personal communication, October 1990.

qB~ed largely on Krahl et al. 1990 (137).


populations (36 CFR 219.19); forage production andrange conditions (36 CFR 219.20(a)); recreationopportunities (36 CFR 219.21 (a)(l-3)); visual re-sources (36 CFR 219.21(f)); water and watershedconditions (36 CFR 219.23 (a),(b), (c),and (e)); cul-tural and historic resources (36 CFR 219.24(a)(l-6)); unique biological and geologic areas (36 CFR219.25); and diversity of plant and animal communi-ties (36 CFR 219.26). Like NFMA, the regulationscontain several planning requirements that imply theneed for resource inventories: determination ofmaximum physical and biological production poten-tials (36 CFR 219.12 (em)); land suitability andassurance of reforestation for timber production (36CFR 219.14 (a)(l-4)); culmination of mean annualincrement of growth of timber species (36 CFR219.16 (a)(2) (iii)); and sustained yield of timberharvests (36 CFR 219.16(a)(2)(iv)).

Problems With Inventory Data

Although NFMA and the implementing regula-tions require national forests to base initial andsubsequent planning efforts on resource inventories,direction is not provided on how ongoing invento-ries should be used in planning (137, 238). Someplans refer to inventories in their goals and objec-tives and monitoring plans, or even include inven-tory activities as a subcategory in each resourcesection of their standards and guidelines. Other plansmay contain little or no reference to resourceinventories, or may list only new inventories thatwould be required for plan implementation.

A report by the Committee of Scientists reviewingproposed NFMA regulations considered adequateinventory data essential to sound forest plans:

No plan is better than the resource inventory datathat support it. Each forest plan should be based onsound, detailed inventories of soils, vegetation,

water resources, wildlife, and the other resources tobe managed (48).

Despite the critical role of good inventory data, thecommittee found that data for most resources in theplans were insufficient for making managementdecisions.

Nonetheless, the Forest Service has made prog-ress in developing inventories in the 15 years sinceNFMA was enacted. A current agency handbookprovides guidance on resource inventories, andidentifies five objectives for Forest Service invento-ries: 1) determine the condition, production, poten-tial, and amounts of key ecosystem components orprocesses; 2) identify a benchmark for describing thecurrent physical and biological situation and forforecasting projected changes; 3) provide ecologicalinformation as a basis for protection and manage-ment decisions about land and resource uses, pro-posed plans, or actions; 4) consider conditions andtrends that either change the demand for resources orthat are affected by resource decisions; and 5) referall inventory information to specific units of land(284).

These general objectives, however, have notensured that forest planning will address pastproblems with inventories, such as gaps in informa-tion on plants and nongame and invertebrate animals(174, 238, 321). For example, of eight forestsexamined, only the Eldorado National Forest identi-fied inventories used in initial plan development(137). (See table 6-l.) Even in this case, the data andmethods used to conduct the inventories were notidentified. Major problems with inventories on thenational forests are discussed below in relation toquantity, quality, and timeliness of inventory data,and compliance with NFMA requirements.

Table 6-1--National Forest Plans Sampled for Inventory and Monitoring Reviews

Draft FinalForest Region State plan planBitterroot . . . . . . . . . . . . . . . . . . . .San Juan . . . . . . . . . . . . . . . . . . .Coconino . . . . . . . . . . . . . . . . . . .Dixie . . . . . . . . . . . . . . . . . . . . . . .Eldorado . . . . . . . . . . . . . . . . . . . .Siskiyou . . . . . . . . . . . . . . . . . . . .Nantahala and Pisgah . . . . . . . .Nicolet . . . . . . . . . . . . . . . . . . . . . .

12345689

MontanaColoradoNew MexicoUtahCaliforniaOregonNorth CarolinaWisconsin

19851982198519851986198719841984

19871983198719861989198919871986

SOURCE: L. Krahl, H. Swertson, and H.H. Carey, The hnpads of NfM4 on Resource /inventories andknitotig onthe NMorta/Forests, OTA background paper, Oct. 31, 1990.

Chapter 6-Biological Dimensions of Forest Planning ● 113

Quantity and Quality of Inventory Data

Absence of inventory data is a problem on manyforests. Some timber inventories have been basedprimarily on air photo interpretation. Critics claimthey contain little information on growth rates andlocation of stands, little field reconnaissance, errorsin classification of plots, and questionable acreagefigures (42). For example, the Cibola NationalForest defined and mapped areas based on soilcharacteristics, potential natural vegetation (PNV),and slope (166). Field data were used for 20 percentof the forest, while the remaining 80 percent wasdelineated using aerial photos, limited site examina-tion, and extrapolation from existing inventories.Thus, field measurements required for accurate andreplicable location of unit boundaries were availablefor only a small number of areas. Accuracy andreplicability could have been improved if more timeand funding had been available. Improvements inthe next planning cycle are likely because of moreextensive survey work being completed on thisforest (166).

In other cases, timber data may be inadequatebecause timber plots from early inventories may notbe remeasured to verify growth rates (42). Growthrates for timber stands may simply be predicted bycomputer programs without field verification (42).Forests also may be classified by site productivityclasses rather than present vegetation—a misleadingclassification system for designating timber standsuitability (42).

As with other resources, inventories on soils andrangeland resources vary in quality and quantity.Some national forests have designed their soilinventories to provide information over large landareas quickly and have relied on air photo interpreta-tion with limited field reconnaissance. Inventoriesdesigned in this way require supplemental informa-tion for use in high intensity or small area planningprojects (42). For example, the Idaho PanhandleNational Forests grouped all soils information intofour categories (sensitive or nonsensitive soils withslopes over or under 40 percent). The environmentalimpact statement noted that a greater number of‘‘specific land types would provide more accurateresponse units, ’ but that FORPLAN was incapableof handling more types.

Variations in range resource inventories are ex-plained by lack of funding as well as amount ofrangeland present on the forest, and thus the priority

in forest inventory tasks (166). For example, only asmall portion of the Idaho Panhandle forests—about7500 acres—is managed for domestic grazing (42).The range inventory for these forests, as described inthe forest plan, is designed to provide usefulinformation about the range resources. However, thedescriptions of range allotments were labeled as“vague and subjective’ (42).

Likewise, the Forest Service has described data onrange condition on the Cibola National Forest as‘‘available but inadequate’ and has criticized pastdata collection strategies for being based on reportsthat ‘‘went back several decades and are notconsistent with present methodologies” (166, 270).

Data quality in the Cibola forest plan generallyhas been poor (166). The Cibola forest plannersstated that it is not Forest Service policy to doresource inventories specifically for land manage-ment planning. Rather, the forest relies on compilinga database for the plans by extrapolating anddisaggregating data collected for other managementpurposes. The forest is, however, now developingtwo data sets based on field inventories. One, fortimber, examines all commercial timber stands. Thesecond is a terrestrial ecosystem survey examiningsoil characteristics, potential natural vegetation, andslope. The forest is also working on implementing ageographic information system in anticipation ofmarkedly improved data.

Timeliness of Inventory Data

Delays in forest plan completion may lead to asmuch as a 10- to 15-year gap between the date thedata were collected and publication of the plan(137). Six of the forests in table 6-1 used timberinventories that were at least 5 years old when thedraft plans were released. The timber inventory wasup to 8 years old in the draft plan for the Siskiyou and15 years old in the draft plan for the San Juan.

Additional problems exist with respect to timeli-ness of data collection. Forest Service planning rulesadopted in 1979 stated that”. . . existing data will beused in planning unless such data is [sic] inade-quate” (36 CFR 219.5). Forest Service Manualprovisions issued in March 1980 added to this rule:

Where additional data and information collectionis necessary, it must be limited to that which isessential for analysis and decisionmaking in theplanning process (267).


Under direction of the Chief of the Forest Service torely substantially on existing data, some forestspostponed new inventories, and used existing datathat were not comprehensive enough to aid planningand management decisions (42). Although the 1982revision of the forest planning rules eliminated thestatement that “existing data will be used,” by thattime, some forests were committed to using existingdata in preparing their plans (42).

Compliance With Inventory Requirements

Several plans from forests in table 6-1 failed tocomply with inventory requirements in NFMA. Oneof the critical requirements is the inventory ofroadless areas. Only one (the Bitterroot) provided foran annual inventory of roadless areas and changes inwilderness characteristics. Staff on the other forestsstated that, although they did not have systematicinventories of wilderness characteristics in roadlessareas, they did include assessments of these charac-teristics in the National Environmental Policy Act(NEPA) documentation for proposed projects in thewilderness areas (137). The forest staff stated thatthe inventory conducted under the second roadlessarea review and evaluation (RARE II) was suffi-cient, and that project-specific assessments wereadequate to maintain the inventory (137).

The sufficiency of the RARE II inventories hasbeen questioned, however. In California v. Block(690 F. 2d 753, 9th Cir. 1982), the court held thatRARE II failed to meet the NEPA requirements forsite-specific evaluation of the consequences ofrecommending that areas be available for non-wilderness management. This ruling required forestplanners to reevaluate RARE II roadless areas forwilderness. For the Idaho Panhandle National For-ests, the Forest Service stated that the analysis ofroadless areas had a substantial effect on theoutcome of the plan (282). However, one criticclaimed that the analysis had little effect on theforest plan because many distinguishing attributes ofthe forests’ roadless areas were not identified inFORPLAN (42).

Only two of the plans from the eight forests intable 6-1 (Siskiyou and Coconino) prescribed inven-tories for threatened fish habitats, and none identi-fied inventories of waters threatened by timberharvests (137). Interviews with forest staff sug-gested that, although the inventories were notprescribed in the plans, conditions of aquatic re-

sources are inventoried, especially within projectareas.

Summary and Conclusion

The poor quality of national forest resourceinventories, the lack of coordination among variousresource-specific inventories, and the inappropriateuse of information in decisionmaking contributed tothe enactment of NFMA (137). The situation on theforests since NFMA was enacted has not changedsubstantially. Absence of data along with poor dataquality, limited collection of new data, out-of-dateinformation, and failure to comply with the law areinherent in many of the resource inventories of theforest plans. These problems are magnified by datathat are poorly documented and inaccessible. Someforests have not set up a well-organized, easy-to-access data system that the public could use to obtainbackground information on resource inventory oreven to know what inventories are maintained. Fewforests summarize their resource inventories in adocument that is appropriate for reading by thegeneral public (238).

A critical first step in the planning process is toidentify key resource management decisions anddefine data needs. The Forest Service, in trying tomake management decisions based on limited data,must examine available knowledge, combine it withexpert opinion, and make predictions about theconsequences of alternative management actions(247). While the national forests rarely have all theinformation that might be desirable to make amanagement decision, and certainly are in need ofmore and better data to assist in managementdecisions, it is important that the existing data areaccessible and applied to appropriate managementsituations. Major roadblocks-an emphasis on tim-ber inventory as well as little funding-have limitedthe scope of resource inventories. Priorities can beset by identifying significant gaps in resource data.New inventories can be designed to provide missinginformation, with special and unusual data needsmet with additional surveys and inventories. Inven-tory data that do exist must provide baselineinformation for identifying and examining impactsof activities conducted on the forests. The inventorydata must be organized and presented in a meaning-ful, usable form that can be aggregated for a broaderpicture of the Nation’s resources.


RESOURCE MONITORING

Monitoring Requirements in NFMAand the Regulations4

In contrast to its inventory requirements, NFMAcontains no general provision requiring monitoring.The word ‘‘monitoring’ appears only once, inreference to research and evaluation of the effects ofmanagement systems (section 6(g)(3)(C)). The needfor monitoring is inferred in requirements forreforestation (section 3(d)(l)), herbicide and pesti-cide use (section 3(e)), revegetation of temporaryroads (section IO(b)), and implementation of even-aged harvest (section 6(g)(3)(f)(v)).

Unlike the law, the regulations highlight monitor-ing as a critical component of forest planning. Theregulations require monitoring plans as part of theland and resource management plan for each na-tional forest. Implementation of these monitoringplans must be reviewed periodically to determine ifthe prescribed monitoring is occurring as well as ifthe resources are being managed sustainably.

At intervals established in the plan, implemen-tation shall be evaluated on a sample basis todetermine how well objectives have been met andhow closely management standards and guidelineshave been applied. Based upon this evaluation, theinterdisciplinary team shall recommend to the ForestSupervisor such changes in management direction,revisions, or amendments to the forest plan as aredeemed necessary (36 CFR 219.12(k)).

Additionally, the regulations imply that monitor-ing must be conducted to assess the impact of timberharvests on soil, water, fish, wildlife, recreation, andaesthetic resources (36 CFR 2 19.27(c)(6)). Monitor-ing to preserve and enhance the diversity of plantand animal communities is also implied in regula-tory requirements for diversity ‘‘at least as great asthat which would be expected in a natural forest”(36 CFR 219.27(g)). The regulations require thatmonitoring include: quantitative outputs and serv-ices and costs of management prescriptions (36 CFR219.12 (k)(l)and(3)); documentation of measuredprescriptions and effects, including significant changesin productivity of the land (36 CFR 219.12(k)(2));and a description of actions, effects, or resourcesmeasured, the frequency of measurements, theexpected precision and reliability of the monitoring

process, and the time when evaluation will bereported (36 CFR 219.12 (k)(4) (i-iii)).

The monitoring requirements in NFMA and theregulations reinforced some existing Forest Serviceactivities. Measuring and reporting outputs andmonitoring project implementation had been con-ducted on the national forests for many years.NFMA and the regulations augmented these proce-dures by requiring the forests to: 1) specify standardsand guidelines for monitoring project implementa-tion; and 2) monitor environmental impacts, apractice that had not been common, especially fornoncommodity resources. NFMA also requires thatforest plans be revised when conditions havechanged significantly, but at least every 15 years(section 6(f)(5)(A)). This implicitly requires thatforest plan implementation and forest conditions bemonitored, to determine when significant changeshave occurred. The regulations further require forestsupervisors to “review the conditions on the landcovered by the plan at least every 5 years to deter-mine whether conditions or demands of the publichave changed significantly” (36 CFR 219.10(g)). Ifthe supervisor finds significant changes, the planmust be revised.

Problems With Monitoring Activities

Compliance With Monitoring Requirements

Monitoring measures the results of resourcemanagement activities to ensure that prescribedactivities are undertaken and that they have theexpected effects. The regulatory requirements forreports on monitoring are not always fulfilled.Although five of the forests in table 6-1 (Bitterroot,Coconino, Nantahala/Pisgah, Nicolet and San Juan)have issued monitoring reports, only the Bitterroothas issued annual monitoring reports according tothe schedule in its plan (137). The Dixie completedits plan in 1986 and the Eldorado and Siskiyoucompleted their plans in 1989. These forests mayrelease monitoring reports by the end of 1991.

Although all of the plans in table 6-1 prescribedmonitoring activities to measure product and serviceoutputs, they were less consistent in prescribingmonitoring to assess noncommodity resources (137).Only two plans (Dixie and Siskiyou) prescribedmonitoring to meet all of the noncommodity goalsand objectives in their forest plans. Three plans

4B~ hgely on Krahl et al. 1990 (137).


(Bitterroot, Coconino, and the Nantahala/Pisgah)prescribed monitoring for at least 75 percent of theirnoncommodity goals and objectives, while theremaining three plans (Eldorado, Nicolet and SanJuan) prescribed monitoring for less than 65 percentof their noncommodity goals and objectives (137).In addition, despite the requirement to submit anannual report on the amounts, types, uses, andbeneficial or adverse effects of herbicides andpesticides, none of the eight plans in table 6-1included this information. Even though this infor-mation was not in the plans, staff from these forestsstated that they report herbicide and pesticide use, incompliance with regional or State requirements(137).

Levels of Monitoring

The Forest Service defines monitoring at threedifferent levels: 1) implementation monitoring, or anevaluation of whether management activities arecarried out according to the forest plan; 2) effective-ness monitoring, or an evaluation of whether themanagement activities meet the plan objectives; and3) validation monitoring, or an evaluation of whetherthe initial plan assumptions are correct (267). (Seebox 6-A.) To date, complaints with implementationmonitoring have been the most common, but prob-lems with all three levels of monitoring have led tocriticism of the management plans.

Implementation monitoring poses the question:“Did the Forest Service do what they said theywould do?’ Many monitoring programs have beencriticized for promising too much (42, 248). Forexample, personnel needs in the ChequamegonNational Forest’s monitoring plan for the next 6years (1990 to 1996) call for an increase of 95percent in the number of work days over that of1989—an unlikely scenario (238). As implied in theplan, however, the proposed increase would consid-erably enlarge the scope of the monitoring programand provide the forest with greater knowledge of thecondition of its resources.5

The Idaho Panhandle monitoring plan has beencriticized for uneven monitoring-items that areeasy to quantify, like the size of timber cutting units,were successfully monitored, while items less easilyquantified, e.g., wildlife and fish population trends,were less successfully monitored. Some items were

Box 6-A—Example of Levels of Monitoringon a National Forestl

Forest Plan Goal: To maintain stream tempera-ture by keeping 10 percent of Moose Creek in shadeand thereby maintain trout populations in MooseCreek.

Forest Plan Standard and Guideline: Do notremove any trees within 15 feet of a stream.

Implementation Monitoring: Did the forest dowhat they said they would do? Did the forestremove any trees within 15 feet of the stream?

Effectiveness Monitoring: Did the Forest Serviceaccomplish what they set out to do, and did they doit in the most efficient way? Can the trout popula-tions in Moose Creek be maintained by notremoving any trees within 15 feet of the stream?

Validation Monitoring: Are the Forest Servicegoals and objectives appropriate? Does maintaining10 percent of Moose Creek in the shade keeptemperatures from rising above the limit for main-taining trout populations?

l~o~on~t~ from-out 11.13, Unit 11, Monitor-ing and Evaluation of the Forest Plan Implementation Course19(B01.

not monitored at all (e.g., the status of certainwildlife species and effects of management oninsects and disease) (42).

Effectiveness monitoring poses the question:“Did the Forest Service accomplish what they setout to do, and did they do it in the most efficientway?” The forest plans have been criticized forinaccurate reporting of resource conditions. An auditby the Idaho State Department of Lands found thatsome timber sales on the Idaho Panhandle hadunacceptable implementation of best managementpractices (BMPs). In 1989, the forest began aprogram to determine if the BMPs were successfulin meeting State water quality requirements. At leastfour of the planned watershed monitoring programswere not completed due to lack of funding andpersonnel (42).

Validation monitoring poses the question: “Arethe Forest Service goals and objectives appropri-ate?” Regardless of specific monitoring programsdeveloped by the Forest Service, the programs must

%e forest has been increasing spending related to forest plan monitoring, going horn $0 spedfkally allocated to forest plan monitoring in fiscalyear 1988 to over $50,000 in fiscal year 1991 (letter from Forest Service to OTA, Aug. 20, 1991).


be defendable in terms of rigorous study design andanalysis (174). If, as is often the case, the forestshave not carried out the proposed monitoringactivities it is difficult to evaluate this question.Thus, investigations of Forest Service monitoringcannot evaluate the appropriateness of Forest Serv-ice goals and objectives because there are few datato analyze and defend.

Summary and Conclusion

Monitoring on the national forests involves therepeated inventory of managed resources to deter-mine conditions and trends. Because the ForestService is directed to maintain a comprehensivesurvey and analysis of conditions of renewableresources under its jurisdiction (section 3(b)), thefocus of this section of the law is really monitoringrather than point-in-time inventory (174). It is stillearly to determine whether the Forest Service hassuccessfully met its monitoring requirements—some of the forests have not yet issued monitoringreports. The monitoring the Forest Service hasscheduled, however, often has not been imple-mented. The forests have typically promised morethan they have been able to deliver.

One way of reducing measures of ecosystemhealth to a manageable level is to review therelevance of the chosen measures to human concerns(127). Important characteristics to include in aninventory and monitoring program relate directly orindirectly to something that people are concernedabout. Identifying these characteristics may requirean explanation of why the measure is relevant.

Newly proposed regulations (287) may strengthenthe role of monitoring in the planning process. Theagency may place renewed emphasis on integrated,multiresource programs and an ecosystems ap-proach. Given the lack of money for detailedmonitoring, however, the forests need to reevaluatetheir monitoring plans. The plans must reflect moreaccurately what is possible and what is mostimportant to accomplish under staff and budgetconstraints and according to public interest.

SPECIAL ISSUES

Biological Modeling

Environmental planning requirements of NFMAare varied and extensive. In fact, the data requiredfrom the Forest Service by law ‘are far beyond those

ever compiled by the Forest Service or anyone else. . . “ (51) Historically, most forests have lackeddata useful to forest planning, including reliable dataon tree growth and yield (particularly for regener-ated stands in plantations) and up-to-date vegetationmaps (64). Forestry research also had not providedmuch support in the way of practical biologicalmodels for forest planning (64). After NFMA, theoverwhelming task facing forest planners was tocome up with reliable, desirable plans for large,complex, million-acre areas-a task requiring a lotof data, time, money, and a skilled workforce. Notenough of any of this was provided to the agency toaccomplish the tasks required in NFMA (64).

As abstractions and simplifications of reality,biological models depict relationships among envi-ronmental factors (174). Models represent a theoret-ical framework for understanding the environment.Simplification is necessary in model development,to describe complex systems in comprehensibleways. The extent and form of the simplification arecritical, because if the simplification is not appropri-ate, management decisions based on the model willbe faulty (174). Inappropriate simplification ofmodels has resulted from poor quality data, data thatemphasize the timber resource, and failure to recog-nize the importance of scale in study design.

Data Problems

Despite RPA/NFMA requirements for integrated,multiresource inventories, Forest Service inventoryand monitoring have failed to support modelsdepicting resource interplay within a complex envi-ronment (174). The historic emphasis on timber inForest Service management has led to inventory datathat fit into models for timber production forecast-ing. Forest models developed for FORPLAN em-phasize the growth, manipulation, and harvest oftrees (64). (See also ch. 7.) FORPLAN’s emphasison timber management reflects both the design ofFORPLAN and the lack of reliable theory and datato quantify nontree outputs. Except for timberassessments, “Land managers have had to rely onintuitive judgment rather than the evaluation ofsystematically organized data sets and processes’(135). FORPLAN directly or indirectly links outputssuch as forage, water, sediment, recreation, fish,visual quality, and wildlife habitat to forest manage-ment through land allocations and restrictions ontimber production (64). For example, FORPLANrarely contains a reliable, well-documented, quanti-


tative yield table to represent nontimber outputs andhow they respond to use and development. In manycases, the existing inventories emphasizing timberare now driving model development, rather than themodels driving data collection by generating hy-potheses that determine critical variables and appro-priate sampling designs (174).

Wildlife managers are especially challenged toprovide sufficient and reliable data on nongamespecies, which are essentially new to the inventory(304). Models have been developed to estimateeffects of forestry activities on these species and toforecast trends in abundance. However, many wild-life population models have been developed onassumptions about habitat suitability that may not bevalid (304). For example, one common assumptionis that species abundance can be used as an index tohabitat suitability. Challenges to this assumptionsuggest that indices based on demographic parame-ters (e.g., clutch size or growth rate) may prove to bemore reliable than indices based on abundance (96,302). Another common assumption in wildlifepopulation models is that populations change inproportion to the availability of suitable habitat(304). However, animal numbers may beheld belowcarrying capacity by other factors, including preda-tion, parasitism, competition, weather extremes, andunpredictable events.

Even if wildlife population models are correct inassuming that abundance may be a good measure ofhabitat suitability, critics claim that the availabledata are still insufficient to draw conclusions forguiding management activities (304):

Existing inventory techniques are generally tooexpensive and they require more skilled personnelthan are available . . . To date, no comprehensivesystem for monitoring wildlife resources on a majorland-management unit has been developed andtested . . .

Questions have also been raised regarding logisticalprocedures for updating files that are used to buildbiological models. Verner (304) claimed that effortsto update inventories on national forests “have beenmarginally successful because of cost and lack ofsuitable computerized data files."

Scale Problems

Use of appropriate scale is also a problem in themodeling of biological systems for the nationalforests. The characteristics of ecological systems

differ at different scales. For example, small plotssurveyed for bird species may show that two speciesare found in different habitats, perhaps in forests ofdifferent age classes. When surveying at a broaderscale, the two species may be associated togetherrather than with other species that occur in moredistinct habitats, such as cattail marshes or sedgemeadows. Thus, inventory results would vary de-pending on the scale of survey.

[I]f we study a system at an inappropriate scale,we may not detect its actual dynamics and patternsbut may instead identify patterns that are artifacts ofscale (319).

Each forest is unique at the continental scale,since major environmental factors such as geologicfeatures, temperature, and precipitation vary through-out the country (172). Each forest is also unique,however, at the local level, where topography,geology, and history influence conditions. It isimportant that management decisions recognize theappropriate scale of influence and impact of man-agement activities. Section 6(b) of NFMA requiresthat a systematic interdisciplinary approach, includ-ing economic and environmental considerations, beused to evaluate management alternatives. Thisimplies that the plans will show interactions amongthe managed resources. Shugart and Gilbert (234)conclude that:

One might argue that the Forest Service shouldnot be trying to do such comprehensive planningforest-wide, and yet the National Forest Manage-ment Act states that a single plan must be produced.

One approach to improve the usefulness ofbiological models in forest planning is to treatmodels as tools rather than goals:

The goal is to apply research findings usefully topredict management effects. . . The model is but onetool to reach the goal (36),

Management is, in many respects, an experiment inapplying models to the real world. Results aremonitored to evaluate and improve the models(146). Development of multiple-resource modelswith linkages to a geographic information systemare described as particularly promising for inte-grated analysis at various scales (146). GIS canprovide information on resources with site specific-ity in an accessible format and assist in the evalua-tion of results from the models and in the estimationsof environmental effects (278).


Biological Diversity

Legal Requirements

Biological diversity refers to the variety andrelative frequency of living organisms (174). Eco-system interactions are integral components ofbiological diversity, and biological diversity, in turn,determines ecosystem interactions. Morrison (174)offered the following analogy for understanding therelationship between biodiversity (biological com-ponents of the ecosystem) and ecosystem function-ing:

You can count all the parts of a vehicle and assesstheir condition individually without being assuredthat the assembled vehicle will start, or how well itwill run over the long term. The fewer parts youinventory and monitor, the less likely you will be topredict whether the finished product is complete andhow it will function.

NFMA directly refers to maintaining biologicaldiversity in the land and resource managementplans. Section 6(g)(3)(B) states that the regulationsfor developing the plans are to:

. . . provide for diversity of plant and animalcommunities based on the suitability and capabilityof the specific land area in order to meet overallmultiple-use objectives . . .

The Committee of Scientists interpreted this asclear congressional intent for considering diversitythroughout the planning process and for maintainingor increasing the diversity of plant and animalspecies and of biological communities (48).

The Forest Service regulations repeat and expandon NFMA’s guidance to provide for diversity ofplant and animal communities in the forest plans:

Forest planning shall provide for diversity of plantand animal communities and tree species consistentwith the overall multiple-use objectives of theplanning area. Such diversity shall be consideredthroughout the planning process. Inventories shallinclude quantitative data making possible the evalu-ation of diversity in terms of its prior and presentcondition. For each planning alternative, the inter-disciplinary team shall consider how diversity willbe affected by various mixes of resource outputs and

uses, including proposed management practices (36CFR 219.26).

The regulations also limit the loss of diversity tobe tolerated under prescribed management practices(36 CFR 219.27(g)) and recognize that nationalforests are ecosystems and that their managementrequires awareness of the interrelationships amongresources (36 CFR 219.1(b)(3)). The regulationsspecify biological diversity as a criterion for evaluat-ing lands as potential wilderness areas (36 CFR219.17(a)(2)(v)).

In addition to the requirement to inventory andmonitor the diversity of plant and animal communi-ties, Forest Service regulations require the forests tomaintain viable populations of species:

Fish and wildlife habitat shall be managed tomaintain viable populations of existing native anddesired non-native vertebrate species in the planningarea (36 CFR 219.90).

A viable population is defined as ‘one which has theestimated numbers and distribution of reproductiveindividuals to insure its continued existence is welldistributed in the planning area” (36 CFR 219.9). ADepartment of Agriculture regulating extends therequirement beyond vertebrates, to maintain at leastviable populations of “all existing native anddesired non-native plants, fish, and wildlife spe-cies” (321). Population viability is one part ofbiodiversity, since diversity clearly declines whenspecies go extinct (174). Thus, inventory andmonitoring for diversity must estimate the numbersof organisms as well as assess the relationshipbetween the numbers and population viability (174).

Wilcove (321) argued that forest plans have failedto address the issue of conservation of biologicaldiversity adequately. The current approach tends toincrease populations of widespread species at theexpense of rarer species, because each nationalforest can assure viable populations for commonspecies but not for uncommon species. In contrast,a regional approach considering all landownerscould better fulfill the intent of preserving biologicaldiversity in all natural ecosystems (321).

The inadequate treatment of biological diversityhas been blamed, at least in part, on the failure toidentify measurable attributes of diversity for inven-tory and monitoring programs (184). Ness (184)outlined a characterization of biodiversity thatidentified three biological components--composi-

SUS, Dwmment of Agl-icu]~e, Dep~mental Regulation 9500-4, Fish and Wildlife policy, Aug. 22+ 19~3


tion, structure, and function--for four levels ofdiversity-regional, community, population, andgenetic. Others have also called for conservation ofbiological diversity using a more comprehensive,landscape-level approach (107, 318).

Diversity in NFMA Planning

Although NFMA requires the national forests toinventory diversity, neither the law nor the regula-tions specify the kinds of data needed to create suchinventories. Forest plans, therefore, vary in the datathey consider in their evaluation of diversity (238).

A review of 20 national forest plans showed thatmost of the forests specified the level of diversity,stated the diversity level in terms of overall multiple-use objectives, discussed the consequences of thediversity level provided, and justified the reductionsin existing diversity in terms of multiple-use objec-tives (167). Management prescriptions to providefor diversity of the natural forest, however, were notidentified by any of the forests and only onecompared diversity of past and present conditions.Also missing were quantitative measures of thedistribution and abundance of plant and animalspecies. Most forests (60 percent) used the percent oftotal forest acreage in different age classes as asurrogate measure of animal diversity. Seven forests(35 percent) measured diversity as the percentchange in forestwide habitat capability for manage-ment indicator species. Specific measures of plantdiversity were not included, under the assumptionthat animal (habitat) diversity reflects vegetativediversity (167). (See also the following discussion ofindicator species.) The study concluded that al-though the 20 forests generally conformed withNFMA requirements to provide for diversity andshow effects of outputs on diversity, the measures ofdiversity were general values for tree age classes oranimal numbers, rather than specific measures forplant and animal communities and species distribu-tion and abundance. These measures were alsoinsensitive to effects of different management op-tions on diversity (167).

Timber and range vegetation types are the mostcommon measures of diversity in these plans offorests listed in table 6-1. The Bitterroot, Eldorado,and San Juan Forests included old-growth forest, butsurprisingly, the Siskiyou did not--even thoughold-growth forest protection has been an issue in thatregion. Six of the forests (Coconino, Eldorado, SanJuan, Siskiyou, Nantahala/Pisgah, and Nicolet) in-

cluded wildlife habitat measures in their inventoriesof diversity. All of these measures of diversity,however, fail to adequately evaluate spatial, tempo-ral, and structural characteristics of biological diver-sity (137). Three of the forests have developedspecial inventories to address these shortfalls. TheEldorado National Forest greatly expanded its plantinventories; the Siskiyou participated in a regionalinventory of vegetative communities that will in-clude measures of fragmentation and biologicalcorridors; and the Nantahala/Pisgah, in response toa successful administrative appeal based on theinadequacy of the diversity section of the forest plan,is evaluating alternative inventory methods to deter-mine status and trend of diversity (137).

To compile information on diversity, the Che-quamegon National Forest staff used data from theWisconsin Department of Natural Resources onvertebrate species, selected sensitive and gamevertebrate species, rare vascular plants, and potentialresearch natural areas. The forest also used generalvegetation information from its Vegetation Manage-ment Information System (238). These data, like thebiological diversity data collected on other forests,are incomplete in that no species list was availablefor invertebrate animals and no information wasavailable for nonvascular plants, lichens, and fungi.The Chequamegon Forest has taken steps to resolvesome of these problems by enlarging the scope ofdiversity information and by focusing monitoringefforts on species and processes of greatest publicconcern or those most affected by forest manage-ment. Examples of programs to be added includemonitoring the reproduction of white cedar and theuse of various plant foods by mammals ( 2 3 8 ) .

Several plans have been criticized for promotingmanagement practices that do not protect the biolog-ical resources of the National Forest System: forestsare being converted to monoculture, genetic diver-sity is not being enhanced, and animal habitats arebeing fragmented (321). Plans from national forestsin Florida, for example, promote management prac-tices that will convert longleaf pine forests intostands of species that would not occur there natu-rally. The final plan for the Ouachita NationalForest, in Arkansas and Oklahoma, was criticizedfor managing almost solely for pine forests and fordecreasing genetic diversity by artificially regener-ating clearcut stands with pine. Restrictions onclearcutting and pine plantations were consideredfor this area in the Winding Stair Mountain National

Chapter 6-Biological Dimensions of Forest Planning . 121

Recreation and Wilderness Area Act.7 However,only an annual timber management report and anadvisory coremittee were finally specified in the act.The plans for the Arapaho/Roosevelt and ShoshoneNational Forests (in Colorado and Wyoming, re-spectively) were criticized because they wouldallow a high level of forest fragmentation. Biologi-cal diversity would not be protected (321).

Indicators

General Indicator Concept

An indicator has been defined as:

A characteristic of the environment that, whenmeasured, quantifies the magnitude of stress, habitatcharacteristics, degree of exposure to the stressor, ordegree of ecological response to the exposure.8

Indicators have been used as an index of conditionsthat are too difficult, inconvenient, or expensive tomeasure directly (140). Indicators can streamlineinvestigations of environmental conditions by mini-mizing the number of characteristics that need to bemeasured. Indicators may be of several kinds. Somemay be ecological in that they provide informationon the biological condition of a resource. Others maybe stressor indicators, providing information onenvironmental hazards, or management indicators,providing information on management activities.

While saving time and money, the indicatorconcept has been criticized for presenting an over-simplified view of environmental conditions. Indi-cator species, in particular--in contrast to thebroader indicator concept that can include character-istics such as climatic fluctuations or levels ofnutrients in tree foliage in addition to individualspecies—have been described as misleading:

Indicator species often have told us little aboutoverall environmental trends, and may even have de-luded us into thinking that all is well with an environ-ment simply because an indicator is thriving (184).

A poor selection process for indicator species couldlead to poor assumptions about the effects of anenvironmental hazard, such as a chemical pollutant.For example, assumin g that a chosen indicatorspecies will decline if the chemical pollutant isharmful to its food source may not be effective if the

chosen indicator does not depend solely on that foodsource. Declines in other species that do rely solelyon the affected food source might go unnoticedbecause these species were not monitored.

Recommendations to make the use of indicatorsmore rigorous include: a clear statement of goals;thorough biological knowledge of the indicator; andpeer review of assessment design, methods of datacollection, statistical analysis, interpretations, andrecommendations (140). The most useful indicatorswill be sensitive to stress, responding to it rapidly ina predictable way; be easy and economical tomeasure; and be relevant to the goals of theinvestigation (127). A set of carefully selectedindicators, rather than a single indicator species, ismore likely to exhibit all of the characteristicsrecommended as selection criteria (184).

Forest Service Use of ManagementIndicator Species

Forest Service regulations require the forests toselect and monitor a set of management indicatorspecies (MIS) (36 CFR 219.9). The Forest Serviceregulations list five categories to be representedwhen selecting MIS: 1) endangered or threatenedspecies identified at the State or Federal level; 2)species sensitive to planned management activities;3) game and commercial species; 4) nongamespecies of special interest; and 5) ecological indica-tor species that are used to monitor the effects ofmanagement practices on other species. Followingthe general indicator concept, the MIS chosen torepresent these categories act as surrogates formeasuring environmental conditions of the forestcommunities. Management indicator species differfrom other types of indicators in that: 1) they arespecies (in contrast to characteristics); 2) theyindicate the effects of management activities (incontrast to effects of other events such as naturaldisasters or changes in rainfall); and 3) they indicatethe effects of management activities on forestresources (not solely on other species). The use ofMIS assumes that some relationship exists betweena prescribed management activity and the presenceor abundance of the MIS (174, 189).

As with the indicator concept itself, several majorproblems confront the use of MIS: guidelines have

T~t of wt. 18, 1989, Public bW 100-499 (102 Stit. 2491).

W.S. Environmental Protection Ageney, “Environmental Monitoring and Assessment Program, Ecological Indicators,” Office of Resemch andDevelopment Washington DC, September 1990.


not been set for the selection of species; training andexpertise to select, monitor, and analyze MIS havebeen lacking; and some species are ignored in theinventory process (174, 189). With no guidelines forthe selection of MIS, selection processes varyamong forests. Some are criticized for choosing aninsufficient number of indicators, others for choos-ing indicators that are not related to ecosystem con-ditions. The following examples illustrate specificproblems some forests have had with the use of MIS.

The Idaho Panhandle National Forests and theCibola National Forest fell short in their selection ofan adequate number of indicators and their collec-tion of data on chosen indicators (42, 166). On theIdaho Panhandle, no indicator species existed formature lodgepole pine which covers a major part ofthese forests. Also on the Idaho Panhandle, no datawere available on populations or population trendsfor most of the nongame indicator species (marten,pileated woodpecker, and goshawks) (42). On theCibola, inventory data were also nonexistent forpopulation size and distribution of nongame indica-tor species (166).

The Chequamegon National Forest plan recog-nized 25 ecological community types, but onlyidentified 15 indicator species to evaluate conditionsin these communities. Deciduous trees dominate atleast half of this forest, but the stands were lumpedinto two classes: young/mature hardwoods withruffed grouse as an indicator, and old-growthhardwoods with the pileated woodpecker as anindicator. Under this classification, several commu-nities (a young, even-aged stand of red oak and redmaple, an uneven-aged pure stand of sugar maple,and a mixed stand of basswood and yellow birch)would all be lumped into one category. Trackingpopulations of ruffed grouse and pileated woodpeck-ers would poorly represent changes in these commu-nities or in their other constituent species (238).

Also in the Chequamegon plan, two species wereselected as aquatic indicators, but were droppedfrom the list because ‘‘little management of aquatichabitats is planned for this decade” (238). Thus thepotential effects of such management activities astimber harvesting or road construction on aquaticecosystems are ignored. In addition, one of thechosen indicator species did not depend on naturalconditions for reproduction in the forest. The mus-kellunge, a game fish stocked in the lakes andstreams in the Chequamegon National Forest by the

Wisconsin Department of Natural Resources, waschosen as the sole “ecological” indicator for warmwater habitats in the forest. But because of artificialstocking, muskie population numbers are inaccurateindicators of the effects of national forest manage-ment (238).

A review of 104 draft and final plans for 118national forests showed that the majority failed tochoose a wide spectrum of indicator species andoverlooked the advantages of selecting plants andsome invertebrates:

Ninety-three plans did not have any plants on theirMIS lists, other than species already listed asthreatened or endangered by the federal government.Eighty-seven did not include any unlisted inverte-brate animals, despite the fact that invertebrateanimals constitute the vast majority of living species.Of the 1,439 MIS in these plans (excluding federalthreatened and endangered species), 50 percent werebirds, 27 percent were mammals, 17 percent werefishes, two percent were reptiles and amphibians,less than one percent were invertebrates, two percentwere plants, and two percent were multi-speciesassemblages of birds, plants, fishes, or invertebrates(321).

Thus, while birds and mammals can serve as goodecological indicators for other species with smallerarea requirements, an MIS list composed only ofvertebrate animals will be inadequate for protectingall rare plants or invertebrate animals in a given area(321).

Indicator Species and a Monitoring Program

The selection of appropriate management indica-tor species must be combined with an adequatemonitoring program. The Forest Service regulationsstate that:

Population trends of the management indicatorspecies will be monitored and relationships to habitatchanges determined (36 CFR 219.19(a)(6)).

The goal of monitoring MIS on the national forestsis to verify assumptions in the forest plans abouteffects of management activities on ecosystemhealth. Monitoring MIS can lead to needed changesin management activities. Three important compo-nents of a successful monitoring program include:1) a scientifically sound method for assessing popula-tions of the MIS in question; 2) a reasonablefrequency of measurement; and 3) a standard forpopulation levels or degrees of change in population

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size, density, or distribution that triggers a reanalysisof management activities.

Monitoring programs in many forest plans do notmeet these standards (32 1). Some plans proposeonly to monitor habitats rather than populations,while others call for only infrequent monitoring ofthe MIS—populations may be counted only onceevery 5 or sometimes 10 years. This infrequentmonitoring will only detect the most drastic popula-tion changes and will not alert the forest in time toavert or alter destructive management activities.

Summary and Conclusions

Forest planning under NFMA requires a tremen-dous database accompanied by time, money, andtrained staff. Emphasis on timber management andthe lack of data on nontree outputs has hindered thedevelopment of thorough and accurate biologicalmodels to assist forest planning. Questions havebeen raised on the validity of assumptions, theadequacy of updating and maintaining data files, andthe use of appropriate scale. Future models to aidplanners in forest resource management must takeadvantage of new technologies in data collection,storage, and updating and must pay closer attentionto scale of analysis as well as to more comprehen-sive, integrated analysis of renewable resources.

NFMA and the forest planning regulations makerepeated reference to maintainingg biological diver-

sity in the national forests. Treatment of this issue inthe plans, however, has not received favorablereviews. The Forest Service lacks adequate inven-tory data to address diversity questions, and criticsassert that the agency has a short-term, myopic viewof conservation of biological diversity rather than along-term, comprehensive approach.

Problems with the use of management indicatorspecies make this requirement subject to variedinterpretations and criticisms. It is not economicallyfeasible to study all species on a forest; the MISconcept offers a less costly alternative to trackingenvironmental trends. Application of the MIS con-cept to the national forests, however, has beendescribed as neither efficient nor effective. Contin-ued use of indicators on the forests should involve aneffort to improve the selection process as well as amore comprehensive approach to evaluating theforest ecosystem. This comprehensive approachshould include analysis of management indicators aswell as indicators of habitat conditions and ecologi-cal processes. The national forests may have numer-ous chances to revise and expand the characteristicschosen as indicators, but interest in collectinginformation for determiningg long-term trends dis-courages this from happening often. It is importantthat the forests select an adequate number ofindicators that will provide the maximum amount ofinformation with reasonable monitoring ease.

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Chapter 7

Technologies forNational Forest Planning

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RelevantTypes of

ContentsPage

Planning Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . .Planning Technologies . . .

Decision Support Technologies .Impact Assessment TechnologiesSupplemental

FORPLAN andTechnologies . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .The Development and Selection of FORPLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .What Is FORPLAN? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .FORPLAN’sFORPLAN’s

Strengths . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Weaknesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Decisions and Tools . .FORPLAN . . . . . . . . . .Options for the Future

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127128128129130131131132133134137137138139

Chapter 7

Technologies for National Forest Planning

The National Forest Management Act of 1976(NFMA) does not explicitly require the use of any

particular technologies in preparing and revisingforest plans. However, NFMA establishes variousresource quality standards, and specifies variousconsiderations for the planning process. While avariety of techniques are available for organizingand analyzing information to meet these require-ments, the Forest Service chose one particularcomputer model—FORPLAN--as the principal ana-lytical tool for forest planning.

FORPLAN is a complex and expensive computerprogram. Some have blamed FORPLAN for a costlyand time-consuming planning process, and haveasserted that FORPLAN has increased the contro-versy over national forest management. Congressasked OTA to assess Forest Service planning partlyto determine if FORPLAN has helped or hinderedthe process. This chapter briefly examines planningtechnologies that exist, reviews the development ofFORPLAN, and discusses FORPLAN’s strengthsand weaknesses for supporting the forest planningprocess.

R E L E V A N T P L A N N I N G

D E C I S I O N S

To assess the planning technologies, it is neces-sary to understand the decisions to be made in theplanning process. As discussed earlier in this report,the purpose of national forest management is toaccommodate uses and produce outputs while sus-taining ecosystems. (See ch. 3.) Thus, technologiesthat can allocate (analyze spatially) and/or schedule(analyze temporally) could be useful in decision-making, while technologies that assess the effects ofdecisions on ecosystems and values could be usefulin understanding the consequences of decisions.

Because of the concerns over clearcutting in theearly 1970s, NFMA focused on protecting the forestenvironment during timber harvesting (123). (Seech. 4.) NFMA included two particular provisionsthat lend themselves well to computer analysis. The

first, section 6(k), prohibits most timber harvestingfrom lands identified as not suited for timberproduction, “considering physical, economic, andother pertinent factors to the extent feasible, asdetermined by the Secretary.” In essence, thisprovision requires a land allocation decision, basedin part on an economic (temporal) analysis of timberproduction.

The second provision, section 13(a), generallylimits timber sales (the allowable sale quantity, orASQ) to a level that can be sustained in perpetuity;this requirement is commonly known as nondeclin-ing even flow (NDEF). Assuring that the plansprovide this perpetual, sustainable flow is a long-term scheduling problem, based in part on the landallocation decision under section 6(k).1 The longtimeframe for managing timber makes both theallocation and scheduling decisions well suited foranalysis using computer technology.

These provisions of NFMA limit timber harvest-ing based on certain specified criteria. The Multiple-Use Sustained-Yield Act (MUSYA) and NFMAfurther require that timber harvesting be coordinatedwith other uses. Decisions coordinated to allocateand schedule the various uses and outputs are onemeans to minimize conflicts and to accommodatecompatible activities. Again, computer models canbe useful in analyzing the allocation and schedulingdecisions for timber production as well as other usesand outputs.

The various legal requirements of MUSYA andNFMA imply a sequential analysis. Lands suitablefor timber production are identified, the ASQ isdetermined, and finally timber management is coor-dinated with other uses and outputs. Notably, bothsections 6(k) and 13(a) provide exceptions to theirlimitations on timber harvesting based on multiple-use considerations. Thus, arguably timberland suita-bility and ASQ are to be determined withoutlimitations based on multiple-use coordination (293).However, Forest Service practices make these threeanalyses (timberland suitability, ASQ determina-

lsome ~bs=erS ~ve ~t~ tit ~mnt ~-a ~ M ~cli~ For~t s~i~ pl- procas Codd lad to d~b b the ASQ b ~chsubsequent plan for a nationsl forest, contrary to the intent of nondefining even flow in NFh9A (163). Such an occurrence can apparently be madeinsignificant with additional restrictions on the current models (134), and thus this Mlcuhy is not considered in this Assessment. However, furtheranalysis of this possibility by the agency maybe warranted.

–127–


tions, and multiple-use coordination) simultane-ously. The regulations for implementing section 6(k)specifically include multiple-use benefits for deter-mining the suitability of lands for producing timber.By including multiple-use benefits in determiningtimberland suitability, multiple-use considerationsalso have been included in determining the ASQ.Thus, the Forest Service has chosen to combinetimberland suitability, ASQ determi nation, and multiple-use coordination in one large, allocation and sched-uling problem.

TYPES OF PLANNINGTECHNOLOGIES

Two types of computer modeling are useful foranalyzing alternative plans. One approach—simu-lation—imitates the relevant system, and is used toexamine how important measures change when thedecisions or inputs change. The other--optimization--attempts to maximize or minimize important meas-ures within the system’s limits. Optimization mod-els are often preferred for supporting decisionmak-ing, but may not be relevant if one cannot define allthe variables that should be optimized. Furthermore,because optimization models (and the calculationsthey require) are often much more complex thansimulations, they can be very expensive to use.

It is important to note that computer models arenot perfect duplicates of the real world. Reality isgenerally too complex to replicate precisely. Thus,models necessarily simplify the real world. None-theless, the results of useful models must approxi-mate the actual results of management actions.Models are tested (verified, in technical parlance) todetermine if their results are sufficiently similar toreality to make the model useful. Computer modelresults, however, are still only estimates of what willhappen. This, together with the human responsibilityfor decisions, is why computer models are used tosupport decisionmaking, rather than to make deci-sions.

Computer tools contribute to forest planning intwo ways—by assisting in allocation and schedulingdecisions and by assisting in estimating the conse-quences of decisions. Additional techniques can beused to supplement and coordinate the technologiesthat contribute to allocation and scheduling deci-sions and that estimate impacts.

Decision Support Technologies

Resource Scheduling Decisions

Resource scheduling decisions determine thelevels of uses and outputs that will occur over time.Most scheduling tools used in business are optimiza-tion models, determining the ‘best’ (typically mostprofitable) timing for activities within the con-straints of the systems. Common scheduling modelsinclude inventory models for reordering decisions,transportation models for the delivery of goods, andmodels for determining the optimum mix of outputsfrom a common input. These latter two models bothuse linear programming, a tool that achieves anobjective function within the constraints of thesystem. For example, linear programming is used indetermining the output mix in the refining of crudeoil: the output of the model (the solution) identifiesthe most profitable mix of gasoline, kerosene, fueloil, and other petroleum products, within the con-straints of current prices for each product; therelationship among the products (producing more ofone product reduces the amount of other productsthat can be produced); the costs to produce eachproduct (which increase as the quantity producedfrom a barrel of crude oil increases); and the capacityof the refinery.

Natural resource scheduling is, in many ways,comparable to the oil refinery decisions. Forest landshave the ability to produce a variety of uses andoutputs, with varying prices and values. The usesand outputs are related, sometimes complimentarilybut also in ways that are competing or incompatible.The financial and environmental unit costs vary, inpart, with the level of each use and output produced.And production is limited to levels that can besustained in perpetuity. As described below, theForest Service chose a linear programming approach—FORPLAN--for assisting in resource schedulingand other forest planning decisions. The requirementto assure sustainable timber production over longperiods and the complex interrelationships amongthe various resources make linear programmingquite useful in attempting to maximize resource usesand outputs within long-run, ecological limits.

Linear programming, however, has inherent limi-tations in supporting resource scheduling decisions.First, linear programming requires massive amountsof data to define the interrelationships amongresources and the changes that result from manage-

Chapter 7—Technologies for National Forest Planning . 129

ment activities. Linear programming also is deter-ministic—risk and uncertainty cannot be included inthe model, even though they are common in naturalsystems (65, 234). Finally, linear programming islinear—all relationships must be direct, continuous,and symmetrical (reversible).2 Linearity is a prob-lem because: 1) inputs on one site can affect theoutputs and management costs of other sites—thereare indirect effects of management (14, 146); 2)some inputs, such as facilities, cannot be adjusted insmall increments--they are not continuous func-tions (14, 179); and 3) ecosystems may havethresholds-irreversible changes can result frommanagement activities (65, 118).

Land and Resource Allocation Decisions

Land and resource allocation decisions determinehow uses and outputs are combined (or separated)over space. Thus, technologies for supporting allo-cation decisions must be able to evaluate spatialrelationships among resources. Linear programminghas some capacity to account for spatial relation-ships (122), and including spatial details substan-tially increases the size, cost, and complexity of themodel (1 18).

The Forest Service has traditionally examined andpresented spatial relationships with maps, which area part of every forest plan. However, the maps havegenerally been produced by hand, with an enormousinvestment of time and energy. Overlays can be usedto combine different types of spatial information, butthe process of creating and using overlays iscumbersome and expensive. Thus, despite its impor-tance, spatial analysis for land and resource alloca-tion decisions in forest planning has been limited bythe shortcomings of FORPLAN and current map-ping practices.

Geographic information systems (GIS) are basi-cally computerized mapping systems that can store,manage, and analyze spatial information. GIS arenot optimization systems, but are very useful forexamining spatial questions. After the user definesthe relevant spatial information to be combined, GIScan display locations of specified conditions (e.g.,mature timber on moderate slopes) or of situationssensitive to certain management activities (e.g.,highly erodible soils or critical habitat for anendangered species). The Forest Service has been

testing a variety of GIS, and expects to have GISavailable at each national forest eventually.

GIS also has limitations for use in forest planning.First, the systems require sizable investments incomputers, plotters, and software. The GeneralAccounting Office (255) recently concluded that theForest Service has not adequately analyzed thealternatives to the estimated $ 1.2-billion investment,and to date, Congress has not funded GIS acquisitionby the Forest Service. In addition, GIS requirespatial information, and putting such informationinto the systems is generally an expensive andtime-consuming manual process. However, the costof putting spatial information into a GIS may notmuch exceed that of manual mapping currently usedin forest planning.

Impact Assessment Technologies

Ecological and Environmental Impacts

Examining the likely ecological and environ-mental impacts of management decisions is animportant part of forest planning. Resource simula-tion models are the principal technologies used forthis purpose. Resource simulations quantify therelationships within natural systems, and attempt toestimate the likely results of management actions.Many simulations have been developed for singleresources; the most common are timber growth-and-yield models, although the Forest Service has alsodeveloped sediment yield and wildlife habitat mod-els. A few have attempted to simulate changes inforest and ecosystem structure over time (with andwithout various management activities), but thesemore comprehensive models are usually more ex-pensive to build, test, and use or more simplified,and thus less precise in their predictive ability.

The Forest Service is considered to be a leader indeveloping resource simulation models (146). How-ever, in contrast to scheduling and allocation mod-els, which address common decisions, the diversityof resources and resource relationships typicallyleads to unique simulation models that addresslocally or regionally specific issues and problems.The diversity of national forest lands and resourceshas prevented the development of universal models.The existing models are often used in modifying thegeneral FORPLAN model to address local issues,

%inear programm ing does not actually require freed linear relationships. Cumilinear and other relationships can be approximated with multipleequatiom, if the relationships are direct+ continuous, and symmetrical.


but this has not always been done well (234), andsome important data and relationships are poorlyknown (72, 278).

Economic Impacts

Predicting the economic consequences of man-agement decisions is another important part of forestplanning. The economics of management is typi-cally examined by comparing the benefits and costsof the proposed activities. Distinct models for suchanalyses exist, but in forest planning it is done withFORPLAN. FORPLAN’s objective function (thegoal) is to maximize present net value (PNV)---thevalue of uses and outputs minus the costs, withfuture values and costs discounted to the present.(See ch. 8 for a fuller discussion of strengths andweaknesses of economic analysis in forest plan-ning.)

The traditional tool used for assessing localeconomic impacts is input-output analysis. Aninput-output model describes an economy in termsof its quantitative financial interactions amongmanufacturing, service, and other sectors. The For-est Service has developed a standardized input-output model with localized adaptations—IMPLAN—for estimating economic consequences on eachnational forest. IMPLAN is useful for appraising thetotal economic impacts of a forest plan, but isinsufficient for evaluating impacts on communities(278). (See ch. 8 for a more thorough analysis ofIMPLAN and its limitations.)

Supplemental Technologies

Database Management Systems

Computerized databases are often used to storeand manipulate inventory information for the na-tional forests. Computerized databases are essen-tially sophisticated filing systems, with the ability tostore, sort, and rearrange massive amounts of data.Information sorting is the only analytical capabilityof databases, and thus databases are not reallyanalytical tools. However, relational databases canstore inventory information with site relationships,and therefore, can provide data for other allocationand scheduling models and for impact assessmenttools.

In addition, one computerized database can belinked to other databases. If uniform structures anddefinitions are used for inventories, individualdatabases can be aggregated, creating a “corporate

database’ —i.e., nationwide access to local data onnational forest lands and resources. This wouldcertainly assist the agency in the RPA planningprocess. However, the Washington Office has notyet decided on the nature and structure of such acorporate database. Many forests are delaying theinitiation of forest plan revisions until they receivesome direction on database structures and defini-tions (146, 166).

Knowledge-Based Systems

Knowledge-based systems (KBS), also known asexpert or rule-based systems, are relatively new innatural resources management. Expert systems canbe optimization models, depending on the rulesincorporated into the system, but the goal for suchsystems is to replace traditional computer logic witha more humanlike reasoning process (146). Cur-rently, KBS are usually based on ‘‘if-then’ rules,such as “if tree age exceeds the specified rotationage, then the stand can be scheduled for harvest’ or‘‘if a stream of the specified minimum width, depth,and flow lacks spawning gravel, then the stream canbe scheduled for fish habitat improvement.” How-ever, because of our limited understanding of therules and limits of natural systems, KBS are usedprimarily for relatively simple, repetitive decisions.

KBS can also be interactive, such that systems askthe users a series of questions with subsequentquestions depending on previous answers. In thiscapacity, KBS can assist decision support andimpact assessment technologies by assuring thatappropriate models and information are used. TheForest Service is developing a KBS to assist inassuring that project planning complies with NFMAand NEPA. However, KBS could be expanded to abroader role in coordinating information and analy-sis in forest planning.

Integrated Systems

Integrated systems combine various technologieswith systematic, automated linkages. Computerizeddatabases can be linked with GIS for allocationdecisions; with resource simulations for estimatingecological and environmental impacts; and/or witha linear programming model for scheduling deci-sions. Simulations and GIS can also be linked withlinear programmingg. The Forest Service is develop-ing an integrated system—INFORMS---coordinatedthrough the Rocky Mountain Forest and RangeExperiment Station in Fort Collins, Colorado. Parts


of the system have been used in various locations,but the integrated system has not yet been imple-mented (146). Another integrated system—TEAMS—has been developed at Northern Arizona Univer-sity in Flagstaff, Arizona (54). TEAMS is used inteaching, and has been applied successfully on theCoconino National Forest and on other lands (146).

As with all planning technologies, integratedsystems have their limitations. First and foremost,the shortcomings of the component technologiesmust be recognized. Computer models cannot giveperfect answers, because the models necessarilysimplify reality, and results are less precise than theyappear (13, 14). Not only modelers and analysts, butmore importantly, managers and the public, must beaware of the limits of the technologies (60). Further-more, the technologies and linkages must be under-standable so that the public (and agency employeesnot involved in planning) can recognize what isbeing evaluated, what the decision criteria and othercritical standards are, and how the results will beused. However, given these cautions, integratedsystems and the technologies that they integrate canbe very useful in land and resource managementplanning for the national forests.

FORPLAN AND FORESTPLANNING

Historically, forestry has focused on sustainingthe production of timber and other forest productsover long periods of time. The European traditionwas to manage forests to achieve a ‘‘fully-regulatedcondition, ’ with stable annual timber harvests andapproximately equal forest areas in various stagesfrom seedlings to “mature’ stands. Forestry educa-tion in America followed this tradition (63), butEuropean forest regulation could not be adoptedeasily for the unmanaged U.S. forests (122). Variousmethods were developed to regulate harvest rates forold-growth timber, and to convert such stands tomore productive conditions. These methods wereessentially designed to determine the allowablecut—the volume of timber that could be harvestedannually while forest productivity was maintained.

Relatively simple approaches to determiningallowable cuts were used until at least the 1950s(122). However, two changes complicated the deter-mination of allowable cuts. The first was theincreasing importance of the national forests fortimber and recreation, which led to the enactment of

the Multiple-Use Sustained-Yield Act of 1960, asdescribed in ch. 3. The second was the recognitionin the early 1960s that timber harvests from privatelands, at least in Washington and Oregon, could notbe sustained at their historic levels. These concernsand the development of computer models led tomore sophisticated approaches for determining theallowable cut from the national forests.

The Development and Selection of FORPLAN

Prior to 1973, the Forest Service had as many as48 different types of functional plans for the nationalforests (212). In the initial response to NEPA, theForest Service chose to develop integrated unit plansfor areas within the national forests. RPA echoedthis direction by requiring “land and resourcemanagement plans for units of the National ForestSystem,” prepared under an interdisciplinary ap-proach. NFMA then provided substantial directionon what to consider in developing plans.

Two linear programming approaches were devel-oped initially to assist in integrated, multiple-usemanagement planning for the national forests. Oneapproach, the Resource Capability System (RCS),focused on site-specific responses to managementalternatives. RCS analysis was generally organizedby watersheds, and the model provided timestreamsfor resource yields, site-specific area control, and abalanced treatment of all resources (i.e., all resourceoutputs were included in the objective function)(125). However, RCS was not widely accepted be-cause of its emphasis on watershed concerns (122)and because of its inadequacies for timber harvestscheduling and control (125).

The other approach was the development of along-term timber harvest scheduling model, in-tended to assure the biological sustainability andmultiple-use compatibility of harvest levels over anentire national forest (122). The frost such model wasthe Timber Resource Allocation Model (TimberRAM), developed in 1971. However, concerns abouta timber bias and increasing interest in site-specificenvironmental effects led to the development of amore sophisticated timber harvest scheduling model,the Multiple Use-Sustained Yield Calculator(MUSYC). However, MUSYC was considered tobe just a more sophisticated timber harvest schedul-ing model, rather than an integrated resource manage-ment model (122). Finally, FORPLAN was devel-oped in the late 1970s to overcome some of these

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limitations. FORPLAN followed the basic approachestablished in Timber RAM and MUSYC, but wasmodified to incorporate some of the advantages ofRCS, such as timestreams for yields, improved areacontrol, and an objective function that included allresource outputs (122).

In 1979, as planning was beginning under the newNFMA regulations, the Forest Service becameconcerned that confusion in management directionand excessive cost might result from having various,competing computer models to assist forest plan-ning. On December 3, 1979, Associate ChiefDouglas Leisz sent a letter to regional foresters andstaff directors designating FORPLAN as the primaryanalysis tool to be used in forest planning (125).FORPLAN was chosen because it addressed two keyissues in forest planning: cost efficiency, and anallowable timber sale quantity (the NFMA term forallowable cut) within constraints (123). WithFORPLAN, the Forest Service felt it would have aconsistent, unified approach to forest planning(122).

FORPLAN has evolved substantially over thepast 12 years (125). As a result, there are two distinctversions of FORPLAN, and more than 10 releases(upgrades) of each version (64). Thus, more than 20different FORPLAN models have been used inforest planning. Furthermore, each national foreststructures the FORPLAN inputs to analyze relevantproblems for that forest (173). In essence, eachnational forest has used a unique FORPLAN modelin developing its forest plan, and will probably usea different FORPLAN model when it revises itsforest plan.

What Is FORPLAN?

As noted earlier, FORPLAN is basically a linearprogramming model. It has three distinct parts. Thefirst organizes the required information into thestructure necessary for linear programming; techni-cally, this is called the “matrix generator, ’ becauselinear programming uses matrix algebra. The secondpart is the calculator-the linear program itself. TheForest Service uses commercial linear programmingsoftware for this. The third part of FORPLANpresents the solution in a variety of formats, to assistin understanding and using the results; this part iscalled the “report writer, ’ because it producesvarious displays of the results.

Linear progr amming is a technique for finding thebest possible combination of outputs within speci-fied limits. Thus, linear programming essentially hasthree components: 1) the objective function (the goalto be maximized or minimized), 2) the constraints(the specified limits), and 3) the production func-tions (the relationships between the constraints andthe objective function).

The Forest Service has directed that economiccriteria will be used for the objective function inFORPLAN. This function is intended to include allnational forest uses and outputs, using market pricesor some other relevant value for unpriced outputs.(See ch. 8 for more information on valuationtechniques.) Future values and costs are discountedto the present for comparing alternative investments.(Again, see ch. 8.) The objective is then to maximizethe present net value of outputs by emphasizingproduction of the most “profitable” outputs (thosewith the largest difference between the price/valueand the cost of production). For example, if recrea-tion is valued at $10 per unit and timber is priced at$8 per unit, and if the costs to produce additionalunits is $6 for each, FORPLAN will emphasizerecreation, within the specified constraints.FORPLAN will not necessarily choose only recrea-tion, or even more recreation than timber; theselection depends on how recreation and timberoutputs are related to the constraints.

A large number and wide variety of constraints areused in FORPLAN (122). Some constraints areabsolutes—total forest area, productive capacity,minimum requirements or production targets, budg-ets, etc. FORPLAN also includes “flow con-straints,’ principally to assure sustained productionof timber and other outputs over long periods; asdescribed above, one flow constraint--nondecliningeven flow of timber-is specified in NFMA. A thirdcategory is relational constraints, which allow theuser to specify relationships among managementactivities and outputs; for example, road construc-tion into a specific area could be required beforetimber harvesting is allowed there.

Production relationships connect the constraintsto the objectives. In FORPLAN, these relationshipsare generally defined by analysis areas and manage-ment prescriptions (specific patterns of relatedactivities). Each prescription in each area includescosts and output yields, to relate possible activitiesto the objective function, and is aggregated for each

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Chapter 7—Technologies for National Forest Planning ● 133

of the relevant constraints. The prescriptions appliedto analysis areas are called “decision variables,”and FORPLAN selects among possible combina-tions to maximize the objective function whilemeeting all of the constraints.

FORPLAN’s Strengths

FORPLAN has been used because it performscertain tasks very well and because it helps organizeplanning around certain issues. The strengths ofFORPLAN have been described as: its analyticalcapacity, its focus on important issues, its commonlanguage for analysts, and its protection of agencydiscretion.

Analytical Capacity

One reason the Forest Service accepted linearprogramming and FORPLAN is that it can be usedto consider thousands of possibilities (combinationsof prescriptions and analysis areas). Linear program-ming is used because the number of decisionvariables to consider is beyond the capacity of thehuman mind (122). For example, in determiningwhether to manage an area for timber production,one must consider the productivity of the land fortimber, the economics of timber management, thecontinued flow of timber over 100 years or more, andthe relationships between timber management andwater flows (quality and quantity), recreation use,big game habitat, endangered species protection,and other outputs and ecosystem requirements. Inaddition, such an analysis must be conducted foreach area that might include timber production aspart of the area’s management. FORPLAN is a toolthat, with the appropriate constraints, can performsuch a complicated analytical task.

Focus on Important Issues

Most of the important values of the nationalforests are related to trees and the manipulation oftree vegetation—wilderness, ancient forests, timberproduction, recreation development, visual quality,water flows, and the like (64). Concerns particularlyfocus on timber management—how much timber toharvest and from which lands.

To foresters ..., the important issues in forestplanning relate to active manipulation of the forest,and such planning should focus on what timberharvest levels can be sustained over time, given theobjectives and constraints from all forest uses (123).

FORPLAN focuses on these issues. FORPLAN isstructured to examine land allocations to variousmanagement prescriptions, many of which includetimber production. FORPLAN relates timber man-agement activities to the other uses and values of thenational forests. And, FORPLAN results are organ-ized to provide information on land allocationsespecially with regard to timber production, and ontimber and other output levels. Thus, FORPLAN isuseful in addressing important national forest man-agement issues.

FORPLAN, or a similar model, is also probably anecessary tool for forest planning. As noted earlier,NFMA limits the allowable timber sale quantity toa level that can be sustained in perpetuity-i. e.,nondeclining even flow. A computerized model isundoubtedly necessary to analyze long-term timberharvest schedules, and thus to determine if thenondeclining even flow constraint is met. Forseveral decades now, the simple formulas fordetermining the allowable cut, generally based oncurrent growth and on harvesting the remainingold-growth timber, have been inadequate, and willprobably remain inadequate for assuring sustainabletimber production from Federal lands.

Common Language for Analysts

One of the problems in interdisciplinary efforts isthat the various disciplines and specialties usedifferent terms and measures for their particularconcerns and problems. The direction to useFORPLAN required foresters, hydrologists, biolo-gists, archaeologists, landscape architects, and oth-ers to deal with one model to address all the issuesand concerns (64, 278). Thus, each of these special-ists had to learn how to translate their particularconcerns and problems into a common format. Therequirement forced the specialists to work together,and to communicate among themselves. The use ofa common model compelled interdisciplinary teamsto be truly interdisciplinary-to combine theirspecialties for assessing management alternatives.

Some have suggested that FORPLAN, and quan-titative analysis generally, has protected against“professional omnipotence. ” In this view, com-puter models and analyses:

. , . prevent professional groups within the ForestService, especially foresters, from imposing theirobjectives for management of the forest on the restof society (123).


Others note that the Forest Service may have simplyreplaced professional wisdom with computer analy-sis for explaining the decisions (64), and thatdecisions based on computer analysis may be nomore acceptable to the public than those based onprofessional expertise were in the late 1960s andearly 1970s. Nonetheless, FORPLAN has shiftedpower within the agency from the traditional re-source staffs toward the analysts and planners of theinterdisciplinary teams (64).

Protection of Agency Discretion

Some observers have asserted that FORPLAN hasbecome a shield to thwart the efforts of interestgroups to shift national forest management invarious directions. The complexity of the issuesanalyzed and the multitude of constraints limit theability of analysts outside the Forest Service tounderstand the process well enough to know whereand how to modify the analysis to get the desiredresults. According to the model’s principal author,K. Norman Johnson, FORPLAN:

. . . is a formidable roadblock to gaining leverage topush the national forests in any direction other thanthe one they wish to go. The complexity andsubtleties of its options, the comprehensiveness of itsview, the incredibly ambitious task given to it by thenational forests, and the tremendous variance in itsuse from forest to forest makes it difficult tounderstand . . .

Thus FORPLAN is very effective at preservinglocal agency discretion. It represents a formidableway for the national forests to insulate themselvesfrom their critics (123).

The difficulties in understanding FORPLAN is aweakness of the model, as will be discussed below.Furthermore, some have hypothesized thatFORPLAN has shifted criticism and control fromlocal interests to national interests, giving greaterpower to such centralized critics as the Office ofManagement and Budget, the National Forest Prod-ucts Association, and The Wilderness Society (23).Thus, FORPLAN may not provide as much protec-tion for local discretion as some have suggested.

FORPLAN’s Weaknesses

As many observers have noted, FORPLAN hasnumerous weaknesses. Some are inherent in linearprogramming; as discussed earlier, linear program-ming cannot include risk and uncertainty, andassumes continuous, direct, and reversible relation-

ships among variables. The FORPLAN model hasnumerous unique shortcomings, such as massivedata requirements, use of economic criteria for theobjective function and the importance of constraints,lack of spatial details, and the ‘black box’ nature ofthe model. Additional problems exist with thesystem for supporting and using FORPLAN, such asdocumentation problems, inadequate verification,the loss of expertise, and the poor understanding ofhow results can be used in decisionmaking.

The FORPLAN Model

Data Requirements—Linear programming re-quires massive amounts of data, and in terms of sizeand complexity, FORPLAN has extended the fron-tiers of linear programming (14). As noted above,FORPLAN requires analysts to develop costs andoutput yields in order to relate activities to theobjective function, and relevant measures to relateactivities to absolute, flow, and relational con-straints. For each management prescription (such asclearcutting with site preparation for natural regen-eration) and each analysis area (areas with similarresource conditions and responses to the prescrip-tions), the user must identify the expected schedule,over 100 years or more, for at least: 1) theimplementation costs; 2) the quantitative yields forall relevant outputs (timber harvests, water flows,animal populations, recreation uses, etc.); and 3) therelationship to the various constraints (endangeredspecies habitat protection, soil erosion limits, nonde-clining even flow of timber, maintaining biologicaldiversity etc.). Thus, FORPLAN clearly requiresenormous amounts of information, which undoubt-edly exceed the limits of knowledge.

Many critics have noted that data are inadequateto meet FORPLAN’s needs. Timber inventories areoften out-of-date (64). Yield information for otherresources is rare, and ‘‘Assessments [of nontimberresources] are subject to large measurement errors’(72). In its recent internal critique, the Forest Servicenoted the lack of data on water, old-growth timber,range condition, and threatened and endangeredspecies, and the lack of tools for addressing culturalresources, biological diversity, erosion and sedi-mentation, cumulative impacts on water quality,visual quality, and wildlife habitat capability (278).The lack of data could lead the various resourcespecialists to coordinate their needs, but ‘the agencystill has not developed an effective strategy todevelop and manage data systems” (64).


One particular data problem could cause seriouslegal difficulties for the Forest Service. NFMArequires assurance that clearcutting is used onlywhere it is the optimal cutting system. However,“FORPLAN has an inherent bias for even-agetimber management’ systems, such as clearcutting(64), and comparable yield data for uneven-agetimber management do not exist (278). “Researchand practice has largely ignored . . . uneven-agedmanagement systems’ (64). This problem has notbeen widely recognized.

The lack of necessary data typically leads analystsand specialists to extrapolate existing data and tomake various judgments and assumptions, as needed(64). “In most cases, modeling coefficients [theinternal data] were based on anecdotal or ‘best-guess’ information rather than scientific quantifica-tion” (13). This is not all bad, especially when itleads to cooperative, interdisciplinary discussionand learning (64). However, in at least some cases,the resource specialists have become resource advo-cates, and subordinated the common good of theplanning team to the needs of their disciplines (13).At this point, it is unclear whether FORPLAN hascontributed to integrated resource management, assome have suggested (278), or has simply created“the illusion of interdisciplinary integration of allmultiple uses’ (13).

Objectives and Constraints-As noted earlier,the goal of the FORPLAN model is to maximize thepresent net value of national forest uses and outputs.While some have argued that this was clearly theintent of Congress (246), others are not convinced:

It is more difficult to find justification for thiseconomic approach in NFMA than the focus ontimber management. . . A much stronger focus is theassurance of protection of the forest environmentduring all actions (123).

The economic objective function has added to thedifficulties with data in building and usingFORPLAN, because all resource uses and outputsmust be measured in dollars, even though onlytimber has a true market price (64). (See ch. 8 for adiscussion of valuation techniques for unpricedresources.)

All goals for national forest management areincluded in FORPLAN through constraints on themodel. Insufficient constraints can lead to unrealis-tic estimates of uses and outputs (and thus to

infeasible targets), but excessive constraints cancause capabilities to be underestimated and lead tosignificant opportunity costs (50).

The most limiting constraints in FORPLAN havebeen the flow constraints, especially nondecliningeven flow for timber (278). Timber harvests areregulated by total timber growth, which is deter-mined by the area allocated to timber managementand by investments in timber growing. However, inforests with substantial timber inventories (i.e., withold-growth timber), nondeclining even flow limitstimber harvests largely by the amount of landallocated to timber harvesting. In many westernnational forests with substantial old-growth timber,timber harvest flow constraints have often been‘‘used as surrogates for restrictions on harvest foreconomic, social, political, or environmental rea-sons” (122). Easing the rigid nondeclining evenflow constraints could substantially increase all ofthe uses and outputs, without compromising long-term timber productivity (278). However, to theextent that timber flow constraints have been used assurrogates for other values, easing this requirementfor FORPLAN analyses may be politically infeasi-ble.

The choice of tools and data is not objective,because the selection carries implicit values andemphases (50, 51). FORPLAN maximizes the valueof uses and outputs. Nonuse values, such as visualquality and soil productivity (or having undisturbedecosystems or providing a natural resource legacy),can only be included as constraints to maximizinguses and outputs. The value implicitly associatedwith a constraint can be determined, but this is acostly and time-consuming process that has not beendone extensively in forest planning (64). As con-straints, nonuse values must be fully achieved at thespecified levels, but FORPLAN grants no additionalbenefits for exceeding the specified levels. Thus,FORPLAN can examine tradeoffs among uses andoutputs, but cannot readily examine tradeoffs be-tween outputs and protection. This approach hasbeen described as reactive--preserving current con-ditions and mitigating damages-rather than asproactive—managing ecosystem functions (234).Therefore, FORPLAN may not provide the balanceamong accommodating uses, producing outputs, andsustaining ecosystems as is intended in the lawsguiding national forest management.


Spatial Limitations--FORPLAN’s capability toaccommodate spatial relationships is limited. Ini-tially, analysis areas were simply areas with similarconditions and responses to management activities--areas with comparable soils, similar timber stands,identical costs, etc. The areas did not need to becontiguous; in fact, version 1 of FORPLAN did notallow the analyst to specify whether the areas werecontiguous (122). In version 2, spatial relationsamong analysis areas could be specified (65).However, including spatial details substantiallyincreases the size of the model (and hence the costto use it), and only a few spatial configurations canbe analyzedinFORPLAN(118).

Spatial relationships are very important in landand resource management:

In terms of outputs such as water, wildlife andfish, and aesthetics, it is probably more importanthow a management action (for example, a timberharvest) is spatially laid out than how many acres areinvolved (1 18).

Furthermore, limited spatial details lead FORPLAN(and all other optimization models) to overestimatethe feasible outputs (54, 72). This happens becauseimplementation requires local adjustments and site-specific tradeoffs that cannot be included inFORPLAN (146). Unless additional spatial analysisis conducted, the use of FORPLAN to establishoutput targets in the forest plan can lead to plannedtargets that exceed the feasible productive capacityof the forest.

The “Black Box” Nature—FORPLAN is a verylarge and complex computer model; its complexityincreases with the number of land areas, outputs,practices, and years being analyzed (51). In somerespects, FORPLAN has gotten so complex thateven professional users fail to understand modelresults.

It is possible to build a model that is so com-plicated that even the analyst no longer understandswhy certain outputs are identified as optimal . . .

The level of sophistication, and the concurrentability to hide assumptions and manipulate data,have risen to the point that even trained users are notalways aware of the ties that bind (122).

Furthermore, the data and constraints in FORPLANcan be, and at times probably have been manipulatedto produce specific preferred results (13).

Some interest groups believe that the data, themodels, or the analysis is, or has been, intentionallyor unintentionally distorted, twisted, or slanted torationalize certain conclusions. Even worse, if thesesuspicions are occasionally true and discovered, thenthe entire analytical system, the analysts, and theplanning process risks rejection. I think some of thishas happened (64).

The sheer size and complexity of FORPLAN, orof any other computer model, lead to a distrust of themodel (64, 234).

The ‘black box’ nature of FORPLAN allows fordata errors and hidden assumptions to go undetected(14).

The frequent modifications to FORPLAN and theresulting variety of FORPLAN models have addedto the confusion (173, 179). Finally, FORPLAN hasnot been widely available for public examinationand testing (123); however, the recent developmentof a FORPLAN model that can be used on a personalcomputer will alter this condition (64). All in all,FORPLAN has probably contributed to ForestService difficulties in communicating with thepublic.

The FORPLAN Planning System

Documentation-The lack of model documenta-tion has posed problems for FORPLAN. Documen-tation is needed to inform the public aboutFORPLAN, and to assure that its use is consistent,not arbitrary and capricious (51). However, “formaldocumentation [of the FORPLAN model] has al-ways lagged well behind [the system’s] develop-ment’ (125). Although FORPLAN has been usedsince 1980, the final user’s guide was not availableuntil May 1986 (125), and scientific publicationsdescribing the system were sparse for the firstseveral years (123). Thus, it has been difficult foragency analysts and outsiders to examine and reviewthe technical structure of the model.

A related problem is the lack of documentation ofhow FORPLAN has been used and on the underlyingassumptions, yield data, etc. The forests havemaintained “unclear and incomplete records suchthat new analysts could neither duplicate nor under-stand what had been done previously” (278). Thislack of documentation could lead to successful legalchallenges on the grounds that the analysis wasarbitrary and capricious.

—


Verification--Verification of the various as-sumptions, yield tables, and other inputs toFORPLAN has generally been inadequate (179).Unverified systems have undoubtedly been usedbecause of the need for immediate answers in theongoing forest planning process (146). Inadequateinitial verification is not a fatal flaw, if forest planimplementation is monitored in a manner whichallows the assumptions, yields, and otherFORPLAN inputs to be examined; plan monitoringwas intended, in part, to verify FORPLAN and itsdata (146). However, to date, monitoring has beeninadequate for this task. (See ch. 6.)

Agency Expertise-In response to the direction touse FORPLAN, the Forest Service developed a poolof talented analysts and modelers (64, 146), andseems to have provided adequate training for usingthe system (278). However, retaining this expertisehas proven to be more difficult. Mixing these expertswith the traditional specialists within the ForestService has led to “culture shock” and has createdsome hostility toward the analysts (64, 146). Fur-thermore, delays, poor data, and other planningdifficulties led to disillusionment and “burnout”among analysts (64, 146). Apparently fruitlessefforts also have contributed to low morale (50).Finally, the analysts often felt locked into their jobs;there has been no career ladder for talented individu-als to move up in the organization (278). That theForest Service still has the personnel to use anddevelop FORPLAN and other models is a tribute tothe agency’s tenacity and commitment, but addi-tional steps may be necessary to assure that thesepeople are retained.

Relationship to Decisionmaking—A major prob-lem has been comprehending how FORPLAN analy-ses can be used in decisionmaking. The lack of‘‘clear understanding of the relationship betweenanalysis and decision making” has led to manyinvalid and useless analyses (14). Analysts aretypically separated (physically and by education andexperience) from the decisionmakers (123), andmanagers often have not understood the limits ofFORPLAN (64)--’ ’people took FORPLAN and itsresults as gospel’ (278). Unless they are familiarwith computers, people commonly do not recognizethat models “are dumb [and] do exactly what theyare told’ (64).

FORPLAN can be useful in assisting ForestService decisionmaking, if its limitations are under-stood.

FORPLAN’s usefulness [is] as an aid to under-standing the nature of forest planning problems [notas optimal answers]. . . Its major purpose is toprovide insight into the behavior of multiple re-sources and their interactions, which in turn can beused to guide the development of effective plans anddecisions, The model is more appropriately used toprevent wrong decisions than for making “right”decisions (13).

Virtually all analysts recognize that models are mostuseful for examining possibilities, and that usingFORPLAN to obtain answers can waste money andinhibit development of a publicly acceptable forestplan. “The phrases ‘FORPLAN says’ and ‘ourmodel says’ need to be purged permanently’ fromconversations with the public (64). Analysis isintended to help managers ‘‘understand the forest,its potentials, limitations, and constituencies, and touse this knowledge to find a balanced, acceptablecourse of action” (64). Thus, FORPLAN is simplya tool, to be used with other tools in preparingimplementable forest plans.

SUMMARY AND CONCLUSIONSNFMA does not prescribe the use of any particular

technology in forest planning, but various computertechnologies can be very useful for analyzingalternatives and assuring requirements are met. TheForest Service designated FORPLAN as the primaryanalytical tool for forest planning, but the manyshortcomings of the model and controversies overforest planning have led some to question whetherFORPLAN may be part of the problem, rather thanpart of the solution.

Decisions and Tools

As discussed earlier, the purpose of national forestmanagement is to accommodate uses, produceoutputs, and sustain ecosystems. (See ch. 3.) Inforest planning, important decisions about the sched-uling (over time) and allocation (over space) of usesand outputs can be examined using various com-puter models. Linear programming is often used forscheduling decisions in business, and such anapproach is useful in forest planning for examin ingthe sustainability of uses and outputs over longperiods. Linear programming also has some capacityfor analyzing allocation decisions, but other tech-


nologies--notably geographic information systems—are better adapted for such analyses; however,GIS are expensive to acquire and use.

Analysis of the ecological and economic impactsof forest management is also important for planning.Resource simulation models are useful for examin-ing environmental and ecological implications, andcan be used to provide input for scheduling andallocation models, but more development is neededto provide sufficient analysis for forest planning.(See ch. 6.) Economic impacts can be evaluated byexamining the benefits and costs of activities overtime and by estimating the effect of managementalternatives on local employment and income; thebenefit/cost analysis is included within the structureof FORPLAN, and the Forest Service generally usesan input-output model--IMPLAN--to estimate localeconomic effects. (See ch. 8.)

Additional technologies can be used to supple-ment the decision support models (for schedulingand allocation analyses) and the impact assessmentmodels (for ecological and economic analyses).Database management systems can be used tomaintain and coordinate inventory and other dataused by the various analytical models. A “corpo-rate’ database (i.e., national access to consistentlymeasured, collected, and stored data) would beuseful, but the Forest Service has not yet setstandards for such a database. Knowledge-basedsystems (also known as expert systems) are usefulfor rule-based decisions, but the state-of-the-knowledge on forest and rangeland systems is tooprimitive to develop more than simple decisionrules. However, knowledge-based systems can alsobe interactive (i.e., questions for users, with theanswer determining the subsequent question), whichopens numerous possibilities for forest planning.Finally, integrated systems provide for automatedlinkages among other technologies, and thus can bevery useful for coordinating analyses; however,integrated systems are still being developed.

FORPLAN

Early in this century, following the Europeanforestry tradition, simple formulas were developedto determine allowable timber harvest levels for theunmanaged American forests with their large stocksof old-growth timber. These formulas no longersufficed by the late 1950s, and computer modelswere developed to assess the long-term sustainabil-

ity of timber harvest levels. FORPLAN was anoutgrowth of these models, and also incorporatedvarious aspects of a land allocation model developedfor watershed analyses. FORPLAN is basically alinear programming model that maximizes thepresent value of resource uses and outputs (minuscosts) within the specified constraints. FORPLANincludes absolute constraints (e.g., acres, productivecapacity, and targets or management requirements),flow constraints (for assuring sustainable productionlevels), and relational constraints (to specify rela-tions among variables).

In December 1979, the Forest Service designatedFORPLAN as the principal analytical tool for forestplanning. The agency believed that consistency inanalytical approach was necessary, and FORPLANwas chosen because it was available and addressedsome of the key questions in forest planning: theallowable timber sale level under a policy oflong-term sustainability, and the lands available fortimber harvesting. This capacity of FORPLAN isone of its strengths for forest planning. Anotherstrength is FORPLAN’s enormous analytical capac-ity; it can consider hundreds of thousands of possiblecombinations of management prescriptions (combi-nations of management activities) and analysisareas. FORPLAN also has required foresters, biolo-gists, archaeologists, landscape architects, and otherspecialists to translate their knowledge into acommon format, thus forcing them to learn acommon ‘language’ and encouraging real interdis-ciplinary efforts. Finally, some have asserted thatFORPLAN’s complexity has served as a barrier tocriticism, and thus has preserved local agencydiscretion for forest management.

FORPLAN also has many weaknesses. Inherentin linear programming is the inability to include riskand uncertainty and the assumption that inputs andoutputs are direct, continuous, and reversible (i.e.,that prescriptions and analysis areas are independentof other prescriptions and areas, that inputs andoutputs can be adjusted in minute quantities, and thatthere are no thresholds for ecological changes).Furthermore, FORPLAN requires data on costs,outputs, and the relationship to constraints for eachprescription and analysis area. Such data require-ments substantially exceed the knowledge base formany resources, including timber if uneven-agedmanagement is to be considered (as is required byNFMA).


The structure of FORPLAN carries importantimplications for forest planning. The goal is tomaximize the value of uses and outputs, but manyuses and outputs are difficult to value because theylack market prices to indicate their worth. Moreimportantly, nonuse values--e. g., protecting water-sheds, preserving endangered species, improvingaesthetics, and other values of having viable eco-systems—are included only as constraints on theuses and outputs. This structure implies that sustain-ing ecosystems is a constraint on production, and nota goal for managing the national forests.

FORPLAN has some capacity to analyze spatialconsiderations, but adding spatial data substantiallyincreases the size, complexity, and cost of the model,FORPLAN is so large that sometimes even the usersdo not understand why certain results occur; it is alsopossible to manipulate the system and to hideassumptions. Furthermore, the documentation of thesystem and of the assumptions and data used hasbeen inadequate, preventing others from examiningthe FORPLAN analyses. Parts of the system havenot been tested (verified), although sufficient moni-toring of implementation could provide the testingneeded. (See ch. 6 for more on monitoring.)

The Forest Service has done a remarkable job ofacquiring the analytical capacity to use FORPLAN.However, the difficulties in forest planning and thelack of promotional potential is causing low moraleamong analysts. The lack of clear understanding ofhow analyses would be used in decisionmaking hasadded to the dilemma. Managers have sometimesused analytical results without understanding thelimits of the analysis. At other times, managers haveignored the results because they did not trust thesystem or the analysts. Better communication be-tween analysts and management and with the publicis needed if FORPLAN is to be useful in forestplanning.

Options for the Future

FORPLAN will undoubtedly continue to evolveand be used in forest planning. The agency has sunka lot of money into developing the system and infinding and training the people to use it (23).FORPLAN can provide useful information (13,

226), and it or a similar model is probably necessaryto analyze the sustainability of timber harvest levelsover long time periods. Furthermore, there are fewreal alternatives to FORPLAN (179). Thus,FORPLAN will continue to be used.

Although the use of FORPLAN in forest planningcould be improved, it cannot do all of the analysisrequired for forest planning.

No approach will produce a perfect model of thereal world, because all models are abstractions whichnecessarily are simplifications of reality (14).

Thus, FORPLAN should be linked to other systems.The Forest Service is already using many resourcesimulations for input to FORPLAN, but additionaldevelopment and more integrated use of simulationmodels are needed (146, 234). A GIS is probablyessential to assure the spatial integrity of planningalternatives, and a corporate database would providea consistent structure for the data needed in thevarious analytical systems.

A more hierarchical planning structure could alsocontribute to the use of FORPLAN in forest plan-ning (72, 179). Some ecological modeling mustoccur at large scales, other at much smaller scales(172). Furthermore, FORPLAN has been devised totry to answer all forest planning questions at onetime (14). The regulation requiring a timber saleschedule in the forest plan has particularly contrib-uted to the complexity of FORPLAN (179, 234).FORPLAN could be substantially simplified, to thepoint where users and outsiders could understand theanalysis, if more analysis was done beforeFORPLAN was used (234) and if additional plan-ning and tools were developed for forest planimplementation (54, 146).

Finally, better communication about the resultsand limitations of the FORPLAN analyses is essen-tial. A simpler FORPLAN model under a hierarchi-cal planning structure would help (14), but closerconnections between analysts and managers are alsonecessary (61, 123), FORPLAN is a useful tool forexamining productive capacity and tradeoffs amongactivities (13). These analyses should contribute topublic participation, rather than limit or prevent.

Chapter 8

Economics in NationalForest Planning

Contents

Legal Requirements *. .*** . .oe. *e. o.*. e*e. .*. .*. *.. Q. Q . . . * . . * * * * * . . . * * * ....**...The Balance Among Resources .*. oo. o.. ***e ... ... e**o. ..*. **** **. .e. **. e * * . . * * ...***.*.

Economic Efficiency in National Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Limitations of FORPLAN in Achieving Efficiency . * * o . * * c o . o . * * * * e * * e o e o o o e o * . o e o + * e

D e t e r m i n i n g g the Balance: An Equity Issue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Impacts of National Forest Management ... **. O*** *o. **?. **o* o*o*e * . $ * . . . * . . * . *.*..*...

Community Stability *.. .*,0 ooo, o.o. eo**o. ..** .ee*@. .*** ***c *.. .Q. . **$.****+..******.Payments to Counties o.. .**o**. ... ..*. o.*. ***. oo **0*****....*.@***.*.....**.***.*..

Forest Planning and the Budget Process .*+. .*. o.** ... ... ... .o*. .e. ... *e. . * e . . . . . . . . . . . . .The Budget Level in Forest Plans o.. ..o. ..oo*o* *eo. *.. .*** .*e. *.. .*. .e*. . *e.***.*.***Plans and the Budget Process ... *.. o*o. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .“Off-Budget” Funding ... ... ..*. .*o. *.*. .*** ***. ... *.. **** *o** *$ Q e * * . * . * . . . **...*...

Summary and Conclusions ..*. ..** *.. ... .. * e . . . . . . * * * . * . . . . . . * * * . . . . . . . . . * * * * . . . . . . . . . .The Balance Among Resource Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .The Impacts of Management o * * * * . . . . * . . . * * * . . * . . . . . . . . * . . * * . e * * * . . . . . . . . . * .@****...

Planning and Budgeting ... *.. *.. ... ... ... ... **. *.. .o. ..o*e. o*e*eec *of..****..*..***.

Boxes

143143144145147148148151151151152154156156158158

Box Page8-A. Valuing Nonpriced Goods and Services . . . * e . * o . . . * * c o o . * * * * o * e * * * . . . . . * * o * e * * * . c . 1458-B. Forest Service Trust Funds and Special Accounts ● . . . * . . . . . * . . * . * . . . . . * * * * . . . . . . . . . . 1558-C. Peculiarities in Forest Service Payments to States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1568-D. Timber Purchaser Road Credits *.. ..** *e. ..oo. *.. ..*. oooo. o.c. ... ..*. *ooo. ..** *.e. 157

FigureBox Page8-1. Receipts From Activities in the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152

Chapter 8

Economics in National Forest Planning

Economic considerations enter into the strategicplanning process for national forest management intwo ways: in evaluating the tradeoffs among thevalues generated by the forests; and in identifyingthe economic impacts of national forest manage-ment. This chapter briefly describes the Forest andRangeland Renewable Resources Planning Act of1974 (RPA) and the National Forest ManagementAct of 1976 (NFMA) requirements for economicanalysis, and then assesses the use of economics indetermining the management balance and in identi-fying the economic impacts. The chapter concludesby analyzing the relation of the Forest Servicebudget process to strategic national forest planning.

LEGAL REQUIREMENTSRPA and NFMA substantially expanded the role

of economic analysis in Forest Service planning andmanagement (246). RPA requires: an Assessmentthat analyzes resource supplies and demands andevaluates investment opportunities; a Program toidentify investment needs and to compare outputs,results, and benefits with costs; a Statement ofPolicy to guide the formulation of budgets; and anAnnual Report to provide accountability for expen-ditures and activities, with appropriate measures ofrelevant costs and benefits and with representativesamples of below-cost timber sales.

National forest planning must also include eco-nomic analysis. NFMA requires that economics beintegrated with physical, biological, and other sci-ences by the interdisciplinary team (section 6(b)).Economic and environmental aspects of manage-ment are to be considered in planning for themultiple uses (section 6(g)(3)(A)). Economic im-pacts, along with environmental, biological, es-thetic, and engineering impacts, are to be reviewedon each advertised timber sale using even-agedsilvicultural techniques (section 6(g)(3) (F)(ii)). Eco-nomic, physical, and other pertinent factors are to beconsidered in identifying areas not suited for timberproduction (section 6(k)). Road needs are to be meton an economical and environmentally sound basis,and road standards are to be appropriate consideringsafety, transportation costs, and land and resourceimpacts (section IO(a) and (c)).

This guidance in NFMA strongly suggests con-gressional interest in efficient Forest Service man-agement. However, as discussed in chapter 3,Congress is also concerned about fairness andbalance. NFMA clearly directs management inaccordance with the Multiple-Use Sustained-YieldAct of 1960 (MUSYA), which requires the ForestService to “best meet the needs of the Americanpeople. ” MUSYA also prohibits maximizing re-turns or outputs as the sole criterion for manage-ment, and NFMA adds that the timber harvestingsystem is not to be chosen primarily to maximizereturns or outputs. Nonetheless, MUSYA also re-quires management ‘‘with consideration being givento the relative values of the various resources. ’Finally, although there is no explicit direction in lawto consider community stability in forest planning,Congress has on numerous occasions clearly ex-pressed concerns about the impacts of national forestmanagement on local communities.

THE BALANCE AMONGRESOURCES

In MUSYA, Congress explicitly directed theForest Service to consider the relative values of thevarious resources. This implicitly requires an eco-nomic evaluation, because the science and art ofeconomics focus on tradeoffs in values. Economicsgenerally concentrates on two issues: efficiency andequity. Economic efficiency aims at minimizingwaste, generally by reducing the cost to produce agiven level of output or by increasing the outputsfrom a fixed budget. Efficiency is no less importantfor government agencies than for private firms, butit is more difficult to achieve because the outputs aregenerally less precisely measured.

Equity considerations center on questions aboutthe fairness and balance of activities, and about thedistribution of income and benefits. Historically, thefield of economics has emphasized efficiency. Forexample, in their recent book on the economics ofmultiple-use management, Bowes and Krutilla (31)dismiss the distributional equity consequences ofpublic land management in one paragraph, and thenspend 300-plus pages on economic efficiency.Efficiency has traditionally been emphasized be-cause it can be measured and evaluated, while

–143–


unbiased measures of fairness and balance do notexist. Nonetheless, equity-the fair distribution ofincome and benefits--is one of the principal con-cerns of government.

As discussed in chapter 3 and noted above,Congress did not accept efficiency as the principalconsideration for managing the national forests inenacting MUSYA. Nonetheless, economic effi-ciency is not irrelevant. In the debate over NFMA,Senator Dale Bumpers (Arkansas) expressed con-cern over ‘‘the problem of wasteful investment intimber production.’ More recent debates over below-cost timber sales also suggest concerns about theefficiency of Forest Service timber activities. TheOffice of Management and Budget (OMB) is partic-ularly concerned about the efficiency of governmentspending (217). The magnitude and persistence ofthe Federal budget deficit will make the efficiency ofgovernment activities, including national forestplanning and management, a continuing concern.

Many economists, inside and outside the ForestService, believe that determiningg the balance amongresource uses, outputs, and protection is essentiallya question of economic efficiency-if uses andoutputs can be valued correctly and the interrelation-ships can be quantified accurately, the properbalance can be determined by a simple economicefficiency decision rule. Some have even argued thateconomic efficiency should be the primary criterionfor forest plans:

If properly done, NFMA planning should benothing more than a series of cost-benefit analysesthat lead to economically optimal forest plans (309).

Economic Efficiency inNational Forest Planning

Efficiency is measured by examining costs andbenefits. Efficiency increases as costs to produce thesame benefits decline or as greater benefits aregenerated at the same cost. In practice, improvingefficiency typically focuses on the cost side--theappropriate budget level and proper mix amongactivities. Neoclassical economic theory dictatesthat the “correct” budget level and mix are definedby the relation of costs and returns, with expendi-tures increasing as long as the returns are greater

than the costs; ultimately, the last dollar spent shouldyield a return of exactly one dollar. (If the return isgreater than a dollar, more expenditures are war-ranted, but if the return is less than a dollar, too muchhas been spent.) In technical parlance, the efficientbudget level is the level where the marginal benefitsequal the marginal cost for each activity; this definesboth the total budget and the efficient balance.

In the private sector, benefits are typically reve-nues, but a government agency often generatessocial benefits from goods and services providedrather than revenues. As noted earlier, many of theuses and outputs of the national forests do not havemarket prices. However, numerous techniques havebeen developed to estimate the value of unpriced orsubsidized uses and outputs. (See box 8-A.) Calcu-lated values can, in theory, be used as proxies forsocial benefits. Thus, the neoclassical theory ofeconomic efficiency can still be used, if the value ofthe goods and services (including nonuse values)can be determined.

Investments complicate the comparison of expen-ditures and returns, because expenditures and re-turns occur at different points in time, and the valueof a dollar today is greater than the value of a dollartomorrow. (The difference in value is interest,usually presented as an annual rate.) However,expenditures and returns can be compared, if theyare adjusted for timing at the relevant interest rate.(This rate is also known as the discount rate, and theprocedure is called discounting future costs andreturns to the present.) There are numerous methodsfor comparing discounted expenditures and returns.A common one, and the one used by the ForestService, is to subtract the present (discounted) costsfrom the present (discounted) value of the returns todetermine the present net value of the investment.The marginal approach of neoclassical economics isnot as useful, since investments are generally notsmall changes. Nonetheless, a similar decision ruleexists: if the present net value is positive (if thediscounted returns exceed the discounted costs), theinvestment is desirable.1

The Forest Service uses an economic efficiencyapproach in its forest planning model--FORPLAN—to assess the balance of uses, outputs, and protection

1~ d~ision tie for r- inves~~ts is somewht more complicated, since alternative investments are ~ely to have different Costs. The ratiOof discounted returns to discounted costs (the infamous benefit/cost ratio) is more useful to rank alternative investments, although a number of othertechniques (e.g., the internal rate of return) are also feasible for ranking investment options.

—.

Chapter 8--Economics in National Forest Planning . 145

Box 8-A—Valuing Nonpriced Goods and Services

Economic value of nonpriced resources results from both value in use and certain nonuse values. Use valuesinclude not only today’s use, but the value of having the option to use the resource in the future (commonly knownas option value). Nonuse values include the value of knowing the resources exist as well as the value of preservingthe resources for the future; these values are often referred to as existence and bequest values, respectively.

There are two basic approaches to measuring economic value of nonpriced uses and outputs. One is based onthe financial impacts of current use, usually by measuring either total expenditures or the value added because ofthose expenditures. Except for evaluating local community impacts, this approach is rarely used, because it doesnot measure the value of the resource. It would be like measuring the value of timber by tabulating how much timberpurchasers spent on labor, equipment, gasoline, etc.

The second approach is based on estimated demand for the resources. This approach is generally preferred forits sound theoretical basis, but is more difficult to apply, because it requires demand curves. Methods have beendeveloped for calculating demand curves for recreation and other nonpriced uses and outputs, typically relying ontravel costs (the travel cost method) (210), on site attributes (the hedonic pricing method) (31), or on an artificiallystructured bidding market (the contingent valuation method) (58). All such methods develop a demand curverelating quantity demanded to various prices. Demand curves can also be developed for nonuse values using thelatter two methods.

Demand curves for nonpriced resources are usually used to calculate consumers’ surplus. Consumers’ surplusis the total additional amount that the beneficiaries are willing to pay for the good or service, in excess of their currentexpenditures. It is also described as the possible revenues of a perfectly discriminating monopolist (i.e., one whocould charge a different price to each customer). This is a useful measure, but may not be directly comparable tomarket prices for commodities, since the market price is how much the buyers do pay, not how much they wouldbe willing to pay.

The Forest Service modified the traditional consumers’ surplus in the 1990 RPA Program (281) by estimatingthe market-clearing price, the price that would balance demand and supply if the uses and outputs were marketed.Theoretically, supply curves would be developed, and the market-clearing price would be the price at which supplyand demand are in balance. The 1990 RPA Program discusses developing supply curves from production cost data,but presents no evidence of such with its estimates of market-clearing prices; the market-clearing prices in the reportsuggest that a single supply curve was used in all regions for many different activities. This approach is conceptuallystrong, but additional information on supply curves is needed.

in national forest planning (246). FORPLAN is a suggest that the proper technique depends on thecomputer model that maximizes the value of usesand outputs while meeting specified constraints.(See ch. 7.) The goal (technically, the objectivefunction) is to maximize present net value ofresource uses and outputs; thus FORPLAN fits theneoclassical economic theory of economic effi-ciency.

Limitations of FORPLANin Achieving Efficiency

Resource Values

One difficulty with economic efficiently in forestplanning arises from the questionable comparabilityof values for marketed and unpriced uses andoutputs. Substantial research efforts over the past 30years have developed various techniques for valuingunpriced resource uses and outputs. (See box 8-A.)Researchers have defended various methods as thebest or most appropriate (31, 58, 210), and some

nature of the resource (242). Furthermore, thecomparability of market prices for commodities tothe calculated values for unmarketed or subsidizedresources has long been debated (154, 262). Theextent of the polemic over this issue indicatessubstantial uncertainty over the comparability ofmarket prices for resource commodities with thecalculated values for unpriced resources. This limitsFORPLAN’s usefulness in examining the economicefficiency of forest planning and management.

Another problem with using FORPLAN to assessefficiency is that some values are not included in theobjective fiction. As discussed in chapter 7, theobjective function in FORPLAN only containsvalues for uses and outputs. However, people alsovalue just having natural areas, protecting theopportunity to use them in the future, and preservinga legacy for future generations-values generallyknown as option values, existence values, and


bequest values. These values are not included in theFORPLAN objective function, and cannot be readilyassessed relative to use and output values. Instead,nonuse values are expressed as constraints on theobjective function. This approach provides only theselected level of protection for nonuse values; lessprotection is not allowed, and additional protectionyields no additional benefits. Assessing the tradeoffsbetween outputs and nonuse values is very difficult,at best. Furthermore, considering nonuse values asconstraints, and uses and outputs as objectives,suggests unequal treatment; uses and outputs arebenefits, but nonuse values are limitations onnational forest management.

Finally, even supposedly concrete values aresubject to considerable uncertainty. Off-budget funds(see below) are often excluded from economicanalyses, and cost data used in RPA and in forestplanning may be inaccurate (217, 259). Timbervalues are also subject to debate. One analyst hasnoted that forest plans assume unrealistic futuretimber prices (187); these prices are based onprojections using the Timber Assessment MarketModel, which is quite sensitive to assumptions aboutfuture U.S. economic performance, wood use tech-nology, and the like (259). The imprecision of costdata and timber values limit the usefulness of theefficiency analysis in FORPLAN.

Resource and Site Interactions

Another limitation to using FORPLAN to assessthe efficiency of forest management alternatives isthat current knowledge about physical, biological,social, and economic interactions among the re-sources is rather limited. For example, efficiency isthe essence of the debate over below-cost timbersales. The Forest Service asserts that timber salescan generate nontimber benefits, and that modifica-tions to generate such benefits often increase costsand/or decrease receipts, but that the sales are themost efficient means to achieve the benefits (222).Critics charge that the Forest Service not only losesmoney on below-cost sales, but that timber salesoften damage, not benefit, the other resources (153,187, 327). However, the cost to generate the desirednontimber benefits without removing the timber(e.g., cutting the trees and letting them decay) hasrarely been examined. Similarly, the possibility ofgreater efficiency in the timber sale process has notbeen analyzed. Thus, the below-cost timber saledebate is being conducted with incomplete informa-

tion on all sides. Such fragmentary understanding ofthe effects of activities on resources and ecosystemslimits FORPLAN’s capability to analyze the effi-ciency of alternatives.

A related difficulty is the meager data on the usesand outputs of noncommodity resources. Whiletimber harvests are measured, to charge for thetimber removed, recreation and other noncom-modity uses and outputs are often estimated.

Annual recreation use figures are notorious amongfield officials for being based on “a horsebackestimate’ of increase or decrease from the previousyear’s level, a figure which itself was based more ona manager’s rough sense of use than on any directquantitative measurement (217).

Thus, imprecision in the existing data, as well as thelack of understanding of resource interactions,restrict the capacity of FORPLAN for efficiencyanalysis.

The analysis of economic efficiency is furthercomplicated by site interactions, because the man-agement of one site may affect the efficiency ofactivities on other sites (138). For example, con-structing a road might be an efficient means ofproviding access to two adjoining stands of timberif both areas are managed to produce timber, butmight not be an efficient use of resources if only onearea is producing timber. Management efficiency ofvarious sites is most likely to be interdependentwhen access (principally road construction) is asignificant portion of the management costs. How-ever, the shortcomings of FORPLAN for addressingsite-specific issues also limit its capability to assessthe efficiency of interdependent management deci-sions.

Inefficient Prescriptions

Many critical decisions about balance and effi-ciency are decided before FORPLAN is used (30). Inparticular:

Decisions about suitable timberlands, the allowa-ble sale quantity of timber, wilderness, unpricedoutputs such as scenic and wildlife resources,silvicultural systems and land allocations are strate-gic elements of a forest plan that are generallydecided outside a FORPLAN analysis, using subjec-tive evaluations that reflect considerations other thaneconomic efficiency (246).

Among the principal inputs to FORPLAN are themanagement prescriptions-the general manage-

. —— — . . . . . . . . .


ment practices that are proposed for an area overtime. If timber is to be harvested, the prescriptionwould specify the rotation (harvest) age and thesilvicultural system to be used, the reforestationpractices, and any intermediate stand treatments,before the harvest and/or after successful reforesta-tion. Prescriptions would also identify other activi-ties expected in the area, such as wildlife habitatimprovements, recreation developments, range im-provements, and erosion control.

The timber industry has argued that the ForestService’s timber management prescriptions are inef-ficient, that different systems could yield greatertimber benefits and still protect the other values(308). However, while research has examined thecosts and benefits of specific activities, very littlehas been written about management prescriptionsand economic efficiency (123).

Forest Service research has shown that manytimber sales are modified to mitigate or enhanceother resources, often increasing costs or reducingrevenues (19, 182, 223). Comparing the efficiency ofvarious management prescriptions can be doneunder a patchwork dominant-use management frame-work (as described in ch. 3), because the outputs ofthe dominant resource can be compared to themanagement costs (assuming that the environmentalquality and resource conditions standards are stillmaintained). However, assessing efficient prescrip-tions under integrated resource management isdifficult because it requires an accurate understand-ing of the quantity and quality changes in allresources that result from a management activity(31, 221). Such knowledge, as well as measures ofquantity and quality for all resources, is currentlylacking.

Investment Commitments

Government agencies generally do not distin-guish between capital and operating expenditures.Annual budgets and appropriations generally con-tain no special provisions for addressing capitalinvestment needs. However, separating these costsfrom operations and maintenance is necessary forefficient investment, especially ‘ ‘if future expendi-tures [such as timber stand improvements] are tied topresent investment decisions [such as reforesta-tion]” (3 1). Mixing capital and operating expensescan contribute to inefficiency; future investmentsmight be poorly timed, if they are made at all.However, Congress is reluctant to commit itself to

fund future investments, regardless of the efficiencyof such investments. Political realities thus inhibitthe management efficiency that FORPLAN shows tobe feasible.

Determining the Balance: An Equity Issue

The technical limitations of FORPLAN are notthe only reason why economic efficiency is not usedto determine the proper management balance for thenational forests. Observers have noted the public’sgeneral lack of interest in economic efficiency forFederal land management (138), and even a philo-sophical opposition to efficiency standards:

Even supposing that the measurement problemscould be miraculously overcome, it would notchange the fact that the benefit-cost analysis is adirect descendent of utilitarian principles and thusphilosophically unacceptable to a growing segmentof the American public (164).

Using efficiency to determine management is alsoproblematic in that the beneficiaries of governmentactivities often do not pay the costs (44). Hunters,hikers, off-road vehicle users, and arguably evenranchers and loggers often do not pay the full cost forthe benefits they receive. This is the essence of theargument set forth by those who advocate marketsolutions for management problems, However, Con-gress rejected this approach in national forestmanagement. Determining the mix of uses, outputs,and protection is more a question of balance andfairness-equity-than one of efficiency.

The Forest Service has implicitly recognized thatefficiency alone cannot determine the acceptablemanagement direction for the national forests. Al-though FORPLAN compares alternatives for anational forest, the preferred alternative (and thefinal forest plan) is rarely the one that maximizesefficiency, as defined by present net value. Nonmax-imum selections by Forest Service line managersessentially acknowledge that computer models prob-ably cannot choose a balance among resource uses,outputs, and protection that is acceptable to thepublic.

How, then, can balanced management be estab-lished in forest planning? As discussed in chapter 5,Congress intended the Forest Service to determinethe proper balance by listening to the public. Thisdoes not imply public decisionmaking, but that theagency discuss goals, opportunities, and limitationswith affected and interested individuals and groups.


Through such interaction and deliberation, theagency can learn about the public’s desires andvalues, about new possibilities and practices forefficient and effective production and protection,and about the use and output levels the public findsacceptable. Members of the public can listen andlearn about their own and each other’s desires andvalues, fostering cooperation, rather than enmity.This is not to suggest that such discussions can leadto agreement on all issues. At times, the ForestService must make hard choices. However, balancecan only be achieved through meaningful interac-tions among the agency and various public interests.

IMPACTS OF NATIONAL FORESTMANAGEMENT

Decisions about national forest management af-fect not only direct users, but also local communi-ties. Congress has also shown concern for commu-nity stability and the effects on counties of the taxexempt status of national forest lands. These con-cerns, and efforts to address them, affect strategicplanning for the national forests. The policy ofsustained yield for stable timber harvests is based onproviding stability for communities. Much of thedebate over the economic impacts of national forestmanagement has focused on the effects on the timberindustry. The following discussion follows thisemphasis, but it is not intended to suggest that theeffect on other sections of local economies areunimportant. The difficulty of assessing such effectsis also discussed.

Community Stability

Concern and Approach

Congressional concerns about the impacts ofFederal land management on communities date backat least to the 1897 Forest Service Organic Act. Thefloor debate over the purposes for which forestreserves could be established strongly indicates thecongressional interest in making timber available tocitizens (233, 326). Some have argued that Congresshas clearly directed national forest management toconsider community stability (185). Others assertthat the congressional commitment to communitystability is far less clear (218), that while localplanning under NFMA includes community stabil-ity, national planning under RPA virtually precludesconsidering it (219).

Regardless of the clarity of congressional com-mitment to community stability, the concern is real.However, the legislative direction for the ForestService to consider community stability is ambigu-ous, at best (193). Nonetheless, as a strategicplanning process, NFMA planning is to addressissues and concerns, and community stability isoften raised as a local concern (225). Thus, commu-nity stability must be considered as an issue in theforest planning process.

Impacts on communities are typically assessed inforest planning using IMPLAN--a multicountyinput-output model adapted to each national forest.(See ch. 7.) Input-output analysis relies on a generalequilibrium model of the economy, with quantita-tive relationships to describe the interactions amongvarious manufacturing, service, and other sectors. Ademand-driven input-output model, such as IM-PLAN, estimates the impact of changes in nationalforest uses and outputs on employment and localincome; it has the ability to separate the directimpacts on one sector from the indirect and inducedimpacts on other sectors. Thus, IMPLAN candisplay the local economic consequences of variousmanagement alternatives for the national forests.

Limitations

Despite congressional and local concern forcommunity stability, the Forest Service has limitedability to assess and to achieve community stability.

Assessing Community Stability-one difficultyin addressing community stability stems from theimprecise definitions of community and stability(157, 218). There is no legal definition of, orrequirement to manage for community stability(193). Furthermore, academia has also struggledwith these concepts.

The first three speakers [at a 1987 conference oncommunity stability (150)] were an economist, asociologist, and a lawyer. They said, essentially, wecan’t measure community stability, we’re not surewhat it means, and the Forest Service has no legalauthority to do anything about it. In response, atlunch, a Forest Service spokesman said yes, thatmight all be true, but the Forest Service is going to“do community stability anyway” (224).

Economists generally define communities basedon their distinctive economic functions (236). Socio-logical definitions typically include both geographicand cultural elements. “Community” can also be

Chapter 8--Economics in National Forest Planning ● 149

defined by social relationships and interactions, orby a shared identity (145). This latter aspect isparticularly important for some groups, such asloggers (40). Small rural communities are oftenassumed to fit the definition on all counts, but suchis rarely the case ( 145). Newcomers frequently bringdifferent styles and cultures to these communities(230); however, these do not always conflict with thelong-term residents of rural areas (26). What all thismeans is that there is no simple definition ofcommunity that can be used for estimating andreporting the effects of national forest managementon ‘‘communities.’

Stability is equally difficult to define, but typi-cally is measured in economic terms-jobs, income,prices, and the like (157, 169). This is importantinformation, to be sure, but not the full measure ofa community’s stability. However, quantitative meas-ures of social stability do not exist. Furthermore,stability is often equated with maintaining the statusquo, but most recognize that change is an essentialpart of long-term stability, that communities aredynamic (218, 236). The difficulty lies in trying todetermine the amount and pace of change thataffords stability-too much or too fast is unstable,but too little or too slow results in stagnation. Thedifficulty in measuring the amount and pace ofchange and the lack of measures of social stabilitylimit our ability to assess the stability of communi-ties.

Input-output analyses have two additional short-comings for assessing community impacts. First,economic sectors are reported by county, but theresulting data can mask local variations within acounty. For example, Montana’s Gallatin Countycontains both timber-based communities (GallatinGateway and Belgrade) and recreation towns (WestYellowstone and Bozeman); similarly, neighboringPark County has one town dominated by a sawmill(Livingston) and another dominated by the touristtrade (Gardiner). Thus, using county data may notprovide an accurate picture of the impacts of nationalforest management on individual communities.

In addition, the economic data used in input-output analyses do not provide comparable detailsfor all resource-based sectors of the economy. TheU.S. Department of Commerce defines lumber andwood products as a separate manufacturing industry.In contrast, forestry and livestock production arepart of agriculture, while recreation is scattered

among a host of industries generally classified asretail trade or as services. Expenditure profiles canbe developed for each type of recreation to getrecreation employment and income data comparableto timber employment and income data (191), butthe task is costly and time-consuming. Thus, exist-ing data on economic interactions provide a morethorough picture of the impacts of national forestmanagement on the timber industry than on otherindustries that may also rely on the national forests.

Achieving Community Stability--The forest man-agement policy of sustained yield for a stable timbersupply has long been justified on the grounds that itpromotes community stability (219). Thus, commu-nity stability has often been equated with timberindustry stability (8, 236). While there is broadrecognition of the importance of other resources tocertain communities, much research and concernstill concentrates on the stability of communitieswhose economies depend on producing wood prod-ucts from national forest timber.

To date, no empirical evidence has shown thatstable timber production leads to stable communities(62, 69, 93), and some studies suggest that timber-dependent communities may be less stable thanother communities (97, 311). A broad array offactors affect the demand and supply of woodproducts, and the stability of local wood supplies isbut one of these (193).

Researchers have found that the cyclicality of thetimber industry has led to a certain communityresponse to distress-a passive expectation thatconditions will eventually return to normal (40).This, however, can lead to a loss of local leadershipthat could help the community adjust to upheavals(1 15). In addition, a mill closure alters the structureof a community quickly and substantially, furtherlimiting its ability to respond (314).

The Forest Service has recognized the difficultiesassociated with defining and achieving communitystability. Thus, its community-stability goal hasbeen defined as that of preventing sudden, cata-strophic instability when possible by graduallyphasing in changes, thus minimizing economic andsocial impacts. According to Associate ChiefGeorge Leonard (151), “community stability meansthe avoidance of radical, or abrupt, changes in theeconomic or social structure.


This suggests that community evolution may be amore apt goal than stability. Darwinian evolutionoccurs through the accumulation of small, gradualchanges. However, an alternative view of biologicalevolution (known as punctuated equilibrium) sug-gests that species may evolve quickly, then remainquite stable for long periods before disappearingquickly (73). This alternative view—long periods ofstability interrupted by abrupt changes—may alsobe more descriptive of community evolution.

Rural communities frequently depend on one or afew industries or firms; economic changes (regional,national, and/or international) may cause severelocal distress and upheaval. A sawmill, for example,may be able to adjust production levels, but it cannotclose gradually. The national forests accommodateuses and produce outputs, but the Forest Servicecannot control the economic factors that determinea fro’s ability to stay in business. With limitedresponsibility and limited means, the agency clearlyhas limited ability to promote community stability(61). Perhaps the best that can be hoped is to not bethe cause of major distress, as the Forest Service hassuggested.

At the 1987 conference on community stability(150), a Bureau of Land Management (BLM)employee questioned the extent of the industry’sresponsibility for community stability (175):

What is the timber industry’s role and responsibil-ity in community stability? . . . Specifically, forthose companies with a land base, to what extentshould their harvest scheduling consider communitystability, especially in light of projected futureshortfalls? For those companies with no land base, orno merchantable volume of lumber, how should thecompany consider future investments, especially toexpand production capabilities, considering commu-nity stability in the long run? Recognizing that manycompanies are active, positive members of thecommunity (while they are there) who make numer-ous contributions to the community ..., what is thetimber industries [sic] larger role in community stabil-ity?

In other words, can the Federal Government beresponsible for community stability when the pri-vate sector cannot be compelled to ignore marketsignals in making timber harvesting and mill capac-ity decisions that affect short- and long-term com-munity welfare? Can, and should, the nationalforests insulate communities from decisions in theprivate sector? And, what about communities that

have grown largely in response to Forest Serviceefforts to develop a timber industry in certain areas(291)?

Implications for National Forest Planning

The impact of national forest management onlocal communities is an issue that must be addressedin national forest planning. Although the congres-sional direction for considering community stabilityis imprecise, the Forest Service is to be responsiveto public concerns in the planning process, and thepublic is often concerned about the very real impactsof national forest management on communities.Thus, as the Forest Service has recognized, thecommunity stability issue cannot be ignored.

Because of the agency’s inability to control futureeconomic conditions, it is probably infeasible toassure community stability. Nonetheless, the ForestService should disclose a full picture of the likelyeconomic and social consequences of alternativeactions considered in the planning process. Currentplans rarely display all financial information+. g.,government revenues, expenditures (including thosefinanced from revenues), and receipt-sharing pay-ments—and often do not discuss impacts that occuraway from the forest-e. g., on downstream fisheriesand municipal and industrial water users (225).

IMPLAN provides a beginning (and will producea more complete picture as the Forest Servicespecifies the various resource-related sectors morefully), but is not sufficient to display the full suite oframifications of national forest management. First,the Forest Service must not view the national forestsas the only source of resource uses and outputs; otherlandowners can also provide the various uses andoutputs. In the planning process, the agency mustconsider the actions of other landowners (includingneighboring national forests), and explore the oppor-tunities to support them.

Furthermore, the Forest Service must also con-sider specific businesses that wholly or substantiallydepend on the national forests (e.g., ranchers withgrazing allotments, certain sawmills, and outfittersand guides who rely on Forest Service backcountry).In particular, the Forest Service must examine theextent to which a management alternative mightthreaten the dependent business. The agency must beaware of and sensitive to the businesses’ minimumoperating needs. This requires close cooperationbetween the agency and dependent businesses, but


the Forest Service must also be careful to avoidmaking decisions behind closed doors. Such “back-room deals” would harm the agency’s credibilitywith others interested in national forest manage-ment.

Payments to Counties

Since 1908, the Forest Service has returned 25percent of its receipts to the States for use on theroads and schools in the counties where the nationalforests are located; these payments are variouslycalled payments to States, payments to counties, andForest Service receipt or revenue-sharing.2 Thesepayments originated in 1907 (at a 10 percent return)to compensate counties for the nontaxable status ofFederal lands and to encourage western develop-ment. (Other Federal lands were also not taxable, butpublic domain lands were available for homestead-ing and other land disposal programs, and thus wereexpected to become taxable at some point.) The ratewas increased to 25 percent in 1908, and the moneywas permanently appropriated (i.e., the paymentswould be made unless Congress acted to stop them).However, there is no discussion in the Congres-sional Record as to why 25 percent was deemed theappropriate compensation for counties.

Forest Service 25-percent payments are often veryimportant to counties. They are not the only compen-sation paid to counties for the local influence of theFederal presence, but they are the only paymentsaffected directly by national forest management.Furthermore, in some heavily timbered counties inthe Pacific Northwest, Forest Service paymentsaccount for more than 80 percent of county operatingbudgets (217). Thus, counties are very interested inmaintaining or increasing Forest Service receipts(and the resulting 25-percent payments).

Timber receipts account for about nearly 95percent of total Forest Service receipts in most years(298). The dominance of timber receipts, combinedwith the importance of Forest Service countypayments, often makes the counties proponents ofForest Service timber sales, even at the expense ofother resources and industries (217). However,timber receipts also fluctuate widely, often changingby 50 percent or more from one year to the next

(298), and are much more variable than other ForestService receipts. (See figure 8-l.) Thus, under thecurrent system of compensating counties for the taxexempt status of national forest lands, counties havelittle certainty about their annual payments (andhence, their budgets). Still, they are more likely tosupport Forest Service timber sales than otheractivities in the planning process.

FOREST PLANNING ANDTHE BUDGET PROCESS

The annual Forest Service budget has a substan-tial affect on national forest management. Budgetsdetermine implementation of strategic plans, andprovide centralized control over planning by anorganization’s units. In forest planning, the budgeteffectively controls plan implementation. The ForestService budget is also the direct link betweenCongress and national forest management. Thissection explores the relationship between forestplanning and the Forest Service budget by:

1.

2.

3.

describing how budgets are considered in forestplanning,explaining how planning and the annual budgetprocess are linked, anddiscussing how funding mechanisms outsidethe annual budget process affect forest planningand management.

The Budget Level in Forest Plans

Economic efficiency is clearly related to thebudget level. As described above, neoclassicaleconomic theory provides an approach for determin-ing efficient budgeting if enough information exists.However, because of the difficulty of measuring andvaluing many government goods and services, suchcalculations are virtually impossible. Thus, thebudget level for each agency and program isdetermined by political debate and ‘‘horse-trading”to achieve a budget level and governmentwidebalance that meets the needs of the American people.

There has been an ongoing debate about whetherbudgets should be constrained in developing ForestService plans (both forest plans and the RPAProgram) (51). The Forest Service argues thatbudget constraints in the planning process limit the

%ese payments should not be confused with payments in lieu of taxes (PILT). PILT payments are made by the Bureau of Land Management(Department of the Lntenor) directly to counties, without restrictions as to their use. They are based on the Federal entitlement acres in the county, butare reduced by other revenue-sharing programs. NationaJ forest lands are included in the entitlement acres for PILT payments, and the payments arereduced by Forest Service revenue-sharing, but PILT payments are in auliirion fo the Forest Service’s 25-percent payments.


Figure 8-l-Receipts From Activities in the National Forests (in millions of dollars)

Millions of dollars1,000

1

4’ ‘,

// \

#/

II

Ib

600% I

‘1 I\ ?. I\ 1-\

400\\\,“’” =\/

200;

0! I I 1 I 11977 1980 1983 1986 1989 1992

Year

SOURCE: U.S. Department of Agriculture, Forest Service, Report of the Forest Serb (Washington, DC: U.S.Government Printing Office, annual series).

agency’s ability to examine all the needs andopportunities for resource management, and thatCongress and the public want to know the profes-sionals’ estimate of the money needed to do the jobright (214).

However, unconstrained budgets typically amountto “wish lists” (215). In the past RPA Programs, theForest Service has often implied that, with enoughmoney, they can solve all resource conflicts (147).Furthermore, Congress and the public need informa-tion on priorities, on what activities should occur iffunding is limited (214, 259). Realistic budget levelsare particularly important for forest plans. Thepublic has spent much time and effort contributingto the plans, and some view the goals and targets inthe plans as essentially moral commitments or socialcontracts (136). If funding is substantially lowerthan was planned, this contract cannot be fulfilled.Furthermore, substantially lower funding may alterimplementation of the planned activities enough torequire that the plan be revised.

Both unconstrained and realistic budget informa-tion is clearly useful in planning, but the ForestService Washington Office gave little direction to

the forests on the budget levels to be used in forestplanning. One regional office directed the forests toconstrain the budget levels used in planning, whileothers gave no direction. On some forests, plannedbudgets were constrained by past budgets, but onother forests, the plans were prepared without anybudget limitations-whatever money was neededwas assumed to be available. Thus, the budgets inforest plans cannot be simply aggregated to aNational Forest System budget proposal; the budgetassumptions differ too much (215) and may notreflect national fiscal priorities.

Plans and the Budget Process

The Current Budget Process

While NFMA directs that the integrated land andresource management plans be prepared by interdis-ciplinary teams, the Forest Service’s annual budgetis not integrated. The House and Senate Committeeson Appropriations use more than 50 line items forthe Forest Service budget, with each line corre-sponding to some resource management program.Thus, while planning is integrated, Forest Service

Chapter 8-Economics in National Forest Planning ● 153

budgeting (at least at the national level) is still doneby resource.

Projects under the integrated NFMA plans areaggregated into budget proposals at each nationalforest, and then the forest budgets are aggregated atthe regional offices; integrated resource manage-ment is translated into budget line items along theway. The functional budget is modified first by theagency’s Washington Office, then by the Office ofthe Secretary of Agriculture, the Office of Manage-ment and Budget, and the House and SenateCommi ttees on Appropriations to meet the politicalexpectations and priorities of each of these partici-pants in the budget process (217). However, theintegrity of multiple-use management under inte-grated forest plans is completely lost in this process,and any relationship between the actual appropria-tions and integrated resource management is coinci-dental (138).

The annual appropriations, along with specifiedoutput targets,3 are allocated among the regions, andthen to the national forests. Allocations are closelytied to specific resources. The translation of line itemappropriations back into integrated management is“done on an ad hoc basis by the resource managersthemselves out there on the individual rangerdistricts” (215).

Allocated funding and output targets thus becomethe management guidance for on-the-ground man-agement. The accounting for expenditures must, bylaw, match the appropriations; managers can be heldpersonally responsible for the misuse of Federalfunds. The Forest Service does have some authorityto transfer funds among programs (technicallyknown as reprogramming), but reprogramming has limited use because:

1. the authority is for relatively limited amounts;

2. the process is time-consuming, but the needmay not be known until the field season isunder way, late in the fiscal year; and

3. conventional wisdom holds that if money is notused, it wasn’t really needed, and won’t beavailable again (i.e., ‘‘use-it-or-lose-it’ (215).

Problems and a Possible Solution

The result of line item appropriations and limitedreprogr amming opportunity is that expenditures areoften reported as they were planned, not necessarilyas the money was actually spent (215, 217, 254).Thus, the accounting data may not reflect the wayfunds were spent managing the various resources.Some of the inaccuracies are intentional, but theimprecision of translating line items into integratedresource projects and then trying to accuratelyallocate time among the resource line items is theprincipal culprit (217).

This cost-accounting problem is compounded byinaccuracies in reporting target accomplishment.For commodities (especially timber), the targets arereadily measurable, and must generally be met. Forother resources, however, the methods for measur-ing and reporting outputs are less precise and lesstangible; watershed accomplishments, for example,are more related to the size of a watershed than to theeffort expended (215). (See ch. 6.) As a result, thereis ‘‘no recognizable relationship between variationsin funding and variations in output” (215). Thus,under the current system of line-item appropriationsand accomplishment reporting, Congress and theAmerican people do not really know what they areultimately buying when money is appropriated fornational forest management.

To eliminate these problems, the Forest Servicehas proposed an alternative budgeting system, knownas end-results budgeting. Under this approach, theline items for national forest management would becollapsed into one operations and maintenanceaccount; separate line items would be retained forinvestments in roads, trails, and facilities, forreforestation and timber stand improvement, and forland acquisition (215). The General AccountingOffice (GAO) (251) was favorably impressed withthe agency’s test of end-results budgeting, findingthat expenditures were reported more accurately andthat more outputs were being produced withoutincreasing costs.

End-results budgeting is not without its problems.Congress may fear losing control over the budget foreach resource program, although this fear is unrealis-tic, because Congress doesn’t really have this

3ConWN~ only e~~bli~hes ~~ sale tmgets ~ tie For~t Semice’s ~@ appropriatio~, and tie regional timber !Xde ~gets haVe OXlly ~enacted during the past decade (a response to the below-cost timber sales debate). Other resource output targets me established by the Forest ServiceWashington Office, based on the enacted appropriations for that resource.


control now if expenditures are reported as planned.Nonetheless, the softness of output measures fornoncommodity resources could lead to increasedfocus on the hard, measurable output targets. (Seethe discussion of monitoring in ch. 6 and ofperformance appraisal in ch. 9.) Wilderness, forexample, is measured in acres managed, a functionof Congress’s designation, not of managerial per-formance. For end-results budgeting to work, accu-rate measures are needed for changes in the quantityand quality of all resources resulting from manage-ment efforts (215, 259).

“Off-Budget” Funding

Special Accounts and Trust Funds

The Forest Service has a number of specialaccounts and trust funds that are independent of theregular, annual appropriations process. (See box8-B.) Not all special accounts and trust funds are‘‘off-budget’ some require annual appropriationsfrom Congress to allow money from the account tobe spent. However, for several special accounts andtrust funds, Congress permanently appropriatedadequate funding when the fund or account wascreated. 4 The Forest Service has 14 permanentlyappropriated special accounts or trust funds, 7 withannual expenditures exceeding $10 million. In 1987,permanent appropriations amounted to more than athird of the Forest Service budget for the NationalForest System (297).

The funding for six of these major permanentappropriations is largely or entirely related to thetimber program. As described above, the ForestService returns 25 percent of its receipts to the Statesfor use on roads and schools in the counties wherethe national forests are located, and timber usuallyaccounts for 95 percent or more of total receipts.(See also box 8-C.) Deposits to the Knutson-Vandenberg (K-V) Fund are a portion of timber salereceipts, while brush disposal and other cooperativedeposits are predominately deposits from timberpurchasers for work necessitated by timber harvest-ing, and the Timber Salvage Sale Fund receivesreceipts from designated salvage sales. Finally, theReforestation Trust Fund uses tariffs on woodimports (principally on imports of softwood ply-

wood from Canada) to eliminate the backlog ofneeded reforestation and timber stand improvementwork.

The Forest Service has substantial discretion todetermine the amount of money deposited in four ofthese funds-K-V, salvage, brush disposal, andother cooperative deposits. The agency determines:

1. the portion of timber receipts deposited in theK-V Fund;

2. whether a sale is officially a salvage sale, withreceipts deposited in the Salvage Sale Fund;and

3. how much timber purchasers deposit for brushdisposal and other cooperative work.

There are virtually no limits on the collections.Deposits to the K-V Fund, for example, accountedfor more than 99 percent of timber receipts on theBeaverhead National Forest in 1987, and more than90 percent of timber receipts on eight other forests(298). Nationwide, nearly 20 percent of timberreceipts were deposited in the K-V Fund in 1987,including more than $9 million on the KlamathNational Forest (47 percent of the forest’s timberreceipts) and more than $8 million on the TahoeNational Forest (55 percent of the forest’s receipts)(298). Deposits for brush disposal and other cooper-ative work are generally less than deposits to theK-V Fund, but still ranged as high as $7 million eachon the Willamette and Mt. Hood National Forests in1987 (298).

All four of these funds must be used on thenational forest where the money was collected(except for the portion allocated to overhead in theregional and Washington offices). Thus, at eachnational forest, the Forest Service has substantialdiscretion for determining a large share of its budget,if it has timber to harvest. A distinction is often madebetween ‘‘rich” forests and “poor’” forests (217).Rich forests simply have more timber availableand therefore more special account or trust fundmoney—than poor forests. (See also box 8-D.)

Within each national forest, the Forest Servicealso has discretion over how to spend the perma-nently appropriated funds. Timber salvage funds arelimited to preparing and administering new salvage

dT~~c~y, ~ ~anent appropriations are not ‘‘off-budget, “ because tbe House and Senate Committees on the Budget must include theseappropriations when considering the Federal budget. However, permanent appropriations occur unless Congress acts to alter therq and are generallyexcluded from discussions by the House and Senate Appropriations Committees and from their committee reports. Since Permanent appropriations occuroutside the regular annuat appropriations process, they are discussed here as ‘‘off-budget” iterns.


Box 8-B—Forest Service Trust Funds and Special Accounts

The Forest Service has 6 special accounts and trust funds that require annual appropriations and 14 withpermanent appropriations.1 (For a more complete description of budget terms and these Forest Service accounts,see The Forest Service Budget: Trust Funds and SpecialAccounts (297).) One permanent appropriation--NationalForest Roads and Trails Fund-has been effectively eliminated by the House and Senate Committees onAppropriations since 1982, because these funds have been transferred to the U.S. Treasury to offset annualappropriations for road and trail construction and maintenance. In addition, a 15th permanent appropriation-theTongass Timber Supply Fund-waste terminated in the Tongass Timber Reform Act of 1990.

Seven of the Forest Service permanent appropriations are substantial sources of funds, with more than$10 million appropriated annually in each account. The seven major permanent appropriations, in order of1990 appropriations (257), include:

. payments to States ($365 million in 1990);● Knutson-Vandenberg (K-V) Fund ($217 million in 1990);● Timber Salvage Sale Fund ($162 million in 1990);● Working Capital Fund ($110 million in 1990);● brush disposal ($47 million in 1990);. other cooperative work ($43 million in 1990); and. Reforestation Trust Fund ($32 million in 1990).

Six of these seven major permanent appropriations are largely or entirely tied to the timber sale program. TheWorking Capital Fund is at most indirectly linked to timber, since it is essentially a means of apportioningequipment and other capital costs among the various forest management activities. The one major ($10 million ormore) special account or trust fund not connected with the timber program is the Land and Water Conservation Fund(LWCF), which provides money for acquiring recreation lands ($63 million for the Forest Service in 1990).However, LWCF requires annual appropriations from Congress; it is not permanently appropriated.

IW diff~~ htw~ -M WXOuntS and trust funds, in Pedmd acamnting, is that interest on the trust fired bahmces accmes to thetrust fur@ while interest on special account baknccs accrues to the U.S. Treasq. There is no difference in the means of finadng or in theauthority of the agency to spend money from the account.

sales, while brush disposal and other cooperative productive timberland in western Oregon. While itdeposits are only available for the specified tasksthat require money to be deposited. However, K-VFunds are available for reforestation, timber standimprovement, or other activities within the timbersale area. In 1990, 53 percent of K-V Funds ($116million) were used for reforestation, 14 percent ($30million) for timber stand improvement, and 33percent ($71 million) for other programs (287).These other programs can include rehabilitation,maintenance, or improvement of watersheds, wild-life habitats, and other resources. Thus, not onlytimber managers have an interest in the collectionsand use of these permanent appropriations; this isparticularly true of K-V Funds (124, 187).

Implications for Planning and Management

Are permanent appropriations necessary to ac-complish various timber management and saleactivities? The answer is unclear. The Bureau ofLand Management (BLM) in the Department of theInterior manages about 2 million acres of highly

must accomplish many of the same tasks as its sisteragency, BLM has no K-V Fund, no authority torequire deposits for brush disposal or other activi-ties, and no purchaser road credits (291). BLM fundsroad construction and certain timber managementactivities through direct congressional appropria-tions or through uncompensated requirements on thepurchasers. The productivity and ownership patternsof the lands might make such funding mechanismsadequate, but BLM has demonstrated that suchprograms may not be necessary to manage lands andsell timber.

No evidence has been presented to show that thepermanent appropriations are efficient (for theForest Service or any other agency). Because themoney is available without action by Congress or theadministration, permanent appropriations are rarelyreviewed. Also, as noted earlier, permanent appro-priations are typically excluded from analyses ofForest Service efficiency, and even from reports of


Box 8-C--Peculiarities in Forest ServicePayments to States

In 1976, Congress amended the1908 Act estab-lishing permanent appropriations to return 25percent of Forest Service receipts to the states foruse on roads and schools in the counties where thenational forests arc located.The counties wereconcerned that the Forest Service was using timberreceipts to pay for reforestation and road construc-tion (see box 8-D, below), thereby redwing thep a y m e n t s t o counties . Therefore, Congress definedForest Service gross receipts to include certainreforestation funds (i.e., deposits to the Knutson-Vandenberg or K-V Fund) and timber purchaserroad credits. on forests with low timber values,these ’’receipts” are often the majority of the timbervalue; for example, deposits to the K-V Fundaccounted for 99 percent of timber receipts on theBeaverhead National Forest in 1987 (298). In suchsituations, Forest Service payments to counties anddeposits to the K-V Fund exceed the cash timberreceipts, effectively requiring transfers of fundsfrom forests with higher timber values. While theForest Service has always had sufficient cashtimber receipts to cover county payments and K-VFund deposits nationally, a number of frostsrequire additional funds to meet these two cashrequirements-28 forests (8 in the Northern Re-gion, 10 in the Intermountain Region, and 10others) with a total transfer of $2.4 million in 1987(298). However, this interregional transfer is wellhidden in the Forest Service budget.

Forest Service expenditures. However, the substan-tial local discretion over the level and use of thesefunds prevents Congress from exercising full controlover the Forest Service budget. Some might arguethat Congress should have limited opportunity totinker with Forest Service funding; the earlierdiscussion and analysis of end-results budgetingsuggest the benefits and problems of greater agencyfiscal autonomy. Nonetheless, whether permanentappropriations are an efficient and appropriatemeans of funding Forest Service activities remainsunclear.

Forest Service permanent appropriations undoubt-edly affect national forest planning. As describedabove, forest supervisors have little direct controlover their annua1 budgets for implementing theforest plans. However, they do control the fundsavailable from the permanent appropriations. Fur-thermore, because at least the K-V Funds are

available for a variety of tasks, employees in manyresource specialties have a budgetary interest insupporting timber sales. Some critics have evensuggested that Forest Service management is drivenpr imari ly by e f for ts to the budget (124,187). The use of K-V and other funds on someforests does lend credence to this view, but managerson other forests apparently rely much less on thesefunds. Thus, budget maximization is certainly notthe sole motive of Forest Service employees. None-theless, budgetary considerations do support aninternal interest in maintaining or expanding thetimber sale program in national forest planning.

SUMMARY AND CONCLUSIONSEconomic considerations enter national forest

planning primarily as concerns about the balanceamong resource values, about management effi-ciency, and about the impacts of national forestmanagement on communities. RPA and NFMArequire various economic analyses, and MUSYAdirects management to consider ‘the relative valuesof the various resources. ” These laws clearlyindicate that efficiency is an important considera-tion, but not the principal criterion for managementdecisions.

The Balance Among Resource Values

Some have suggested that efficiency is the appro-priate standard for determining the balance amongresource outputs and environmental protection. Effi-ciency is generally evaluated by comparing benefits(social benefits generated by a government agency)with costs (including nonfinancial costs). To analyzeinvestments, current and future benefits and costsare compared by calculating the present net value ofthe investment. The Forest Service uses a computermodel--FORPLAN--for such analysis. As describedin chapter 7, this model maximizes the present netvalue of the specified objectives, subject to variousconstraints.

FORPLAN is a useful tool for examining theefficiency of management alternatives, but haslimited capability to determine the most efficientmanagement balance. First, many uses and outputsof the national forests are not marketed, and theexisting techniques for valuing unmarketed uses andoutputs might not provide values that readily com-pare to market prices. Furthermore, the FORPLANobjective function includes only uses and outputs;nonuse values of the forest (option, bequest, and


%rcha?m insuchdtmtiom are also lea likely to face compedtioninbidding forl&ust Service tirober, however, and the fewer biddersgenelally lmalla ~ ov~ ~ ~ a relative price advantage. McbserS an mill poorer timk and face hi@H Opeming costswithout ncmsdly being less profitable

% aach Ml@iOns,-can bid up timber pricea by * amount of the ineii’e credib Witkut hcreamg“ thelqrlked cashpymalta. such bi@~ ~ ‘%oodcn dollar” bida, anew pumhasmtodelay thoirctulh ~ *m the Credits cdhctive(usable)+ “wooderl dollar” bids also incrcme Forc8t service P-~cmmties (see box K above), and thus have ade “mnelual &&x onthe Us. melwlly.

existence values) can only be included as constraints In addition to these limitations on using efficiencyonuses and outputs. FORPLAN analyses are only asgood as the information in the model, and thus arerestricted by incomplete knowledge of biologicalinteractions, by sparse data on noncommodity usesand outputs, by model limitations for addressingspatial relationships, and by inadequate analyses ofthe efficiency of the management prescriptions used.Finally, investment efficiency may require thatfuture investments be tied to current expenditures,but Congress is reluctant to commit to expendituresby future Congresses.

criteria generally, and FORPLAN in particular, todetermine the management balance for the nationalforests, Congress and the public have rejectedefficiency as the standard for determining manage-ment direction. Furthermore, the beneficiaries ofmany management activities pay less than the fullcost of producing the benefits, and some pay little ornothing. The Forest Service has implicitly recog-nized these limitations in selecting forest plans thatdo not maximize present net value. Instead, thebalance among uses, outputs, and protection can


only be determined through public involvement-asthe Forest Service and the public discuss their needs,concerns, and values and consider the possibilities ofachieving them through national forest management(See ch. 5.)

The Impacts of Management

The impacts of national forest management oncommunities are typically addressed in terms ofcommunity stability. Congress has long expressedconcerns about community impacts, but the legisla-tive direction to consider community stability inforest planning is ambiguous. Nonetheless, forestplanning is to address local concerns, and locals areoften concerned about the impacts of managementon their communities.

The Forest Service generally uses an input-outputmodel—IMPLAN--to identify the economic im-pacts of management alternatives. IMPLAN esti-mates the employment and income by industrysector for multicounty areas around each nationalforest. However, this approach can mask impacts onspecific communities, because different resource-related firms may exist in separate communitieswithin a county. Furthermore, the wood productsindustry is the only resource-dependent industryidentified as a separate sector in Commerce Depart-ment data; although the Forest Service is working toimprove IMPLAN, modifying the data to separaterecreation, livestock, and other resource industries isan expensive and time-consuming task. Finally, theimprecise definitions of community and of stabilitylimit the agency’s ability to fully display the impactsof national forest management.

Traditionally, community stability has been equatedwith sustained yield, particularly of timber, but noevidence exists to show that sustained yield ortimber management can promote community stabil-ity. Furthermore, the Forest Service has no ability toinfluence demand factors, which are important tostable industry production, and it is questionablewhether the Forest Service alone bears responsibil-ity for timber industry stability. Nonetheless, abruptchanges in Forest Service timber sales can bedisruptive. Thus, the Forest Service has defined itsresponsibility to communities as attempting to avoidcausing radical or abrupt shifts in local social andeconomic patterns.

An additional significant impact of national forestmanagement is the potential effects on county

budgets. The Forest Service returns 25 percent of itsgross receipts to the States for use on the roads andschools in the counties where the national forests arelocated. In most years, more than 90 percent ofForest Service receipts result from timber harvest-ing. Thus, to meet budget needs, counties oftensupport continued or expanded timber harvesting.This is also a problem, because timber receipts canfluctuate by 50 percent or more from year to year.Counties need to be fairly and consistently compen-sated for the tax exempt status of the national forests(and other Federal lands), but the current systemmight not approximate tax compensation.

Planning and Budgeting

The budget may be the most important economicconcern in forest planning and in plan implementa-tion, but the current budget system has seriousdefects. Various national forests used differentbudget assumptions in preparing their plans, someconstraining the budget to realistic alternatives andothers allowing any budget level. Because of this,current forest plan budgets cannot be simply aggre-gated into an annual budget proposal for theNational Forest System. Unconstrained budget as-sumptions are useful for examining a full range ofopportunities, but realistic budgets are necessary fordisplaying priorities and likely management activi-ties to Congress and the public. Although difficult toachieve, both types of budget assumptions should beconsidered in planning.

Another problem is that the current budget systemsubverts the integrated resource management re-quired by NFMA. More than 50 functional line itemsappear in the annual budget, with the funding andoutput targets modified by the Forest ServiceWashington Office, the Secretary of Agriculture, theOffice of Management and Budget, and the Houseand Senate Committees on Appropriations. Theresulting appropriations bear little resemblance tothe integrated management presented in the forestplans. In the field, the allocated funds and targets areretranslated back into integrated projects, but theallocations may not match the plans very closely.

This process leads to inaccurate reporting of costsand accomplishments. Despite direction to reportexpenditures accurately, they have often been re-ported as they were planned, without assurance thatactual expenditures match the plan. Furthermore,while hard, measurable outputs are reported for


commodity resources, the measures used for otherresources allow for substantial imprecision in report-ing. (See ch. 6.) The Forest Service has proposed“end-results budgeting’ to eliminate these prob-lems, and the General Accounting Office has foundthe test to accurately report expenditures. However,measures that relate management efforts to changesin resource quality and quantity are needed beforeend-results budgeting can take into account allresources.

Finally, permanent appropriations account fornearly a third of the Forest Service budget annually.Most of these special accounts and trust funds arerelated to the timber program, deriving money fromtimber sales and/or providing money for timber

management activities. Each national forest hassubstantial discretion to determine the amount ofmoney available in several of these accounts, and inone, the K-V Fund, the money can be used for anymanagement activity in a timber sale area. However,the BLM operates without permanent appropriationsin western Oregon, suggesting that they may not benecessary. No evidence has shown that permanentappropriations are efficient, and there has beenvirtually no congressional oversight or control overthese discretionary funds. Nonetheless, these perma-nent appropriations clearly can influence nationalforest management, because managers have theopportunity to increase their own budgets by in-creasing timber sales.

Chapter 9

Organizational Factors inForest Planning

. . - - - -- - - . . . . . .

ContentsPage

Professionalism and Diversity in the Forest Service . * . . * . . . . . . . * . * . . * * * * * . . . . * . ****....*Professionalism ... ... ... ... ... ... ... ... ... ..*. .*** .*** .*. .**. *c C*** *e+. *.*e***S***oeDiversity and Interdisciplinary Efforts ..*. ... ..*. .ooO*. *e** ***. **, **. *$, *.. *.. .$.*...

Organizational and Employee Values ... o.. e.. ..** .*. **ss**. .*+* ***. ... .*. .., $.. *.. .Q*

Performance and Rewards ..** ... .*. . . . * * . * . . * . . . . . . . . . * * . . * * . * . * * * * . * * . * . * . * ****.*..*Production ... ... *.. ..** ... .*. **. ... .*. *.. ... ..** ... ... **** *.. **. .*** *.*. .*$* Q$ """"'*Team Spirit ... .*. *o*o*. ... ..*. ..* ....*...**.*.....***.*...*.**.*..*".""""*"""""*""Rewarding Plans and Planning ... .*o*o. ..*. ..*. ... e e . . . . . * . . . * * * * . * * * * * * * * . . ..*.*..*.

Summary and Conclusions ... ... .*o. ..** *.. .*. ... .**. .*+. .*. .$** *.. .. **$***.......*.*..Forest Service Culture and Diversity *.. ..*. ***. ..** *.. **. .*** +.$. *.. @.. *.. .Q*. ***. QQ, .Performance and Rewards .*. ..** .*** .*. ... *.. *.. ... .**. **. ... ***. *.. *.. **. .Q ..****.

Table

163163167169171171173173175175176

Table Page9-1. Forest Service Interdisciplinary Team Members . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 169

Chapter 9

Organizational Factors in Forest Planning

In some respects, the Forest Service appears to beunder siege even by some of its own employees. Theplans and the planning system are being attacked,and the agency is accused of damaging the resourcesand ecosystems it is mandated to protect. Onecommon allegation is that the agency’s problemsresult from the dominance of professional foresters.Others assert that the problems arise from theunbalanced reward system for agency managers.This chapter examines these allegations, and con-cludes by assessing the impacts of organizationalfactors on forest planning.

P R O F E S S I O N A L I S M A N D

D I V E R S I T Y I N T H E

F O R E S T S E R V I C E

This section explores the strengths and limitationsof the agency’s forestry-oriented professionalism,examines diversity and the use of interdisciplinaryteams, and concludes by assessing organizationaland employee values.

Professionalism

Foresters

Foresters have dominated the ranks of the ForestService from the very beginning. Bernard Fernow,Gifford Pinchot, and others emphasized the impor-tance of professional forestry training for those whomanage forested lands, and focused on hiringforesters for the agency (240). Today, professionalforesters are less dominant than in the past, butforesters still account for more than 50 percent ofprofessionals and for more than 75 percent of thetechnicians employed by the Forest Service (284).

Foresters, as any professional group, are boundtogether by a common educational core and profes-sional identity. The professional foresters organi-zation—the Society of American Foresters (SAF)--contributes to this cohesive identity by providing thefocus for professional activities and by accreditingforestry school curricula. This assures that forestrygraduates are schooled to meet the needs of theForest Service and the forest industry, the majoremployers of foresters. An interlocking network ofagency-university-industry establishes a successful

paradigm of scientific forest resource management(316, 330). This paradigm emphasizes resource useand has implications for the direction of forestplanning.

Emphasis on Use—The extent to which forestersdo and should emphasize timber production hasbeen debated for more than 50 years (31). SAFExecutive William Banzhaf (12) recently noted thecurrent SAF president and vice president reflect thediversity among foresters in differing over “thelevel of emphasis we as professional foresters shouldgive the production of wood for commodity uses.’

Wood production is an important part of nationalforest management and of professional forestry.Timber management has traditionally been at thecore of a forester’s training.

In the United States, foresters were initiallyeducated to be custodial managers with heavyemphasis on timber production, an educationalphilosophy that persisted for some 40 to 50 years(71).

Two decades ago it was alleged that:

The professional forester apparently accepts . . .the belief in the primacy of timber as a use of theforest, based on the fear of a wood famine, inter-woven with a puritan ethic that utilitarian or com-modity uses are always more important than anyamenity values (29).

Foresters are the only professionals who have theeducation and experience to manage forests forwood production-they are the only ones who canbe the timber specialists (53). Thus, foresters mustbe concerned with timber production.

This is not to suggest that foresters are all ‘timberbeasts,” with no interests other than maximizingwood production. The forestry profession has longendorsed the concept of multiple-use management,and foresters in the Forest Service have recognizedmultiple uses of forest lands since the GiffordPinchot era(131, 330). Wood production is only oneof the many forest uses, albeit an important one, butmanaging trees is critical to many forest values, suchas aesthetics, water flows, and wildlife habitat.Furthermore, forestry education exposes foresters to

–163–


all the various forest resources, and many forestershave additional training in other resource specialties.

Nonetheless, foresters typically emphasize use ofthe resources. The SAF Code of Ethics, for example,focuses on forestry as practices, rather than onforests as natural systems, and on management offorest resources, rather than of forests (209):

. . . foresters’ traditional view of themselves [is] asmanaging resource things (i.e., objects like trees orgame animals), rather than managing these resourcesas objects of changing social values (includingnon-consumptive and symbolic values) (129).

Some of the emphasis on uses comes from theGifford Pinchot tradition of unbiased, professionalmanagement of the public’s lands. Prices (or othermeasures of use value) are quantifiable, objective,and unbiased indicators of public preferences, andforesters prefer ‘‘neutral’ economics for assessingsocial value over direct, emotional, face-to-face,unquantifiable expressions of social value at publichearings and political demonstrations (128). How-ever, economics has developed better techniques forvaluing unpriced or subsidized uses and outputs thanfor valuing nonuse benefits of forests. (See box 8-A,p. 145.) Thus, foresters (and economists) uninten-tionally emphasize use of forest resources over otherforest values.

Implications for Forest Planning—The empha-sis on forest uses has merit in national forestplanning. People care about the forests, and whetherand where to cut trees are central to much of thedebate over forest management. Thus, in somerespects, foresters’ emphasis on uses addressespublic interests and concerns. However, some for-estry educators believe that foresters’ commitmentto the public interest has diminished:

A strong commitment to . . . the public good wascentral to the forestry profession in this countryduring the first half of this century. More recently,however, this commitment appears to have declinedboth within the profession and in the eyes of thoseoutside it (71).

Why do some believe that foresters’ commitmentto the public good has declined? Some foresters haveasserted that society has changed, and the professionis no longer in tune with social values. For example,Scott Wallinger of Westvaco Corp. (3 10) noted that:

What is changing rapidly is not the validity forforest practices but the values most of the public uses

to judge them . . . Current logging is heavilyunbalanced toward just one system [clearcutting] . . .

William Ticknor of Mead Corp. (249) similarlyobserved:

. . . the public is saying, “Even, when I understandwhat you are doing, I still don’t like it.".

There is no debating matters of taste. You can’tpersuade a person to like broccoli, Penn tennis ballsor clearcutting. Or, preferring seedlings to maturetrees.

Others have noted that America is becoming moreurban and our urban society views nature moreromantically (26, 106). Urbanization has brokenmany of the direct ties with utilization of nature, andthus has led to the more romantic, less utilitarianview of nature. Furthermore, this is not a socialchange that can be corrected by ‘‘educating thepublic. They know what they like, and are unlikelyto accept traditional justifications for standard for-estry practices that have undesirable effects on thenonuse values of the forests. This implies the needto do things differently. Again, Scott Wallinger(310) observed that:

. . . we [foresters and the timber industry] must adjustto changes in public and landowner values andattitudes, not just defend traditional ways.

And William Ticknor (249) added:

. . . I think we [foresters] will find it useful to putaside the ‘‘we-they” mentality as we approach ourtask, and acknowledge that we, as a society, want toapproach forest resource management differently inthe future than we have in the past.. . . it is inevitable that forest practices, as we knowthem today, are going to change.

Other Professionals

The Forest Service may still be dominated byforesters, but the agency has always used otherprofessionals as well, and these are becoming a moresignificant part of the agency’s personnel structure.The Forest Service has traditionally employednumerous engineers, with range conservationists,soil scientists, hydrologists, economists, and otherspecialists. Engineers are still important, accountingfor more than 10 percent of the professionalworkforce and nearly 20 percent of the technicians(284). Forest Service engineers are relatively similarto foresters in their view of the agency mission,decision criteria, and disagreements with the organi-

—-—.— ...—.——.

Chapter 9--Organizational Factors in Forest Planning ● 165

zation, although they tend to place greater emphasison cost efficiency than do foresters (33).

In addition, over the past 20 years, the ForestService has added or expanded to include otherprofessionals, largely in response to the NationalEnvironmental Policy Act (NEPA), the NationalForest Management Act (NFMA), and various otherlaws governing the management and/or protection ofthe national forests (l). Wildlife and fisheriesbiologists have become the second largest profes-sional group within the Forest Service, accountingfor nearly 15 percent of the professional staff (286),but the agency also has landscape architects, archae-ologists and anthropologists, and various otherprofessionals.

The agency has developed a strong cadre ofprofessionals in each of [the important resource]areas (146).

Biologists have become a significant professionalsubculture within the agency, ranking with engi-neers in numbers (33, 132, 133). While biologistshave much in common with foresters, they alsodiffer in several ways. Education in biology, notsurprisingly, focuses on biological and ecologicalprocesses. In contrast to forestry, biology has not hadan industry to employ its graduates, and does nothave the lengthy historical focus on land manage-ment. Thus, biologists in the Forest Service typicallyhave a more biocentric, less utilitarian view of forestresources than foresters have (33).

Other specialists within the Forest Service havetheir own educational emphases, Landscape archi-tects, for example, emphasize visual values, whilearchaeologists and anthropologists are more likelyto be concerned with cultural values. However,regardless of their training, most of these variousspecialists share with foresters, engineers, and biolo-gists a sense of professionalism, and undergorigorous education and training in their specialty.

Benefits of Professionalism

Perhaps the greatest benefit of Forest Serviceprofessionalism has been the agency’s long historyof success. For more than half a century, the ForestService was viewed as a premier Federal agency,being a relatively strong and independent entity inmanaging resources for the public good. Shortlyafter the passage of the Multiple-Use Sustained-Yield Act in 1960, one observer wrote that:

. . . the Forest Service has an esprit de corps and aprofessional dedication unmatched in federal servicewhich should not be damaged. The present finecondition of the national forests is a monument to thedevotion and ability of the Forest Service and this isan important factor in any decision about theappropriate scope of professional responsibility.

Others have noted the traditional view of districtrangers as local heroes (130) and the Forest Serviceas a hero-agency (128). Few would argue that theForest Service had a long tradition of managementwith relatively little public challenge to its authorityor direction, at least until the 1960s.

The Forest Service’s professionalism and historyof success (as measured by the lack of major publicchallenge to management direction or authority)have contributed to the agency’s unusual esprit decorps. However, it may stem primarily from thehomogeneity and shared perceptions of the foresterswho have dominated the agency (50). Regardless ofthe source, Forest Service employees have had aconsistent sense of mission matched by few Federalagencies.

Preserving this strong sense of mission is the keyto maintaining the historic esprit de corps of theForest Service. Some employees are concerned,however, that the management direction for thenational forests is not consistent with the currentmotto “Caring for the Land and Serving People. ”Forest supervisors have been particularly outspokenin recent years about actions they perceive to beinconsistent with the agency’s mission (90, 91).

Drawbacks of Professionalism

While professionalism has contributed to the longhistory of Forest Service success and esprit de corps,it also has drawbacks. The scientific conservationparadigm (see below) limits the ways in whichprofessionals interact with the public, and publictrust in professionals has declined. These criticismshave been directed principally at foresters, largelybecause of their historic dominance of the ForestService, but apply to all of the professionalsemployed by the agency.

The Scientific Conservation Paradigm—Thescientific conservation paradigm essentially pre-sents conservation as primarily a scientific effort,with a focus on correct technical practices andprocedures. This view was behind conservationefforts of the mid-1800s, and persists largely


through the education of foresters, biologists, andother professionals in scientific and technical mat-ters (330). Foresters are traditionally taught to beobjective, scientific managers (131), and ‘‘forestryeducation emphasizes specialization, skill in quanti-fication, and rational problem-solving approaches”(315). Furthermore, the sciences (in contrast tophilosophy) typically eradicate disproven theoriesfrom their texts, leading students to view theireducation as the correct way of doing things (159).

This emphasis on technical matters creates nu-merous problems for the Forest Service in dealingwith the public. The agency has been accused of‘‘groupthink,” whereby cohesive groups (e.g., for-esters) view problems and potential solutions simi-larly (130), leading to insular and inflexible ap-proaches (50). Such cohesiveness limits the individ-ual’s ability to explore new solutions and opportuni-ties (161).

The technical emphasis also contributes to publicperceptions of arrogance and aloofness (130). For-esters and other resource professionals are notori-ously weak at interpersonal relationships: “manyprofessionals are reluctant to interact with ‘nonex-perts, ’ those who are not members of their profes-sional subculture’ (315). “Groupthink” amongprofessionals often results in unconscious or indirectcensorship of contrary or disquieting information(130); “listening [to the public] seems to occurwithout hearing’ the message (159).

Finally, the technical emphasis leads profession-als to believe that they know the correct way ofdoing things. This belief has been described in termsof the traditional professional-client relationship,with the client simply accepting the professional’sdecisions:

In the traditional professional-client relationship,the professional’s expertise is wrapped in mystique,and the client accepts the professional’s authorityand agrees not to challenge his judgment or demandexplanation (316).

The public is considered to be uninformed, and theprofessionals are “ ‘uniquely qualified’ to makenatural resource decisions’ (159). Foresters andengineers have been most likely to object to agencydecisions when they felt that politics or the publicwas interfering in sound management (33). Further-more, physical and biological scientists are morelikely to discount the public’s knowledge than are

social scientists (economists, sociologists, etc.) (237).Foresters typically accept scientific answers, andreject emotional ones:

The argument is that in our [foresters’] specialneed to achieve scientific validation of everything,we have invalidated most everything that we findscience cannot examine. In the process of second-rating all that is not “scientific’ we have devaluedromantic, emotional, and intuitive insights. We havetrained hard to distrust those voices in ourselves andothers, lest they prove to be unsound (106).

This is not to suggest that technical information isnot important in forest planning. Indeed, technicalanalysis is essential, but it is not enough.

Technical competence is a necessary but not asufficient condition for success in public forestresource management (316).

In its recent critique of land management planning,the Forest Service noted that it began the processexpecting to find the ‘‘right’ scientific answer forhow to manage the national forests (276); thecritique concluded, however, that many technicallycorrect answers exist for land management, and thatthe public should be involved in determiningg whichof the technically correct answers is most desirablesocially.

The problem is not so much public ignorance ofresource management as professional ignorance ofthe public (159).

William Ticknor (249) described the situation thisway:

Traditional forest science is the essence of aleft-brain endeavor. . . analytical, quantitative, logi-cal, linear. Most of us who are practitioners are sobecause that’s the way we were trained, and becausewe enjoy and excel at left-brain pursuits.

But the solution to our problem, I propose, is tomove toward a more intuitive, multidimensionalapproach which places a high priority on blendingthe not inconsiderable scenic, aesthetic and spiritualaspects of forestry with the biological and businessaspects.

Decline in Trust of Professionals-Several au-thors have noted that the decline in public trust offoresters is not unique. Society appears to have lesstrust for all professionals (1 12, 158), including thosein other government agencies, such as the NationalPark Service (316), and outside the government. Thelist includes lawyers, engineers (121, 315), and


doctors, as indicated by the rising cost of, and needfor, medical malpractice insurance.

Some have suggested that part of the problem isthe lack of public consensus about the propermanagement of the national forests (158). Oneobserver wrote:

We [foresters] do have a difference of opinionwithin our ranks (which mirrors society) about howlands should be managed . . . Our image will neverreturn to its previously untarnished sheen becauseour increasingly complex and strident society cannotform a single vision of what it seeks. Probably thebest we can hope for is an uneasy consensus (95).

Thus, it seems that the public is simply less willingto accept the knowledge and expertise of profession-als in deciding what to do about public issues.

Diversity and Interdisciplinary Efforts

Change in the Forest Service

Change is occurring within the Forest Service.Although it is still predominately a white, maleorganization (more than 50 percent of all employeesand nearly 75 percent of professionals are whitemales), the number of women and of minoritiesdoubled between 1976 and 1989 while total employ-ment climbed by only 20 percent (284). Further-more, as noted above, the dominance of foresters isdeclining as the agency adds biologists, landscapearchitects, archaeologists, anthropologists, and otherspecialists.

The change is not problem-free. The ForestService has been successfully sued in California(Region 5) for its slow development and promotionof female employees. The addition of numerousplanners and computer specialists for usingFORPLAN and preparing the forest plans has causedculture shock—both to the traditional employeesand to the new recruits (146). Organizations have astrong, innate tendency to exclude ‘‘outsiders’ theForest Service’s history of success, for example, hasled to ‘‘resistance to incorporating the nonutilitarian,amenity values of a post-industrial urban nation . . .and a manifest reluctance to share power with thepublic and with other professionals” (130).

We [foresters] are fond of saying our diversity isour greatest strength, but right now it really isn’t. Theway many of us are going about our business isbringing us to denial and intolerance instead. Ifdiversity is going to be our strength, then we need to

find a way to face our differences and respect them(105).

A study of attitudes based on educational andgender differences found that, a female forester ismuch more like a male forester than a male biologistis like a male forester. “[M]ost of the job frustrationand prejudice women and men experienced wererelated to their [wildlife and fish biology] professionconfronting traditional timber-range chauvinism’(132). Gender diversity is important for manyreasons, but educational diversity is more importantin terms of diversifying ideas and opinions.

Benefits of Diversity-Increased diversity withinthe Forest Service can yield several benefits in forestplanning and public involvement. A diverseworkforce brings a broader array of ideas, leading togreater creativity and flexibility for the organization.“Professional monoculture” resist change (132),and often unconsciously or indirectly censor infor-mation that contradicts insider views (130). Five outof six Forest Service interdisciplinary (ID) teammembers felt that “ID teams foster a holisticapproach to problem-solving” (94). Furthermore,“creativity in environmental problem solving is agroup activity that involves inputs from manydifferent fields” (94).

Workforce diversity also can improve publicinvolvement. Various segments of the public preferdifferent kinds of involvement in activities anddecisions (159, 231). A diversity of professions,ages, and genders provides more avenues for variousgroups to be heard.

Diverse disciplinary backgrounds and genera-tional differences create centrifugal forces thatprovide access to sympathetic decisionmakers by abroad range of groups (237).

Finally, diversity also provides a broader spec-trum of values among agency employees (133). Onereason for using interdisciplinary teams is ‘‘toovercome the narrowness of a single professionalfocus” (94). Foresters tend to focus on utilitarianvalues, and downplay the spiritual, symbolic valuesof the forest (128, 209). Biologists, in contrast, placegreater value on biological processes (33), and theseecological values are more akin to the intrinsicvalues our substantially urban society holds forforests (194, 209). By combining the variety ofvalues of a diverse workforce in its planning andmanagement, the Forest Service could generatebroader support for its activities and plans.

I@ ● Forest Service planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Costs Costs of Diversity--Increasing workforce diver-sity also imposes costs on the Forest Service. Onemajor cost is increasing internal conflict. To theextent that the conflicts are professional differencesabout technical matters, such conflicts can bebeneficial, fostering creativity and flexibility. How-ever, many of the differences occur because nontra-ditional employees are challenging the traditionalassumptions and operating styles, and thus become“change agents” within the agency (130). Chal-lenges to “standard operating procedures” are oftenviewed as disloyalty to the agency, and can damagecareer prospects (104, 132). Sometimes the differ-ences among staff devolve into personal conflicts(94), and can be very disruptive.

It is also difficult to build a team from a collectionof diverse individuals. Time is required to overcomedistrust of other professions and to abandon theresource advocacy roles many employees mustemploy during budget negotiations (94). ID teamsstill often operate as a collection of advocates ratherthan as a team:

Consensus is not the norm on most interdiscipli-nary teams; rather the relationship among most teammembers is adversarial and, in some cases, antago-nistic (13).

Frequent changes in interdisciplinary team member-ship complicates the task of fostering teamwork, asemployees are hired, transfer to other positions orlocations, or leave the agency. In addition, some IDteam members have only part-time team duty andmany nonteam duties (94). Thus, building an effec-tive interdisciplinary team is a difficult and chal-lenging task.

Strategic planning can overcome some of theproblems of workforce diversity. If a strategic planestablishes a sense of mission that is consistent withthe values of the employees, and of the public, all ofthe diverse elements of the agency can be broughttogether to implement the plan. As noted above, astrong sense of mission can rekindle the esprit decorps that has traditionally been one of the ForestService’s strengths. However, this entails moretolerance of diverse opinions and of challenges totraditional practices. Moreover, achieving a unity ofmission and sense of teamwork is a time-consumingprocess.

Use of Interdisciplinary Teams

The use of interdisciplinary teams in nationalforest planning is mandated by NFMA and NEPA.However, the functional organizational structure hasinhibited integrated forest planning. As noted in ch.7, FORPLAN has in some ways forced the variousspecialists to learn to talk a common language (123,278), but it also has contributed to advocacy by thevarious specialists (13). Furthermore, when debatesbecome “use versus nonuse” (rather than how toachieve all relevant values), they can polarize bothinternal and external groups (160). FORPLANcreates other barriers for many employees who arenot on the planning team, and thus can separateplanners from managers and other employees (23).Nonetheless, to the extent that teamwork can becreated, ID teams can lead to more effective,coordinated planning (94).

Most ID teams used in national forest planninginclude specialists in wildlife, timber, recreation,engineering, hydrology, soils, economics, range,and a plethora of other disciplines. (See table 9-l.)Many of these specialists have college degrees intheir area of specialty (94). However, some special-ties are represented by employees trained in otherareas. For example, foresters dominate the recrea-tion, hydrology, and economic specialties (94). Thisdoes not necessarily mean that these people areunqualified to perform the necessary tasks, sincemany foresters have additional training in otherdisciplines. Nonetheless, to the extent that forestersare used in an assortment of specialty roles: 1) thebenefits of educational diversity will not be achieved,and 2) foresters may lose the special characteristicsthat make them a distinct profession. Some forestryeducators have noted this as a possible problem:

. . . as foresters fill evermore varied assignments, theterm forester has lost much of its former meaning,and an identify crisis exists for the profession (71).

The Forest Service is not required to use ID teamsexcept in planning, and ID team outside planning usehas been rather limited. Several forests, such as theAllegheny in Pennsylvania and the Lolo in Montana,have apparently reorganized away from the tradi-tional resource functional approach. However, theForest Service is still generally organized by re-source function, especially at the regional andnational offices (276). Furthermore, despite theimportance of teams and teamwork, Forest Service

Chapter 9-Organizational Factors in Forest Planning ● 169

Table 9-l—Forest Service Interdisciplinary Team Members

Interdisciplinary Degree in DegreeSpecialty team use Degree in specialty forestry in other

(percent) (percent) (percent) (percent)

Wildlife . . . . . . . . . . . . . . . . . . . . . . . . . . . 91%Timber . . . . . . . . . . . . . . . . . . . . . . . . . . . 89Recreation . . . . . . . . . . . . . . . . . . . . . . . . 76Team leader . . . . . . . . . . . . . . . . . . . . . . 75Engineering . . . . . . . . . . . . . . . . . . . . . . . 74Visual quality . . . . . . . . . . . . . . . . . . . . . 73Hydrology . . . . . . . . . . . . . . . . . . . . . . . . . 69Planning . . . . . . . . . . . . . . . . . . . . . . . . . . 64Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64Program analysis . . . . . . . . . . . . . . . . . . 59Economics . . . . . . . . . . . . . . . . . . . . . . . . 58Range . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52Public involvement . . . . . . . . . . . . . . . . . 47Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . 41Archeology . . . . . . . . . . . . . . . . . . . . . . . . 38Fisheries . . . . . . . . . . . . . . . . . . . . . . . . . 30Writing . . . . . . . . . . . . . . . . . . . . . . . . . . . 27Sociology . . . . . . . . . . . . . . . . . . . . . . . . . 23Geology . . . . . . . . . . . . . . . . . . . . . . . . . 13

80%9540a

2909746

078

42447

051

08 9b

80214182

(biology)(forestry)(recreation)(planning)(engineering)(landscape architecture)(hydrology)

(soil science)(computer science)(economics)(range conservation)

(social science)

(archeology)(biology)(English)(sociology)(geology)

4Y0955264

20

4671100564031824188

00

2900

6%58

34838

2912 &

403622188

121120505918-. .- -.,

alncludes landscape architecture (37 percent ofthetotal).blncl~esa nthropolo~ (68 percent of teetotal).

SOURCE: M.W. Garcia, “ForestS erviceExperience With Interdisciplinary Teams Developing Integrated Resource Management Plans;’ EnvironmentalManagement13 (5):583-592, 1989.

success is still symbolized by the “heroic districtranger”:

Although agency guidelines .. . are stressing theimportance of teams working together in coopera-tion with other organizations and the public, thetraditional image of the strong, heroic individual stillhas considerable symbolic potency in the ForestService (131).

The resource functional approach to nationalforest management is particularly a problem forbudgeting. As discussed in chapter 8, the forestsdevelop budget requests based on their interdiscipli-nary forest management plans, but these integratedrequests are translated into resource functions, tomeet the current requirements of the administrationand the House and Senate Committees on Appropria-tions (217). Actual appropriations are then allocatedto the forests, with substantial discretion vested inthe regional resource staffs (217). Resource special-ists at the national forest level must compete forfunds with comparable specialists from other forestsand with other specialists on their own forest. Thus,the current budget process inhibits an interdiscipli-nary or integrated approach to project planning andimplementation.

Organizational and Employee Values

Successful organizations in American businesshave distinctive corporate cultures that contribute totheir success (195). Those corporate cultures typi-cally provide both the stability needed by organiza-tions and their employees and the ability to evolveas the needs of customers (and society) change.Stability is provided by the formal structure-thelaws, rules, and regulations governing the organi-zation—and by informal rules and internal goals(50). Providing for evolution is much more difficult,but is a key to success in business (195).

Many observers have considered the Forest Serv-ice to be among the best of Federal agencies (109,128, 250). The agency certainly has a distinct culturethat has provided stable direction for the nationalforests for many decades. Evolution in response tosocial changes is more problematic. Some haveargued that the Forest Service has not responded tochanges in social values (161, 310, 320). However,others suggest that the Forest Service has been moreeffective than other agencies at evolving to meet therequirements and intent of NEPA ( 1 ), and has at leastrecognized the broad mandate for national forestmanagement:


To their credit, the principal public land agencies,the Forest Service and the Bureau of Land Manage-ment, have been seeking larger roles for wildlife onthe millions of acres in their charge (197).

Recent research has examined employee percep-tions of agency and personal values, and foundsubstantial differences. The following sections de-scribe apparent organizational values and employeevalues, and explore the reasons for the differencesthat have been found.

Organizational Values

Many Forest Service critics have alleged that theagency is biased toward timber production (66, 104,187). A survey of employees found that employeesalso believe that the agency values timber morehighly than other resources; other resources arevalued equally among themselves (133, 250). Thebelief in timber’s primacy is also reflected in therecent letters from forest supervisors to the Chief ofthe Forest Service asserting that current programsare not consistent with proper land stewardship (90,91). This belief permeated the agency, from newemployees to forest supervisors, and even to topmanagement (regional foresters and the Chiefsoffice) (133).

Others who have examined the Forest Serviceconclude that agency actions reflect an inherent biasnot toward timber, but toward maximizing its budget(124, 187). O’Toole (187) in particular has sug-gested that the agency only appears to emphasizetimber production because of the numerous specialbudget accounts associated with timber harvesting.(See ch. 8 for a discussion of these accounts.)Another study suggests that the reliance on standardprocedures and the civil service protections frompolitical interference account for the agency’s ef-forts to maximize its budget (213). Despite theirlogic and some evidence to support these arguments,other evidence suggests that the Forest Service hasnot taken full advantage of the opportunities toexploit its special budget accounts (298). Thus, thebudget maximization hypothesis is insufficient toaccount for Forest Service values and actions.

Studies have shown that Forest Service employ-ees believe the agency primarily values productivityand team spirit (132, 133). Productivity includesmeeting targets, working hard, and being competent,while team spirit includes loyalty, teamwork, pro-

moting the Forest Service image, and getting alongwith your peers (133). Team spirit is clearlyimportant to the Forest Service and its traditionalesprit de corps. Displaying behaviors consistentwith agency values is considered pivotal for successin the agency (131). This belief, along with theperception that the agency values timber over otherresources, is widespread among the employees, withlittle difference by gender, professional background,or level of experience and responsibility (132, 133).

Such views are not inappropriate, but can haveunintended consequences. One potential problem isthat, although the agency’s “New Perspectives” isan attempt to encourage internal change, challengesto traditional practices and procedures are oftenperceived as disloyalty (130). This is more likely tobe a problem for nontraditional employees, such asbiologists and landscape architects, and could hinderthe agency’s ability to adapt to changing socialvalues. Another potential problem is the message tonew employees-’ ‘don ‘t make waves’ and ‘‘goalong to get along” (104). While such messages areimportant to team spirit, they can inhibit employeesfrom speaking out and thus inhibit challenges totraditional practices and procedures.

Employee Values

In many respects, employee personal values differfrom the organizational values of the agency. Forestsupervisors have noted that their values and those oftheir employees have been changing (90). In contrastto the agency’s apparent emphasis on timber re-sources, employees report that they value recreationhigher than other uses, followed by wildlife and thenwater (133). Again, this is true for employees at alllevels in the agency, even top management (regionalforesters and the Chief’s office). These values,moreover, matched employee perceptions of thepublic’s values. Thus, employees believe that theagency values timber relatively more than eitherthey or the public does.

Employees also believe that the agency shouldreward additional behaviors. Professional compe-tence, hard work, and teamwork are and should berewarded, but employees believe that concern forhealthy ecosystems, for the long-run future, and forthe welfare of one’s peers should also be rewarded(133). Again, employees at all levels shared similarbeliefs about what the Forest Service should reward.

. .—..——


Why Are There Differences?

One might hypothesize that differences betweenorganizational and employee values exist becausenew employees differ from experienced employees.Differences do exist-new employees are older atthe beginning of their Forest Service careers, theyare more likely to hold advanced degrees, and moreare biologists and fewer are foresters (133). How-ever, as noted above, these differences did not leadto differences in opinions about agency and personalvalues. The letters from the forest supervisors to theChief also suggest that the managers’ views arerelatively consistent with those of their employees(90, 91). In fact, some of the long-time employeeshave been among the leaders in supporting ForestService changes:

. . . many of these senior people have becomeadjusted to the challenges and promise of thepost-NEPA era, and have supported and authoredinnovative approaches . . . (130)

Thus, it seems that increasing diversity is not thesource of the differences between agency values andemployee values.

Some differences probably occur because of thetradition and inertia common to large organizations.The Forest Service certainly has along and respectedtradition (13 1), and it is difficult to change comfort-able and successful modes of operation (161). TheForest Service has also institutionalized its tradi-tional practices through common training, promo-tion from within, and regular transfers (250). Someargue that historic patterns persist because of proce-dural standards and civil service protections forgovernment employees (213). Finally, the idea thatchange is necessary also implies that traditionalpractices represent the wrong way to do things (1 1).Despite the clear changes in social values, it isdifficult to distinguish the appropriateness of pastprocedures for their era from the current relevance(or irrelevance) of such procedures.

The various external pressures on the ForestService also limit the ability of the agency to alteragency values. External constituencies-’ ’the wel-ter of interdependent organizations surrounding theorganization in question’ (316)----impose somerigidity tending to hold the Forest Service to thestatus quo (50); and it is impossible to exist in a‘‘social environment of combative constituencies’without reflecting those constituencies (250).

Finally, the differences between agency valuesand employee values can result from the rewardsystem. Perceptions of agency values may simplyreflect the reward system rather than the organiza-tion’s actual values. Many have suggested thatachieving timber targets is more strongly rewardedthan achieving other targets (66, 104). New employ-ees, forest supervisors, regional foresters, and theChief’s office all “give the agency reward system alow legitimacy rating” (133)--i.e., what the em-ployees believe the agency rewards does not matchwhat they believe it should reward.

Employees gave overwhelming endorsement thatthe vision statement values should be rewarded bythe USFS [U.S. Forest Service] . . . and there waslittle disagreement between ranks, gender or profes-sional identity. However, most survey respondentsbelieved the agency reward system did not ade-quately endorse and support these values (133).

PERFORMANCE AND REWARDSPerformance of the appropriate tasks may be the

most important aspect of any endeavor. In business,performance (typically measured by profitability)defines success, and achieving long-term successrequires that appropriate performance be rewarded(195). Assessing performance is more difficult for agovernment agency than for a business, becausegovernment agencies rarely have simple, financialmeasures of success. Nonetheless, individuals andorganizations respond to incentives (187), and thusa system that rewards appropriate performance isnecessary.

As discussed above, Forest Service employeesbelieve that the current system does not consistentlyreward behaviors that promote the Forest Servicemotto of Caring for the Land and Serving People.Forest supervisors have written to the Chief that wejust can’t continue to do more [more targets, moreinitiatives, more customer service projects, moreconflict resolution] with less [money and people]”(91). According to employee opinions, the agencyrewards production and team spirit (133). Thus, thissection explores the agency’s reward system, andassesses the relationship between that system andthe planning system.

Production

Production is an important part of any organiza-tion’s performance. Employees have reported thatthe agency rewards professional competence and


hard work, and, to an even greater extent targetachievement (133). This seems appropriate, sincesuccessful efforts (meeting the goals) should berewarded more highly than unsuccessful efforts.However, observers have suggested that timbertargets are more important than other targets to theForest Service (104); at least timber target achieve-ment is assessed more diligently than other perform-ance (217).

Obviously, employees are likely to expend moreeffort to achieve objectives that are measured thanthose that are not. Nonetheless, the lack of appropri-ate measures of performance is a surprisinglycommon failing of unsuccessful businesses (195).The entire purpose of the management-by-objectives system widely touted in the 1960s was toidentify measurable targets that employees and theirsupervisors could agree on (220). One problem forthe Forest Service is the lack of appropriate perform-ance measures for some of the objectives for nationalforest management (100).

What Gets Measured, Gets Done

Meeting targets is clearly important to the ForestService, but what targets get measured? The answeris not as simple as it may seem. The 1990 OTAreport on RPA planning (259) assessed the annualReport of the Forest Service, and found it to be aninadequate report on Forest Service performance.Management activities for the national forests aredisplayed, but activities are generally not related totargets for national forest outputs or conditions. Theonly output information contained in the ForestService’s annual report which shows the results ofmanagement efforts is timber sales and harvests.

Several observers have noted the existence of‘‘hard targets’ for national forest management (104,217).

The hard targets tend to be the tangible, directlymeasurable outputs of commodity resource pro-grams: board feet of timber, number of cows or sheepgrazed, mineral leasing permits issues (217).

Forest Service managers, not surprisingly, focustheir efforts on meeting such ‘‘hard targets.”

Whether or not a forest supervisor has met his orher assigned target for timber sale volume is quicklyand unequivocally determined by direct, physicalmeasurement; whether recreation or wildlife targetshave been met is a matter of broad professionaljudgment . . .

Forest Service field officials indicated that theprimary focus of performance evaluations continuesto be the attainment of the “hard targets” for timberand, to some extent, range and minerals. On most ofthe national forests, the district rangers in particularindicated that their overwhelming management con-cern relating to their own performance evaluationswas to ‘‘get out the cut, ’ that is, meet the annualtimber sale volume targets assigned them (217).

The important timber targets are not those estab-lished in forest planning, but the targets set in budgetprocess. Congress typically sets targets only fortimber in the annual appropriations laws (217).Furthermore, congressional timber targets have con-sistently exceeded the timber sale levels requestedby the Forest Service for the past decade (217)although the timber funding and outputs in theagency’s budget request have been below thoseidentified in the forest plans with unconstrainedbudgets. Thus, meeting the annual timber targets isclearly important to meeting congressional directionfor national forest management.

What Isn’t Measured, Is Important

In contrast to the hard targets for timber and othercommodity outputs, the measures for noncom-modity resources are called ‘soft targets. ’ As notedin chapter 6, consistent and comprehensive meas-ures of nontimber outputs do not exist. Measures ofrecreation use, for example, have been described as“horseback estimates” (217). Wilderness manage-ment is reported in acres managed, which is afunction of congressional wilderness designations,not of managerial performance (215). The ‘output’of watershed management depends more on the sizeof the watershed treated than on the efforts or theresults (217).

Equally important is the lack of measures ofresource and ecosystem conditions. Range, water-shed, and wildlife habitat improvements are meas-ured in acres, but results of these efforts are notreported in terms of changes in conditions (100).Even for timber, the Forest Service does not reporton changes in resource quality (215).

The Forest Service also does not assess produc-tion costs. (See also ch. 8.) Cost data reportednationally are incomplete and inconsistent withappropriations data (259). Unit costs are no longerimportant to managers in annual budgeting, andinaccuracies result in few sanctions (217). Further-

——.. .


more, costs are not related to outputs, even for thehard targets, in any meaningful way (217, 254).

It is difficult, if not impossible, to hold ForestService managers accountable for all the relevantmanagement tasks when appropriate measures forcosts, outputs, and conditions are lacking. It isadmittedly difficult to develop measures for all thetasks. However, without such measures, ForestService managers will continue to be evaluated onachieving the hard targets for national forests. Inparticular, managers cannot be rewarded for achiev-ing and maintaining healthy ecosystems (as employ-ees at all levels believe they should) unless the healthof ecosystems is measured, at least indirectly.

Team Spirit

Loyalty, teamwork, and other measures of teamspirit are even more difficult to assess. The ForestService has stressed the importance of teamwork,but has done little to reward or encourage it (131).Little research has been conducted on how to buildand maintain esprit de corps, probably because of thedifficulties in measuring and assessing it. Clearly,team spirit is important, and has been a traditionalstrength of the agency. Equally clearly, team spirit,as measured by employee pride in the ForestService, has declined at all levels of the organizationover the past 20 years (133).

Team spirit will be more difficult to build andmaintain with the increasing professional, racial,and gender diversity within the agency. Challengingtraditional practices is often construed as disloyalty(130), but challenge is likely to be more common ina more diverse agency. Challenge--if done withinproper and necessary limits-is an appropriate wayof assuring that the agency is responsive to itsmission and to the public. An open, strategicplanning process, wherein employees and the publicagree on management direction for the nationalforests, can lead to a spirit of cooperation andconsistency.

Rewarding Plans and Planning

Forest plans are not just pretty documents to set ona shelf and gather dust. The plans must be imple-mented—to guide management of the nationalforests. Forest supervisors must ultimately be re-sponsible for the forest plans and their implementa-tion, and must make the time to ensure the plan isright. “The manager should be willing to devote

considerable personal time to the process” (60) tomotivate the planning team and assure that theresults are feasible.

Plan Feasibility

Clearly, plans must be technically feasible. Thechosen alternative must be internally consistent—allthe outputs must be achievable and the ecosystemsprotected. Foresters and other professionals are quitegood at examining technical feasibility; as describedabove, the scientific conservation paradigm com-mon to many physical and biological disciplinesemphasizes the technical aspects of management.

The plans must also be politically feasible, at thelocal and national levels; technical competence is anecessary but not sufficient condition for successfulnational forest management (316). It has long beenrecognized that public involvement is needed tounderstand the social values of the forest (29). Theforest supervisors have reiterated the call for effec-tive public involvement, arguing for increasing workwith “local, state and national key publics andelected leaders’ (90). (See ch. 5.)

A major difficulty for forest planning is the lackof public consensus on how and for what the nationalforests should be managed ( 158). Foresters and otherprofessionals are typically not very good at face-to-face, emotional confrontations about management(129). Many of the planning ‘failures result becauseresource professionals are working to change thepublic’s mind about management practices ratherthan developing alternatives to satisfy public goals’(159). However, foresters have traditionally beencommitted to serving the public interest (71). Thiscommitment to service must be strengthened andmolded to building a public consensus, becauseconsensus is crucial to building politically feasibleforest plans (158, 231).

Some have described the goal of the forestplanning process to be a “social contract” betweenthe agency and the public (130, 230). This view isuseful, but may not recognize the need for plans tobe politically feasible at the national level—i.e.,consistent with the RPA Program, the annualbudget, and other national policy direction fromCongress and the administration. (See also ch. 10.)Research indicates that national RPA direction hashad relatively little direct effect on the forest plans(213). However, national direction on budgets andon targets can subvert the direction established in the


plans, as described above. Forest plans must beconsistent with likely national decisions aboutbudgets and targets and other policy guidance, ifthey are to be implemented. This probably willrequire modifying the planning and budgeting proc-esses to impose some consistency in budget consid-eration, and to display how budget changes willaffect forest plan implementation. (See also ch. 8.)

Manager Responsibility

Another requirement for implementing the forestplans is that the managers-forest supervisors,district rangers, etc. —be accountable for performingaccording to the plan. Plans are unlikely to beimplemented if managers are not held responsible inperformance reviews for both the technical andpolitical feasibility of the plans.

Technical feasibility can be assessed annually bycomparing actual outputs, changes in conditions,and unit costs with those projected in the forest plan.Some variability is certainly to be expected, andunanticipated events, such as Hurricane Hugo, candevastate a forest. Nonetheless, if the plan was donecorrectly, it should give a reasonably accurateprojection of activities, costs, and results. Managersand their planning teams should be evaluated, inpart, on the output condition and cost targets in theirplans.

The public also needs to examine the activities,costs, and results of management annually. Theannual Report of the Forest Service was intended toprovide such information at the national level,although it has not fulfilled this task (259). Acomparable annual report on the consequences ofimplementing the forest plan could provide thepublic with the relevant information, and manyforests are now preparing annual reports (137).However, as discussed above and at greater lengthunder monitoring in chapter 6, the existing measuresof outputs and activities are inadequate to assess theresults of management activities on total outputs,ecosystem conditions, and unit costs. The lack ofcomplete and relevant measures of national forestproduction make it difficult to evaluate how manag-ers perform in implementing the forest plan.

Political feasibility, at least at the local level, isalso important to implementing forest plans. Onesimple and obvious measure is the number ofadministrative appeals and lawsuits filed against aplan. Agency critics have suggested that the appar-

ent increase in litigation, despite increasing publicparticipation efforts, suggests that the agency is notreally responding to the public (159). However, oneshould also recognize that the plans and the subse-quent activities cannot be “bomb-proof,” becauseforest plans are not comprehensive, site-specificaction plans (13). Forest management is oftencontentious, and thus some appeals and litigationshould be expected. Furthermore, conflict, and evenlitigation, are not necessarily bad, because they canlead to improved understanding and agreement.Nonetheless, managing conflict and reducing ap-peals and litigation is a relevant goal for ForestService managers, and the agency does rewardmanagers who deal with contentious issues at thelocal level (217).

The number of appeals and lawsuits is onemeasure of local conflict over management deci-sions: fewer appeals and lawsuits suggest betterconflict management. However, it is possible toreduce appeals and lawsuits without resolving con-flicts, by postponing controversial decisions to alater date or to another forum. Managers could,through such techniques, shift the controversies totheir successors or to other decisionmaking forums.Thus, the number of appeals and lawsuits is anincomplete measure of the political feasibility of aforest plan. Additional measures of the effectivenessof public involvement and manager responsivenessneed to be developed to assure that managers areproperly rewarded for preparing politically feasibleforest plans.

Difficulties in Accountability

As noted above, the lack of complete and accuratemeasures to assess the technical and politicalfeasibility of forest plans is a problem. Another,related problem is objectivity-it is difficult formanagers and planners to be impartial in monitoringand evaluating the plans they have spent so muchtime and effort preparing (50). Effective, unbiasedassessment of performance requires monitoring byquasi-independent groups within the national for-ests, such as interdisciplinary teams that includenonemployees (e.g., retirees and experts from vari-ous interests). However, purely external monitoringand evaluation can reduce planners’ and managers’commitment to developing effective, implementableplans.

A more intractable problem relates to the fre-quency of transfers for agency employees. Habitual


transfers, including laterals, are important for em-ployees to advance in the organization, but oftendrain local expertise from a forest (64) and can be aproblem for dual-career families (132). Furthermore,frequent transfers and the inability to quicklydemonstrate improved resource quality mean thatmanagers face relatively little risk of being heldresponsible for failures to meet resource quality andecosystem health targets (215).

In the extreme case, transfers can make onemanager and planning team responsible for imple-menting a plan prepared by another manager andteam. Two steps can minimize this potential prob-lem. First, the plan should identify all the relevantinformation needed for implementation: the partici-pants, their issues and concerns, the current outputsand conditions and their trends, and the goals anddirection for managing the forest. Second, improvedcommunication and a sense of shared responsibilityis needed between employees and their predeces-sors. This would include informal talks as well asformal communication, and possibly even jointperformance review.

SUMMARY AND CONCLUSIONSOrganizational factors, such as traditions and

incentives, affect the ability of an organization todevelop and implement strategic plans. Within theForest Service, the traditional dominance of forest-ers is changing as the agency’s workforce diversifiesand as foresters adapt to changes in Americansociety, but Forest Service tradition still exerts astrong influence over national forest management.The reward system for national forest managementalso determines the effectiveness of strategic forestplanning under NFMA.

Forest Service Culture and Diversity

The Forest Service has long been dominated byforesters, and foresters still account for at least halfof the agency’s professionals and at least three-quarters of its technicians. Foresters, by training andexperience, typically emphasize the uses and outputsof forests, and particularly, the management of trees.However, the increasingly urban American societyholds a less utilitarian, less anthropocentric, moreromantic view of nature. Thus, society increasinglyvalues the nonuse benefits of forests, which are oftendiscounted by foresters.

The Forest Service also employs a variety of otherprofessionals. Traditional engineers and range con-servationists hold values relatively similar to forest-ers, and thus have contributed to the agency’sconsistent internal philosophy. However, other pro-fessionals, such as biologists, landscape architects,and archaeologists, are diversifying the educationalbackground of the agency’s workforce, Biologistshave become the second largest professional groupwithin the Forest Service (after foresters), and theireducation typically emphasizes the biological andecological processes of forests, rather than theutilitarian view of foresters. Thus, as more biologistsand other specialists are employed, the values andorientation of the agency is broadened.

As a Federal agency, the Forest Service has longbeen highly regarded for its professional approach toits mission. The professionalism of Forest Serviceemployees has contributed to the agency’s historicalsuccess and to the strong esprit de corps within theworkforce. However, professionalism also has itscosts. The professional training of foresters andbiologists emphasizes technical competence. Whiletechnical competence is important to, and indeednecessary for, management of the national forests, itinhibits listening to the public. The public isgenerally perceived as uninformed and overly emo-tional, while the professionals consider themselvesspecially qualified to make rational resource man-agement decisions. However, this view often leadsprofessionals to ignore or discount the public’s goalsfor the national forests and public objections to somecommon management practices.

The Forest Service workforce is becoming morediverse, in racial and gender as well as educationalcomposition. Research suggests that educationaldiversity is more important than racial or genderdiversity in terms of broadening the values and ideasof the workforce. Such diversity is important be-cause it leads to greater creativity and flexibility inmanagement, tends to open more channels ofcommunication to various interests, and broadensthe basis for management decisions. However,diversity also creates internal conflict, because newideas often challenge traditional practices and canseem to be disloyalty to the agency. It takes moretime and effort to build teamwork and trust amonggroups with disparate backgrounds and values thanamong groups with shared outlooks and experi-ences. A shared sense of mission can overcomesome of the difficulties, but many employees are


concerned that the current motto--"Caring for theLand and Serving People’’—is not really beingimplemented and rewarded.

Diversity is important to developing and usinginterdisciplinary teams as required by NEPA andNFMA. The Forest Service uses ID teams in forestplanning, although in many cases the diversity ofspecialists is less than that specified in the laws.More importantly, however, the interdisciplinaryapproach is not used widely other than in forestplanning; the Forest Service is still generally organ-ized functionally, by resource specialty. This isparticularly a problem in budgeting, as integratedmanagement activities are translated into resourcefunctions; the subsequent appropriations may bearlittle relationship to integrated management.

Finally, the apparent values of the organizationand the employees differ significantly. Regardless ofexperience, level within the agency, or educationalbackground, employees believe that the agencyemphasizes timber above other resources, and pri-marily rewards outputs and team spirit. However,employees’ personal values apparently emphasizerecreation, wildlife, and water, and match theirperception of the public’s values. Employees believethat the agency should also reward healthy ecosys-tems, long-run concerns, and the welfare of theirpeers. However, the agency’s traditions, normalorganizational inertia, pressures from various exter-nal groups, and the existing reward system allimpede change.

Performance and Rewards

As noted above, employees believe that the ForestService rewards production and team spirit. Produc-tion and productivity are appropriate standards forevaluating employees, but the existing measures areincomplete for assessing performance. ‘‘What getsmeasured, gets done. Timber and other commodityoutputs are more easily and accurately measured,and thus commodity output goals are commonlyknown as “hard targets.” Other national forestgoals--noncommodity outputs, nonuse values, andefficiency (unit costs)--are either poorly measuredfor annual production (i.e., they are “soft targets”)or are not measured at all. Thus, employee perform-ance evaluations emphasize achieving the hardtargets.

Spirit is far more difficult to measure, and thus toassess, than is production. One problem for estab-lishing and maintaining esprit de corps in a diverseworkforce is that challenges to tradition are oftenperceived as disloyalty to the agency. Strategicforest planning can overcome such perceptions, ifthe established direction and the subsequent man-agement are widely accepted by the employees (andthe public).

Successful implementation of forest plans mustalso be rewarded. To be implemented, the plans mustbe technically feasible, something the various pro-fessionals employed by the Forest Service aretrained to assess. However, the plans must also bepolitically feasible. This means building a localpublic consensus on the appropriate managementdirection and practices for the forest plan, anadmittedly difficult but essential task. The resulting“social contract” must also be politically feasiblefrom a national perspective, fitting with the nation-wide goals for resource management and for Federalbudget priorities and limitations.

Accountability is the key to forest plan implemen-tation. The limited number of performance measuresmake it difficult to hold managers responsible forachieving all the management goals for their forests,and for the political feasibility of their plans. Thenumber of administrative appeals and lawsuits is onemeasure of political feasibility, but the number canbe reduced by simply postponing controversialdecisions to another forum or to a successor. Thus,additional measures of effective public involvementare needed to assess managerial performance in thisarea. Another difficulty is that managers and theirstaffs are likely to be predisposed to favorableevaluations of their performance, thus limiting theirimpartiality in monitoring forest plan implementa-tion. Finally, the habitual transfers of managers canreduce their accountability; one manager and/orplanning team may develop a plan which must thenbe implemented by a successor. These problems canbe minimized with distinct monitoring teams and athorough description of planning participants, issuesand concerns, and past and current conditions. Thedirection and goals in the forest plan also must beclearly specified.

Chapter 10

Relationship of Forest-Level NFMAPlanning to National RPA Planning

. .

Contents

Introduction ... ... ..*. .*. ... ... ..*. ... ... ..*. ***. ..*. ..** *.*. ..** .**. *Q...*..*.*.*"**The Current RPA-NFMA Linkage *.. . . . . . . . . .**.. . . . . . . . . .**.. . . .**..*. .*.*. . . . . .****.Direction and Flow of Information e.. ..*. .e*. .**. oo. ... .o**. *.** ... **. Q..**...****@..*..

NFMA Planning and the RPA Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .NFMA Planning and the RPA Program ... ... ... ... *.. ... ... **. ... ..** . .$*.@*******..NFMA Planning and the Budget Process ● **. c*. ... * * 0 . . . * * * . . . . * . . * * * * @ * * * * . . ****...**

NFMA Planning and the Annual Report ● . . . . * * . . . . . . . . * . . . . . . . . . . . * * . . * . * . . * ***.*...*NFMA Planning, RPA, and the Role of the Regions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Conclusion ... ... e.. .**. *.*. ... .*. **. . .*...**.......**.****.***..*""".*""""""""""*""'""

179179180181181182183183184

Chapter 10

Relationship of Forest-Level NFMA Planningto National RPA Planning

INTRODUCTIONThe Forest and Rangeland Renewable Resource

Plannning Act of 1974 (RPA) establishes a strategicplanning process for an integrated, national exami-nation of renewable resource conditions and oppor-tunities for all forests and rangelands. The strategicplanning process envisioned in RPA is structuredaround the preparation of four documents: the RPAAssessment, the RPA Program, the PresidentialStatement of Policy, and the Annual Report. TheRPA Assessment is to provide information onrenewable resources--conditions and outputs, inter-relationships, and present and future supplies anddemands. This information serves as the basis for theRPA Program and the development of directions andgoals. The Presidential Statement of Policy, trans-mitted with the Program to Congress, guides formu-lation of annual budget requests. The Annual Reportinforms Congress of the Forest Service’s progress inimplementing the RPA Program. Together, thesefour documents enable the Forest Service to developalong-term strategic plan to guide present and futuremanagement decisions.

RPA also establishes a strategic planning process,at the local level, that stresses an interdisciplinaryapproach and public involvement. The NationalForest Management Act of 1976 (NFMA) amendedthe original RPA legislation by providing substan-tial additional direction in preparing land andresource management plans for the national forests.These forest plans are intended to set long-termdirection for on-the-ground management activities,including desired future resource conditions andsubsequent management actions to achieve thoseconditions. In contrast to the national scope of thefour RPA documents, the forest plans guide manage-ment activities at the local level. The plans take intoaccount local situations, capabilities, and opportuni-ties, and attempt to balance local resource uses andvalues to accommodate the public’s interests.

If the strategic planning process envisioned inboth RPA and NFMA is to be effective, nationaldirection and goals must mesh with local capabili-ties. The RPA documents must incorporate informa-

tion from the local level on resource availability andconditions as well as on public opinion, desires, andconcerns. The information on local interests andcapabilities must be available for use in the nationalanalysis. Only with this meshing of national andlocal planning can the forest resources be managedsustainably for the future.

THE CURRENTRPA-NFMA LINKAGE

Congress did not envision a clear, direct systemfor meshing national and local planning efforts(329). The RPA and NFMA planning processes havebeen evolving slowly, however, to become moreintertwined. Historically, the Forest Service hasapproached planning as a hierarchical process thatallocates resource output targets from the RPAProgram to the regions, and from the regions to theforests (206). This approach contrasts with thedescription of the linkage between RPA and NFMAin the Forest Service regulations as:

. . . essentially iterative in that the information fromthe forest level flows up to the national level wherein turn information in the RPA Program flows backto the forest level (36 CFR 219.4(a)).

In 1989, Forest Service Chief Dale Robertson(206) testified that the 1990 RPA process wasinfluenced by an integrated approach, with “morecareful consideration of the resource opportunitiesas developed in the forest plans. ” This integrationwas accomplished by using data from the plans inthe RPA Assessment and by building RPA Programstrategies using forest plan standards and guidelines.Robertson stated that, because most of the forestplans are now complete and more comprehensivethan earlier plans, data from the forest plans wereused extensively in the 1990 Program. Thus, the1990 program may mark the beginning of aniterative exchange of information, from the forests tothe national level and the national level to theforests, contemplated in the regulations.

The historic pattern of top-down targets from theRPA Program to the national forests was possiblebefore the completion of the national forest plans

–l79-

7q7.WIA II - q7 _ 7


only because of lack of information. Many foreststook 10 to 15 years to complete their frost plans underNFMA, providing little information from the locallevel to feed into the national process. The lack offinal forest plans permitted the top-down flow ofinformation to dominate, and led to allocation ofresource output targets from the national level to theregions and forests.

RPA target allocations are difficult to mesh withNFMA planning because: 1) targets are set only foroutputs and 2) allocated targets may be infeasible.Output targets are not necessarily incompatible withlocal level strategic planning, but forest managers donot have the measures to determine annual outputsfor all resources. (See ch. 6.) Annual timber produc-tion can easily be measured, and is directly under thecontrol of the managers, but recreation use, waterflows, wildlife populations, and other uses andoutputs are less easily measured, and less readilygoverned by managers. Furthermore, the RPA Pro-gram has not established effective targets-those forwhich managers can be held accountable-forresource conditions of forests and rangelands. Thus,RPA targets have become synonymous with na-tional timber sale targets.

Equal treatment of all resources could be accom-plished by setting national targets for all importantoutputs and conditions. This approach would requiredeveloping measures for nontimber values-anadmittedly difficult task. Meaningful production andcondition goals for recreation, range forage, water,wildlife, and fisheries have not been established, andreported accomplishments might be impossible toverify or to evaluate objectively (277). Nonetheless,accountability standards for all important forest andrangeland outputs and conditions are a prerequisiteif the RPA process is to establish broad and balanceddirection for the Nation’s renewable resources.

Even if acceptable national targets are establishedfor all significant outputs and conditions, the allo-cated RPA targets probably would not match thetargets set in forest plans. NFMA plan targets aredeveloped locally, with information on resourceconditions and interactions and with substantialpublic input. The dilemma arises as to how to decidebetween allocated RPA targets and NFMA plantargets. Should national targets override the NFMAplanning process when so much time and effort goesinto local planning? Allocated RPA targets couldmake local analysis and public involvement in

NFMA planning useless and ineffective, becausetargets are set by people removed from the localresource conditions and public desires. Alterna-tively, should the local planning process ignore theregional, national, and global concerns reflected inthe RPA targets? NFMA planning targets couldresult in missed opportunities or regional disloca-tions not considered locally.

A second, and more serious problem in trying tomesh RPA targets with NFMA planning, is thatallocated RPA targets maybe infeasible, despite theresource capability information in the NFMA plans.In past RPA Programs, resource production goals,especially for timber, have been a reflection ofprojected national demand more than a reflection ofthe resource capabilities to actually meet thatdemand (277). Even before NFMA was enacted,participants of a national symposium organized bythe Forest Service at Pajaro Dunes, CA, discussedthe need for data aggregation to proceed in a local‘‘bottom-up’ approach (192). In addition, even withaggregated local data from the forest plans, nationalanalyses of capabilities and opportunities necessar-ily lack information on site-specific resource inter-actions and conflicts. RPA analyses, therefore, willtypically overestimate the productive potential ofthe lands being analyzed (72). (See ch. 7.) Thus, thenational planning process under RPA is likely tooverstate the opportunities for producing outputsfrom the national forests.

DIRECTION AND FLOW OFINFORMATION

The conflict between allocated RPA targets anddirections established in NFMA planning might bealleviated if the flow of information between theforest plans and the RPA documents is continuousand two-directional. Precedent has been set for aprocess that is based on capabilities set locally, withgeneral guidance from the top. In a 1988 court case,a Federal district court ruled that while productiontargets under a timber management plan are impor-tant goals, they are not legally enforceable decisions(277). The Chief of the Forest Service expressedagreement with this decision in an internal memo tothe regional foresters (207).

The compatibility of output potential determinedat the local level, and output goals determined at thenational level, must be discussed and planningadjusted depending on national and local interests,

Chapter 10--Relationship of Forest-Level NFMA Planning to National RPA Planning ● 181

resource sustainability, and budget allocations. Thisapproach would shift the RPA Program’s emphasisfrom setting hard targets for the national forests tosetting an overall direction for the Forest Service--for Research, State and Private Forestry, and Inter-national Forestry as well as for the National ForestSystem. The Program would guide national policiesand identify considerations and approaches forNFMA planning. The NFMA plans would deter-mine capabilities based on resource inventory andmonitoring, public input, and local managerialexpertise.

T o , summarize, the Forest Service regulationsdescribe the information flow among the RPAdocuments and the forest plans as iterative. Informa-tion from the plans is used in compiling the RPAAssessment, and the plans and the Assessmentcontribute to the RPA Program, which then providesguidance for the forest plans. The problems createdby this process could be alleviated with a continuousand interactive information flow among the fourRPA documents and the forest plans.

NFMA Planning and the RPA Assessment

Data gathered to prepare the national forest plansand to monitor plan implementation provide basicinformation on resource conditions and predictedoutcomes of proposed management actions, and onopportunities and limitations for expanding the usesand outputs of the national forests. Forest plannersshould be aware of resource demands outlined inprevious Assessments and compare local assess-ments of physical, biological, and economic capabil-ities of the land with the national assessment, toassure that the conditions and possibilities consid-ered in planning address national concerns (277).Standardized procedures and measures for invento-ries and monitoring can improve communicationand minimize the costs of developing analyticalmodels-each forest can take advantage of com-puter capabilities and models developed for theentire agency (51). (See also ch. 6.)

The RPA Assessment can assist forest-levelplanning by serving as a source book for planners.First, the Assessment provides information on meth-ods used on national forests, private, and otherpublic lands to collect data on resource outputs,conditions, and trends. This information can helpplanners design inventories and monitoring activi-ties on their forests so that data will be compatible

with previous inventories and with studies in prog-ress. Measures used on the national forests must alsobe comparable to measures used on private and otherpublic lands so that data can be aggregated andcompared. Coordination of data measures allowsinformation from the national forests and fromprivate and other public lands to be used in acomprehensive analysis. These data are then avail-able for national use in the RPA Assessment,Program, and Annual Report.

In addition, the RPA Assessment (and the sup-porting data) is a source of information for forestplanners to consider in examining alternatives fortheir national forests. The Assessment is to describethe existing resource conditions and outputs fromprivate and other public lands, as well as from thenational forests. Forest planners can use the Assess-ment database to assess the extent to which variousregional, national, and global concerns are beingaddressed on the lands surrounding their forest, andthus can assess the need for addressing suchconcerns in their forest plans. The RPA Assessment,therefore, is a source of information on inventoryand monitoring measures and methods and on theconditions and outputs from lands surrounding thenational forests.

NFMA Planning and the RPA Program

The forest plans can contribute to the RPAProgram by providing information and guidance onthe public’s preferred management alternatives forthe National Forest System. The forest plans aredeveloped with substantial public input, and thusshould describe locally acceptable managementdirection. Furthermore, the NFMA planning processidentifies public issues and concerns relevant to themanagement of the national forests. Issues andconcerns that are widespread at the local levelshould receive special attention in the Program. Forexample, a national policy on below-cost timbersales might demonstrate agency responsiveness topublic concerns. In essence, NFMA plans are part ofthe public’s participation in the RPA process.

As a strategic plan, the Program needs to setdirection for all planning on the national forests aswell as for research, cooperative assistance, andinternational programs. The Program, however,should not override local decisionmaking. Instead, itcan augment NFMA planning by addressing re-gional, national, and global problems not identified


or considered locally. The Program can then includeissues and concerns to be considered in amendingand revising the forest plans, with a clear explana-tion of why such issues are of regional, national, orglobal concern and should be addressed in nationalforest management. This interpretation of the influ-ence of the RPA Program on local planning ispatterned after a theme of “firm central directionand maximurn individual autonomy’ ‘—a themecommon to effective organization in the privatesector (195). This view was expressed by ChiefRobertson in his 1990 testimony, stating that re-source output targets will be replaced by moreflexible, general guidance from the RPA Program(206).

Strategic planning does not require the elimina-tion of national targets. In fact, targets may becritical to reaching stated goals for the variousresources. Hard national targets, however, can effec-tively negate local decisionmaking, i f targets are se tonly for certain outputs and only for the nationalforests. Such targets also tend to discourage aninteractive flow of information from the local levelto the national level and thus run counter tofunctional strategic planning and the iterative proc-ess. Alternatively, national output and conditiontargets can be used to identify impending orpotential problems that are to be considered innational forest planning, in setting research prioritiesand in determining the financial and technicalassistance needed by States and private landowners.

NFMA Planning and the Budget Process

The forest plans are intended to serve as the basisfor developing the agency’s annual budget proposal(217). However, the budget requests from the forestscannot simply be added together to arrive at a grandtotal for the National Forest System, because theforests have used different assumptions about possi-ble budget levels in their NFMA plans. (See ch. 8.)Currently, the forests identify the appropriate proj-ects for implementing the forest plan. These multiple-use projects must then be converted into budgetrequests by resource activity, and the budgets foreach resource activity are subject to modification bythe administration and Congress.

The Forest Service budget request for the NationalForest System must be balanced against overallspending constraints and management priorities.According to Chief Robertson (206), the rate of

forest plan implementation-and the mix of projectscarried out under the plans-depends on the annualFederal budget process:

[The] forest plans are strongly linked to anddependent on the national budget process. As wedevelop our annual agency budget request, wecarefully consider the needs documented in theforest plans in light of competing agency prioritiesand constraints. Ultimately, the rate at which we areable to implement each plan-and the relativeemphasis given to each component of the plan--reflects national priorities and constraints that areresolved as the President proposes a budget and theCongress appropriates funds.

Congress appropriates funds by resource activity.The appropriations are then allocated to the regions,and subsequently to the forests. The appropriationsby resource must be converted back into multiple-use projects, not an easy task because it is unlikelythat the appropriations will match the balanced mixof resource activities needed to implement the forestplans.

A better flow of information between the forestplanning and the budget and appropriations processis needed for implementing the forest plans. Con-gress needs accurate information on the likelyoutputs and conditions that will result from imple-menting the plans with a given level of appropria-tions. Congress also needs information on theimprovements possible with increased tiding, andon the consequences of reduced funding. Further-more, the local publics need to know how the forestplan will be implemented, if the full funding calledfor in the plan is not appropriated. Thus, to beintegrated with the budget and appropriations proc-ess, the forest plans must contain information on thelikely outputs and conditions under a range ofbudgets, including both the most likely and the mostdesirable budget levels.

The budget and appropriations process also mustbe better integrated with forest planning. The currentstructure of appropriations by resource activity isinconsistent with the integrated, multiple-use man-agement direction established in the plans. Congressmay object to reducing the current budget details,fearing a loss of control over the Forest Servicebudget. However, actual expenditures and accom-plishments often differ, sometimes substantially,from the appropriations and from the reportedexpenditures and accomplishments. Furthermore,

Chapter 10-Relationship of Forest-Level NFMA Planning to National RPA Planning ● 183

special accounts and trust funds account for morethan a third of the Forest Service budget, but thesubstantial agency discretion over the size and use ofthese funds occurs with little congressional controlor oversight. Thus, Congress has, in fact, already lostsome of its apparent control in the appropriationsprocess. Congress could reestablish control over theForest Service budget while allowing the implemen-tation of national forest plans by:

1. appropriating funds by activity (e.g., planning,producing, maintaining, investing, monitoring)rather than by resource;

2. examining the use and discretion over perma-nent appropriations; and

3. requiring full disclosure of expenditures andunit costs for significant activities-regionallyand fictionally.

NFMA Planning and the Annual Report

Monitoring of the forest plans can provide infor-mation to be presented in the Annual Report on theexpenditures and results of management activitieson each national forest. This information can be usedto compare the performance of forest supervisorsand regional foresters, and thus can serve as anincentive for the Forest Service to make sure itsefforts are balanced and efficient.

Peer pressure is an important component ofquality performance. Thus, monitoring of forest planimplementation should provide information for theAnnual Report on what each forest is doing and howwell management activities have been implemented.Consistent reporting is necessary so that data can beaggregated and compared. Unit cost information isimportant, especially for certain critical activitiesand results, such as reforestation success, timber salepreparation and harvest administration, and wilder-ness quality improvements. Furthermore, as dis-cussed earlier, measures are needed for all theimportant outputs and conditions, to assure that allgoals are being achieved; finally, managementactivities, such as range improvements and water-shed rehabilitation, must be related to the outputsand conditions of interest to Congress and the public.

A third connection between forest planning andthe Annual Report may be the identification ofimportant issues that arise quickly, in the time

between RPA Programs. To address rapidly emerg-ing issues in a timely fashion, the issues can bediscussed in the local context and included inAnnual Reports. In this way, forest planning and theAnnual Reports can serve as issue scoping for eachRPA program, and as a basis for considering new orrevised policy direction for national forest manage-ment.

NFMA Planning, RPA, and theRole of the Regions

In the RPA and NFMA planning processesdescribed in this OTA assessment, the regionaloffices serve three main purposes: to aggregate data,to allocate budgets, and to coordinate and facilitateproblemsolving of regional scope.1 Budget andresource data from all of the national forests are toounwieldy to accommodate directly at the nationaloffice. The regional offices can aggregate these dataand present them to the national office in a manage-able form. The regional offices also work withbudget decisions from the national level, allocatingbudgets to the forests.

The regional offices’ third role, to coordinate andfacilitate problemsolving of regional scope, maybeespecially important when problems involve severalforests as well as State, private, and other publiclands. The regions can identify issues common toseveral national forests, and can assist in coordinat-ing responses and identifying issues that need to beaddressed nationally, in the RPA planning process.The regional offices can also serve as a focal pointfor coordination with State agencies that have astake in national forest management, includingagencies that regulate forest practices, that managewildlife populations, and that enforce water rightsand water quality standards.

If the RPA Program is not seen as a documentproviding hard output targets and budgets to theforests, the regions would not be required to serve asa liaison in these areas. Rather, they could providecoordination between local decisionmaking (as themajor impetus behind planning) and national policyguidance. The regions could assist in finding waysto deal with regional disputes and conflictinginterests before they are brought to national atten-tion.

IRe@o~ offices ~doubt~ly sme o~er functions, as well, but this section focuses solely on tieir role ~ WA ~d NFMA planning.


CONCLUSIONConcern over land and resource capability and

sustainability has contributed to the debate overcentralized, top-down planning versus decentral-ized, forest-based, bottom-up planning (277). Re-source capability information developed at the locallevel was intended to provide the foundation forRPA planning; at the same time, national objectivesare essential to strategic planning and setting long-term goals. National and forest level information‘‘address the nations’s resources demands andrecognize natural and practical limitationsof the land and forests to meet those demands’(277).

Binding targets set at the national level in pastRPA Programs have resulted in a concentration ontimber outputs, at the expense of considering otheroutputs and conditions. Furthermore, national analy-ses are likely to overestimate productive potential,because site-specific resource interactions are neces-sarily lost in aggregating data on local capabilities.Replacing hard targets with general guidance andflexible goals would lessen the emphasis on top-down planning and allow for a more iterativeprocess, as prescribed in the regulations.

A two-directional, interactive exchange of infor-mation between local forest planning and nationalRPA planning would encourage resources to bemanaged for realistic and desired goals and long-term sustainability. The forest plans can provideinformation: on resource capabilities for the RPAAssessment, on public desires for national forestmanagement for the RPA Program, on opportunitiesand likely results for the annual budget, and on theresults and costs of management for the AnnualReport. The Assessment database can inform plan-ners about conditions and outputs from neighboringlands, and about measurements and methods forinventorying and monitoring. The Program can pro-vide policy direction for considering regional, na-tional, and global issues and concerns. The annualappropriations determine the extent of implementa-tion of the forest plans. And the Annual Reportallows managers to compare their performance inimplementing the forest plans with the performanceof their peers. Thus, by improving the flow ofinformation between local NFMA planning andnational RPA planning, the national forests can bemanaged to achieve local desires, address nationalneeds, and assure the long-term sustainability of theforest ecosystems.

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Conflict and Reso-

Index

Index

Administrative appeals, 5,65-66,83,95-99, 105Advisory committees, 20, 80Allegheny National Forest, 168Allowable timber sale quantity (ASQ), 18,97, 127-128, 131,

132, 133, 146Alternative dispute resolution (ADR), 92-94,95,98Annual reports

for national forests, 12, 22, 115Report of the Forest Service, 25, 172, 174RPA, 9,40, 143, 179, 183, 184

Appropriationsforest plans and, 12,23,52,86, 169, 182-183

. permanent, 154, 155-156, 159resource-oriented, 8, 12, 23, 24-25, 86, 158, 182-183

Arapaho-Roosevelt National Forest, 121

Banzhaf, William, 163Barrett, Frank, 37Beaverhead National Forest, 154Best Management Practices (BMPs), 70, 116Biological diversity

data inadequacies, 6, 123legal requirements, 6, 115, 119-120, 123in NFMA planning, 120-121

Biological modeling, 117-118Biologists, 165, 175Bitterroot controversy, 17,40,54,79,82,87Bitterroot National Forest, 40,79, 112, 114, 115, 116, 120Belle Report, 40,42,82,85,86Boundary Waters Canoe Area, 39Budget

differing assumptions, 8, 12, 13,23,25, 151-152, 158,182

effect on planning decisions, 12,23-24end-results budgeting, 8, 153-154forest plans and, 8, 12-13,23-27,52,53,86, 151-156,173-174, 182-183

off-budget funding, 154-156policy options, 12-13,23-27, 183reprogr amming, 153resource orientation, 8, 12, 23, 24-25, 53, 86, 169,182-183

special accounts and trust funds, 8, 12, 13, 23-24, 25-26,154-156, 182-183

Bumpers, Dale, 144Bureau of Land Management (BLM), 13,26-27,98, 100, 150,

155, 170

Carter, Jimmy, 78Chattahoochee/Oconee National Forest, 92Chequamegon National Forest, 116, 120, 122Chugach National Forest, 66,92Church Clearcutting Guidelines, 40Cibola National Forest, 113, 122Clarke-McNary Act of 1924,35Clean Water Act, 70, 102

Clearcutting, 33,4041,79, 135Cleveland, Grover, 34Coconino National Forest, 112, 114, 115, 116, 120, 131Community stability, 7-8, 103, 148-151, 158Computer models. See Technologies for planningCounty payments, 7-8, 12, 13,23,26-27, 151, 154, 156Critical habitat, 71-72

Data collection. See Inventories; MonitoringDatabase management systems, 130Dixie National Forest, 112, 115Dominant use, 4,43-46

Economic analysis. See also Budgetof economic impacts, 7-8, 148-151efficiency, 143-147, 156-157in endangered species determinations, 71equity, 143, 147-148legal requirements, 143technologies for, 7, 130

Ecosystems approachconstraint rather than goal in FORPLAN, 7, 135inventory and monitoring, 10-11, 18-19,21,24-25, 110, 119,

122MUSYA and, 10,4749need for, 4,6,9, 10-11, 17-19,21,24-25,28,4749, 110, 119,

122NEPA and, 10,62NFMA and, 65

Eisenhower, Dwight D., 37Eldorado National Forest, 112, 115, 116, 120Endangered species. See specific species; Wildlife

protectionEndangered Species Act of 1973,33,70-72, 101Engineers, 164-165Environmental impacts, 61-62,78, 129-130Environmental Protection Agency, 70, 121

Fernow, Bernard, 163Fish arid Wildlife Service, 33,46,71,72,98Ford, Gerald, 80Forest and Rangeland Renewable Resources Planning Act of

1974. See RPAForest managers. See also Human resources

accountability, 65-66, 87-88, 173, 174-175, 176constraints, 85-86effects of bias favoring outputs, 11, 21, 172, 173forest plan implementation, 52, 174NFMA and, 65-66

Forest plansas a baseline for RPA planning, 9-10, 13-14,27-28,180-184

development, 17-21,63-64, 173-174implementation, 9,21-23,52, 173-174purpose, 4, 179

Forest Service. See also Human resources

–203–


agency vs. employee values, 9, 169-171, 176history and organization, 3, 35public involvement efforts, 81-86,91response to social change, 8, 169-170

Foresters, 163-164, 166-167, 175FORPLAN. See also Linear programming

criticisms of, 3, 7, 127, 136-137, 138description, 7, 127, 132-133development and selection, 7, 18, 131-132, 138as an economic efficiency model, 7, 144-147, 156-157future options, 11,20-21, 139as a planning tool, 136-137, 138, 139strengths and weaknesses, 7, 18, 20, 133-136, 138, 156-157timber focus, 18, 117-118

General Accounting Office (GAO), 8,96,97,98, 153Geographic information systems (GIS), 6, 11, 118, 129, 130,

138Gila Wilderness, 38Goals and objectives

achieving, 49-53government ownership rationale, 42-43historical development, 34-42setting, 50, 63

Government ownership rationale, 42-43Grazing, 35-37,60

Hatfield, Mark, 77Human resources

diversity, 137, 167-169, 175-176employee vs. agency values, 9, 169-171, 176foresters, 163-164, 166-167, 175interdisciplinary teams. See Interdisciplinary approachperformance and rewards, 171-175, 176professionalism, 84-85, 163-167professionals other than foresters, 164-165, 175transfers, 174-175

Humphrey, Hubert, 39,40,41,79-80

Idaho Panhandle National Forest, 113, 114, 116, 122Impact assessment technologies, 129-130IMPLAN, 7,20, 130, 138, 148, 150Indicator concept, 121Indicator species, 6, 121-123Information base, 10-11, 18-19,51-52INFORMS, 130-131Input-output analysis, 7, 20, 130, 138, 148, 149Integrated systems, 130-131Interagency cooperation, 102-103Interdisciplinary approach, 8-9,22,40,55,62,63,80, 86, 109,

111,115,118,119,131, 133-135,138,143,152, 167-169,176, 179

Inventoriescompliance with requirements, 114funding and, 11, 111integrated, multiresource, 6, 109, 110, 117legal requirements, 111-112objectives, 112policy options, 18-19,51problems with, 6, 10-11, 18-19,21,51, 110-111, 112-114,

117-118, 123quantity and quality of data, 113statistical requirements, 110-111timeliness of data, 51, 113-114use of, 109

Investment, 147

Jefferson National Forest, 92Johnson, Norman, 134Joint production, 4,42,4346Judicial review, 5-6, 99-101

Klamath National Forest, 154Knowledge-based systems, 130Knutson-Vandenberg (K-V) Fund, 8,23-24,25, 26, 154, 155,

156, 159

Land and resource allocation technologies, 129Legal framework. See also specific laws

concerns about, 59-60, 72-73Forest Service mission and authority, 60-66legal constraints, 66-72

Legislative direction, 10, 18Leisz, Douglas, 132Leonard, George, 149Linear programming, 6, 128-129, 131, 132, 137-138. See also

FORPLANLitigation, 3,5-6, 17,33,73,79,99-101, 105, 174Local concerns, 103. See also National vs. local planningLolo National Forest, 168

Management indicator species. See Indicator speciesMcClure, James, 77Mission ’66, 37Monitoring

compliance, 115-116funding, 111indicator species, 122-123integrated, multiresource, 6, 109, 110, 117legal requirements, 115levels of, 116-117policy options, 11-12,21-23problems with, 6, 11,21-23, 110-111, 115-117public involvement, 12, 22-23purpose of, 6,21, 109statistical requirements, 110-111

Monongahela decision, 17,33,40,54,61, 79, 82Monongahela National Forest, 40,79,92Mt. Hood National Forest, 154Multiple use, 4,35, 43-46Multiple-Use Sustained-Yield Act of 1%0 (MUSYA), 3,4,5,

17, 18,35-38,41,43,46,61, 78, 101, 143Multiple-Use Sustained Yield Calculator (MUSYC), 131

Nantahala/Pisgah National Forest, 112, 115, 116, 120National Environmental Policy Act of 1969 (N EPA), 3,4,20,

78-79,97, 165National Forest Management Act of 1976 (NFMA)

criticisms of, 17, 33, 50, 77

Index . 2 0 5

economic analysis requirements, 143forest plan requirements, 63-64guidelines for timber management, 18,64-65, 127-128inventory requirements, 111-112legislative history, 3, 17,33,4042,63,79-80, 179management discretion, 65-66monitoring requirements, 115national RPA planning and, 9-10, 13, 34, 41, 49, 63,179-184

public involvement and, 3,65,77,79-81regional office role in planning, 183regulations implementing, 80-81

National Forest Systemcreation, 34-35trust fund concept, 5,48

National forestsAllegheny National Forest, 168Arapaho/Roosevelt National Forest, 121Beaverhead National Forest, 154Bitterroot National Forest, 40, 79, 112, 114, 115, 116, 120Chattahoochee/Oconee National Forest, 92Chequamegon National Forest, 116, 120, 122Chugach National Forest, 66,92Cibola National Forest, 92, 113, 122Coconino National Forest, 112, 114, 115, 116, 120, 131Dixie National Forest, 112, 115Eldorado National Forest, 112, 115, 116, 120Idaho Panhandle National Forest, 113, 114, 116, 122Jefferson National Forest, 92Klamath National Forest, 154Lolo National Forest, 168Monongahela National Forest, 40,79,92Mt. Hood National Forest, 154Nantahala/Pisgah National Forest, 112, 115, 116, 120Nebraska National Forest, 92Nicolet National Forest, 112, 115, 116, 120Ochoco National Forest, 86Ouachita National Forest, 112, 120Rio Grande National Forest, 92San Juan National Forest, 112, 113, 115, 116, 120Shoshone National Forest, 121Siskiyou National Forest, 112, 113, 114, 115, 120Tongass National Forest, 66, 155White Mountain National Forest, 80Willamette National Forest, 154

National Park Service, 35, 37, 98, 166National vs. local planning, 9-10, 13-14,27-29, 179-184Nebraska National Forest, 92Nicolet National Forest, 112, 115, 116, 120Nixon, Richard, 78Nonuse values. See Outputs and uses vs. nonuse values

0 & c Act of 1937,47Ochoco National Forest, 86Office of Management and Budget (OMB), 134, 144, 153Old-growth forests, 5,17,33,44,51,53,100, 101,120,131,133,

135, 138. See also Timber resources managementOrganic Act of 1897,3,4,5,33,34-35, 40-42,60-61, 101, 148Organizational factors, 8-9, 163-176Ouachita National Forest, 120Outputs and uses vs. nonuse values

bias favoring outputs, 4,6,9, 10, 17-18,28,4749,163-164, 172-173

in FORPLAN, 7, 18, 135MUSYA and, 18NFMA and, 18policy options, 10-11, 14, 17-21,28-29setting values, 144, 145-146

Payments in Lieu of Taxes (PILT), 13,26-27Performance rewards, 171-175Pinchot, Gifford, 47,60, 163, 164Policy options, 10-14, 17-30Present net value (PNV), 130, 132, 144Presidential Statement of Policy, 9,40, 179Privatization of Federal lands, 44-45Professionalism, 85, 163-167Public involvement

accountability and, 22, 87-88cooperation and collaboration, 86-95diversity and, 167Forest Service efforts, 81-86,91ineffectiveness, 4-5, 20, 81legal requirements, 20,77-81, 104means, 5measuring effectiveness, 91-95models of effectiveness, 88-91in monitoring, 12, 22-23NEPA and, 20,62,77,78-79NFMA and, 3, 20, 65, 77, 79-81, 181policy options, 11, 20reasons for, 5, 50-51, 87-88reasons for difficulties, 83-86, 104, 166-167State, tribal, and local governments, 101-103

Reagan, Ronald, 81Recreation, 9,35,36-37,46, 172Red-cockaded woodpeckers, 17,33, 53,70Reforestation Trust Fund, 26, 154Regional office role in RPA and NFMA planning, 183Report of the Forest Service, 25, 172, 174Resource allocation technologies, 129Resource Capability System (RCS), 131Resource scheduling technologies, 128-129Resource simulation models, 6, 129-130Rio Grande National Forest, 92Road construction, 143, 157Roadless Area Review and Evaluation (RARE I), 40, 68Roadless Area Review and Evaluation (RARE II), 68-69, 114Robertson, Dale, 59,72,82-83, 179, 182RPA (Forest and Rangeland Renewable Resources Planning Act

of 1974)legislative history, 3,3940,63, 179policy options, 13-14,27-29purpose, 3,39-40,49, 179regional office role in planning, 183relationship to NFMA planning, 9-10, 13, 34, 41, 49, 63,179-184

RPA Assessment, 9, 143, 179, 181, 184RPA Program, 9,34,49, 143, 152, 173, 179, 180, 181-182,183, 184


San Juan National Forest, 112, 113, 115, 116, 120Scientific conservation paradigm, 163-164, 165-166Shoshone National Forest, 121Siskiyou National Forest, 112, 113, 114, 115, 120Society of American Foresters (SAF), 163, 164Special accounts and trust funds, 8, 12, 13,23-24,25-26,

154-156, 182-183Spotted owl, 5, 17, 18-19,33,51,53,70, 100, 101, 102State, tribal, and local government involvement, 101-103,

105-106State responsibilities, 101-102Strategic planning principles, 4,34,49-53,54-55Sustained yield, 4,4749, 149Sustained Yield Forest Management Act, 47

Targets, 9-10, 11, 13, 14, 19,27,28-29, 172-173, 179-180,182

TEAMS, 130-131Technologies for planning. See also FORPLAN

policy options, 11, 20-21relevant planning decisions, 127-128types, 6-7, 128-131

Ticknor, William, 164, 166Timber Assessment Market Model, 146Timber Resource Allocation Model (Timber RAM), 131, 132Timber resources management

administrative appeals, 96,97-98clearcutting, 33, 40-41, 79, 135community stability and, 7-8, 148-151county payments, 7-8, 12, 13, 23, 26-27, 151, 154, 156emphasis on, 10-11, 12, 17-18, 23, 35, 110, 117, 163-164,

170, 172, 184litigation, 33,4041, 100NFMA guidelines, 18,64-65, 127-128policy options, 10-11, 17-21receipts, 151, 154, 158‘rich’ and ‘poor’ forests, 154technologies for, 6, 18, 117-118trends, 35-37

Timber Sale Program Information Reporting System (TSPIRS),25

Timber Salvage Sale Fund, 8,24,25,26, 154Tongass National Forest, 66, 155Trust fund concept of National Forest System, 5,48,55

User fees, 60

Wallinger, Scott, 164Watershed protection, 18,22,35,46,60,70, 153, 172Weeks Law, 35White Mountain National Forest, 80Wild and Scenic Rivers Act of 1968,67-70, 102Wilderness Act, 38-39,66-67, 101-102Wilderness areas, 37,68-69, 133, 146, 154, 172Wildlife protection, 18, 22,46, 60, 70-72. See also

Biological diversity; Inventories; Monitoring; specificspecies

Willamette National Forest, 154Winding Stair Mountain National Recreation and Wilderness

Area Act, 120-121

IJ. s. GOVERNMENT PRINTING OFFICE : 1992 0 - 2gT-gOd QL 3

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